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April 2023
The Pennsylvania Department of Environmental Protection (DEP) Bureau of Safe Drinking Water is proud to provide updates, information, explanations and reminders to you with this edition of the Drinking Water News. In this issue:
- Do I Need a Registered Lab ID?
- CyanoHABs, Cyanotoxins, and Monitoring Considerations for Public Water Systems
- Cybersecurity Awareness for the Water Utility Sector
- Source Water Protection: Protecting Your Groundwater and Surface Water Sources
- Coagulation Optimization
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| Do I Need a Registered Lab ID?
June Black, Water Program Specialist, DEP Central Office
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There is a lot of confusion out there regarding registered lab IDs. The most common thing we hear is “But I’m not a laboratory”.
So, let’s start there and talk about What Is A Laboratory?
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- Any entity or individual that performs testing or analysis of environmental samples required by an environmental statute is considered to be an environmental laboratory.
- Testing for Accreditation-By-Rule (ABR) parameters (25 Pa. Code § 252.6, 25 Pa. Code § 109.304(c) including turbidity, fluoride, disinfectant residual, temperature, pH, alkalinity, orthophosphates, silica, calcium, conductivity, daily chlorite and magnesium hardness meets this definition.
- It is important to note that this definition includes testing at either the entry point(s) and/or in the distribution system.
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Using these definitions, many Public Water Systems would be considered laboratories, even if they only test for chlorine.
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- Under the Environmental Laboratory Accreditation Act of 2002, all environmental laboratories must register with the Department of Environmental Protection.
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So, you might be a laboratory. Do you need to apply for a registered lab ID?
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To figure out the answer to that, let’s talk about Requirements for Testing ABR Parameters:
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- Each system that tests for ABR parameters is required to have a Certified Operator who is licensed for the appropriate class and subclass(es).
- For example, if the system uses non-gaseous chlorine for disinfection, the operator needs subclass 12.
- A complete list of operator classifications and subclassifications can be found at 25 Pa. Code § 302.901.
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- Depending upon the system size and resources, the Certified Operator may be full time or part time. Also, the Certified Operator may work solely for the system or may represent several systems (i.e., Circuit Rider).
- 25 Pa. Code § 302.101 defines Circuit Rider as “a management program in which a Certified Operator may make process control decisions at more than one system of different ownership”.
- A Certified Operator may also act as a Circuit Rider. If the full time Certified Operator for the “Look Before You Leap” water system also acts as a part-time Certified Operator for a nearby manufactured home park, this would be an example of a Certified Operator acting as a Circuit Rider.
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- The Certified Operator can perform the ABR testing – OR – they can develop a Standard Operating Procedure (SOP) for another individual who will perform the testing under their guidance. When an SOP is used, the Department recommends the certified operator provide training to ensure it is followed properly.
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Now let’s put these pieces together to answer the question Do I Need a Registered Lab ID?
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- If you are small system that does not perform any ABR testing, you do NOT need a registered lab ID.
- If your system performs ABR testing and employs one or more full-time Certified Operator(s), you DO need a registered lab ID.
- You COULD use a lab ID registered to one of the Certified Operators employed by the system
- We RECOMMEND that you get a lab ID registered to your water system, so the same lab ID is used regardless of any change in Certified Operator status
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- If your system performs ABR testing under the direction of a part-time Certified Operator or Circuit Rider, you do NOT need a registered lab ID if the data are reported using the Circuit Rider or Certified Operator’s lab ID. You MAY want to get a lab ID registered to the system, so the same lab ID is used regardless of any change in Certified Operator or Circuit Rider status.
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And finish up with some examples:
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Scenario 1: The PWS “Drink Me” is a large Community Water System that employs several full time Certified Operators. The system has continuous monitoring for turbidity and chlorine residual, and also performs daily testing for orthophosphate.
- This system SHOULD obtain a registered lab ID, so that all data reported for the system comes from the same Lab ID, regardless of the status of its Certified Operators.
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Scenario 2: The PWS “Tall Glass” is a Non-Transient, Non-Community Water System using non-gaseous chlorine disinfection. They employ a Circuit Rider to act as the Operator in Responsible Charge and to collect samples within the distribution system. Another individual who works in the system’s treatment plant performs the daily chlorine testing following an SOP provided by the Circuit Rider.
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- This system MAY want to obtain their own registered lab ID.
- By getting their own registered lab ID, if the system changes Circuit Riders or hires a dedicated Certified Operator they will not need to change the lab ID used to report their results.
