Meeting the October 2024 Deadline: A Quick Guide for Water Utilities Struggling to Get Started with Lead Service Line Inventory Compliance
Drinking Water | 4 MIN READ

Meeting the October 2024 Deadline: A Quick Guide for Water Utilities Struggling to Get Started with Lead Service Line Inventory Compliance

The Lead and Copper Rule Revisions (LCRR) mandate that all Community Water Systems (CWS) and Non-Transient, Non-Community Water Systems (NTNCWSs) submit an initial inventory of their service lines by October 16, 2024. This can be a significant undertaking for many small, rural water systems that often lack historical records, adequate staffing, or other resources to assist with completing their inventory. Many small water systems are just beginning their inventory efforts, while others have made considerable progress or have even completed the initial inventory.

The EPA and state primacy agencies offer detailed guidance on their respective inventory requirements and methodology that must be followed. Despite differences in EPA and some state requirements, there are some common practices that can assist a small system in its initial stages with minimal effort.

First, it is critical to have a complete customer list that accounts for each service line. Ideally, this information should be readily accessible or require minimal effort to acquire from the utility’s billing system. Depending on each state’s template, certain required or optional information may be easy to determine, including unique service line IDs, other location identifiers, sensitive population data, current Lead and Copper Rule (LCR) sampling sites, and building types.

Once this information is incorporated into the required inventory template, water systems must conduct an initial records review. This may involve reviewing system maps, records, construction and plumbing codes, or other pertinent information. Parcel boundary data can be useful when containing characteristics like address, owner names, and home built year, which is used to identify older homes and neighborhoods that are more susceptible to having lead service lines.

Another strategy used for inventorying service line materials is providing customers with a public survey form. The survey form would provide instructions to inspect the service line coming into their home. The survey form should encompass all relevant information needed for the customer side of the service line inventory. It should also include instructions on identifying material types by scratch and magnet testing, along with tips for capturing good photos.

The customer survey approach also allows the collection of contact information, such as owner or tenant names, phone numbers, email addresses, or even water meter serial numbers. There can also be a scheduling option where the customer requests the utility staff to complete the home service line inspection. Public surveys can be advertised on utility or town websites, emailed to customers, shared on Facebook, door hangers, or flyers attached to bill stubs with scannable QR codes.

Deploying a customer survey is also an excellent way to show engagement with customers, inform them about the significance of the new EPA lead service line inventory requirements, and share any other pertinent system information. In many states, a completed and well-documented public survey can serve as proper verification of the service line material on the customer side.

Following the public customer survey, a water utility system may be off to a solid start and pleasantly surprised with their progress, but often utilities may only report about a 5-10% response rate from their customers. A water utility may look next to identify sensitive populations such as schools and daycares, or target efforts in areas where lead is most likely located. At this juncture, excavation or other investigative methods will need to be explored.

Completing the service line inventory will undoubtedly demand a substantial investment of time, effort, and money for most small systems. There are few shortcuts in this process and there are some strategies that can aid a small, rural water system in making progress if they are feeling anxious about the October 2024 deadline. Following these steps, a water system may end up with an adequate inventory to submit, but efforts will still be needed to identify any remaining unknown service lines in accordance with state or EPA regulations.

Disclaimer – This article is intended solely for informational purposes. For details regarding specific processes, completion, or submission of the service line inventory, kindly consult your state primacy or EPA.

This article was funded under the EPA NPA 1 22 – 24 Grant. 

March 26, 2024
Red Cliff Wastewater Treatment Plant Compliant Treatment Process
Wastewater | 4 MIN READ

Red Cliff Wastewater Treatment Plant Compliant Treatment Process

Red Cliff Public Works Department, which includes the Red Cliff Band of Lake Superior Ojibwe’s wastewater treatment plant, is located on the southern shores of Lake Superior. The Wastewater Treatment Department is run by the Public Works Administrator, along with two operators. They are also hiring a new Assistant Director.

