March 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:
  • Laboratory Reporting Instructions – New Look, Streamlined Content
  • Biofilms and How to Control Them
  • Chemical Compatibility, Storage, & Secondary Containment
  • System Management Responsibilities: Annual Plan Update Requirements
  • Finished Water Storage: How Is Your Tank Doing?
  • Managing Your Assets for Efficient Operation
  • We’re Glad You Asked…
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Laboratory Reporting Instructions – New Look, Streamlined Content
June Black, Water Program Specialist, DEP Central Office
Laboratories and Public Water Systems will be familiar with the Laboratory Reporting Instructions, which were provided by the PA Bureau of Safe Drinking Water (BSDW) for each new or modified regulation that required data to be reported to the Drinking Water Electronic Lab Reporting System DWELR:
Laboratory Reporting Instructions Image
Historically, these guidance manuals contained a wealth of information on proper reporting, monitoring requirements, and technical guidance for compliance. The amount of information presented in the documents made them lengthy (> 50 pages), and it could be a daunting task to read and understand them.
To simplify the process and provide needed information to laboratories and water systems in a more streamlined manner, the format of the reporting instruction manuals is being revised. Laboratory Reporting Instructions guidance documents will now be split out into three parts – Form Instructions, Publications, and Technical Guidance. Future newsletter articles will provide more information on the Publications and Technical Guidance pieces, but for this article we’re going to focus on the Form Instructions:
Instructions for Reporting Inorganic Chemicals image
The Form Instructions will contain only the information necessary for reporting results to DWELR, including:
  • lists of method and analyte codes;
  • information on applicable sample types and location ID#s;
  • regulation-specific reporting requirements; and
  • screenshots of example entries.
There will be a set of Form Instructions for each analyte group or rule (VOCs, IOCs, SOCs, PFAS, Rads, DRR, WQPs, etc). Form Instructions will be available on the DWELR Instructions and Messages page and in the eLibrary.
As of January 2023, the following Form Instructions are available: VOCs, IOCs, SOCs, and Rads. The BSDW is actively working to complete Form Instructions for all contaminant groups, so be sure to check the eLibrary regularly.
Biofilms and How to Control Them
John Cairnes, Compliance Specialist, DEP Southeast Region
Biofilms are a common hazard in drinking water distribution systems, even those with continuous disinfection and well-maintained chlorine residuals. A broader understanding of what biofilms are, how they form and how they can be eliminated can be an important factor in providing safe, potable drinking water.
Biofilms occur when bacteria begin to cluster together in drinking water. Some biofilms are free-floating, but the majority of them form on solid surfaces, such as the interior wall of a pipe. Biofilms form when bacteria secrete an extracellular matrix (ECM) from their cell walls that causes them to stick together. When the ECM comes in contact with a fixed surface, the cluster of bacteria cling to it and become rooted in place. Biofilms can also form when bacteria begin clustering on the inside of a pipe that has accumulated organic matter on its inner surface, providing a nutrient source for the bacteria. Because the matrix is composed of extracellular polymeric substances (EPSs), the biofilm can provide a natural barrier to disinfectants such as free chlorine and monochloramine. The EPSs are polymers with a high molecular weight that resist dissolution by oxidizing chemicals.
Biofilms are more than just biological slime layers. They are biological systems in which bacteria organize themselves into a coordinated, functional community, sharing both nutrients and protection. The biofilm itself can entrap organic matter in water, providing a food source for the organisms within it. Because of this, biofilms can facilitate rapid microbial growth within them. A biofilm may consist of multiple species of bacteria, so a disease vector such as E. coli or Legionella may take refuge and multiply in a biofilm consisting mostly of harmless coliform species. Biofilms generally have a thickness of 50 to 100 microns. As they grow thicker, portions of the them can shear off and become rooted downstream, amplifying the problem of eliminating and controlling them. In addition to being a safe-haven for opportunistic, disease-causing pathogens, biofilms can also cause taste and odor issues in drinking water, and contribute to pipe corrosion.
Controlling and eliminating biofilms can be difficult. It will require water suppliers to take additional actions beyond simple disinfection. One method of controlling biofilms is to minimize the amount of organic matter that enters a distribution system. Limiting the organic carbon available to microbes will inhibit their growth and keep their numbers below the level where they are likely to colonize. A source water protection plan or cross-connection control plan can be useful in controlling biofilms. Low flow rates and pipe corrosion can also contribute to biofilm growth.
