ConnectionThe Wyoming

Fall 2019

Fall Expo Wrap Up

Source Water Protection Plans are for Sharing

Regulatory Activity Quarterly Report

Cover Photo – Katie Asay, Donna’s neice, packing out her first elk kill last fall. Photo by Nick Asay, her husband.

Contents and FeaturesRegulatory Activity Quarterly Report, Mark Pepper ................................................5

18th Annual Fall Expo Wrap Up, Mark Pepper .......................................................6

Source Water Protection Plans are for Sharing!, Michelle Christopher ..................7

Secondary Biological Treatment – Trickling Filters, Mark Court .............................8

Value Added, Kathy Weinsaft ...............................................................................10

Contract Operator Services Between Towns/Districts, Ross Jorgensen ..............12

WYOWARN ..........................................................................................................13

Associate Members ..............................................................................................14

Small Town Operators, Joe Dankelman ...............................................................15

Operator’s Corner, Mark Court & Michelle Christopher ........................................16

PFAS, NRWA ........................................................................................................17

Ford Fleet Program ..............................................................................................20

40 Years, and What a Ride!, Floyd Field Retires ..................................................21

Cost-to-Serve Rates? Really?, Carl Brown ..........................................................22

Chrysler Group Fleet Program .............................................................................24

Our Western Heritage – Looky Loo, Kathy Weinsaft ............................................25

Scrawny Girl’s Elixir of Life, Michelle Christopher ................................................28

The AssociationWyoming Association of Rural Water Systems is a non-profit association that provides on-site, one-on-one technical assistance and training to small municipalities under 10,000 population and all water and wastewater systems throughout the state. Equal Opportunity Provider.

WARWS’ Mission:To provide the assistance necessary to meet the needs of ourmembership and to ensure the protection of Wyoming’s water

~ our most precious resource.

Fall 2019 – Issue 115

The Wyoming Connection is the official publication of The Wyoming Association of Rural Water Systems. It is

published quarterly for distribution to member systems, water and wastewater Operations Specialists, water

related agencies and companies, legislators and government officials.

Graphic Design/Layout – Donna Uribe, WARWS

Articles, letters, and photos are welcome. Submit to:

Wyoming Association of Rural Water Systems, PO Box 1750, Glenrock WY 82637 “An equal opportunity provider”

(307) 436-8636 TDD 1-800-877-9965 e-mail: warws@warws.com

Web Site: http://www.warws.com

WARWS Staff Office:

Mark Pepper, Executive Director(307) 259-6903 markp@warws.com

Jane Jeffs, Office Managerjanejeffs@warws.com

Donna Uribe, Administrative Coordinator(307) 258-3414 warws@warws.com

Field:Ross Jorgensen, USDA Registered Circuit Rider, UMC UFC

(307) 251-2803 rossj@warws.com

Johann Nield, Circuit Rider (307) 751-1138 johannn@warws.com

Kathy Weinsaft, USEPA Training Specialist, UMC

(307) 262-3943 kweinsaft@warws.com

Mark Court, USDA Registered Wastewater Specialist, UMC(307) 262-3974 mcourt@warws.com

Joe Dankelman, State Small Systems Circuit Rider, UMC (307) 439-9065 joed@warws.com

Michelle Christopher, Source Water Specialist UMC UFC259-8239 mchristopher@warws.com

UMC - Utility Management CertificationUFC - Utility Finance Certification

WARWS Board of DirectorsPresident

Erin Martin, Shoshone Utility Organization(307) 330-6144 emartin@easternshoshone.org

Vice PresidentChuck McVey, Town of Saratoga

(307) 329-5807 cmcvey_7@yahoo.com

Secretary/TreasurerRon Overson, Grand Targhee Resort

(208) 705-7899 roverson@grandtarghee.com

National Director Earl McKinney, Rural West, LLC

(307) 250-2186 ruralwestwyo@yahoo.com

DirectorDan Coughlin, Sheridan Area Water Supply

(307) 763-6011 dcoughlin@sheridancounty.com

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•LIFETIME WARRANTY ON THE SEAT RING

•ROLLING DIAPHRAGM HELPS DELIVER INDUSTRY LEADING LOW FLOW CONTROL

Regulatory Activity Quarterly Report Recent Examples of NRWA Advocacy Saving You Money:NRWA and the state affiliates are always busy working with regulatory agencies and congressional committees. Follow-ing is an update from the NRWA Regulatory committee. Mr. P.

