Embed Size (px)
Citation preview
Association of Idaho CitiesWater AcademyOctober 29 - November 8, 2018
1
AIC Water Academies Platinum Sponsors!
2
THANK YOU!
Today’s Agenda• Introductions & Regional Overview
• Statewide Support and Services
• Evaluating Your Utility Priorities
• Working Lunch: Regional Legislative Forum
• Regional Challenges and Current Projects
• Best Practices and Tools for Delivering Safe, Affordable Drinking Water Over the Long Term
• Best Practices and Tools for Ensuring IPDES Permit Compliance
• Current Efforts and Future Needs
3
AIC Water Academy Speakers AIC – Johanna Bell, Policy Analyst
ICRMP – Jim McNall, Risk Management Coordinator
IRWA – Adrianna Hummer, Source Protection Specialist and Trainer
USDA RD – Dave Flesher, Community Program Director
Other Policy and Technical Resources in the Audience
4
IntroductionsName
City and Utility Name
Position and Tenure
Top concern regarding Idaho’s water?
OR
Favorite volunteer activity or coalition?
5
Association of Idaho CitiesMission:
To promote excellence in and advocate for city
governance, community leadership, and services
to citizens in order to strengthen Idaho cities.
Advocacy + Training + Technical Assistance
6
AIC Board of DirectorsOfficers
President: Elaine Clegg—Council Pres. Pro Tem, Boise
1st VP: Suzanne Hawkins—Councilor, Twin Falls
2nd VP: Tom Jenkins—Council President, Malad
3rd VP: Kevin England—Mayor, Chubbuck
Past Presidents
Imm. Past Pres. Jeri DeLange—Councilor, Hayden
Past Pres. (16-17): Brian Blad—Mayor, Pocatello
Past Pres. (15-16): Greg Lanting—Councilor, Twin Falls
Past Pres. (14-15): Tammy de Weerd—Mayor, Meridian
Past Pres. (12-13): John Evans—Mayor, Garden City
Past Pres (05-06): Mitch Hart-Council Pres., Soda Sprgs
Past Pres. (03-04): Garret Nancolas—Mayor, Caldwell
District Directors
Dist. 1: Shelby Rognstad—Mayor, Sandpoint
Ron Jacobson—Mayor, Post Falls
Dist. 2: Bob Blakey—Councilor, Lewiston
Bill Lambert—Mayor, Moscow
Dist. 3: Darin Taylor—Mayor, Middleton
Kenny Everhart—Councilor, Idaho City
Dist. 3A: Lauren McLean—Council President, Boise
Genesis Milam—Councilor, Meridian
Dist. 4: Casey Andersen—Councilor, Burley
Bruce Hossfeld—Mayor, Paul
Dist. 5: Terry Larson—Councilor, Preston
Rick Cheatum—Councilor, Pocatello
Dist. 6: Robert “BJ” Berlin—Mayor, Roberts
Rebecca Casper—Mayor, Idaho Falls
7
AIC Municipal Water Users GroupRegion 1 (AIC District 1 and 2):
• Councilor Edie McLachlan, Genesee
• Councilor Shannon Williamson, Sandpoint
Region 2 (AIC District 3 and 3a):
• Mayor Nathan Leigh, Parma
• Councilor Sandi Levi, Nampa
Region 3 (AIC District 4):
• Councilor Robert (Bob) Culver, Jerome; CHAIR
• Councilor Randy Hawkins, Burley
Region 4 (AIC District 5 and 6):
• Councilor Terry Larson, Preston
• Mayor Rebecca Casper, Idaho Falls
• “At Large:” Councilor Richard (Rick) Cheatum, Pocatello
8
AIC StaffJess Harrison, Executive Director – [email protected]
Justin Ruen, Senior Policy Analyst – [email protected]
Johanna Bell, Environmental Policy Analyst – [email protected]
Dara Von Lossberg, Financial Services Coordinator – [email protected]
Sheila Christensen, Events Coordinator – [email protected]
GayDawn Oyler, Administrative Assistant – [email protected]
Jerry Mason, Legal Counsel – [email protected]
Nancy Stricklin, Legal Counsel - [email protected]
9
AIC Events in 2018-19Legislative Committee Meeting: November 30, 2018 (Boise)
Annual Water Summit: January 23, 2019 (Boise)
City Officials’ Day at the Capitol: January 24, 2019 (Boise)
Spring Academies: April/May, 2019 (AIC Districts)
Annual Conference: June 19 – 21, 2019 (Boise)
Idaho City Clerks, Treasurers & Finance Officers Association: September 18 – 20, 2019 (Nampa)
10
One WaterWater as a precious resource...
.........WATER – ENERGY – FOOD.........
