Kansas Kick-off Meeting

The TSC Optimization Team and ASDWA held a kick-off meeting with Kansas Department of Health and Environment (KDHE) drinking water program representatives in Topeka July 12-13, 2016. The purpose of the meeting was to review the Area-wide Optimization Program (AWOP) structure, activities, benefits, and participant roles/responsibilities. Based on that review, KDHE representatives decided to formally commit to the program. The meeting then focused on the details of: data management and other activities needed to adopt the program goals; informing water utilities of the state’s commitment to the program; and monitoring water treatment plant performance against optimization goals. KDHE staff explored methods of tracking plant performance within the existing state data collection activities and developed action steps to begin program implementation. The optimization team is excited to welcome the KDHE as the most recent addition to the AWOP network. (Rick Lieberman, US EPA, TSC)

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Hydrant Sampler Website and Training Video

On May 4, the website www.epa.gov/hydrant-sampler was launched with a YouTube training video produced by the Optimization Team to describe how to use a hydrant sampler. This tool, developed by the team, allows users to collect representative distribution system water quality samples in a controlled, safe manner. The website describes the parts required to assemble a hydrant sampler as well as the procedure for appropriately using it.

Automated Hydrant Flushing Program in Flint, MI

TSC’s Optimization Team, in collaboration with ORD, developed a low-flow automated flushing program to improve chlorine residual throughout the City of Flint while not disturbing the development of scale in pipes. During the week of April 11th, approximately 130 samples were collected throughout the City to identify areas of low chlorine residual. During the week of April 18th, 13 automated flushing devices were installed on hydrants in areas where low chlorine residual was identified. Both of these activities included training for utility staff by the Optimization Team. TSC will continue to support the City of Flint as they carry out and expand their automated flushing program and engage in other distribution system optimization activities.  (Matthew Alexander,  Alison Dugan, & Ouro Koumai, US EPA, TSC)

Region 3 Area-Wide Optimization Program

The TSC optimization team, in partnership with Region 3 and ASDWA, held a strategic planning meeting and technical workshop April 5-7, 2015.  The state of Connecticut, which has participated as an “adopted” member of the EPA Region 3 AWOP for several years, hosted the meeting. Representatives from Massachusetts, Rhode Island, New Jersey, New York, and EPA Region 1 attended to learn more about the program and were joined by participants from the Region 3 AWOP states (Maryland, Pennsylvania, Virginia, and West Virginia).  States reported on their optimization program activities and continue to document positive impacts.  The Region 1 states discussed their respective interest in AWOP and several requested additional information from TSC.

The technical workshop focused on disinfection data integrity, teaching participants how to investigate areas of disinfection data generation, collection and reporting that may be inaccurate (and potentially have a significant impact on public health). Other topics included: applying optimization concepts to corrosion control; helpful start-up tips for new-states (data collection and applicable tools); simultaneous compliance challenges; and approaches for conducting water system inspections using a team approach.  (Alison Dugan, US EPA,TSC)

Drinking Water Optimization Training

During the week of March 7, 2016, the TSC Optimization Team led a training class for drinking water staff with the Kansas Department of Health and Environment (KDHE). Topics addressed during the 2½ day class include surface water treatment optimization; assessing water system turbidity performance and data interpretation; and turbidity sampling, testing, and data development. A turbidity data integrity workshop was conducted at a nearby water treatment plant and provided participants the opportunity to identify challenges that may lead to inaccurate turbidity and disinfection data. Participants concluded their training by summarizing their findings and developing action steps to implement aspects of their training in their work.  This was the first class in a series of three that the KDHE will complete as they prepare to join the EPA Regions 6/7 Area-Wide Optimization Program (AWOP). (Alison Dugan, US EPA, TSC).