To eliminate biofilms, it may be necessary to treat the water with high-concentration chlorine, such as may be used to disinfect a water main after replacement. Unidirectional flushing can also dislodge biofilms. Increasing the flow rate during flushing produces a kinetic effect called shear flow, in which the friction of the passing water can shred and peel off biofilms. In extreme cases, a water system may resort to line pigging, by using a device to scour the inside of a pipe to dislodge the biofilms.
A successful biofilms control plan should include all aspects of a water system, including source protection, effective treatment and diligent maintenance of storage facilities and distribution systems. A multiple approach strategy is more likely to control established biofilms as well as prevent future occurrences.
Chemical Compatibility, Storage & Secondary Containment
Doug Macik, Compliance Specialist, DEP Southcentral Region
Many drinking water system operators use a variety of chemicals during the routine operation of their treatment facilities. Operators must know the reason for any chemical addition, the goal of adding a certain amount of that chemical, as well as any safety precautions or procedures they need to follow when handling the chemical in question. Another important aspect of treatment that can often go overlooked is what to do with the chemicals when they’re not in use. How should they be stored and handled correctly and safely? Fortunately, the Department has guidance and regulations related to the safe storage and handling of various drinking water treatment chemicals. These regulations can be found in 25 Pa. Code § 109.602 and in guidance for design and construction, such as the Public Water Supply Manual Part II.
Every treatment chemical should come with a Safety Data Sheet (SDS, formerly MSDS) which contains information about how to use and dispose of the product properly, as well as occupational and safety hazards that may be present. One section of the SDS that should not be overlooked and is just as important to safety relates to chemical compatibility. A dangerous reaction can occur if incompatible chemicals are mixed. This could happen due to incorrect labelling, improper storage, or failure of a chemical storage vessel. In order to limit the risk of chemical storage failing, the Department provides the following table that lists what storage materials are acceptable and which are not (DEP Document Number: 383-2125-108). Please note that this materials table also applies to any secondary containment that may come into contact with the chemical.
Chemical Storage and Handling Materials table
The public water supply design manual states that liquid chemical storage tanks must have some sort of level indicator as well as secondary containment. Secondary containment is defined as a receiving basin or drain capable of receiving accidental spills or overflows. The secondary containment must be of adequate size to at least hold the volume of the largest chemical container (DEP Document Number: 383-2125-108) so that a potential failure of this storage container could be contained. Below you will find a table of some common chemicals used in the drinking water industry along with a list of incompatible chemicals. Most operators are aware that incompatible chemicals cannot be stored together, but did you know that these chemicals should not share secondary containment either? The potential for incompatible chemicals to encounter each other causing a dangerous reaction is increased when containment or an overflow basin is shared.
<%2Fspan>%20<%2Fspan>" style="font-weight: normal;font-weight: normal;color: #a64ecb;text-decoration: underline;color: #a64ecb;text-decoration: underline" target="_blank"> Chemical Compatibility Table
Besides providing guidance on how chemicals should be kept and handled correctly, the Department also enforces industry standards when it comes to storing certain chemicals. Activated carbon requires its own isolated storage that should be fireproof and contain special explosion-proof lights, electrical outlets, and motors due to the risk of combustion. Gaseous chlorine needs its own isolated storage room with additional safety requirements because of the potential danger posed by the gas. The room needs to be climate controlled, contain doors with panic hardware that open to the outside, and have a ventilation system installed that can exchange one full volume of air every minute (DEP Document Number: 383-2125-108). The more reactive and potentially dangerous a chemical is, the more likely the Department will have regulations and guidance on proper storage and safety.
System Management Responsibilities: Annual Plan Update Requirements
Matthew Shope, Compliance Specialist, DEP Northeast Region
Among the numerous responsibilities of a public water supplier, continually ensuring the information contained in Comprehensive Monitoring and Emergency Response plans is current and accurate is often overlooked. Although this may seem tedious, the information is critical in ensuring the safe operation of the public water system and responding to emergencies.