- In addition, if the system employs a new Circuit Rider who does not have a registered lab ID, there would be no lapse in reporting while waiting to obtain a new lab ID.
- Chlorine results for this system could be reported using EITHER the Water System’s lab ID — OR — the Circuit Rider’s lab ID
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- This system may OPT to use the Circuit Rider’s lab ID to report data.
- If the Circuit Rider has a registered lab ID, the system does NOT need a registered lab ID.
- Since the Circuit Rider provided the SOP used for daily chlorine testing, both daily & distribution chlorine results can be reported using the Circuit Rider’s registered lab ID.
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The bottom line is that all results must be reported using a valid lab ID. Coming in the future there will be additional error checks when entering ABR parameter data into the Drinking Water Electronic Lab Reporting System (DWELR), to ensure that results are reported with valid lab IDs. Now is the time for each system to determine if they need a lab ID, and to begin reporting their ABR parameter data in accordance with the guidelines described above. Any questions regarding lab IDs can be directed to ra-padwis@pa.gov.
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| CyanoHABs, Cyanotoxins, and Monitoring Considerations for Public Water Systems
Jill Anderson, Technical Support Section Manager, DEP Central Office
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Cyanobacteria are microscopic organisms found naturally in many surface waters and are sometimes referred to as blue-green algae. When conditions are favorable, including excess nutrient levels and elevated temperatures, cyanobacteria can grow rapidly to produce thick mats or blooms, sometimes referred to as harmful algal blooms (HABs) or harmful cyanobacterial blooms (HCBs or CyanoHABs). Different types of cyanobacteria may also produce several different types of cyanotoxins. If a CyanoHAB occurs in a surface water source of supply for a public water system (PWS), there is a risk of cyanotoxins being introduced into the finished drinking water.
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There are four primary cyanotoxin groups: microcystins, cylindrospermopsin, anatoxins, and saxitoxins. While none of these are regulated in drinking water at the federal or state level, EPA has established 10-day Health Advisory Levels (HALs) for total microcystins and cylindrospermopsin, as noted in Table 1 below. Note that there are two sets of values: one for adults and school age children, and one for children under 6 years of age. The lower of these is considered the treatment target as it is the most protective of the most sensitive subpopulation.
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Table 1. EPA 10-day Health Advisory Levels for cyanotoxins.
| | Total Microcystins | Cylindrospermopsin | | Children under 6, including bottle-fed infants | 0.3 µg/L | 0.7 µg/L | | Children 6 and older, and adults | 1.6 µg/L | 3.0 µg/L |
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Even though cyanotoxins do not have primary maximum contaminant levels (MCLs) established for drinking water, PA DEP has the authority to require water systems to take corrective actions if results indicate levels are above a health advisory. DEP’s guidance and long-standing protocols have established that levels in finished water exceeding an acute HAL constitutes a Tier 1 situation. If this occurs, required PWS follow up actions may include:
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- One-hour reporting of sample results to DEP (§ 109.701(a)(3))
- Collection of confirmation samples (§ 109.302(c))
- Issuance of Tier 1 Public Notification (PN) within 24 hours of receipt of sample results exceeding HAL (§ 109.408)
- Additional monitoring at each entry point (EP) to the distribution system that exceeded the HAL to determine whether levels are still exceeding the HAL (§ 109.302(d))
- If levels continue to exceed the HAL, additional actions would be needed to reduce levels to below the HAL (i.e. taking sources off-line, blending, treatment optimization) (§ 109.4)
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When levels in raw water or water collected at a location prior to the entry point exceed an acute HAL, PWS follow up actions may include:
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- One-hour reporting of sample results to DEP (§ 109.701(a)(3))
- Collection of confirmation samples (§ 109.302(c))
- Additional monitoring to determine whether levels are exceeding the HAL in finished water (§ 109.302(c))
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Because they do not have primary MCLs established, PWSs are not required to conduct routine monitoring for cyanotoxins. However, some PWSs, particularly those that use sources that may be considered to be vulnerable to cyanobacterial growth, may want to be prepared to conduct monitoring if a CyanoHAB affects their source, and may even want to consider a routine monitoring program. There are several key considerations when a PWS wants to have samples analyzed for cyanotoxins.
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Where to sample: The HALs are for finished drinking water, so sample collection at the EP and possibly distribution locations are important. But it may also be helpful to sample the raw water at the intake, upstream of the intake, at the location of the bloom, etc. It may also be helpful to sample at locations within the treatment plant.
