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July 2024 Edition
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:
- Responding to a Loss of Positive Pressure
- Reminders for PFAs Sample Collection
- What Happened to my NSF Certification?
- Health Effects of Epichlorohydrin and Acrylamide in Drinking Water
- What to do if Your Continuous Analyzer for Chlorine Reads “0”
- Should You Operate Continuously?
- Valve Exercising Programs for Public Water Systems
- How Plant Start-ups & Shutdowns Affect Turbidity Monitoring and Reporting
- REACHING OUT: FREE LUNCH?
- Notification Requirements for Lead, Galvanized Requiring Replacement and Unknown Service Lines
- Did You Know?
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| Responding to a Loss of Positive Pressure
Gail Guenther, Compliance Specialist, DEP Southwest Region
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If your system has experienced a situation resulting in a loss of positive pressure, foremost in your mind should be “what do I do now to protect the distribution system and our consumers from contamination”? This article will go over the resources and requirements to address that concern.
Public water suppliers must always operate and maintain their facilities, and take investigative and corrective action as needed, to ensure that safe and potable water is continuously supplied to users of the water system. That obligation is laid out in Section 109.4 of DEP’s Safe Drinking Water Regulations, which are codified in Title 25, Chapter 109 of the Pennsylvania Code 25 Pa. Code § 109.4
There are numerous situations that can result in a loss of positive pressure, such as line breaks, power disruptions, extreme usage/storage depletion, equipment repairs or construction, and so on. In some situations, one-hour reporting to DEP will be necessary and possibly a Tier 1 public notice (PN) in the form of a Boil Water Advisory to system users. Those situations are discussed in more detail below.
Situations requiring one-hour notification to DEP were discussed more broadly in the February 2024 issue of Drinking Water News: February 2024. This one-hour reporting is required by Section 109.701(a)(3) of the regulations, 25 Pa. Code § 109.701(a)(3). In general, it is required whenever there are circumstances that may adversely affect the quantity or quality of drinking water.
Speaking specifically to the loss of positive pressure (in any portion of your distribution system), a public water supplier must report the situation to DEP within one hour any time: 1) there is a loss of positive pressure in any portion of the distribution system caused by a situation other than a main break (e.g., power or source outage, pump failure or depletion of storage); 2) the loss of positive pressure is caused by a main break, repair or replacement and there is evidence of contamination OR a high risk of contamination; 3) a main break is not repaired in accordance with the specifications of AWWA Standard C-651 (for disinfecting water mains during repair or replacement); or 4) you have E. coli-positive special sample results (from samples collected in accordance with Standard C-651).
A little elaboration on item 2 above will be helpful. Evidence of contamination can be observed through the senses – unusual color, taste, odor or temperature – or by a change in water chemistry demonstrated through field tests. A high risk of contamination can result from numerous circumstances. Here are some examples: your repair area is flooded at or above the level of the repair, sewer leaks or poorly performing septic are nearby, stream or river crossing(s) are near your break, or there’s a back flow or cross-connection nearby. This list is in no way exhaustive – there can be any number of conditions that could lead to contamination entering your distribution system during a loss of positive pressure. And, remember, the situation can arise in an area other than one with a break or repair; lower pressure zones are always a concern and should receive extra attention at such times.
So, importantly and not surprisingly, the determination as to whether evidence or a high risk of contamination exists is a process control decision that must be made by a Class E certified operator. If a Class E operator is not available to make that evaluation and determination, then there is assumed to be a high risk of contamination and you must report the situation to DEP within one hour.
Why is a loss of positive pressure so important? It’s important because the integrity of your distribution system is the final layer of protection for your consumers, and a loss of positive pressure in that system presents the potential for a serious threat to public health. The loss of pressure presents the opportunity for biological pathogens or other contamination in the surrounding environment (or a cross connection) to enter your distribution system, potentially causing illnesses or worse for those who consume the water.
For that reason, DEP’s Loss of Positive Pressure policy document lays out the affirmative steps water suppliers should take to identify potential contamination and protect system users from consuming compromised water. The policy is available on DEP’s website and was updated in 2022. It contains significant additional information beyond what can be encapsulated in this article and is well worth your time to read and maintain as a reference.