A Comprehensive Monitoring Plan (CMP) is a plan that that describes both the frequency and appropriate sampling locations for compliance monitoring. As per 25 PA Code §109.718, the CMP must include a list of all sources, purchased interconnections, treatment plants and entry points. The CMP is also required to include a schematic of all sources, associated treatment plants and entry points, and the relative locations of the points of entry into the distribution system. Additional requirements include a description of normal operating conditions for each entry point, a description of how all permanent sources and permanent entry points are included, and the distribution system sample siting and monitoring plans required under other sections of Chapter 109.
The Comprehensive Monitoring Plan is required to be updated annually and as necessary with the date of the most recent update recorded in the plan.
An Emergency Response Plan (ERP) describes strategies, resources, plans, and procedures public water suppliers can use to prepare for, and respond to, an incident, natural or man-made, that threatens water quality. Examples of these incidents range from small main breaks to hurricanes.
25 PA Code §109.707 requires the ERP to contain an organization table that includes a prioritized list of names and contact numbers of persons in charge of the water system during an emergency, communication procedures, means of communication, a summary description of the public water system, an assessment of available resources, and corrective actions for probable emergency situations.
The Emergency Response Plan is also required to be updated annually and as necessary with the date of the update recorded in the plan.
Community water suppliers are required to develop Operation and Maintenance Plan (O&M) for their systems. The O&M Plan is a useful reference for staff on the system’s standard operating and emergency response procedures. The plan is required to conform with the guidelines presented in the Department’s Public Water Supply Manual. Some examples of the content the plan should contain are an overview of the system, start-up operating procedures, staff contact information, and applicable manufacture manuals for components of the system. Although it is not required by 25 PA Code §109.702 to update the operation and maintenance plan on an annual basis, prudence dictates updating the information in correlation with the CMP and ERP is a good management practice. The date of the most recent update is required to be recorded in the O&M Plan.
Ensuring the Comprehensive Monitoring and Emergency Response plans are updated annually is critical to protecting the public health. One lesson learned from the COVID-19 pandemic is how vulnerable water systems can be due to staff shortages. Although technology offers some safeguards to prevent a drinking water catastrophe, having properly trained staff or at least a reliable resource of accurate information for staff to consult in the face of an incident is critical.
Finished Water Storage: How Is Your Tank Doing?
Sasha Minium, Environmental Group Manager, DEP Northcentral Region
Have you checked your finished water storage tank recently? How is it doing? Finished water storage is a critical part of your water system, because it helps to ensure that your users have enough potable water available to them and possibly that your service areas have adequate fire flow protection. But with all of the other parts of your water system that need attention, it can be easy to forget about checking on your finished water storage tank, especially if your tank is located further away from your treatment plant.
One of the simplest maintenance activities is visual inspection of the outside of your finished water storage tank. Be on the lookout of possible signs of leakage, cracks, or excessive rusting. Be sure to keep good records of when you inspect the tank, any changes or concerns that you observe, and any maintenance and repairs you may conduct.
It can be difficult to fully assess the top of your finished water storage tank and other parts that aren’t normally visible from ground level, but there are a couple of things you can try. If you already have maintenance activities scheduled where you need to climb up the tank, that would be a good time to also check on any hatches, screens, or locks that you normally can’t see, and then snap a picture if you can to document the condition. If you have contacts with people who do maintenance on nearby cell phone towers or other structures that are higher than the tank, you may also be able to ask them for assistance in taking a couple of pictures of the top of the tank while they’re looking down at it. If at all possible, the pictures should be date stamped (there are free apps available to date stamp pictures taken on cell phones) so that there’s a clear record of when the pictures were taken. If you have contacts with people who are licensed drone operators, you may be able to work out an agreement with them to do surveillance and/or take pictures of your tank using their drone.
The condition of the interior of your finished water storage tank can also be difficult to fully assess, but usually the best time is when you’re already conducting planned maintenance or drawdown. Similar to the visual inspection of the outside of a tank, it is critical to keep records of any tank interior inspections as well. Please be aware that certain maintenance activities on the storage tank interior actually require a permit! This includes activities like relining or repainting the tank interior. For more information about permitting requirements, please contact your regional Safe Drinking Water Technical Services section.
All of this information about the condition of your finished water storage tank will be valuable when your next sanitary survey occurs. Your sanitarian will be asking a variety of questions related to your finished water storage tank, such as:
  • Is the roof or cover of the storage tank watertight?