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Analytical methods: EPA Methods 545 and 546 are approved for analysis of cylindrospermopsin and microcystins (respectively) in drinking water. There are lots of other potential analyses for different purposes, so it is important to be clear when requesting analyses from a lab.
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Laboratory selection: There is currently no PA accreditation program for cyanotoxin analysis, and there are very few nationally accredited laboratories. When selecting a lab for cyanotoxin analysis, it is important to ask questions so you can be prepared to defend the reliability of any results. For example:
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- Does the lab follow the approved methods (EPA 545 and 546) with no deviations?
- Do they follow all method required QA/QC and acceptance criteria?
- What reporting limits are used? Are they low enough to determine compliance with the HALs?
- Does the lab participate in any ongoing third-party oversight to demonstrate method proficiency, such as a performance testing program?
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Turnaround time needed: This can vary greatly between labs, and often very quick turnaround of cyanotoxin results is needed in order to respond promptly.
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Sampling supplies: Know what bottles, preservatives, etc. are needed so that they can be on hand. It may be best to work with a lab in advance and have the supplies ready to go when needed. Also, consider sample delivery – samples may need to be shipped overnight to the lab.
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Here are a few additional resources for more information on cyanobacteria and cyanotoxins:
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| Cybersecurity Awareness for the Water Utility Sector
Scott Alderfer, Water Program Specialist, DEP Central Office
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While a wide range of businesses, institutions, government entities, and utilities face cybersecurity threats from a variety of actors in our current world, a cyber attack on a Public Water Supplier (PWS) could have devastating effects on the supply of ample safe drinking water to the PWS’s customers.
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The Bureau of Safe Drinking Water wishes to provide PWSs in our Commonwealth with general information to guide them in their cyber security decision making. Please understand that the following information should not be construed as technical guidance but rather as talking points for conversations between key decision makers within the PWS and their information technology/ operations technology (IT/OT) staff, outside IT/OT vendors and telecommunications vendors.
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All community water systems (CWSs) are required to have an emergency response plan that meet all required elements specified in 25 Pa. Code § 109.707(a) for water supply emergencies, such as water main breaks and natural disasters; however, PWSs of all types and sizes should also have emergency preparedness plans for cyber attacks. Cyber emergency plans should be prepared in consultation with a utility’s IT staff, outside IT vendors, operations staff, any operations vendors, and the utility’s cyber insurance carrier. Don’t wait for a cyber attack to put a team together and build your defense.
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Among the most common cybersecurity threats are:
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A Denial of Service (DoS) attack can occur when a malicious cyber threat actor interferes with an organization’s information systems, devices, or other network resources to prevent users from accessing the organization’s network or its information or devices. A DoS attack essentially locks the PWS and its customers or vendors out of its computer network.
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A distributed denial-of-service (DDoS) attack occurs when machines in a variety of locations are hacked into and made to operate together to attack one target. DDoS attackers frequently use a botnet—a group of hijacked internet-connected devices – to carry out large scale attacks. The goal of a DDoS attack is to overwhelm the target organization’s servers with millions of data packets per second, crippling the servers.
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To orchestrate a DDoS attack, hackers take advantage of vulnerabilities or device weaknesses within a targeted organization and use command and control software to direct multiple machines to target the primary victim of the attack. Once in control, an attacker can command the botnet they have assembled to conduct DDoS on a target organization. In the case of a botnet attack, the infected devices are also victims of the attack.
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In a malware/spyware attack, malware or spyware is introduced to the organization’s computer network. This infection is most often the result of spear phishing – phishing emails targeted to unsuspecting employees of the target organization. In a spear phishing attack, infected email attachments are used to introduce malware into an organization’s internal networks where it can be cause numerous problems as numerous as the hackers’ gain access to sensitive company information such as passwords or even customers’ Personal Identifying Information (PII) and billing information. Malware can be as basic as stealing passwords or posting disinformation on the organization’s website, or as vicious as taking control of Operational Technology systems, such as chlorination, reverse osmosis, or UV treatment.
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Ransomware is a specific form of malware designed to encrypt files on a device such as a mail server or file server, rendering the files unusable to the organization under attack. Such an attack could freeze a PWS’s operational capabilities, potentially threatening water treatment and distribution capabilities. Hackers will then demand a ransom in exchange for providing the victim organization access to their files or network.