So, what do you do in this situation? As we’ve already discussed, you notify DEP within one hour whenever the circumstances so require. At the same time, you can consult with your regional Safe Drinking Water staff about whether a Boil Water Advisory is needed. Once actual or potential contamination to the system occurs, the only means of protecting consumers and preventing water-borne disease is to prevent people from consuming the water. DEP’s Policy for Issuing and Removing Water Supply Warnings can be found on our website. The Tier 1 PN template for a Boil Water Advisory resulting from loss of positive pressure is included in DEP’s PN Handbook online and here: TIER 1 PN LOSS OF POSITIVE PRESSURE.PDF 3930-FM-BSDW0180.
Next, you need to take corrective action in accordance with industry-determined Best Management Practices (BMPs). Per DEP’s policy, those can be found in AWWA Standard C-651 discussed above, with additional information and procedure available in the AWWA field guide titled “Disinfection of Pipelines and Storage Facilities.” Both of those documents are available directly from AWWA.
The BMPs will walk you through methods to minimize the entry of contaminants to your distribution system, disinfect your pipe(s), remove contaminants that have entered the system and dechlorinate your discharge (requirements of the Clean Streams Law apply), determine whether your actions have been effective, and complete a sufficient repair log.
Before the situation next arises at your system, take a look at all these resources and you will be prepared to respond quickly and effectively to protect your distribution system and the health and safety of those who use it.
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| Reminders for PFAS Sample Collection
Dan Ackers, Compliance Specialist, DEP Northeast Region
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With the first two quarters of initial monitoring for Per- and polyfluoroalkyl substances (PFAS) for Community and Nontransient Noncommunity water systems serving a population of over 350 now well under way, a review of things to consider when collecting these samples might be helpful. As noted in training provided by the Department, which is available on the PFAS MCL Rule website under the heading “Training,” due to the general prevalence of PFAS and PFAS-containing materials in everyday life, added precautions should be observed to prevent incidental cross contamination and ensure that good, analytically valid sample data is achieved; good sampling practices are key to achieving this.
With regards to avoiding cross contamination from the sampler themselves, the sampler should be aware of what they are wearing; waterproof/water resistant and stain resistant clothing & shoes as well as some cosmetic products and sunscreens may contain PFAS that could be accidently transferred to the sample. Clothing washed with fabric softeners as well as new, unwashed new clothing can contain PFAS. Food could also present certain issues; things such as fast-food wrappers contain PFAS which could possibly be transferred from the samplers’ hands to the sample. The simple act of documenting sampling activities can potentially have an adverse effect on those samples as commonly used waterproof field notebooks and markers (i.e. Rite in the Rain®, Sharpie®) may contain PFAS. Hand washing with a laboratory grade, non-phosphate containing detergent followed by a rinse with laboratory reagent grade water before sampling can help to reduce the risk of cross contamination.
As with other sample matrices (VOAs, Microbiological, etc.) the sampling area, sample tap, and environment they are contained in can present concerns with getting an accurate sample. Removal of the aerator of the sample tap is important to prevent the potential “off gassing” of the PFAS, which could lead to a potential false low reading. Plumbing and sample taps used for PFAs sampling should be free of Teflon® containing materials or if this cannot be avoided, given longer flush times prior to sample collection. And while we may not be able to change anything about the sampling area, we can make sure that any effects of that area are accounted for with the proper use of Field and/or Trip Blanks. Other things to consider are: the use of a fresh pair of Nitrile gloves for each sample, not opening the sample container until you are ready to take the sample, being careful not to touch the inside of the sample container or the lid, and to not rinse out the preservative of the sample container by pre-rinsing or overfilling the sample container.
Even if you have done a great job up to this point, there is one last hurdle to overcome: getting the sample safely to the lab. Coolers for PFAS sampling should be set aside for just this purpose and not shared with other sample types or matrices. These coolers should be regularly cleaned using the same laboratory grade, non-phosphate containing detergent and then rinsed out with laboratory or reagent grade water. Double bagging the sample containers with self-sealing bags will help to control cross contamination. The ice in the coolers should also be double bagged. Only use “wet” ice; no dry ice and no “blue” chemical ice, unless the laboratory provides “blue” ice that is tested and certified PFAS-free.
Finally, always follow the directions and instructions of the certified laboratory that is analyzing your PFAS samples. This might include sample container and cooler prep & handling, quality control/assurance considers (use of blanks, field duplicates, etc.), or any other things that they request of you during these sampling procedures.
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| What Happened to my NSF Certification?