Aided by the many years of knowledge between the experienced Public Works Administrator and Lead Operator, the utility has been making great strides to get the Wastewater Treatment Department in compliance with US Environmental Protection Agency (EPA) regulations and keep it there.

When the administrator came on board, the first task he undertook was to lead the utility to completion of the EPA’s Administrative Order of Compliance. The administrative order required a set of tasks and responsibilities to be conducted within two years. This was accomplished in nine months.

One of the many positive changes made on the way to compliance was moving the chemical feed of aluminum sulfate to the splitter box prior to effluent entering the clarifiers. By injecting the aluminum at the splitter box, the additive now has enough “contact time” to assist the wastewater with phosphorus and ammonia removal via the process of flocculation. As the particles combine, they become floc and settle out. The better the flocculation, the better the overall effluent, with less phosphorus and ammonia.

Let’s review the wastewater treatment process at Red Cliff:

First, we have our influent, which is pumped to the treatment plant from lift stations and gravity-fed sewer lines throughout the collection system. As the wastewater begins its process, it starts off at pretreatment, where it passes through a bar screen which is used to remove large physical materials and debris.
From the bar screen, the wastewater continues through a fine screen where smaller debris is removed.
From there, the wastewater passes through a grit removal process that helps remove the finer granular matter from the wastewater.
As the wastewater makes its way through the grit removal process, it now enters the oxidation ditch. This is where the raw wastewater is introduced to microorganisms and the microbiology portion of treatment begins. It is the wastewater operator’s job to keep the microorganisms happy and healthy. The dissolved oxygen (DO) must be monitored and set at the correct level to keep the tiny critters alive, but not give them too much DO where they won’t eat any of the biological matter in the wastewater to keep the treatment process going. There is a fine line that needs to take place with the microorganisms as they play a major role within the wastewater treatment process. The biology and microbiology that take place within wastewater treatment is just one of the many processes that most people do not know happens.
From the oxidation ditch, a portion of the mixed liquor is pumped back to the oxidation ditch, also known as Return Activated Sludge or RAS. RAS has a healthy batch of microorganisms which will be used to jump-start the natural microbiologic treatment process.
Now, as wastewater has been introduced to the microbes and natural matter has been removed, aluminum sulfate has been added to aid in phosphorus and ammonia removal and the effluent makes its way to the clarifiers.
As the alum interacts creating floc, this matter will settle to the bottom which creates a clearer effluent.
From the previous treatment process, the final product, known as effluent, is sent through an ultraviolet light bank which neutralizes any pathogenic organisms. This process prevents any remaining pathogens from being able to reproduce if they have made it through the treatment process.

Numerous steps are taken to ensure the effluent is safe and meets all the EPA’s stringent standards before final discharge. Many samples, analytical data, and test results are collected, reviewed, and recorded before the final effluent is discharged. Biosolids created during the treatment process are pumped to the utility’s reed beds, where they are dewatered and stored. The reed beds can dewater natural materials many times the weight and size of the reeds themselves. Through a collection of underdrains, any liquid collected is sent back to the top of the plant to be reintroduced and begin the process all over again.

Through the hard work of the utility’s staff and the partnership with RCAP, the Red Cliff Wastewater Treatment Plant has met and continues to meet the requirements and standards needed to stay in compliance.

This article was funded under the EPA NPA 2 22 – 24 Grant. 

March 26, 2024
How Smoke Testing Can Help Your Small Wastewater Collection System
Smoke Testing | 5 MIN READ

How Smoke Testing Can Help Your Small Wastewater Collection System

Every year as wastewater systems continue to age, thousands of additional gallons of non-wastewater make their way to the treatment facility. Or even worse, actual wastewater leaves the system before being properly treated.  As any system ages, it will begin to weaken, and at that point, additional water either enters the system or exits the system prematurely. The two main sources of additional water in the system are infiltration and inflow.  Infiltration is when water enters the system via broken or worn infrastructure such as cracks in manholes, broken pipes, cleanouts, or missing cap covers. Inflow is when water is deliberately and illegally introduced into the system via sump pumps hooked into the system or roof gutters hooked into the system.  We will explore how smoke testing can locate both of these problems and correct them.  