New EPA Perchlorate Rule: On July 26, 2019, the EPA pro-posed a new drinking water MCL for perchlorate of 0.018 mg/L with a projected “compliance cost” of $10.2 million annually. In our August 26, 2019 comments, NRWA made 4 arguments for EPA to not finalize a MCL for perchlorate (one of the proposed options). If successful, this could save public water systems the projected $10.2 million annually in compliance costs.

New Drinking Water Rules for PFAS: On February 14, 2019, the EPA Administrator announced that EPA will make a de-termination whether to craft an MCL for PFOA and PFOS, two of the most well-known and prevalent PFAS chemicals, by the end of 2019. In our November 21, 2018 comments, NRWA urged EPA to craft non-regulatory/non-enforcement levels for PFAS and require the responsible parties to pay for treatment.

The U.S. Air Force estimates that it will cost them $2 billion to clean-up PFAS-contaminated water. This doesn’t include cleanup cost from industry sources.

Unregulated Contaminant Monitoring Cost (UCMR5): NRWA urged Congress to require that any small communi-ties required to conduct UCMR monitoring should be com-pensated. The 2018 amendments to the Safe Drinking Wa-ter Act require such compensation of communities between 3,300-10,000 persons (5,231 public water systems in EPA’s most recent inventory). Some small communities reported approximately $5000 per source for UCMR4 testing – mul-tiply this by approximately 5,000 for a potential cost of ap-proximately $25,000,000 if UCMR5 is as costly as UCMR4.

New Requirement to Update Vulnerability Assessments: All community water systems serving more than 3,300 persons MUST conduct a New Risk & Resiliency Assessment (RRA) and Emergency Response Plan (ERP) by July 2021 (Public Law 115-270). However, NRWA urged Congress to limit EPA’s review authority under the new law over the content

of RRAs. Systems only have to certify they have completed the assessment. Assessments conducted by consultants can cost upwards of $10,000 (or more). NRWA is planning on developing a free RRA tool for small communities which could potentially save upwards of $50,000,000 compared to a federal mandate for a specific assessment that would have required a consultant or professional certification.

Mandatory Federal Consolidation Authority: On 11/1/2017, the House Energy and Commerce Committee unanimously passed HR 3387 which included Section 4 “MANDATORY CONSOLIDATION” authority for states or EPA for certain water systems in noncompliance. NRWA urged the Senate to limit the new federal authority in the final bill.

On 9/4/2018, the Senate passed the “American’s Water In-frastructure Act” which removed all authority to the states or EPA to mandate the proposed consolidations. The President signed the bill into law on 10/23/2018, which included the Senate version of Section 4 (Public Law No: 115-270). It is difficult to estimate the monetary value to a community that could have been captured by this new federal regulatory authority.

Exempting Communities from Potential Superfund Liability from PFAS: In July, 2019, the House of Representatives ap-proved legislation as an amendment to the annual must-pass National Defense Authorization Act that requires EPA to de-clare within one year that PFAS are hazardous substances under the Superfund law, potentially opening up any water utility with PFAS in their effluent, biosolids, or drinking wa-ter treatment residuals to Superfund liability.

The House-passed legislation/amendment was not included in the Senate-passed bill. NRWA is currently collaborating with the other national water associations including AWWA, AMWA, NAWC, NACWA, etc. to exempt water utilities in the final version of the legislation which is likely to pass by October. NRWA is still working on estimated savings to wa-ter utilities which could be immeasurably large.

18th Annual Fall Expo Wrap UpThank you to everyone who attended our 18th Annual Fall Training Expo at Little America in Cheyenne. A very nice venue (albeit, it was a hike from the ballrooms to the restrooms – poor floor plan layout). We had just under 200 utility industry professionals attend this year’s event.

The Big surprise was the Governor’s Proclamation proclaiming February 3rd-9th, 2020 as Wyoming Water and Wastewater Professional Operator Week. Even though the formal recognition is a few months away, the Governor wanted to let all of the operators know how he views the work you do. Other commitments prevented him from sharing in person, but I think Deputy Administrator Alan Edwards from DEQ did an admirable job!!