Chloraminated Distribution System Field Event

During the week of May 12th, members of the Optimization Team, in partnership with Pennsylvania Department of Environmental Protection’s (DEP) and Allegheny County Health Department (ACHD), conducted the first field event to support the development of a Distribution System Comprehensive Performance Evaluation (DS CPE) for chloraminated water systems. The DS CPE protocol was originally developed for water systems that use free chlorine as a secondary disinfectant. As a result, the existing DS CPE is in the process of being adapted to apply to chloraminated water systems. The field event provided an opportunity to field test aspects of the
DS CPE that were recently modified (e.g., additional monitoring parameters) or added (e.g., evaluation of chlorine and ammonia practices) to apply to chloraminated water systems. The event also provided an opportunity to assess the system’s performance relative to the proposed goals for chloraminated water systems. The host system, Oakmont Water Authority, welcomed the feedback from the team during the exit meeting and TSC will request updates on their pursuit of optimization from DEP and the ACHD staff. (Matthew Alexander, Alison Dugan, & Tom Waters US EPA, TSC)

Denny Krieder (Oakmont Water Authority) provides a tour of Oakmont Water Authority’s Hulton Purification Plant to Bill Davis (PAI) and Larry DeMers (PAI).

Denny Krieder (Oakmont Water Authority) provides a tour of Oakmont Water Authority’s Hulton Purification Plant to Bill Davis (PAI) and Larry DeMers (PAI).

 

Tom Waters (USEPA TSC) and Paul Handke (PA DEP) prepare to collect water quality samples as part of the storage tank assessment special study.

Tom Waters (USEPA TSC) and Paul Handke (PA DEP) prepare to collect water quality samples as part of the storage tank assessment special study.

Distribution System Comprehensive Performance Evaluation

During the week of June 10th, members of the Optimization Team, in partnership with Pennsylvania Department of Environmental Protection’s (DEP) Distribution System Optimization Coordinator, provided training to additional DEP staff on the Distribution System Comprehensive Performance Evaluation (DS CPE) protocol.  This CPE training event enhanced understanding of distribution system related issues (especially related to water quality), which will help with the implementation of “regular” drinking water program activities.  The trainees provided excellent feedback on potential applications and implementation of the DS CPE protocol.  In the near-term, DEP staff hope to use elements of the DS CPE to provide Stage 2 DBPR compliance assistance to water systems.  Longer-term, it’s possible that the DS CPE could be incorporated into their established Filter Plant Performance Evaluation program, which could have a significant positive impact on distribution system water quality. Participants described the DS CPE as an excellent training tool for state staff, and the training approach used could be effective in other AWOP states or Regions.   (Alison Dugan and Matthew Alexander, US EPA TSC)

Continuous chlorine monitor used to collect data to support the storage tank assessment special study

Continuous chlorine monitor used to collect data to support the storage tank assessment special study

Paul Handke (PA DEP) collecting chlorine samples from a sample tap

Paul Handke (PA DEP) collecting chlorine samples from a sample tap

Paul Handke (PA DEP) collecting in-tank samples (Note:  In-tank sampling is not a required element of the DS CPE)

Paul Handke (PA DEP) collecting in-tank samples (Note: In-tank sampling is not a required element of the DS CPE)

EPA Region 6 AWOP Planning Meeting and Training Event: May 8 – 10, 2012 Dallas, Texas

A Region 6 AWOP planning meeting and field training event was hosted in May by the Region at their Dallas office. Participants included AWOP partners from Arkansas, Iowa, Oklahoma, Texas, EPA Region 6, TSC, and PAI. The 1-day training event included an overview of turbidity data integrity activities that have occurred in the AWOP network since the fall field event in Austin. Presenters were also invited to the session to discuss recent instrumentation developments with turbidity measurement and integration with SCADA systems. Representatives from Hach Company presented information on low level turbidity measurement including features of their laser turbidimeter and a calibration demonstration. A representative from Schneider Electric presented information on SCADA system design and applications for water treatment. The training event also provided opportunities to discuss common turbidity data integrity issues that the network has identified in plants and possible solutions. One example is the capping of data from IFE and CFE turbidimeters. Options for modifying existing analog signal outputs as well as upgrading to digital signal outputs were discussed by the speakers.