Sara Henninger, Compliance Specialist, DEP North Central Region
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During various inspections and filter plant performance evaluations this year, we have discovered a trending issue that multiple systems are facing. Drinking water treatment chemicals are being delivered to systems without the NSF seal of approval. Without that certification, the Department and the system have no assurance that the product has been held to the stringent requirements that the NSF seal signifies.
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Citric Acid barrel without the NSF certification
NSF is an internationally recognized organization focused on developing and improving the public health standard among food safety, medical device safety and the safety of your drinking water quality. The NSF certification tells the consumer of a certified product that the product has met very stringent requirements. It has passed various quality assurance checks that set the certified product apart from those without that seal of approval. More specifically, ANSI/NSF 60 is the seal of approval for drinking water treatment chemicals. These are established requirements for the chemicals that are added to drinking water from drinking water treatment chemicals. The standard for these chemicals is monitored, updated and reviewed regularly by a committee of individuals who are public health experts and industry members.
Water treatment facilities that choose to utilize non-NSF certified products, without receiving prior approval by DEP, are in violation of Chapter 109.606(b). Chapter 109.606(b) states that chemicals used by a public water supplier which come in contact with the water or may affect the quality of the water and which are certified for conformance with ANSI/NSF Standard 60 (Drinking Water Treatment Chemicals—Health Effects—NSF) or meet the food grade standards of the United States Pharmacopeia are deemed acceptable to the Department. Chapter 109.606(c) states that materials or equipment used in the construction or modification of a public water system, including waterline extensions, mechanical devices and drinking water treatment equipment, which come into contact with the water or may affect the quality of the water and which are certified for conformance with ANSI/NSF Standard 61 (Drinking Water System Components—Health Effects—NSF) are deemed acceptable to DEP.
Now you may be asking yourself, how can I combat receiving chemicals that are not NSF certified? The owner/operator should make it common practice to be at the plant while the delivery is being dropped off if at all possible. This is to prevent the delivery of chemicals without the NSF certification. If it is found that the delivery of chemicals is not NSF certified, the problem can be addressed immediately, and the items can simply be placed back on the truck and returned to the warehouse. This will eliminate the potential for extra costs that may be associated with returning chemicals that have already been delivered and requesting that the warehouse return to the plant to pick up the chemicals that are not properly certified.
Owner/operators may also try to establish a rule with your supplier that your system is not willing to accept any substitutions, unless the supplier can provide proof that the substitution is also NSF certified. Doing this should eliminate the chance of being supplied non-NSF certified chemicals by giving the supplier options if they run into the issue of not having your chemical in stock. With this knowledge, they know that they may either provide an approved alternative or inform the system that their inventory does not support the order and should allow for the opportunity to get chemicals elsewhere in a timely manner.
The final way your system can ensure that your chemicals are NSF certified is to place your orders in advance. Supply chain issues are more prevalent than ever before, so placing your order for NSF certified chemicals may prevent you from getting non-NSF chemicals delivered to your system as an alternative. The NSF website allows customers to search for the chemical they need by including their location and manufacturer. As always, you are welcome to reach out to your local sanitarian to start a conversation about this issue if you find yourself with uncertified chemicals at your system.
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| Health Effects of Epichlorohydrin and Acrylamide in Drinking Water
Gina Kellett, Compliance Specialist, DEP Northeast Region
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Drinking water often undergoes a variety of treatment processes between its source and its destination – drinking water taps. Treatment depends on the source from which the water came from and the quality of that raw water. Surface water for example, goes through pre-treatment processes prior to its main treatment on its way to become safe for human consumption. One such pre-treatment process – clarification - includes coagulation, flocculation, and sedimentation, which are all steps meant to remove suspended solids, particles, and other impurities to purify the water.
During the clarification process, chemicals are added to the water to allow for removal of dissolved solids and other particulate contamination. Epichlorohydrin (a coagulant) and acrylamide (a flocculant) are two of these chemicals added to raw water to trap those suspended solids into clumps to allow the solids to settle into sediment and be removed from the water. This step in the purification process allows for the water to be ready for additional treatment so that it can be safely consumed by humans.
Epichlorohydrin is a colorless pungent garlic smelling chemical. Typically, it is removed from the water along with the sediment, however, it can remain suspended in the water as a contaminant. This chemical has been determined to potentially cause a number of health effects in humans if they are exposed to acute levels above the maximum contaminant level for a short period of time. Potential health effects caused by acute exposure to epichlorohydrin include skin irritation and detrimental effects on the liver, kidneys, and/or central nervous system. Therefore, in 1992, the EPA began requiring public water suppliers to show that when epichlorohydrin is added to water, the remaining uncoagulated amount of the chemical is less than two (2) parts per billion. Additionally, the EPA has determined that the drinking water standard is a treatment technique of 0.01% dosed at 20 parts per million (or equivalent); EPA has also established a Maximum Contaminant Level Goal (MCLG) of zero.