Smoke tests are used on gravity collection systems — those that use the force of gravity to move effluent. When we perform a smoke test, we take a large gas-powered fan and place it over an opened manhole.  The fan pushes massive amounts of air into the collection system.   Smoke is introduced from the fan via a special smoke candle or a liquid smoke, and travels into the predetermined section being tested (usually only a couple of hundred feet at a time). Rubber plugs are used to seal a section of the system to narrow the test area.  Several personnel walk the area being tested, watching for smoke coming out of areas it should not be, like gutters around houses. Personnel take pictures, make notes, and place flags at potential problem areas. It usually only takes 5 to 10 minutes to test these areas. Personnel move to the next section until the entire system has been completed.  As a note, this type of testing only works on a gravity system with no pressure. For force main testing, a pressure test will need to be used to determine leaks. 

After all on-site testing is completed, all notes and pictures are compiled to prepare a plan of action for the system.  Important questions to consider before presenting results to the community include: “What did we find?”, “Do we have lots of inflow?”, “Do we have lots of infiltration?”, “How can the system fix these?”, “Where are the worst areas?”. These questions help drive the solutions  that are reported to the system. Then the technical assistance provider works with the system to implement a plan to afford and track repairs or changes.  Once these repairs have been completed, it will determine if the fixes have lowered the overall amount of influent (untreated or contaminated water) going to the treatment facility.

Inflow problems we commonly encounter are roof gutter systems dumping into collection systems, basement sump pumps hooked into the system, and construction sites that dewater (infiltration of runoff/silt )the system. Inflow issues need to be corrected through policy, and not direct physical action. Ordinances need to be in place that make it illegal to hook into the system without approval and specify how and when authorized personnel may inspect for illegal connections. Customers also may need to be educated to know what is and what is not allowed, and why it is harmful to the system. The system also may need to take legal action against a customer to disconnect their illegal inflow.   

Infiltration can sometimes require more investigating to figure out an exact problem, but almost always takes physical corrective action to remedy the problem. Easy infiltration fixes could involve placing new caps on broken or missing cleanouts, or installing new manhole covers with rubber gaskets. If during smoke testing, a possible line break is identified, a sewer camera may have to be used to determine the exact location and problem with the line. This would require more time and money. Line replacement costs can be noted during the smoke testing, and the system can develop a plan to replace those badly damaged sections first.   

Another common problem of infiltration is leaking manholes. The system may need to rehabilitate the inside of the manhole, which can be costly and time-consuming. They may also need to add risers to manholes in low-lying areas to prevent rainwater from seeping in. Again, these are some of the most common issues, but these are not all the possible issues that could arise during a smoke test. 

Having a smoke test completed on your system is a great way to gauge the overall health of the collection system, how your system works, and annual problem areas. If a plan is developed from the smoke testing, the system can plan corrective actions through it’s asset management plan. Once the repair plan is implemented, the hope is that the amount of influent to the treatment facility will be lowered, leading to lower operating costs, and less wear and tear on the system overall. Operators should plan to get their system smoke tested this year in order to begin seeing lower operating costs.  

This Drop of Knowledge (DOK) was funded through our EPA NPA 2 22 – 24 grant. 

February 21, 2024
The Beginner’s Guide to Geospatial Asset Management
3 MIN READ

The Beginner’s Guide to Geospatial Asset Management

The biggest problem that we’re facing is that nobody knows where all the stuff is. Our current operator has been here for 40 years, and he knows every single meter and dog in the town, but his son is trying to train to take over for him and he can’t figure out where anything is! The kid can’t memorize it fast enough and the dad can’t transport his knowledge into the kid’s head.