The planning meeting included discussion on priority topics such as developing a DBP Status Component based on Stage 2 data, approaches for internal development of AWOP teams, and limits for algae (cyanobacteria) in filtered water. The next meeting and training event is planned for July 31 – August 2, 2012 in Baton Rouge. The training event will include a field demonstration of the Extended Terminal Subfluidization Wash (ETSW) method that can be used to potentially lower filter backwash recovery turbidity and reduce the volume of water required for filter-to-waste.

Mike Sadar with Hach Company demonstrates the features of a laser turbidimeter and associated bubble trap to the group.

Julie LeBlanc with Louisiana AWOP displays the cookie baking skills of Jose Rodriquez with EPA Region 6. Jose was very popular at the meeting!

Distribution System Performance Based Training in Alabama

On April 17, 2012, the Optimization Team, in partnership with the Alabama Department of Environmental Management (ADEM), conducted Session 4 of a Performance Based Training (PBT) project focused on distribution system optimization. Six water systems (the parent system and five consecutive systems) are participating in this project. Each system has made considerable progress through this PBT, and reported on their efforts since Session 3 to identify areas with poor water quality and expected higher water age in their distribution systems. Additionally, each system reported on results from a special study they developed and implemented to address an area of poor water quality in their system. During Session 4 the special study concept was revisited and focused on assessing the impact of tank operations on water quality. Participants were tasked with developing and implementing a special study related to a storage tank in their system in preparation for Session 5.  (US EPA TSC Matthew Alexander & Alison Dugan)

Area-Wide Optimization Programs Strengthen Public Water System Supervision Programs

By Rick Lieberman, EPA TSC

An area-wide optimization program’s (AWOP) drinking water quality and monitoring goals typically exceed what is required by regulation.  This fact has contributed to the misconception that AWOP is only applicable to high performing water systems and does not help a Public Water System Supervision (PWSS) program ensure regulatory compliance within its jurisdiction.  In reality, PWSS programs that have adopted the optimization goals and effectively implemented AWOP have documented broad-scale water quality improvements from a variety of water systems.  AWOP implementation cultivates excellence while simultaneously bolstering compliance with the baseline requirements.  This article describes how AWOP implementation has been used to perform some of the key activities of a PWSS program and has been a cost effective way to strengthen PWSS programs.

The US EPA website describes the PWSS Grant Program as follows:  “Since 1976 EPA has annually received a Congressional appropriation under section 1443(a) of the Safe Drinking Water Act (SDWA) to assist states, territories, and tribes in carrying out their Public Water System Supervision programs.”  States and other agencies that have been delegated Primary Enforcement Responsibility (Primacy) for the Public Water System Supervision Program are eligible to receive grants.

PWSS programs implement the requirements of the SDWA and ensure that public water systems comply with the National Primary Drinking Water Regulations.  Key activities carried out under PWSS programs include:

  • Developing state drinking water regulations
  • Maintaining an inventory of public water systems (PWSs) state-wide
  • Managing a database of PWS compliance information
  • Conducting sanitary surveys of PWSs
  • Reviewing PWS plans and specifications
  • Providing technical assistance to managers and operators of PWSs
  • Carrying out an enforcement program to ensure that PWSs comply with state requirements.

The first and last PWSS program activities listed above involve establishing and enforcing drinking water regulations.  AWOP tools have been an integral part of the drinking water regulations through the Composite Correction Program (CCP) which was once used to assess the ability of water treatment plants (WTPs) to meet the requirements of the Surface Water Treatment Rule (SWTR) (54 FR 27486, June 29, 1989).  The CCP has subsequently been included in the Interim Enhanced SWTR, the Long Term 1 Enhanced SWTR, and the Filter Backwash Recycling Rule.  These regulations require the implementation of CCP or a Comprehensive Performance Evaluation (CPE) under certain conditions.  AWOP implementation provides ample opportunities to gain experience with CCP protocols and concepts, thus enabling agency staff members to directly implement those requirements of the regulations more effectively than states without CCP experience.

The ability of optimization approaches to successfully address PWS violations and facilitate the production of high quality drinking water without major capital improvements has been documented.  In fact, during the revisions to the SWTR, data collected from CCP activities were used in the regulation development process to help determine water quality levels that could typically be achieved without major capital costs.  Thus the optimization program has a history of supporting and strengthening the regulations by bringing real world experiences and measureable impacts to the regulation development process.