  • Are ladders and storage tank hatches locked?
  • Is the interior of the storage tank protected from wildlife?
In the meantime, we recommend that your water system follow recommended practices from the American Water Works Association (AWWA) for finished water storage inspection and maintenance, as well as any specific recommendations directly from your finished water storage tank manufacturer!
Managing Your Assets for Efficient Operation
Matthew Hollen, Compliance Specialist, DEP Southcentral Region
As some may have noticed during routine inspections of your water system, you are questioned about having an Asset Management Plan. Well, what exactly is the Asset Management Plan (AMP) and how can it benefit your system? This article should clear up any confusion about what an AMP is, highlight the many benefits and show you how to get started.
An asset management plan is a tactical plan for managing an organization’s infrastructure and assists in maintaining a desired level of service. Overall, an AMP is a look at the major components of your public water system. An AMP can keep track of routine maintenance on equipment, expiration dates of chemicals, the manufacturer’s recommended life expectancy, and a chemical ordering schedule. This includes chemical feed pumps, booster pumps, generators, heavy equipment, vehicles, distribution piping, valves, etc. You should also include anything else the water system deems a vital aspect. The more complete your AMP, the better prepared your system is.
Although an AMP is not directly required by 25 Pa. Code Chapter 109, it is highly recommended to ensure smooth, continuous operation under any condition or circumstance. It helps to prevent problems and helps to save money by replacing instead of constantly repairing broken or damaged equipment. Implementing and maintaining an AMP will help keep your system complaint with 25 Pa. Code §109.4 and ensue you are continuously and reliably supplying your customers with safe and potable water.
There are many benefits of having an AMP at the water system. One benefit is that the plan with help prolong asset life and aide in repair or replacement decisions through efficient operation and maintenance. The plan can also assist in meeting consumer demands with a system as well as assist with setting rate based on operational and financial planning. Another benefit is a more focused approach to budgeting on activities that can help sustain performance for the water system. Having an implemented AMP can help improve response times to emergencies as well as help improve security and safety of assets that are owned or controlled by the water system. Lastly, an AMP can also help increase your score when applying for a PENNVEST assistance. Having an Asset Management Plan can help systems with the many challenges that they will face during normal operations.
If an Asset Management Plan is something that interests you, and is something that may be beneficial to your system, more information can be found on the DEP Website. This link will take you to the Department’s Asset Management page where you can find more information detailing what and how a plan can be implemented at your system. Your plan can be done in a variety of ways, depending on how the system wishes to implement it. The plan can be a simple excel or word document that tracks your critical infrastructure. Also included at the link above, are 2 different Excel templates that can help you get your Asset Management Plan started. If you would like to know more about the Asset Management Plan please go to the EPA's website. If you have questions or would like to get started, please contact your local Safe Drinking Water Sanitarian or contact the PA DEP Capability Enhancement Program at Information and eligibility for Capability Enhancement Assistance can be found here.
We're Glad You Asked
Gail Guenther, Compliance Specialist, DEP Southwest Region
Why does DEP ask us to accept documents by email and confirm receipt?
You’ve probably experienced it – DEP staff will reach out to you or someone else at your system and ask if you will accept delivery of a permit, notice, order or agreement by email. The reason is simple: electronic delivery of these documents is the fastest way to get important information to you and enable you to act.
In the case of permits, you get your permits faster and can get started on projects that are often on tight time constraints, avoiding delays and the possibility of increased construction costs or missed deadlines. For enforcement notices and documents, faster notice means faster opportunity to consult with DEP and resolve the problem before it develops into a worse or more costly or time-consuming situation. Additionally, the Safe Drinking Water regulations impose a variety of deadlines for a public water supplier to act when problems arise – being apprised and able to take action quickly can help your system to avoid additional violations.
Image of a man reading documents
The reason for DEP’s request that you confirm your agreement to receive a document electronically and that you did receive it is equally simple. If DEP does not receive a response to its request for email confirmation, considerable delay in the delivery of your document may result, especially in cases of certified mail. Detriment to your ability to respond or your cost in responding could be the consequence.
It is in everyone’s best interest if documents – for both permitting and compliance – are received by public water suppliers as quickly as possible. So…we’re glad you asked and please respond to those emails from DEP staff!
Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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