▪Water and Energy▪Population Growth▪Drought and Water Scarcity▪Economy▪Public Health
11
One Water: Water and Energy The Water – Energy Nexus
Global Water Sector
• Uses over 7% of the world’s energy demand!
• Large Idaho energy footprint for treatment and transmission of drinking, waste, and irrigation water.
• Nationally, water and wastewater treatment accounts for 35% of a city’s energy budget.
• Conserving water conserves energy!
The Energy – Water Nexus
Global Energy Sector
• Uses 15% of the world’s water demand!
• Second-largest water footprint (largest is agriculture).
• High water use at fossil fuel refineries and nuclear plant operations (cooling, heating).
• Wasting energy wastes water!
12
Slide: Amit Pramanik, WERF
One Water: Population Growth (Why Re-Use?)
13
Over 70% of Idahoans live in one of Idaho’s 200 cities.
Idaho’s population is growing rapidly.
Drought is increasing in duration and severity.
Water quality concerns have significantly increased treatment and monitoring costs.
Slide: Amit Pramanik, WERF
Urbanization: Key Issues
▪ Political disputes▪ Lack of future planning▪ Inadequate capacity (TFMC)
▪ Technical Capacity▪ Financial Capacity▪ Managerial Capacity▪ Compliance Capacity
▪ Environmental Challenges▪ Unfunded Regulatory Mandates
14
One Water: Drought and Water Scarcity
15
Slide: John Abatzoglou, UofI
16
Summer and Winter Drought: Idaho
Slide: John Abatzoglou, UofI
Pacific Northwest: Annual Warming Stripes
17
Slide: John Abatzoglou, UofI
Climate2015 and 2018: USDA Secretarial Drought Disaster Declarations
18
Slide: Kate Gordon, Risky Business Project
19
Looking Ahead
Slide: Kate Gordon, Risky Business Project
20
One Water: Drought and Water Scarcity
Slide: Kate Gordon, Risky Business Project
Idaho Overview: Water Quantity▪Eastern Snake River Plain/Aquifer: adjudications (2014); curtailments; Surface Water Coalition Term Sheet Agreement; mitigation programs; recharge efforts; Ground Water Management Plan
▪Bear River Basin/Aquifer: funding for adjudications planned for 2020
▪Upper Henry’s Fork Basin: drought “early warning system” study planned
21
Idaho Overview: Water QuantitySurface Water Coalition: Actively works with the Idaho Ground Water Coalition to secure water rights for agricultural and irrigation district interests.
Coalition of Cities: (Bliss, Burley, Carey, Declo, Dietrich, Gooding, Hazelton, Heyburn, Jerome, Paul, Richfield, Rupert, Shoshone and Wendell), Idaho Falls and Pocatello, have negotiated a Settlement Agreement with the SWC and IGWA to be signed by the end of 2018
Other cities who want to participate will need to opt in - contact AIC!
22
Regional Overview: Water QuantityGrowth and Urbanization
▪ Treasure Valley Aquifer – groundwater flow model
▪ Suez Petition for Reasonably Anticipated Future Needs (RAFN) Right
▪ Lucky Peak Re-Fill Rights (and proposed New Storage Authority)
Others?
23
Regional Projects: Additional Storage
▪ Boise River Dam Raise▪ Galloway Dam (Weiser River)▪ Lost Valley Dam Raise (Weiser River)▪ Mountain Home Aquifer/Air Force Base Sustainable
Water Project
24
Source: IWRD, IWUA, House Speaker Bedke
Idaho Overview: Water Quantity▪Rathdrum Prairie Aquifer: joint management
▪Palouse River Basin: joint management
▪Treasure Valley & Big Wood Ground Water Models
▪Snow Supplied Resources: impacted by 'snow drought'
25
▪Drought is a Natural Phenomenon
▪Anticipate and Plan Deliberately
▪Be Proactive within the Law:▪Idaho Code § 42-222A: Approve, without advertisement, upon a formal drought declaration, the temporary transfer of a point of diversion, place and purpose of use, or temporary exchanges; Change effective until December 31
Planning for Drought
26
Water Conservation▪ Fixture efficiencies continue to increase▪ Water Efficiency/Wastewater Cost Nexus
▪ Saving water reduces treatment costs▪ Outside use in summer is typically the greatest demand▪ Water meters drive conservation – and ensure equitable rate
structures and allows the system to identify water loss▪ Demonstrating a commitment to conservation improves local
acceptance and may help water right negotiations
27
Water Re-Use▪ Cities can use their water “to extinction”
▪ Helps ensure cities have enough water
▪ Addresses environmental concerns relative to discharges into natural surface water bodies
▪ Stacks environmental benefits (ex., carbon sequestration markets)
28
Protecting Water Quantity▪Best option is to use the water!