The origins of the optimization program were in direct support of the drinking water regulations, but the focus of AWOP has always been to help PWSs achieve water quality goals that are generally more stringent than the regulations.  Although AWOP goals are not enforceable they appeal to many water systems because of the greater public health protection associated with meeting those goals, and the additional “insurance” optimized performance provides against incurring a violation.  Furthermore, the methods used to help a PWS achieve the optimization goals can be used in an enforcement situation.  An AWOP protocol known as performance-based training (PBT) has been used by states in enforcement actions to bring water systems into compliance.  The protocol is focused on optimized performance, but PWSs striving to attain high levels of water quality through PBT often meet and surpass the regulatory requirements.  One AWOP state utilized a PBT format to bring together a parent system and multiple consecutive systems that were projected to be out of compliance with the DBP rules, based on monitoring data collected prior to promulgation of the rules.  The training project focused on in-plant as well as distribution system DBP control strategies.  These water systems attended periodic training sessions with their state trainers and facilitators, and the project impact included improved performance and compliance by most of the water systems.

Other key activities that are to be conducted as part of a PWSS program include maintaining state-wide inventories of PWSs and managing databases to hold PWS compliance information.  AWOP implementation simply builds off of those activities to establish a method of using PWS data in a strategic way to proactively address performance problems.  This typically involves enhancing the type and amount of data traditionally collected by the state agency and the processes used to manage the data.  It essentially takes the concept of a performance assessment for individual PWSs and expands it to an area-wide approach, enabling the primacy agency to look inside the “black box” of a PWS and assess if each treatment process and distribution system operation is optimized for producing and maintaining a high water quality for the consumers.  Rather than relying on enforcement to fix a problem that has potentially already put the public at risk, state resources can be targeted to optimize barriers that are not fully in place.  When implemented, these modifications to existing PWSS program data handling procedures can strengthen the public health protection and regulatory compliance responsibilities of the PWSS program.

Next on the list of key activities of PWSS programs is the requirement to conduct sanitary surveys of PWSs.  The surveys typically assess compliance with overall drinking water regulations in eight areas that range from source to distribution and include equipment, operation, and maintenance.  Surveys can be conducted by trained agency personnel (or other designated party) who interview system operators based on a ‘check-list’ type of evaluation.  Sanitary surveys typically involve limited, if any, review of performance data or the fundamentals of how compliance is achieved (e.g., how turbidimeters function, how disinfection credit is determined, etc.).  Many of the states implementing an AWOP have built upon existing sanitary survey protocols and included performance data to achieve a greater awareness of the PWS performance status by the regulated community.  The modification encouraged inspectors to review annual charts of raw, settled, individual filter effluent, and combined filter effluent data trends with operators during the surveys.   Some states have reported significant state-wide performance improvements due to this modified protocol.  States have also used information gained during the implementation of PBT or CPEs to modify sanitary survey questions.  These enhancements will enable inspectors to detect conditions that can contribute to an inaccurate determination of disinfection credit.  Modifications to the state’s permitting process have also been suggested to help identify situations where the C x T values may need to be reevaluated.  This will assist inspectors as they review operating permits prior to conducting sanitary surveys.

States have also reported the discovery of poor equipment calibration and improper sampling through AWOP implementation.  This has resulted in the development and implementation of additional procedures to determine if samples are representative of filter performance or if performance data are captured during the filter-to-waste cycle.  One state reported that it initiated an equipment calibration audit program as a result of finding equipment calibration problems during several CPEs.  Results of this ongoing audit have been documented over time (see Figure 1 below) and presented to representatives of states in the AWOP network to make them aware of the issue.  State staff members implementing AWOP have indicated that these data integrity problems were not detected prior to applying optimization protocols.  Figure 1 shows that the problem is persistent and widespread.