Acrylamide is a white odorless solid that is soluble in water. Human exposure (via dermal contact and inhalation) to acrylamide typically occurs when handling the chemical. However, the public can potentially be exposed to the chemical from the leaching of the flocculants used in water treatment. The EPA has determined that acute and chronic exposure to acrylamide can cause a number of health effects. Acute exposure to the chemical above the maximum contaminant level can cause damage to the central and peripheral nervous systems, weakness and ataxia in the legs. Long term exposure above the maximum contaminant level can potentially cause damage to the central and peripheral nervous system and paralysis. Lifetime exposure of the chemical above the maximum contaminant level has been linked to cancer. The EPA has determined that the drinking water standard is a treatment technique, which states that when acrylamide is used in drinking water, the combination of dose and monomer level may not exceed 0.05 % dosed at 1 part per million in drinking water. The MCLG is zero. Additionally, the EPA has determined Health Advisory Levels (HAL) for acrylamide, which are levels at which acrylamide in drinking water is considered "safe" for short-term (acute) exposures are: a one- day exposure of 1.5 mg/L for a 10-kg (22 lb.) child consuming one liter of water per day, a ten-day exposure of 0.3 mg/L for 10 kg (22 lb.) child consuming one liter of water a day, and up to a 7-year exposure of 0.002 mg/L for a 10 kg (22 lb.) child consuming one liter of water a day.
25 Pa Code Chapter 109.701(d)(7) states that water suppliers shall keep records concerning the use of acrylamide and epichlorohydrin for at least 12 years. These records must include verification that the chemicals used were certified for conformance with ANSI/NSF Standard 60 in accordance with § 109.606 (relating to chemicals, materials and equipment) and that the combination—or product—of dose and monomer level did not exceed the MCLs for acrylamide (0.05% dosed at 1 ppm (or equivalent)) and epichlorohydrin = 0.01% dosed at 20 ppm (or equivalent).
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| What to do if your continuous analyzer for chlorine reads “0”.
Shannon Huss, Compliance Specialist, DEP Southcentral Region
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So, let’s suppose you are the operator of a Surface Water / GUDI system or a community water system with groundwater serving over 3,300 customers. This morning you’ve gotten your coffee, you have your clipboard, you have begun making your rounds, turning on lights, writing numbers and checking boxes.
All is going well until you get to the continuous chlorine residual analyzer. You know, the brand-new unit that ate up the rest of your maintenance budget for this fiscal year?
And... It reads…. ZERO!
What do you do?
First, things first, take a grab sample and establish if the reading on the continuous monitor is, in fact, a “true zero” with a known verified colorimeter. If you have an assistant available, send them to verify if the chlorine dosing equipment is functioning and check any available date recordings to ascertain when this problem began.
If the grab sample comes back zero, it’s time to notify DEP and prepare Tier 1 Public Notification!
For surface water / GUDI systems this is a failure or significant interruption of treatment technique requirements for pathogenic bacteria, viruses and protozoan cysts, which is a violation of 25 PA Code section 109.202(c) and requires a 1-hour notification to DEP as per section 109.701(a)(3) and the issuance of a Ter 1 Public Notification within 24 hours as per Section 109.408(a)(6).
For groundwater systems, this is a failure or significant interruption in 4-log treatment of viruses as per section 109.1307(a)(1)(ii). The response is the same: 1-hour notification to DEP and Tier 1 Public Notification within 24 hours.
Now, for a different scenario, let’s assume that the grab sample proves that you have 0.42 mg/l of chlorine at the entry point. You’ve verified that your chlorine dosing system is functional and found that your meter is non-functional, however, you have manually verified that you still have chlorine in the system.
What do you do now?
The rules covering this vary slightly if you operate a surface water or GUDI system as compared to a groundwater system.
For surface water or GUDI systems, according to section 109.301(1)(D), “If a public water system’s continuous monitoring or recording equipment fails, the public water supplier may, upon notification of DEP under Section 109.701(a)(3) (relating to reporting and recordkeeping), submit grab samples or manual recording every 4 hours in lieu of continuous monitoring.” Section 109.701(a)(3) requires that this notification be made to DEP within 1 hour of becoming aware of the equipment failure.