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Cyber insurance policies can cover a variety of cyber attack scenarios and resulting damages. Therefore, it is crucial for PWSs to review their cyber insurance policy with an IT security expert to evaluate whether your coverage has any exclusions or gaps in coverage that can be avoided. While it’s not possible to offset all potential cyber risks, financial loss from many risks can be mitigated. In the event of a cybersecurity event, remember to notify your cyber insurance agent or broker of the security breach promptly. Some cyber insurance carriers may require you to work only with IT professionals on the insurance carrier’s approved vendor list. A PWS may risk not having their usual IT vendor’s invoices covered by their cyber insurance company if the invoices are from a non-approved vendor.
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There are many resources available for increasing cybersecurity awareness. See EPA Cybersecurity Best Practices for the Water Sector for resources and best practices on cyber resilience as a good place to start. In addition, WaterISAC’s website contains several downloadable guidance documents about cybersecurity for the water sector, including: 15 Cybersecurity Fundamentals for Water and Wastewater Utilities. WaterISAC is a non-profit organization formed by, and governed by, water and wastewater utility managers and state drinking water administrators. The organization’s mission is to provide its members with tools to identify and manage risks and to help utility manager apply their limited resources where they are most needed.
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| Source Water Protection: Protecting Your Groundwater and Surface Water Sources
Andrew Kaufman, Compliance Specialist, DEP Southwest Region
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Wellhead with new sanitary seal well cap
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Our country abounds with many resources which have been utilized by us for hundreds of years, and whether you have thought about it or not, one of our greatest and most precious resources in this vast land is our water supply. Because one of its most important uses is for our everyday consumption, both protecting and preserving this natural resource is imperative to our daily lives. Even though most customers probably don’t think about the importance of having water safe to use and drink when we turn on the tap, luckily there have been those who do. And while it is very important to ensure that our drinking water is properly treated and tested before it is sent out to our homes, one of the most important keys to ensure safe water for our everyday consumption and use starts with ensuring the protection of our source water, whether it be from an underground source or contained in your local reservoir.
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Protection of this very vital resource can encompass many different actions and precautions. To start, one of the first and possibly most beneficial ways to protect your source is through establishing a Source Water Protection Program for your system. The source water protection program helps a system to not only take a close look at and evaluate their source waters’ surrounding land area, but it can help set up the needed tools and information for that system to proactively help care for and protect their vital drinking water source from harmful contamination and diminishment.
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The key elements of a Department-approved source water protection program are as follows:
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Surface Water Source Reservoir and Intake Tower
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1.) Creating a committee made up of varying representatives from the water system, local government officials from the systems’ jurisdiction, representatives of the area’s industrial and commercial businesses, and any other pertinent representatives of the water system’s community.
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2.) The education and encouraged participation of the local public residents to help encourage the support of the source water protection activities.
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3.) Creating a detailed map which depicts areas and lands encompassed by the source water protection program, which helps to illustrate what geographical lands need the most protection to ensure clean and safe source water.
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4.) Establishing a source water assessment for each of a system’s sources, which encompasses identifying potential and current possible sources of contamination for each water source.
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5.) Developing and implementing management areas and practices which can affect the source water. This can mean purchasing or establishing written agreements with surrounding lands and property owners to inhibit any harmful use of the areas surrounding a system’s source water and stem possible contamination.
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6.) Development of contingency planning for contamination of your source through identifying alternate water supplies and establishing emergency response protocols in the event of your source water being contaminated.
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7.) Having the forethought to ensure the protection of any possible future water source sites as your system continues to grow and evolve in its needs.
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With a Department-approved source water protection program the system will need to ensure that they keep their plan up-to-date annually and submit the current version of the Department-provided annual update form to the Department.
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Standard sign used to warn the public
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While a Department-approved source water protection program can be a key resource and vital in protecting your drinking water sources from harm it can still fall short if the actual physical work is not carried out. But a system can easily help protect its source water by simply implementing any number of proactive measures. These measures can range from something as basic as posting signs warning the public against misusing or carrying out harmful activities within an established management area, to physically visiting your water shed’s surrounding area and source facilities to ensure no possible contaminating actives are taking place. Other actions which can be taken by a system are ensuring the proper creation of groundwater sources (wells or springs) through proper encasement and grouting, the use of sanitary seal well caps, and proper setback distances, which are all measures to prevent contamination of the underground aquifer.