▪Preserve parcel water rights during development via ordinance or rule
▪Improve infrastructure◦ Surface water for irrigation
◦ Fire protection pressure
◦ Metering
▪Water right marketing ◦ Idaho Water Supply Bank
◦ Idaho Rental Pool
29
Regional Overview: Water QualitySafe Drinking Water Act Compliance▪Current challenges (nitrates, arsenic, lead/copper, coliform, changes to system classification)▪Emerging contaminants (blue-green algae, magnesium, methane, others?)
Clean Water Act Compliance▪Current challenges (toxins in fish and fish advisories, nutrients, temperature, bacteria, copper, selenium, ammonia, pharmaceuticals, aquaculture, others?)▪Emerging contaminants (endocrine disruptors, arsenic, blue-green algae, others?)
Others?
30
Protecting Water Quality▪Best Option is to Re-Use or Reclaim the Water!
▪Preserve Floodplains and Riparian Areas via Ordinance and Acquisition
▪Protect Utility Systems via Ordinance or Rule
▪Protect Water Quality for Surface and Groundwater ▪ Find out what your risks are (monitoring data and studies)
▪ Consider “area of drilling concern” or “sensitive aquifer” designations
▪ Infiltrate stormwater via “Green Infrastructure”
▪ Fully fund “Asset Management” for conveyance system replacements and improvements
▪ Look for opportunities to “Stack Benefits” (examples: wastewater energy co-generation, industrial use incentives, pollutant trading with agricultural neighbors)
31
32
ICRMP
33
ICRMP
34
ICRMP
35
ICRMP
36
ICRMP
37
▪Claims▪Risk Management
ICRMPCoverages -◦Property◦General Liability◦Auto◦Machinery (electric)◦Employment◦Bonds (Crime coverage)◦E&O
38
ICRMP
39
▪$13,535,369▪1,273 claims▪$10,632/claim
ICRMP
Water/Wastewater Dept. Claims:◦Water in homes/businesses◦Damage from leaks ◦Pump/controller failure◦Lids not secured – damage to persons and autos◦Driving related◦Personnel claims
40
ICRMP
41
➢Avoid repeat claims – correct deficiencies➢Provide ongoing training & reminders to employees➢Look at losses and near misses for preventability not just liability➢Facilitate immediate reporting and initial clean up ➢Staff - keep eyes open – pay attention
ICRMP
42
ICRMP
43
Idaho Rural Water Association (IRWA)
To provide technical assistance, training and a strong representative voice for the benefit of
Idaho’s water and wastewater systems.
44
Statewide & Regional Support: IRWAIdaho Rural Water Association
▪ Non-profit 501(c)3 corporation formed in 1987▪ Provide technical assistance and training to public drinking water and wastewater utilities▪ Governed by 7-member Board of Directors▪ Composed of over 350 member “systems” (utilities)
Idaho Rural Water Association
▪ Funding from USDA Rural Development, EPA, DEQ
▪ 7 field staff provide on-site technical assistance for utilities throughout Idaho
▪ 3 office staff address legislative initiatives, industry relationships, grant administration, social media, and member support
▪ Field staff visit around 120 systems per month
▪ Countless systems assisted via phone and email
Idaho Rural Water Association
Onsite assistance can include:
▪ Troubleshooting
▪ Help meeting regulations/sanitary survey follow-up
▪ Community and Council education
▪ Financial assistance and planning
▪ Asset management, long-term sustainability
Idaho Rural Water Association
▪ Largest provider of classroom training for Idaho’s drinking water and wastewater operators
▪ Training topics include:
Pumps, motors, disinfection and treatment, workplace safety, emergency response, sampling, filtration, lagoons,
valves, sustainable utility management
Idaho Rural Water Association▪We represent Idaho’s utilities and utility employees in the state and national legislature
▪ Comment or position to be brought to the Idaho Legislature? Email Shelley Roberts: [email protected]
▪ National Rural Water Association (NRWA) represents you on a national level for policy changes and current issues
▪ Comment or position to be considered by the NRWA Regulatory Committee? Email Mike Keegan: [email protected]
IdWARNIdaho Water and Wastewater Agency Response Network
▪ Free, quick-response network of utilities helping utilities
▪ Provides industry-specific assistance during critical times
▪ Reduce expensive damage from natural disasters
▪ Maintain water and sewer services for community
www.idwarn.org
Contact Your Regional IRWA Representative
Southcentral and Southeastern Idaho Southwestern and Northern Idaho
Drinking Water Assistance:Jeff Cook 208-599-5786 [email protected]
Drinking Water Assistance:Gary Sievers [email protected]
Wastewater Assistance:Craig Sturman [email protected]
Wastewater Assistance:Paul Sifford 208-930-5575
Source Water Protection, Compliance, Community Resources, Board Education, General Questions:Melinda Norris 208-761-4118 [email protected]
Source Water Protection, Compliance, Community Resources, Board Education, General Questions:Adrianna Hummer [email protected]
Statewide Training/Licensing Assistance: Barbi Burke 208-634-6694 [email protected]
Statewide Membership, Legislative, Other:IRWA Office [email protected]
51
USDA Rural Development
Committed to the future of rural communities.