For groundwater systems, it’s section 109.1305 (a)(1)(iii), which requires systems to “Conduct grab sampling every 4 hours until the continuous monitoring equipment is returned to service if there is a failure in the continuous monitoring equipment and notify the department within 24 hours.”
In either case, grab sampling may not continue for longer than 5 working days after the equipment fails.
Now, it’s time to investigate the cause of the malfunction, call your equipment supplier, replace the probe, etc. as quickly as possible to get the analyzer back online and keep DEP informed of the progress. It would also be a good time to find out why there were no alarms going off, assuming you have them, and they are set! And, of course, keep up on that grab sampling every 4 hours until the meter is back online!
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| Should You Operate Continuously?
Matthew Hollen, Compliance Specialist, DEP Southcentral Region
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It is well known that not all surface water treatment plants continuously operate. This is either due to lack of staffing or demand or due to the high production rating of the plant itself. Which option is the better choice? Could it be the start and stop operations of the plant or could it be reducing the plant’s flows and continuously operating night and day? Both options both have their potential benefits and consequences. For this article, we will focus mainly on the benefit of maintaining continuous operation and what steps you can take at your plant.
Right now, you may be asking yourself what is the main advantage of continuously operating your plant? Start/stop operations can create hydraulic surging that can drive particles deeper into a filter, damage plant piping and disrupt sedimentation/clarification. By maintaining continuous operation of the treatment plant, the removal of any pathogens or debris is maximized. This will allow your treatment plant to have the best opportunity of producing safe drinking water for consumers. All plants will eventually stabilize and reach an equilibrium in the treatment process.
So how can one achieve continuous operation? They are a few options that a system can choose from. Option one is just by reducing the flow rate through the system or by operating just one treatment train, if multiples are present, at a time. Another option to utilize is adjusting the high and low levels in distribution tanks. The final option one can utilize to maintain continuous operation is by using variable speed drive on pumps in the treatment process. This will allow the amount of energy being sent to the pump to be controlled so the flow of water going through the plant can be regulated to help maintain a constant flow.
Speaking of variable speed drives and pumps, it is shown that pump life is inversely proportional to the speed at which the motor rotates. So, by reducing the operating speed of the pump, pump life can be increased which reduces the amount of down time for pump and motor maintenance or change outs. Additionally, wear and tear on the pumps and motors can be minimized by operating in a continuous fashion. The act of stopping and starting a pump can induce stress into it as well as burn out the pump motor. This will lead to untimely costs and repairs that can not only affect the continuous operation of the plant, but also the budget for the system. Reducing wear and tear is another benefit to have your plant continuously operate.
Considering all that was mentioned in the above paragraphs continuous operations seems to be the route to take. From more effectively removing pathogens and achieving equilibrium in treatment to reducing hydraulic shock and wear and tear on pumps, continuous operation of water plants can attribute to a decrease in chemical and maintenance costs throughout the facility. There are additional benefits as well as cons for operating your treatment plant on a continuous basis. It is up to you, as a water system operator, to decide what will work best for your system. Though, as always, let’s “Continuously” strive for a more optimized performance in drinking water treatment.
References:
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Valve Exercising Programs for Public Water Systems
John Cairnes, Compliance Specialist, DEP Southeast Region
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Maintenance of a distribution system includes ensuring that all components within the system are fully functional and in good condition. One aspect of water supply maintenance that is often overlooked is the regular exercising of valves within the distribution system. All public water supplies have valves in them, but it’s easy to forget about them if the water supply is stable and experiences few main breaks or pipe replacements. Smaller water supplies rarely alter their distribution maps or add new customers regularly, so the regular maintenance of valves may not be a high priority. But all water suppliers should have in place a program for periodically inspecting and exercising the valves within distribution. Failure to maintain valves can lead to valve corrosion, degradation of mechanisms and other problems that can cause the valve to seize up or otherwise fail to operate when they are needed.
The benefits of fully operational valves are many, including quick isolation of main breaks, reduction of water loss and labor costs, options for unidirectional flushing, and ease of repair and replacement. Periodic inspection and exercising of valves should be a part of all public water systems’ operation and maintenance plans.
The first part of a valve exercising plan is knowing where all the system’s valves are located. It is important to develop and maintain an inventory of all your system’s valves, including a map of their locations. For each valve, you should include information about the size, type, function, manufacturer, type of access, normal position (open or closed), whether the valve opens clockwise or counterclockwise, date of installation, and the number of turns required to completely open or close the valve. This will save time and money when it’s time to exercise, repair or replace them, and can be helpful in leak detection.
