No Small Feat

April 2, 2018

About the author: Rob Shirley is trainer and technical assistant for California Rural Water Assn. Shirley can be reached at [email protected].

The operation and maintenance of small (serving 501 to 3,300 people) and very small (serving less than 500 people) water systems are facing considerable regulatory challenges while attempting to balance technical, managerial and financial (TMF) guidelines provided under the Safe Drinking Water Act (SDWA) Amendments of 1996. TMFs were emphasized under the SDWA to assist with providing safe, reliable drinking water to customers. For some systems, however, all of these guidelines have been affected adversely by decreases in revenue.

The U.S. Environmental Protection Agency (EPA) issued a document in February 1984 titled “Cost Equations for Small Drinking Water Systems.” The document discusses how a small water system lacks operating revenues and does not receive the same economic benefits as large urban systems. It states: “Future proposed standards will likely compound these problems for the small utilities when they are faced to install additional technology in order to meet new quality requirements.” Organizations providing technical and financial assistance to rural and small water systems would agree it is evident the majority of the smaller systems are currently facing these issues.

Get Educated
In addition to SDWA TMFs, the EPA included Small Systems and Capacity Development guidelines designed to help small system owners and operators, state and tribal agencies, technical assistance providers and consumers learn more about helping small water systems provide safe drinking water and protect public health. One of the purposes of this inclusion was to assist key personnel in reviewing options available in modifying water operations to meet regulatory issues along with prevention of significant operation and maintenance (O&M) expenses attached to their budgets.

The first option recommended under these guidelines is to review nontreatment scenarios to reduce or eliminate a regulated contaminant. For some of these systems, a contaminant such as arsenic may require some type of treatment technology in order to ensure compliance with National Primary Drinking Water Regulations, resulting in unpopular water rate increases.

Understandably, primary drinking water standards are a small water system’s focal point for predicting future O&M costs to maintain regulatory compliance. Other regulatory issues, including the Ground Water Rule (GWR), noticeably alerted water system staff of possible increases to O&M costs. Water operators for rural water systems are learning about GWR sanitary survey inspection requirements and the TMF implications from any reported significant deficiencies. Under the GWR, a significant deficiency reported in a sanitary survey will in all probability lead to corrective action. The corrective action includes correcting several deficiencies if found, providing an alternative source of water, eliminating the source of contamination or providing treatment that reliably achieves at least 99.99% (4 log) removal for each groundwater source. As these corrective actions may be common knowledge to numerous water system operators, there are several small water supplies that have found this information technically and financially disconcerting.

People Count
Managerial issues are challenging for small water systems as well. It is no surprise that the smaller a water system, the smaller the number of personnel employed to operate and maintain the system. Managers of water systems have a genuine desire to do the best for their potable water supply and attempt or entice a person earlier in their years to assist with operating their small water system. The managers of the system realize there is little monetary incentive for future apprentices, but they realize how important it is to have someone available to continue the good work if they become ill or need vacation time. Treatment systems for small systems normally have an autodialer installed, yet they are required to remain close to the facility if an alarm condition should occur.

A review of the technical aspects is another demand placed on the water system and its personnel. Water operators who have obtained their distribution certification are now confronted with obtaining their treatment certificate because a treatment system was installed at their site. Issues in regard to arsenic, nitrates and GWR will require some type of treatment system if nontreatment options are unavailable. Technical skills of computing chemical dosages, performing a chemical feed drawdown and conducting CT calculations will be required skills for system operators.

TMF knowledge does not rest solely on the shoulders of managers or supervisors. Importance of water and wastewater knowledge by board members or commissioners is necessary, as they make decisions affecting the O&M of the facility or facilities. Their acquiring a basic understanding of a water system’s O&M makes them invaluable in maintaining a good water rate structure and performing long-term planning for an aging infrastructure. Additionally, arming these fiduciary-responsible people with the importance of asset management and establishing reserve accounts assists everyone involved with operating and maintaining the water system.

Confer & Conquer
Another critical stakeholder in regard to the TMF guidelines is the engineering firm, when providing designs or resolutions to noncompliance issues. It is of great significance for operators and maintenance personnel to request that all nontreatment options (e.g., source water blending) be reviewed by the engineer prior to the issuance of design specifications. Communications between water system staff and engineers involves several meaningful meetings.

These meetings require discussion of how the system will be operated and maintained if treatment modifications are designed, including the knowledge level of the operator and all related O&M costs for a new system. For example, a treatment system being installed with a SCADA system typically involves remote telemetry units and programmable logic controllers. If system personnel do not have the skills to troubleshoot or the money available to maintain the equipment, the result over the long term may be less than desirable for the water system.

Small water system managers and operators are able to overcome many challenges by being resourceful. The TMF challenges can be overcome through using nonprofit organizations for training and technical assistance. Under specific state or federally funded programs, the small water system normally is able to receive this type of assistance at no cost. Management of the systems may use resources that include free software available on the EPA’s website. One example under the TMF program is the budget spreadsheet templates that are free to water system managers and operators. The EPA has free distribution modeling software available (EPANET), which has been shown to be of value for small water systems when either troubleshooting a distribution system or preparing a line extension. The fiscal responsibility has intensified for small water systems as drinking water rules and regulations are being implemented by the primacy agencies. O&M of small water systems may be enhanced greatly by using the TMF strategy on a continuous basis.

As a final note, the president’s signed budget for fiscal year 2010 released a policy regarding Clean Water and Drinking Water Infrastructure Sustainability. The policy encourages communities to develop sustainable systems that employ effective utility management practices to build and maintain the level of TMF capacity necessary to ensure long-term sustainability.

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About the Author

Rob Shirley