52
Funding Overview Summary▪Majority of projects have multiple funding sources
▪Get Funding Agencies involved early and often!
▪Cities can use a revenue bond (either with an election or judicial conformation), GO Bond, or LID
▪Use RD Apply, IDEQ can use that information as part of their application & IDOC uses as a reference as well
53
Statewide & Regional Support: USDA▪Communities <10,000 Population -WEP (<20,000 - CF)
▪Apply Anytime Using RD Apply (WEP)
▪Direct Loan Program, Supplemented by Grants
▪Interest rate and grant % based on MHI and health issues
▪Revenue bond and grant funds - 40 year Minimum Term (w/grant)
▪Guaranteed Program - Loan made by a bank
▪ECWAG if Emergency Water Situation Exists
▪American Iron and Steel (AIS)
54
Statewide & Regional Support: IDEQ-SRF
▪Annual Process using a Letter of Interest (LOI) for planning and construction –mailing in October, LOI due in January
▪LOI’s rated and ranked (public health, compliance, etc.)
▪Intended Use Plan issued –March / Final Use Plan -May
▪Loan / Grant offers from July 1st through June 30th
▪State Office processes / Regional Staff monitor constr.
▪Davis Bacon plus American Iron and Steel (if $1 in project)
55
Statewide & Regional Support: IDOC-CDBG▪HUD Funding –block granted to States (less than 50,000)
▪Application due Friday before Thanksgiving. Max is $500,000, $150,000 (sr), and $100,000 (Imminent Threat)
▪IDOC Staff reviews, Governor’s Economic advisors assign priority points – Short List informed by end of January
▪Addendum due March 1st, decision by Gov. by late April
▪Subject to Davis Bacon if CDBG $ spent in construction
56
Statewide & Regional Support: USACE▪No population limits; emphasis on communities < 10,000
▪Program funding is appropriated by the Congress
▪USACE works closely with other Idaho funding agencies to leverage $ for shovel ready projects
▪Obtain the support of your Congressional Staff
▪No application process – just submit a request for assistance to USACE
▪Have funding in place from all potential agencies
▪Davis Bacon plus American Iron and Steel57
Funding Agencies: Contact InformationUSDA Rural Development https://www.rd.usda.gov/id
IDEQ http://www.deq.idaho.gov/water-quality/grants-loans/
IDOC https://commerce.idaho.gov/communities/community-grants/grant-resources/
USACE Karen L Kelly, Planning Study Specialist, 509-527-7248, [email protected]
NRWA National Rural Water Association, Rural Water Loan Fund: https://nrwa.org▪ For our members, under 10,000 in population, limit $100,000 max
▪ Quick disbursement, low interest
58
BREAK
59
Understanding Utility Priorities: Drinking Water System “Evaluations”
▪ Evaluations are broken into four categories
▪ Address the capacity of managerial, financial, technical, and compliance aspects of your drinking water system
▪ Each category is critical for long-term success and sustainability
▪ Today we will briefly cover each topic and provide resources for you to find out more. We will cover a few key reclaimed/wastewater topics afterwards
▪Take notes as we proceed regarding where your utility ranks
60
Resources: Evaluations
61
• Additional resources and links are posted on the AIC website; along with copies of these presentations.
• “AIC 2018 Water Academies Report” prior to the Annual Water Summit on January 23, 2019.
Managerial Capacity: System Regulations or Ordinances
▪ Ordinances are your utility’s means of enforcing its rules (ex: cross connection policy, new connection requirements)
▪ Templates are available for most topics
▪ Process: draft, public hearing, do you need to codify?
Public Water System Rules: https://adminrules.idaho.gov/rules/current/58/580108.pdf
Ordinance Templates: www.idahoruralwater.com/resources/ordinances/
62
Managerial Capacity:Facilities and Strategic Plans
▪ Evaluating your utility, and encountering an emergency, may prompt strategic facility planning▪ Elements: ▪ Establish need for project▪ What solutions are available, alternatives?▪ Obtain public input▪ Recommendations from third parties▪ DEQ approves every facility plan, even self-funded
63
Managerial Capacity: Emergency Planning▪What are your most likely risks or threats? How can you minimize these threats? (Security Vulnerability Assessment)
▪Where do you turn for assistance when disaster strikes? (Emergency Response Plan)
▪ What requirements are there to receive funding during or after an emergency?