Figure 1 Results of State-Wide Turbidimeter Calibration Checks

Reviewing PWS plans and specifications is another key PWSS program activity that has been strengthened through AWOP implementation.  Reviews were typically focused on compliance with 10 States Standards – Recommended Standards for Water Works, but some states have incorporated specific comments that contribute to WTP optimization or alert the PWS to potential Disinfection By-Products formation problems due to excessive water age caused by the proposed project.  One state’s implementation of AWOP resulted in a better understanding of treatment process performance which allowed for the use of cost-effective methods to increase WTP capacity.  State staff members directed the use of special studies by a PWS to collect performance data.  The results of these studies justified re-rating permitted flows and allowed the PWS to avoid plant construction to gain additional capacity.  The insights gained from AWOP implementation have therefore been beneficial for state staff during their review and approval of new drinking water facilities as well as modifications to existing facilities.

Permitting and review of plans and specifications for new or unique drinking water facilities can be a challenging PWSS program activity.  Participation in AWOP provides the opportunity for states to easily tap into the expertise of the optimization network to answer specific questions on new or unique treatment technologies.  In recent years the network has been tapped multiple times (through the Association of State Drinking Water Administrators website discussion forums, AWOP meetings, etc.) with inquiries on areas such as ballasted sand sedimentation, membrane filtration, UV disinfection, and storage tank mixing.

Another key activity that is carried out under a PWSS program involves providing technical assistance to managers and operators of PWSs.  States have provided many examples of strengthening their technical assistance capability through AWOP implementation.  In particular, the use of PBT has enhanced the technical assistance capability of state staff members through their roles as trainers and facilitators.  Participation in AWOP activities at the treatment system level provides state staff with unique opportunities to understand how treatment processes work and the ongoing challenges that operators face each day in achieving their treatment objectives.  At the root of this success are the concepts of “drawing the graph” and “data based decision making.”  Through AWOP training and experience, state and EPA regional office staff have become very good at using performance data and goals to assess the impact of their activities at the utility (and customer) level.

The Capacity Development program is another PWSS activity that has been strengthened through AWOP implementation in some states.  The primary goal of capacity development is to assure that technical, managerial, and financial (TMF) capacity is in place for all water systems.  In recent years the program has also included infrastructure needs within its scope.  All states must have a strategy in place that supports the program.  In 2003 a brochure was published by the EPA Office of Water[1] that explored the areas where AWOP could support a Capacity Development program.  The main focus at that time was the TMF capacity for surface water treatment plants.  Since surface water treatment systems represented a significant number of water systems and population served in many states, several states utilize part of their Capacity Development program set-aside funding to support their state AWOPs.  Elements of AWOP that directly support the Capacity Development program include the public health risk-based prioritization of water systems and targeted performance improvement activities.  Many AWOP states have CPEs and/or AWOP formally included in their Capacity Development strategies.

A fundamental goal of AWOP is improving water quality at individual water systems, and natural activities to support this goal are technical assistance and operator training.  Many AWOP states have conducted one or more PBT events that were funded through Capacity Development Program set-aside funding as well as Operator Training Grants.  Some states plan to include all of their surface water treatment plants in a PBT series.  Through this training, operators as well as managers gain key skills in goal setting, performance data tracking, problem solving and priority setting.  PWS staff members participating in PBT have provided testimonials about the effectiveness and benefits of the training, through letters and press releases.  Many PBT participants report that the training was the best ‘hands-on’ training that they have ever received within their state.  They continue to utilize the skills they learned to maintain their treatment performance and address new treatment challenges.

The purpose of this article has been to describe how, throughout the history of AWOP, states have been able to utilize their optimization expertise to strengthen their PWSS programs.  Several examples were provided in this discussion, and many more exist in the AWOP network.  In times of tight budgets and diminished resources for PWSS program implementation, some decision makers may be tempted to view an AWOP as focused on high performing water systems and as a luxury that they cannot afford.  However, as mentioned above, optimization applies to all water systems and AWOP is not typically implemented as a stand-alone, “extramural” program.  Although AWOP implementation involves unique activities that are distinguishable from traditional PWSS activities, they are typically accomplished by existing staff members through enhancement of existing PWSS program activities.  The resulting benefits to public health protection and the robust and creative approaches to fulfilling PWSS program responsibilities are too numerous and significant to ignore.