Preconference started the week with a bang. The 84th Civil Support Group certainly is an amazing resource for Wyoming. Hopefully you can take the info about them back to your councils and boards to make sure they are aware of this resource and how to engage them as needed.

The new America Water Infrastructure Act Risk and Resiliency requirements will be something we are dealing with for some time. WARWS intends to make sure that the “survey” requirements are not just a ‘check a box’ format but actually taking the info and employing needed fixes or finding the resources for fixing or plugging security issues.

The work you do was certainly recognized as having Kevin Frederick, Water Quality Administrator at DEQ talk about many of the regulatory items underway, and WARWS involvement on your behalf, as well as WYDOT Director Luke Reiner talking about transportation, tourism and water issues was a treat. Being able to present our very first ‘Quality on Tap’ award for Consistent Professionalism and Delivery of Quality Drinking Water to the Waltman Rest Area, with them and Director Reiner in attendance, shows the special nature of this new award. As I said in making the announcement, we may not award this recognition every year, just when we feel someone or a system is totally deserving.

We received a lot of positive comments from you all regarding the quality of the training sessions and their current applicability. I want to thank DEQ for having staff discuss NPDES permits, Chapter 12 Permitting and operator certification issues. The State Engineer’s Office for discussing water rights, water quantity monitoring and other items of interest on “Where Does Your Water Come From?”.

A special thanks to Ed Harlow for bringing his VFD training systems for some very intense hands-on training. Now when the engineer trying to fix your VFD programming asks what happened, you can tell him how the thingamabob was making a doohickey sound.

Social Media usage is going to continue to be a medium

to get the word out to your customers, thanks to Cheyenne BOPU and to the Cheyenne Police Department for showing how they are employing social media. Record Retention from the State Archives, Apprenticeship availability from the US Department of Labor, our own Utility Management Certification, Cyber Security from Cyber Wyoming, and how to build a wastewater plant during a flood, as well as many more sessions. Thanks to all of our instructors.

And a big thanks to all of the exhibitors, and special thank you to Ferguson Waterworks and Sunrise Engineering for being EXPO Sponsors. See you all at the Ramkota in Casper April 13th-17th, 2020 for the Spring Training Conference and Industry Expo. Mr. P.

The very first ‘Quality on Tap’ Award - L-R Luke Reiner, Director of WYDOT, Chad Shaffer, and Chase Hood, the operators of the Waltman Rest Area; Mark Pepper, WARWS ED

Source Water Protection Plans are for Sharing!

Everyone knows that protecting sensitive infrastructure information is an important part of keeping our systems safe and secure. We know that making our Emergency Response Plans available to the general public is a bad idea, because it releases information on how to take down a water or wastewater system.

We’ve even been taught to post minimal information on buildings, particularly those that house toxic or noxious chemicals, because that would give the bad guys a shopping list.

What then about Source Water Protection Plans (SWPP)? Shouldn’t we protect those as vigilantly as we do our Emergency Response Plan, since having a high-quality water source is one of the most important parts of our infrastructure? No! Hear me out on this. Sometimes, the easiest way to protect something is to keep it in plain sight. When plans are shared with decision-makers, land managing agencies and regulators decisions regarding new developments, resource management, or new permits maintaining water quality can become part of the decision, not merely an afterthought or something to react to later.

The Source Water Protection Program in Wyoming is voluntary, and each of the plans that WARWS develops is the sole property of the water system (we do keep a copy). What you do with it is you and your system’s choice. I strongly encourage you to share these documents. Wyoming Department of Environmental Quality does not have most of the completed Source Water Protection Plans on file. The Source Water Protection Program does not maintain copies of any SWPPs unless the system has sent them in. The program knows which systems have completed plans, but that’s about it.

I strongly encourage every system that has a completed SWPP to send the DEQ a copy of that plan. Now – they may or may not review the plan or approve it at this time, but the document would be available to all divisions as information when applications for Underground Injection Control systems are being reviewed, new landfills are proposed, leaking underground fuel tanks are being remediated, etc. If they are unaware where your wells are (and they don’t – unless you tell them), they will not be able to protect those wells when they are reviewing permits. Who then should you submit a copy of your SWP to? Kim Parker, who maintains

the Operator Certification Program is also the point of contact for DEQ Source Water Protection. Email her a copy at kim.parker@wyo.gov.