 
The excerpt above is from a conversation that took place between the mayor of a small, rural community, and me during a recent site visit. He went on to talk about the difficulties of retaining employees and training new ones in a town that is already low on eligible workers. This conversation highlights a common problem that many utilities face, which is an older generation of workers who have remained at their jobs for decades and a younger generation who favors transience and pursuing other opportunities. With expansive technology is there a way for small rural communities to solve this issue?

As water and wastewater utilities move toward using technology for digital forms of asset management, it is essential that activities such as smoke testing are recorded electronically for future use. Collecting data on smoke testing and other maintenance and inspection activities can help operators pinpoint common locations that experience leaks or defects. The data can also be used to highlight locations which need repairs and help track repair progress.  Without technology, this data would be lost with the experience of the worker who completed it. An inexpensive ($0.99) tool that utility systems can use to begin collecting this data is Solocator. This app can be used as a first step toward a geographic information system (GIS)-based wastewater inventory. It is simply a camera that stamps each of the pictures with GPS coordinates, project names, watermarks, time, date, and other optional information such as bearing and altitude. These photos can then be exported in multiple different formats for sharing or archiving. The geographical data can also be exported to a .CSV format for easy incorporation into your GIS software, such as ArcGIS, later.

Some illustrative steps for using Solocator are included below:

Download the Solocator app.
 
Adjust the settings to include the desired data.

Add watermarks, descriptions, and/or Project names.

Take photos of the smoke test.
Export your photos to begin a database of locations needing repair..CSV output:

Map output:

Asset Management is an essential part of a water system’s continued growth and is continuously changing as time passes Solocator is one of many affordable tools available to help communities start tracking asset management. Incorporating a sustainable data retrieval plan will help systems accommodate future employees and gain a more expansive understanding of their utilities.

This Drop of Knowledge (DOK) was funded through our EPA NPA 2 22 – 24 grant. 

February 21, 2024
Resolving Inflow and Infiltration Issues in a Growing Community
Wastewater | 3 MIN READ

Resolving Inflow and Infiltration Issues in a Growing Community

Members from Communities Unlimited’s (CU) Environmental Team recently visited the rural community of Martindale, Texas, population 1250. Located in the fast-growing region of Central Texas, this small city owns and operates its own wastewater treatment plant, while the city’s drinking water is provided by the Martindale Water Supply Corporation.

The original reason for the visit was to help the wastewater operator find a solution to the inflow and infiltration in the flood plain of the San Marcos River, where stormwater was entering the wastewater system through open sewer lines. However, during discussion with the operator, CU learned that I&I was not the only problem affecting the system: the plant was also in violation with the Texas Commission on Environmental Quality (TCEQ) for high pH levels in their wastewater ponds/lagoons. The team also discovered that the plant was suffering from excessive sludge build-up, reducing pond capacity and useful life.

Regarding the I&I, the operator informed CU that storm water was entering the wastewater system at a site where homes had been demolished to mitigate a flooding problem. Unfortunately, when the homes were destroyed, the construction contractor did not cap the lateral sewer lines for each vacant property lot. Since then, during rain events when the area floods, stormwater enters the wastewater system, overburdening the wastewater plant.

In such situations, a smoke test is often the first option for locating open sewer lines that are allowing stormwater inflow. Unfortunately, after contacting several agencies and organizations, they could not find any smoke test equipment to borrow. Instead, the team and operator decided that the next best solution would be to borrow a sewer line inspection camera from a local plumbing contractor. The camera would then be inserted at the maintenance hole located in front of vacant property lots to search for sewer lines and buried taps, and capping the lateral sewer lines to stop the infiltration and inflow.

After addressing the I&I issue, the team turned its attention to the lagoon’s high pH levels. They discussed several options with the plant operator, leading to a short-term, yet cost-effective, solution of treating each pond with muriatic acid and implementing a pH monitoring schedule.

Finally, the team provided the plant’s operator with a list of chemical vendors specializing in enzyme-based products that decompose sludge– an affordable alternative for improving the hydraulic volume and loading capacity of the ponds.