When planning your exercising pattern, establish a set of priorities. High priority should be given to critical customers, such as hospitals, care facilities and schools. Other factors for priority include the amount of flow, the age of the valve and proximity to busy streets and intersections where a valve failure or main break can create immediate hazards to the community.
Your plan should include an inventory of critical tools for exercising valves. Besides tools for opening and closing valves – which may be hand-held or truck mounted, depending on the size of the valve and the amount of torque needed to open and close it – consider adding a utility vacuum cleaner for cleaning around gate valve boxes, shovels and a tape measure, and perhaps a metal detector for pinpointing locations. Other useful items include flashlights, system maps, street maps, screwdrivers, a logbook or journal and a digital camera to create visual records of locations.
When closing a valve, be careful not to over-stress the mechanism. Do not apply excessive force; if using an electric valve tool, start at the lowest torque setting. Don’t rush through the process. Closing or opening a valve too quickly can cause water hammer that can damage the valve and connecting pipes. Gradually close the valve by turning the handle or stem in a back-and-forth pattern, such as five turns closed to three turns open, to redistribute any lubricant that may have settled over time and work out any stiffness in the mechanism. Be alert for any sudden changes in resistance while turning. It could indicate that the valve is partially clogged with sediment or other debris. Listen for the change in flow to confirm that the valve is moving. Keep a count of the number of turns needed to close the valve; the same number should be used to fully re-open it. Gradually re-open the valve with the same care used to close it. Make a note of any difficulties encountered, as they may be evidence that the valve needs repair or replacement.
Valve exercising can sometimes stir up sediment with the change in flow. Before you begin, give your affected customers adequate notice of what they may expect from the process, and provide them with guidance on flushing their taps. This will help keep the dirty water complaints down. You may also consider combining your valve exercising program with a flushing program, to reduce disruption of customer service.
It is easy to think of a water distribution network as a static, unmoving entity, in which the only moving part is the water that flows through it. But those fluid dynamics can change, due to main breaks, fires, weather incidents, the consolidation of one water supply into another and development of land in ways that increases or alters an existing distribution system. Ensuring that water system’s valves are regularly exercised and maintained reduces the time, costs and stress of adapting to those changes.
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How Plant Start-ups & Shutdowns affect turbidity monitoring and reporting
Sabrina Haydt and Kurt Smith Water Program Specialists, (DEP) Central Office
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Water filtration plants are all unique in many ways. One thing that is common among most of them is they can be started and stopped. But what does that mean when a filter plant starts-up or shuts down? Does every process turn on or off, or is there something more specific that defines if a plant is starting-up or shutting down? Below is some information that explains this more and how turbidity reporting requirements change if they occur.
Defining a “Start-Up” and “Shutdown”
For conventional, direct, membrane, and Diatomaceous Earth (DE) filter plants a “start-up” is when water starts flowing to production at the combined filter effluent (CFE) location (or any individual filter effluent (IFE) location if use of flow-weighted average has been approved by DEP) and a “shut down” is when water stops flowing to production at the CFE location (or all IFE locations if using flow-weighted average).
- Membrane Specific Requirements:
For membrane plants that only have one individual skid/train/unit operational at a time, pulses (e.g. back pulse, reverse flush, air scrub, backflush, etc.) are not considered to be plant start-ups or shutdowns.
- DE Specific Requirements:
For DE plants that only operate 1 filter at a time, start-ups and shutdowns will primarily occur with the backwash (septum cleaning) and pre-coat process. If a system operates more than one filter at a time, they may not have CFE start-ups/shutdowns if one filter is still sending water to the CFE when the backwash/precoat processes are occurring on the other.
Recording and Reporting “Start-Up” and “Shutdown” Turbidity Readings
For each filtration technology, readings need to be recorded when the water begins flowing through the CFE again (start-up reading) and just before it stops flowing through the CFE (shutdown reading). There is no lag time with these readings.
To properly report these readings, they should be added to the “Number of Measurements” box on the SDWA-5 form. For every time the plant shuts down there should be two additional readings reported (start-up and shutdown) in addition to the 15-minute readings, unless the shutdown reading falls at the same time as a 15-minute reading.
Seems simple but wait a minute. You may be asking, do 15-minute readings need to be taken exactly 15 minutes after the start-up reading or can it be on the next quarter hour?