Many municipal wells are located on public land and recharge areas or watersheds commonly include public lands. The Bureau of Land Management (BLM) and United States Forest Service (USFS) are responsible for permitting activities, including mineral exploration, grazing, logging, roads, pesticide spraying, and fire mitigation and control. All of these activities can affect water quality.

Each district office is charged with creating a field management plan. These are called Resource Management Plans at the BLM, and the Land and Resource Management Plan (Forest Plan) at the USFS. These plans outline the agency’s goals and priorities for the area that the office manages. Each of these documents are reviewed and updated on a 5-year basis according to the National Environmental Planning Act (NEPA) process.

While protecting water quality is a common priority for these agencies, it is important they understand the specific concerns that a municipal well or watershed may have. They can include your system’s SWPP as an appendix or amendment to their management plan to ensure that protecting your community’s drinking water source is included when reviewing permit applications.

Finally, all of our water systems are located within the twenty-three counties of Wyoming. (Yes, I can think of a few watersheds that include out of state areas, but the systems are in Wyoming!) These counties are responsible for the planning and zoning of private land within their boundaries. These decisions may have sweeping impacts on water quality.

During the 2019 Wyoming Legislative Session, $50,000 was set aside for each county to update or create a Natural Resource Plan for the county. The counties must apply for the funding, but it is available for them to take advantage of. These Resource Plans outline the goals and priorities of the county, and direct how industry will be permitted, developments created, etc. Once again, it is not a requirement, but I strongly encourage you to share your SWP with your county so the water source for your community will be considered as an important natural resource within the county.

While I don’t recommend that you post the specifics of your SWPP on the Town webpage, I do encourage you to reach out to your community. Source Water Protection is voluntary, but if people are educated on how their activities affect their community’s drinking water, they are more likely to modify their behavior. Take school children on tours of your wells or treatment facilities, speak at local rotary clubs or senior centers. Partner with scouting groups to clean up the local creek. If protecting water quality remains at the table for conversation, it will be easier to protect our drinking water sources and keep “Quality on Tap!”

Secondary Biological Treatment (Part 1)Trickling Filters

IntroductionA secondary treatment plant contains primary treatment followed by biological treatment. Secondary treatment plants incorporate microbiology to further reduce organic waste and develops a sludge that can be easily settled. There are many types of secondary biological treatment plants with many different types of configurations including trickling filters, rotating biological contactors, activated sludge, and lagoons. In this first part of secondary biological treatment, we will discuss the trickling filter.

EquipmentA trickling filter is an aerobic secondary treatment process that utilizes a fixed film media to grow an aerobic biological slime that is used to treat the wastewater. The heart of the trickling filter is of course its media. The media can be made of relatively large river rock, crushed stone, or synthetic media which are placed over a concrete collection system. A rock media system is typically less than 10 feet deep while other medias are usually more than 20 feet.

The configuration of the media can either be in a pile on the collection system which serves to collect treated wastewater and allows air to circulate through the filter media, or the media is contained in a concrete tank and wastewater is applied to the media bed through an orifice placed on either fixed piping or on a rotating distributor arm.

Besides the typical influent and effluent piping, the trickling filter is also commonly equipped with a recirculation pumping and piping system where some or all of the effluent water is pumped back to the influent of the filter. This system is designed this way for two reasons. First, to maintain a constant flow over the filter media and second, to improve removal efficiency.

Operation TheoryThe purpose of the trickling filter is to remove nonsettleable suspended solids and dissolved organic matter from settled sewage. This is accomplished by a biological slime growth on the filter media. Aerobic biological activity reduces the organics in the raw wastewater to produce settleable sludge.Organisms such as bacteria, protozoa, fungi and algae, attach themselves to the available surface area of the media and become what is known as the zoogleal film. These organisms require at least two essential elements for life, that is food and oxygen. The food supply comes from the wastewater

which is distributed on the media surface and is allowed to trickle through the voids, passing over the zoogleal film on the media where they can eat as much as they desire.

Oxygen is supplied in the form of air which may pass either upward or downward through the filter depending on the difference in temperature of the wastewater and the surrounding air. As wastewater trickles over the organisms growing in the film, some of the organic matter in the wastewater is converted by the organisms to energy and some produce new organisms, carbon dioxide, water and mineral solids. As the organisms grow, they produce more slime, and eventually the slime becomes too thick where it sloughs off and is carried in the stream to the final settling basin.