Thanks to CU’s Environmental Team, the City of Martindale’s plant operator is aware of next steps to take – and low-cost resources to use– to triage the system’s immediate technical issues. Long-term issues still loom, however: recently, a developer approached the city with plans to build a new subdivision, bringing flows that would exceed the capacity of the existing system. The CU team stands ready to help city leaders evaluate options for appropriate treatment technology to accommodate the potential increase in flow and embrace the city’s growth.

January 18, 2024
Effective Communication with the Community
Information | 4 MIN READ

Effective Communication with the Community

Despite the lack of knowledge among many individuals regarding the workings of their local water utility, the expectations of customers concerning drinking water tend to be high. These expectations, however, do not account for the challenges faced by utilities, particularly smaller ones, in delivering their product. When issues arise or changes must be made, customers often do not understand why their expectations are not met. As such, utilities need to ensure that their customers are aware of the challenges they face so that their expectations align with reality. Consistent communication with customers is crucial in building community understanding of the system.

Water utilities rely on their customers to comprehend how the system operates and the difficulties it encounters to secure community support for present operations and future enhancements. A utility should educate consumers on the source of their water and the procedures required to provide safe and clean drinking water. Utilities should also communicate any ongoing issues, such as a lack of staff, insufficient funding, difficulties in complying with increasing regulations, and challenges encountered when dealing with source water. Community support is critical when situations arise that are usually met with agitation or resistance, such as issuing a boil order, blocking traffic for repairs, or raising rates.

There are methods by which a system is required to communicate with its community, such as the Consumer Confidence Report (CCR) Rule mandated by the EPA, which necessitates that all public drinking water systems send water quality reports to their customers. In some states, utilities must also keep track of customer complaints. Although these are two effective ways to exchange information, systems should be proactive and take further steps to connect with their customers. A multi-faceted approach is ideal for educating customers who are likely to have little knowledge of water system management difficulties. Below are some methods utilities can use to increase communications with their customers:

The utility should actively seek feedback from the community about their experiences and expectations. If a utility is not actively soliciting feedback from the community, it is likely only receiving feedback in the form of complaints. Complaints provide valuable information about what users expect from a system, but usually not under the best of terms. Feedback can be solicited through other means, such as making phone calls, sending out surveys with bills, or participating in local events. Actively seeking feedback aims to increase utility and customer interaction, providing the utility with an effective line of communication to share information.
The utility’s staff and information should be accessible to users. Ensuring that staff and information are available to customers demonstrates that they can quickly receive answers to their questions. One way to achieve this is through in-person events. Some utilities have begun setting up booths at farmers’ markets and festivals, enabling employees to interact with customers and become seen as active members of the community. Utilities can offer classes for customers or incorporate education into an annual meeting. Lastly, utilities should encourage customers to call the office with questions and make this information available on a website or email.
Inviting the community to meetings is also recommended. An annual meeting is an excellent opportunity to educate customers about the system, but inviting users to monthly meetings can increase the likelihood of gathering feedback, educating, and answering questions. Information about meetings should be posted in multiple locations frequented by customers, including the post office, libraries, and churches. The event should be posted online on the utility’s website or social media and promoted frequently through social media campaigns.

There are various ways to improve communication with customers, and utilities should choose the methods that best suit the community they serve. Engaging with customers can lead to a more supportive customer base. An informed community of customers is more likely to comprehend the challenges faced by the system and support the needs of the utility.

December 20, 2023
Prudent Board Training in Prudence Island, Rhode Island
Management and Finance | 4 MIN READ

Prudent Board Training in Prudence Island, Rhode Island

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.

November 27, 2023
System Vulnerability Assessments and Emergency Response Plans
Emergency Response | 8 MIN READ

System Vulnerability Assessments and Emergency Response Plans

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!

October 27, 2023
Staff in Nebraska is Helping to Build a Sustainable, Resilient Utility Workforce
Infrastructure | 5 MIN READ

Staff in Nebraska is Helping to Build a Sustainable, Resilient Utility Workforce

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.

September 21, 2023