Find funding: https://ioem.idaho.gov/ https://www.rd.usda.gov/idCounty contacts: https://ioem.idaho.gov/Pages/AboutUs/Contact/CountyCoordinators.aspxSVA, ERP templates and planning: www.idahoruralwater.com/resources/emergency/Planning: www.epa.gov/waterresilience
64
Managerial Capacity: System & Billing Records
▪ Detailed utility records are critical for business continuity
▪ Paper and electronic copies encouraged
▪ System information and customer information must be secure (Red Flag Rule)
▪ Utility Management Certification Course (http://wateruniversity.org )
Daily, weekly, monthly, annual record keeping: https://www.epa.gov/dwcapacity/operation-and-maintenance-resources-small-drinking-water-systems-0IRWA Support Services: 208-343-7001Billing and record keeping assistance: Diane Sauer 208-818-2843 [email protected]
65
Managerial Capacity:Source Water or Wellhead Protection
▪ “An ounce of prevention is worth a pound of cure.”
▪ Planning for the future: drinking water quantity and quality considerations
▪ Address any local threats to source, enforce regulations, work with local businesses and residents to achieve common goal
Online tool to create SWPP: https://www2.deq.idaho.gov/water/swppIRWA Source Water Protection Specialists: Adrianna and [email protected] and [email protected]
66
Managerial Capacity:Customer Communications
▪Reduce community rifts by becoming transparent
▪ Although utilities should be approached internally as a business, they are in fact not-for-profit public services
▪Website, social media, utility bills, emergency messages, public meetings, newsletters
▪ Show your customers the challenges faced using pictures and video!
Customizable brochures, flyers: www.idahoruralwater.com/resources/brochures-and-flyers/Affordable website services: www.ruralwaterimpact.com
67
Financial Capacity:Water System Budget
▪Does your budget support and facilitate your goals?
▪Is your budget fair and equitable for all users?
▪ What are the different types of budgets?
▪When was the last time your budget was assessed?
UMC CourseAlliance for Water Efficiency: http://www.allianceforwaterefficiency.org/1Column.aspx?id=710https://www.epa.gov/planandbudgethttp://www2.deq.idaho.gov/water/SMSWS/Pages/Login.aspx
68
Financial Capacity: Rates Meet Expenses
69
O&M Expenses
+ Short-Lived Assets
+ Debt Service (P&I)
+ Capital Projects Funded by Rates
= Total Revenue Requirement
Financial Capacity:Rates or Fees Meet Expenses
70
▪ Remember: your revenue requirements change over time!
▪ Financial needs should be reviewed annually to keep up with the full costs of the system
Financial Capacity:Capital Reserve and Depreciation Fund▪ Evaluate true costs of service (revenue requirement)
▪ Identify Reserve Requirements (unknowns make this difficult)
▪ Design defensible rate structure (transparency aids community support)
▪ Implement full cost utility rates
▪ Evaluate annually and modify, as needed
http://www2.deq.idaho.gov/water/SMSWS/Pages/Login.aspx
Environmental Finance Center http://efc.web.unc.edu/2013/02/22/more-on-reserve-funds-how-much-is-too-much/
71
Financial Capacity:Asset Inventory & Replacement
▪Idaho: $961.8 million in drinking water infrastructure needs over next 20 years (ASCE, 2017)
▪ Idaho: $1.38 billion in wastewater infrastructure needs over next 20 years (ASCE, 2017)
▪ Systematic, routine replacement of infrastructure is required to stay afloat
CUPSS: https://www.epa.gov/dwcapacity/Asset management guides and resources from EPA: https://www.epa.gov/dwcapacity/asset-management-resources-small-drinking-water-systems-0www.idahoruralwater.com/resources/emergency/
72
Financial Capacity:Current Rate Study▪ Income > Revenue Requirement
▪ Do you have the same fees for industrial and residential connections?
▪ Do your rates encourage conservation?
▪ What future challenges do you foresee? (reserves)
▪ Every 3 – 5 years recommended
USDA RD, EPA, AWWA, RCAPIRWA Support Services: 208-343-7001Diane Sauer: 208-818-2843 [email protected]/Water University: https://wateruniversity.org
73
Financial Capacity:Affordability▪ Affordability for municipal water utilities is an increasing concern on a national level
▪ Best Practice: achieve revenue requirements through a “fair and equitable rate structure”
▪ Assess options to develop community funds for low income or senior customers
▪ Grant funding may not be available if rates are low, have not been recently assessed, or reflect an outdated economic climate
74
Technical Capacity:Adequate Supplies & Legal Rights
▪ Do you know what your utility’s water rights are?
