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.