Well lucky for you, the answer is that either is an option. A water system may choose to begin taking 15-minute readings exactly 15 minutes after the start-up reading is taken or beginning with the first quarter hour.
Let’s look at some examples. For a water system that starts the plant at 6:56 am (i.e. water begins flowing to production at the CFE location) either of the following is acceptable:
- The system collects the start-up sample at 6:56 am and then collects the first 15 min. reading at 7am (followed by 7:15, 7:30, 7:45, etc.)
- The system collects the start-up sample at 6:56 am and then collects the first 15 min. reading at 7:11 am (followed by 7:26, 7:41, 7:56, etc.)
As a reminder for any filter plant that relies on summary reports that are generated by their SCADA to conduct monthly reporting to DEP, it would be beneficial for them to make sure that the SCADA system logic captures the start-up/shut down turbidity results and includes them in the reports.
In closing, before a SDWA-5 form is submitted to DEP, a water system should able to answer “Yes” to the following questions:
- In addition to my 15-minute readings, am I recording a CFE reading each time my filter plant starts up and shuts down?
- Am I including the start-up and shutdown readings when reporting my data to DEP?
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REACHING OUT: FREE LUNCH?
Brad Baker, Operator Outreach Program Coordinator, DEP Southcentral Region
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Good morning Pennsylvania!
As the new coordinator of the Operator Outreach Program, I wanted to make sure everyone was aware that this program exists! The only complaint I’ve heard so far in relation to Operator Outreach is that not all systems know this free assistance is out there for the taking. Following this introductory piece, I plan to use this biannual “Reaching Out” column to keep you informed of what’s going on with Operator Outreach, to include completed projects and upcoming trainings. With everything our program has to offer, I’m willing to bet there’s something we can do for you!
“What does the Operator Outreach Program do?”
The Operator Outreach Program offers no cost technical assistance to drinking water systems to promote public health protection, regulatory compliance, optimized treatment, long-term system sustainability, and resiliency. Specifically, here is a partial list of the free service we can provide:
- Water Auditing
- Asset Management Planning
- Utility Management Training
- Process Control
- Laboratory Procedures
- Pre-Treatment
- Distribution System Operations
- Record Keeping and Reporting
“There’s no such thing as a free lunch. What’s this actually going to cost me? Why would I willingly invite DEP to look into my system?”
I’m glad you asked!
For starters, while the Operator Outreach Program is facilitated by the DEP, the actual Outreach Providers that you’ll be working with are experienced private sector water professionals (operators and managers) from outside the DEP. These Providers offer peer-to-peer assistance to water systems using their extensive knowledge and experience.
The purpose of the program is to help systems (not regulate them). We want to help you address issues before they are compliance concerns. We want to help make sure your system is financially sound. We want to help verify operations are optimized. We want to help ensure that the citizens of Pennsylvania are receiving a safe and reliable supply of drinking water. Period.
“Well, that all sounds great, but is it ACTUALLY free?”
This is where an economics teacher would discuss the time involved. As we all know, time is money. The time it takes you to meet with the Outreach Provider, tour the facility, explain operations, send in financial documents, etc. There are no free lunches. However, there will be no line item in the budget. All services provided come with a $0.00 price tag!
The only thing it costs you is the time spent with the Outreach Provider to ensure they have all the information they need to effectively help you and your system.
Note: Some expenditures may result from implementation of RECOMMENDATIONS to improve system operations. For example, we’re not going to pay to replace your finished water pump installed in 1948.
Note on Note: For more information on a program which MAY cover some expenses, please visit the Capability Enhancement Program website which offers select free Professional Engineering Services.
“So, why wouldn’t I reach out to Brad Baker for more information?”
Maybe everything in your system is perfect. Maybe you have conducted your own Water Audit and have up-to-date Asset Management Plans and Operational SOPs. Maybe none of your operators could use training in any area. Maybe you just can’t get yourself to contact someone with a government email address. For everyone else, please reach out!
Disclaimer: Lunch will NOT be provided!
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Notification Requirements for Lead, Galvanized Requiring Replacement and Unknown Service Lines
Sabrina Haydt, Water Program Specialist, DEP Central Office
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Hopefully by now your water system is well on its way to having an initial Service Line Inventory (SLI) completed in time for the looming October 16, 2024 deadline. As we’ve described in past Drinking Water News articles (Winter 2023 & Summer 2022), one of the requirements of the SLI is to categorize each service line as either Lead, Galvanized Requiring Replacement (GRR), Non-lead, or Lead Status Unknown (Unknown). If you are one of the fortunate water systems that has determined through an evidence based method that all of the service lines within your system are made of a non-lead material, then the remainder of this article does not pertain to you…for all other water systems, keep reading!