▪ IDWR has all water rights online: http://idwr.idaho.gov/
▪ AIC: Municipal Water Users Group
▪2 representatives per IDWR region
▪ Contact AIC to request clarification, express concerns, convene with special interest groups
AIC: https://idahocities.org
75
Technical Capacity:Adequate System Capacity
▪Source Water Adequacy – quality and quantity
▪Infrastructure Adequacy - treatment, storage, collection, distribution, discharge, etc.
▪Ability of personnel to implement required technical knowledge
▪Existing plan to protect source water and deal with emergencies
DEQ’s Capacity Development Program: http://deq.idaho.gov/water-quality/drinking-
water/capacity-development/
Building the Capacity of Small DW Systems: https://www.epa.gov/dwcapacity
76
Technical Capacity:Certified Operators & Backup Operators
▪Skilled operators are a critical investment for your utility
▪Responsible Charge and Backup Operator requirements set by DEQ, IDAPA 58.01.08.554
▪Requirements for obtaining licensure set by IBOLhttp://www2.deq.idaho.gov/water/OpForHire/SearchIRWA Support Services: www.idahoruralwater.com/services/support-services/
77
Technical Capacity:Operation & Maintenance Manual▪Requirement for public utilities
▪Detailed, complete, duplicated records
▪Consider: would a new employee be able to run the system using only your manual?
Templates: www.idahoruralwater.com/resources/emergency-response/Daily record keeping: https://www.epa.gov/dwcapacity/operation-and-maintenance-resources-small-drinking-water-systems-0
78
Technical Capacity: Cross Connections and Backflow▪A “cross connection” is any real or potential connection within your public water system between potable water and non-potable water or fluid.
▪Backflow is the reversed flow of water through your distribution system.
▪Public Water Systems (PWS) are required to have a program in place to eliminate cross connections and prevent backflow from occurring (IDAPA 58.01.08.543 and .552.06).
79
Requirements of a Cross Connection Control Program
1. Inspection program or schedule to identify cross connections within the water system.
2. Appropriate backflow prevention assemblies must be installed at cross connection locations and at all new connections prior to starting new service (ordinance).
3. Annual testing of backflow prevention assemblies is required. Proof of inspection, and repair if needed, must be provided to utility.
4. Testing must be performed by a Backflow Assembly Tester, certified through IBOL.
5. Assemblies that do not pass the test must either be repaired, replaced, or isolated within 10 business days.
6. Water service must be discontinued to any resident or business that will not comply with Cross Connection Control Program.
80
Cross Connection Resources▪IRWA website has all templates needed to implement your CCCP www.idahoruralwater.com/resources/cross-connection/
▪DEQ has some good FAQ sheets and guidance on CCCPs http://www.deq.idaho.gov/water-quality/drinking-water/pws-tips-guidance/guidance-fact-sheets/
▪Regional DEQ Drinking Water representative or IRWA staff member can assist
81
Technical Capacity:As-Built Plans & Distribution Map▪Distribution map may not be current depending on system upgrades
▪ Work with system engineer to obtain as-built plans during infrastructure projects
▪ Current maps should be created if they are lacking
IRWA: https://idahoruralwater.com/services/support-services/Tui Anderson: 208-871-8437 [email protected]: http://deq.idaho.gov/assistance-resources/for-engineers-developers/checklists/
82
Technical Capacity:Water Loss Accounting▪Recover production capacity
▪Recover lost revenue
▪Extend the life of pumps▪Reduce utility liability due to possible contamination from cross connections
Free water loss software: https://www.awwa.org/resources-tools/Water Research Foundation: www.werf.orgTui Anderson: 208-871-8437 [email protected]
83
Technical Capacity:Customer Usage▪ Public education plays a role in usage habits
▪ Do your customers understand the value of the service they are being provided?
▪ Best practices: meters, outreach/education, incentive programs
http://www.allianceforwaterefficiency.org/Tracking-Tool.aspxIDWR funding for meters, email: [email protected] funding: https://nrwa.org/initiatives/revolving-loan-fund/WaterSMART efficiency grants: https://www.usbr.gov/watersmart/weeg/
84
Compliance Review: Overview▪ Typically a compliance review or emergency will trigger strategic facility planning▪ Look at your agency and trade organization resources:
▪ DEQ▪ IDWR▪ AIC▪ ICRMP▪ IRWA and NRWA▪ USDA Rural Development▪ Others....