Filter ClassificationTrickling filters are classified according to the applied hydraulic and organic. Hydraulic loading is the total volume of sewage including the recirculation that is applied to the trickling filter per day per square foot or filter surface area. It is expressed as gallons per day per square foot (gpd/ft2).

A trickling filter 80 feet in diameter treats a primary effluent flow of 1.8 MGD. If the recirculated flow is 0.3 MGD, what is the hydraulic loading on the trickling filter?

1.8 MGD + 0.3 Recirc = 2.1 MGD

2.1 MGD x 1,000,000 gal/MG = 2,100,000 gallons

HLR = Flow, gpd Area, ft2

HLR = 2,100,000 gpd (0.785)(80ft)(80ft)

HLR = 418gpd/ft2

The organic loading is the pounds of BOD per 1000 ft3 of filter media volume.

A trickling filter 70 feet in diameter with a media depth of 5 feet receives a flow of 1,150,000 gpd. If the BOD

concentration of the primary effluent is 230 mg/L, what is the organic loading on the trickling filter?

1,150,000 gal = 1.15 MGD 1,000,000 gal

(0.785)(70 ft)(70 ft)(5 ft) =19233 ft3

OLR = BOD, lbs/day Vol, 1000 ft3

OLR = (1.15 MGD)(8.34 lbs/gal)(230 mg/L) 19.233 1000 ft3

OLR = 46 lbs BOD/day 1000 ft3

Trickling filters are grouped into two classifications; standard or low rate and high filters. The standard filter loading rate is designed for 25 gpd/ft2 to 100 gpd/ft2 with a BOD loading between 5 to 25 pounds BOD/1000 ft3. In comparison, the high rate filter is designed for flows between 200 gpd/ft2 and 1,000 gpd/ft2 and a loading between 25 and 300 pounds BOD/1000 ft3. In standard rate trickling filters, the biological oxidation is accomplished in one pass of the wastewater through the filter. With the higher loadings of the high-rate filter, it is usually necessary to recirculate filter effluent to the incoming wastewater from one to three additional passes through the filter.

Process ControlProcess control on trickling filters is very limited. The fact is, the only control is the quantity of recirculation. It is also best when the trickling filter flow remains relatively constant from day to day. Recirculation rates are varied to assure the flow changes very little between wet weather conditions and dry weather conditions.

As stated earlier, the operator has control of only the recirculation on a trickling filter. Recirculation accomplishes two things. First, it will increase the efficiency of removal through the filter. Second, it helps to reduce the thickness of the zoogleal film. If this film becomes too thick, it can plug the filter media.

Operational ProblemsThere are four common operational problems associated with the trickling filter.

• Organic Loading (Reduction of Treatment Efficiency)

• Air Temperature• Odor• Filter Flies

Organic LoadingThe average BOD removal efficiency of a single stage filter plant is about 85%. To achieve an effluent BOD of 30 mg/L, the raw wastewater must be essentially domestic in source that does not exceed a BOD greater than 200 mg/L. When municipal wastewater exceeds an organic loading greater than 200 mg/L, the final effluent quality is likely to deteriorate and the filter may produce offensive odors.

TemperatureIn northern climates, the temperature of air and wastewater passing through the filter may be considerably lower in the winter and may adversely influence BOD removal. Covers can be placed over trickling filters to help maintain seasonal variations in effluent quality. Another factor to consider with cold weather, the more that you recirculate, the colder the water temperature. So as previously stated, recirculation is the only control. This control is extremely limited under cold conditions.

OdorThe microbial zone immediately adjacent to the surface of the media is anaerobic and highly capable of producing offensive odors. If the voids in the media become filled with excessive biological growth, foul odors will emit during the spring and fall when air temperature reduce natural air circulation through the bed. The filters may also become partially plugged which can result in ponding of water on the media surface. Aeration has greatly improved through the media with the use of newer synthetic filter media. This has resulted in an enormous reduction of odor.

Filter FliesPsychoda, or simply referred to as filter flies are a nuisance in warm weather around trickling filters. They breed in sheltered zones of the media and on the inside surface of the retaining walls. Wind can carry these flies a long distance, but in the general vicinity of the filters, they are extremely irritating to the operating personnel. To combat the situation, periodic spraying of the periphial area and wall of the filters with a chlorine helps to disrupt their hatching cycle.