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Additional actions would encompass limiting the actions and sources of contamination by either owning or entering a written agreement with the owner of the surrounding area of your ground or surface water source to restrict the access, usage, and management of those surrounding grounds.
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While creating a source water protection program and carrying out the needed actions and precautions can be very effective in ensuring quality and safeness of your source water, it can be an uphill battle if those most affected are not in support, and that would be the public whom consume and use the drinking water you produce. So through education, outreach, and involvement with the public you serve, they can be really the most vital resource to help protect your system’s source water as they can act as extra eyes and ears for your system are more likely to report any harmful activities when they feel invested in protecting “their” water, because all of your customers want to continue to have access to safe drinking water.
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| Coagulation Optimization
Amanda Ferguson, Environmental Engineer, DEP Central Office
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For filter plants, coagulation is a critical step in the multiple-barrier approach to removing contaminants and providing safe drinking water to consumers. Surface water can experience rapid changes in raw water quality and these changes impact how well a coagulant dose will aid in particle removal. There are several tools available to aid operators in optimizing the coagulation process; and improving coagulation will improve the overall effectiveness of the plant. Improved coagulation results in improved settling and filter performance. For this reason, it’s important for systems to be aware of, and consider, all available coagulant optimization tools as they can. Not only will this aid operators in making process decisions which lead to better plant performance, but this may also provide cost savings by requiring less chemical addition and improving plant efficiency.
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Tools available range from simple operator observations, trending, and SOPs to commercial lab and online monitoring of water quality parameters. Raw water turbidity monitoring can be helpful in indicating changes in source water quality and directing coagulant dosage adjustments, while settled and filtered water turbidity are lagging indicators of coagulant effectiveness. While reduction in turbidity is a proven indicator in reduction of pathogens, because turbidity is not a good indicator of dissolved organic carbon, turbidity may not be as helpful for determining proper coagulant dosing to remove natural organic material (NOM) which can contribute to formation of DBPs. Other tools that may be helpful to optimize coagulant dosing, in addition to turbidity, include streaming current or zeta potential analyzers, filterability tests, TOC analyzers or UV254 analyzers, jar tests, chemical dosage charts, and chemical feed pump monitoring devices.
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Each coagulant optimization tool has both benefits and drawbacks. Jar tests have historically been a tried-and-true method for determining the optimum coagulant dose and other chemical dosages. Jar tests generally take two hours to perform, however, and are not appropriate for making immediate dosage adjustments in response to rapid changes in source water. Still, jar tests can serve to optimize coagulant dosage for seasonal, monthly, or weekly changes, as well as test alternative strategies, such as pH adjustment and mixing rates, without changing the performance of the full-scale plant.
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Analyzers such as streaming current and zeta potential, which provide a measurement of the negatively charged particles (typical of raw water), can be used to monitor the charge of the mixed water just after coagulant addition and allows operators to respond more quickly by creating a setpoint for optimal coagulant dose (as determined by jar tests) and adjusting coagulant up or down to maintain that setpoint. There are both lab and online versions of these charge analyzers. These analyzers require proper maintenance and may have interference from sudden changes in pH or conductivity.
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TOC analyzers and UV254 analyzers can assist operators similarly in providing information on organics in the raw water to aid in adjusting coagulant dosing, however they may be limited in their ability to identify all organic carbon.
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Filterability methods use newly settled water from a jar test to determine if the selected dose will provide the best filtered turbidity and allows more quantitative analysis of the strength of floc particles (the ability of the particles to stick together).
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Some equipment, such as jar testing equipment and filterability equipment, may be less expensive and more accessible than the more expensive online or lab analyzers; however, even equipment for jar tests and filterability are not without costs. The least expensive tools may be operator observations of weather patterns, floc formation, and maintenance needs for chemical feed equipment, but operator observations may be more qualitative and subjective, leading to inconsistent operation between operators. Additionally, operator observations can only assist in reacting to future source water quality when the observations have been documented.
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Jar testing equipment (photo by Kurt Smith)
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Coagulant optimization tools may provide operators with better information to respond to varying surface water quality over different seasons, months, and even throughout a day. This will aid in better removal of organic carbon, reduction in coagulant or other chemical usage, better settled water turbidity, better filter performance, and ultimately better water quality for a system’s customers. Although some tools may have upfront costs, overall benefits of using one or more of these tools could potentially assist in paying for the tools themselves. As such, it is important for systems to be aware of the various methods that could aid in optimizing coagulant dosing and overall plant performance.
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Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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