85
Compliance and Protecting Health▪ Operators are taught their primary responsibility is
protecting public health and safety▪ Safe drinking water and wastewater treatment should be
at the forefront of your utility’s goals▪ What can stand in the way of achieving those goals? ▪ Stay informed: www.ruralwater.org
86
Compliance Review
▪ Outstanding Violations/Obligations
▪ Significant System or Service Deficiencies
▪ Forecast Capacity less than 80% of Need within 5 Years
▪ Violations of Maximum Contaminant Levels
▪ Monitoring and Reporting
▪ Lab Testing Facilities & Personnel
▪ Public Notice (Consumer Confidence Report or Other)DEQ, IRWA can assist
87
Compliance Review:Forecast System Capacity <80% within 5 Years▪Has the capacity of your water system (fire fighting pressure, wells, treatment, distribution, storage) been evaluated recently?
▪ How does your system function during droughts (if surface supplied)? Does the quality of the water degrade?
▪ Are system demands approaching or exceeded 80% of your established capacity?
Resources: DEQ and Engineering Firm
88
Compliance Review:Lab Testing & Personnel▪ Unless you are a new utility, this is established already
▪ Consider: lab to use during emergencies/after hours?
▪ Generally same lab for Drinking Water and Waste or Reclaimed Water
▪Chain of Command
http://healthandwelfare.idaho.gov/Health/Labs/CertificationDrinkingWaterLabs/tabid/1833/Default.aspx
Emergency/After-hours Lab Services: Water Laboratory Alliance
89
Compliance Review:Public Notice▪Consumer Confidence Report (CCR) required each year
▪Find creative ways to share with public (social media?)
▪Public notices required for violations
▪How are they distributed efficiently and effectively?
DEQ Switchboard: http://www.deq.idaho.gov/water-quality/drinking-water/pws-switchboard/IRWA Support Services: 208-343-7001Public notice templates: www.idahoruralwater.com/resources/emergency/Diane Sauer: 208-818-2843 [email protected]
90
Understanding Utility Priorities: Reclaimed/Wastewater Utility “Evaluations”
▪ Same four categories: managerial, financial, technical, compliance
▪ Some overlap between drinking water and reclaimed/wastewater topics
▪ We will highlight some issues that are unique to the wastewater industry
▪ Follow along on Wastewater Evaluation Form (not all topics will be covered)
91
General - IPDES Permits▪ Permits are required for discharge of treated wastewater into surface waters
▪ Idaho is taking over primacy of the program (IPDES)
▪ Change in permitting authority comes with a fee based on population and equivalent domestic units (EDUs)
www.idahocities.orghttp://www.deq.idaho.gov/permitting/water-quality-permitting/npdes/http://www.deq.idaho.gov/permitting/water-quality-permitting/ipdes/
92
General – Reclaimed/Re-Use▪ Permits are required for land application and all other activities that address treated wastewater disposal
▪ Idaho DEQ issues these permits
▪ AIC has convened a Water Re-Use Task Force to explore whether there are some policy, rule making, or statute barriers for municipal re-use
http://www.deq.idaho.gov/permitting/water-quality-permitting/wastewater-reuse/http://www.deq.idaho.gov/permitting/issued-permits/
93
Managerial Capacity: Pretreatment▪Reduce hardships and financial drain on wastewater collection systems
▪Biologic interference limits the functionality of wastewater treatment systems – impacts lagoons, land applications and surface water discharge systems
▪Effective pretreatment starts with an enforceable ordinance and implementation program: fats, oils, grease (FOG)▪ Restaurants and coffee shops
▪ Dental and doctor’s offices/clinics
▪ Industrial/commercial users
www.idahoruralwater.com/resources/ordinances/http://www.abcwua.org/Industrial_Pretreatment.aspx
94
Technical Capacity: Secondary or Equivalent Treatment▪Generally larger volume treated or increase in BOD (biochemical oxygen demand) require secondary treatment
▪ Planning for growth: secondary treatment will require financial investment, updated master facility plan, more operator requirements
▪Peak flow and design flow review should be performed regularly (engineer)
95
Technical Capacity: Greater Treatment Capacity▪Needed to accommodate population growth, or new or expanded industry
▪Or prompted by water quality based limits needed to protect the receiving stream/river:
▪Total maximum daily loads (TMDLs), most common example is need to reduce phosphorus, sometimes sediment (or total suspended solids, TSS), ammonia, organics, aquaculture
96
Technical Capacity: Water Infiltration/Inflow Accounting▪Operators should be reading and recording every day
▪How does water used by customers (drinking water pumped) compare to wastewater collected?
▪Consider Supervisory Control and Data Acquisition (SCADA) system for accurate inflow monitoring and accounting
▪ Routine system inspections can identify issues as well (ex: damaged manholes)
EPA’s Wastewater Collection System Toolbox: https://www3.epa.gov/region1/sso/toolbox.htmlIRWA’s Wastewater staff can come work with you directly!