The federal Lead and Copper Rule Revisions (LCRR) requires, under 40 CFR §141.85(e), that all water systems which have determined for their initial SLI that they have Lead, GRR or Unknown service lines within their water system, provide notification to all persons served by one of those connections. The regulation provides specific requirements for when this notice must be delivered and what it must contain, which we will review below. DEP is currently working on developing templates for these notifications and will make them available on eLibrary as soon as possible. The form numbers for these forms are as follows:
- Consumer Notification of a Lead Service Line: 3930-FM-BSDW0100
- Consumer Notification of a Galvanized Requiring Replacement Service Line: 3930-FM-BSDW0101
- Consumer Notification of an Unknown Service Line: 3930-FM-BSDW0102
When must the notification be provided?
A water system must provide the notification within 30 days of completion of the initial SLI. Since the due date for the initial SLI is October 16, 2024, that means that all notifications must be provided to persons served by the service line no later than November 15, 2024.
Water systems must then repeat the notification on an annual basis until the entire service connection is no longer categorized as a Lead, GRR, or Unknown service line in the SLI. For new customers, water systems must also provide the notice at the time of service initiation.
What information must be included in the notification?
The notification must include the following information, as required by 40 CFR §141.85(e)(3):
- A statement that the person’s service line is “Lead” if it is categorized as a lead line; “Galvanized Requiring Replacement”, if it is categorized as a GRR line; or that the “service line material is unknown but may be lead”, if it is categorized as an unknown line.
- An explanation of the health effects of lead, using the following statement will meet this requirement: “Exposure to lead in drinking water can cause serious health effects in all age groups. Infants and children can have decreases in IQ and attention span. Lead exposure can lead to new learning and behavior problems or exacerbate existing learning and behavior problems. The children of women who are exposed to lead before or during pregnancy can have increased risk of these adverse health effects. Adults can have increased risks of heart disease, high blood pressure, kidney or nervous system problems.”
- Steps persons served by the connection can take to reduce exposure to lead in drinking water, such as:
- Run the water for 15-30 seconds before using and use cold water for cooking and drinking to reduce your exposure to lead in the water.
- Do NOT use water from the hot water tap to make baby formula.
- Do NOT boil water to remove lead. Boiling water will not reduce lead.
- Look for alternative sources or treatment of water, such as using of a pitcher filter that is certified to remove lead and replace cartridges on a routine frequency or bottled water.
- Identify and replace premise plumbing fixtures containing lead. Brass faucets, fittings, and valves, including those advertised as “lead free” installed prior to 2014, may contribute lead to drinking water because the law allowed fixtures with up to 8% lead to be labeled as lead free.
- For service lines categorized as Lead, the notice must also include:
- Information about opportunities to replace lead service lines as well as programs that provide financing solutions to assist property owners with replacement of their portion of a lead service line.
- A statement that the water system is required to replace its portion of a lead service line when the property owner notifies them they are replacing their portion of the lead service line.
- For service lines categorized as GRR, the notice must also include information about opportunities for replacement of the service line.
- For service lines categorized as Unknown, the notice must also include information about opportunities to verify the material of the service line.
How must the notice be distributed?
The notice must be provided to persons served by the service connection by mail or by another direct delivery method approved by DEP, such as hand delivery or electronic mail. If being provided by mail, the postmarked date must be no later than the required deadline of November 15, 2024.
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America’s Water Infrastructure Act (AWIA), Section 2013, amended Section 1433 of the Safe Drinking Water Act (SDWA), requiring all Community Water Systems serving more than 3,300 people to conduct Risk and Resilience Assessments (RRAs), develop Emergency Response Plans (ERPs), and certify completion of these plans to EPA. In addition, systems are required to review their RRA and ERP every five years, revising them if necessary, and certify completion of these actions to EPA. These assessments and plans are intended to help water systems identify, evaluate, and mitigate risks due to cyber threats as well as physical threats.
AWIA also specifies deadlines for certification to EPA. The next 5-year cycle for submission of RRA and ERP certifications is approaching, as noted below:
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RRA certification deadline
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ERP certification deadline
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Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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