97
Technical Capacity: Customer Usage▪Important factor in health and sustainability of your wastewater utility
▪Sensitive biologic process that can be disrupted by improper use of drains (healthy sewage vs. non-healthy)
▪Ordinances and education ▪ Pharmaceutical “take-back” programs, FOG program,
methamphetamines, baby wipes, commercial customers
www.idahoruralwater.com/resources/ordinances/www.idahoruralwater.com/resources/brochures-and-flyers/
98
Compliance Review: Active Permit or Administratively Extended▪Permitting program shifting from EPA Region 10 to IDEQ, extensive backlog of expired EPA permits
▪Check expiration date of permit. If expired, confirm letter received from EPA to administratively extend until reissued by EPA or IDEQ
▪Make sure you made timely reapplication for the permit (180 days before expiration)
99
Compliance Review: Active Permit or Administratively Extended▪Be aware of events that may make reissued permit more challenging (TMDLs), and prepare accordingly
▪Check the data submitted with reapplication:
▪ Is it no longer representative of your facility’s performance?
▪ Collection and submittal of updated information is a good idea
▪ Data-driven decisions are best
▪Work with the DEQ and assess whether additional data collection is needed prior to the establishment of a new effluent limit (copper BLM; selenium, etc.)
AIC: https://idahocities.orghttp://www.deq.idaho.gov/permitting/water-quality-permitting/npdes/http://www.deq.idaho.gov/permitting/water-quality-permitting/ipdes/
100
Compliance Review: Schedule of Compliance and Variance
Schedule of Compliance – a schedule of enforceable interim requirements in a permit that will lead to effluent limit compliance “as soon as possible” (ex., actions, operations, or milestones)
Variance – a temporary change in a state's water quality standard for a specific pollutant and its relevant criteria, allowing deviation from meeting a water quality-based effluent limit (WQBEL) for particular discharger(s)
Variance Examples: Montana Nutrient; Spokane River PCBs; Willamette River Mercury
http://www.deq.idaho.gov/permitting/water-quality-permitting/ipdes/
101
Schedule of Compliance: Affordability Analysis▪ Reviewed community affordability during IPDES permit compliance schedule for development or enforcement
▪ “Residential Financial Capability:” Medium Household Income▪ % of Home Ownership▪ % of Low Income Customers ▪ % of Customers Unemployed > State or National Average▪ % on Disability
▪ City Finance Capability Indicators▪ Debt▪ Socioeconomic ▪ Financial Management
https://www.awwa.org/resources-tools/water-knowledge/affordability.aspx#351341648-awwa-technical-resourceshttp://www2.deq.idaho.gov/water/SMSWS/Pages/Login.aspx
102
Compliance Review: Exceedance of Effluent Limits▪Enforcement actions, fines and penalties, can be severe
▪Third-party lawsuits are allowed and not uncommon under the Clean Water Act
▪Can be another indicator of Infiltration/Inflow problems
▪Other potential causes:▪ Inadequately sized treatment units▪ Lack of proper maintenance or operation▪ Fluctuation in receiving water parameters ▪ Fluctuations in customer use
www.idahocities.org
http://www.deq.idaho.gov/permitting/water-quality-permitting/ipdes/
103
Compliance Review: IPDES Permits▪ Idaho is taking over primacy of the program (IPDES)
▪ AIC has invested time and resources to assist in the development of Effluent Limit Development Guidance(s) for Idaho’s permit writers
▪ A supplemental guidance and other resources anticipated soon to address special topics:▪ Nutrients▪ Temperature▪ Select Toxics (Arsenic, Phthalates, PCBs)▪Monte Carlo▪Offsets▪ Bubble/Watershed Permits▪ Adaptive Management
104
Compliance Review: Significant System, Service or TMDL Related Deficiencies▪ Sanitary sewer system overflows or spills (at manholes, basements, or elsewhere), during dry weather or storm events?
▪ If sewer overflows or spills discharged to a surface water body, were the notification and response requirements followed?
▪ How have you addressed the above problems if they’ve occurred?
▪ Is there a TMDL or new receiving water criteria that requires revised treatment or facility modifications?
▪ How are you planning to accommodate that need financially and technically?
Contact IRWA for technical assistance!
105
Compliance Review: Operating Capacity >80% of Design within 5 Years▪Has the capacity of your treatment plant been evaluated recently?
▪Do you have recent, DEQ approved facilities plan in place (less than 5 years old)?
▪Are influent flows approaching or have exceeded 80% of your established design capacity?
▪Does your NPDES permit have a requirement regarding capacity and facilities planning?
Resources: DEQ, IRWA, Engineering Firm
106
IPDES State Contacts
107
Open Discussion or Feedback(Please be brief – we are getting ready to eat!)
108
Lunch Break
109