Value AddedThat’s what you get when you become a Certified Utility Manager. There are only seven in the state of Wyoming and I want you to become number 8 or 9 or …. et al. Becoming a Certified Utility Manager not only adds value to yourself, but it is good for your system, the state, and the profession as a whole.

The course was developed by the National Rural Water Association to enhance the financial, managerial, and technical effectiveness of water and wastewater utility staff throughout the country.

The course is based on national rather than local standards. Unlike state certifications, the National Utility Management Certification establishes a relevant threshold for managerial effectiveness for all 50 states. Certified Utility Managers have a thorough knowledge of the federal standards that serve as the framework for all state agency regulations.

Here is another happening. I just returned from a workgroup meeting on Tribal Utility Management Certification. There is now a test available especially for those that work with tribal utilities, including members of tribal councils and boards.

Board members and Councils often express an interest in learning more about how to manage the utility they own and are responsible for operating. Here is your chance. For more information about the Tribal Utility Management Certification, please contact Brian Bennon with the Inter-Tribal Council of Arizona. It is very possible there will be reciprocity with this certification in the future.

The Utility Management Certification is all about capacity development. It increases understanding of the financial, managerial, and technical aspects of utility management and how these must function in unison.

Because the Certification focuses on all three legs of the capacity stool, it is a great class for operators, managers, and decision-makers alike. There is no one that could not benefit from taking this class and becoming certified.

It enhances the professionalism of our systems and gives us the ability to improve and further protect human health and the environment, and that is the bottom line for doing what we do.

To pass your Utility Management Certification test, a knowledge of Financial Capacity is necessary. This includes specifically knowing about appropriate accounting practices and financial planning to ensure current and future compliance and sustainability. Financial accounting, rate setting and adjustments, budgeting and planning, as well as asset management must be understood and are covered on the exam.

Having taken the test myself, I am guessing this is the area most of us are going to be weakest in. We know that we do not have the financial where-for-all to operate our systems at an optimum level, but we are not sure why. We need to correct this deficiency. As an operator or decision-maker, you may well be in charge of the largest investment in your community. We need to be able to understand the fiscal environment we are working within.

No matter how much money your system may have, if you don’t understand the technical operations of the system, disaster looms. Technical capacity covered in this certification refers to the physical infrastructure of the water or wastewater utility, including, but not limited to, the source water adequacy (treatment, storage, collection, distribution and discharge), and the ability of system personnel to implement the required technical knowledge.

Managers of water and wastewater utilities need to be aware of the technical processes involved in providing water and wastewater services to their customers. This involves understanding the necessary measures required to stay in compliance with federal and state regulations and how managerial decisions can impact water quality and technical capacity.

Last, but not least is managerial capacity. Effective managerial capacity requires leadership, accountability, staffing, organization, and effective internal and external communication.

More so than financial or technical capacity, managerial capacity can be difficult to define and measure. It is far easier to spot insufficient managerial capacity than it is to define appropriate managerial strength. You know it when you see it! This section of the course and exam require that you know the qualities associated with effective utility leadership and ways to improve and develop managerial capacity.

Based on the EPA self-assessment checklist to gauge managerial capacity, the study material emphasizes the following:

• Pride of ownership• Internal and external linkages• Staff training and credentials• Staff understanding of monitoring requirements • Maintenance and Standard Operating Procedures

• Safety• Lines of authority• Rules and Standards• Communication• Regulatory Compliance• Planning for future operational demands• Emergency Response• Planning for success

It is a long list of what you need to know to become a Certified Utility Manager. But remember, knowledge is power, and this is a powerful certification.

To become certified, you begin by filling out an application at the National Rural Water web site. National will score your application based on time of service, education, and experience. Once 100 points is reached on the application, you may pay a $250 fee and take the computer based certification exam.

I highly recommend that you purchase the Utility Management Certification Study Guide. It is also available at the National web site at a cost of $65. In the last few months we have presented two classes on an introduction to Utility Management Certification. More classes will be available in the future. Get the information, study, come to the class, and get certified. Your profession needs you.

If you would like to schedule a Utility Management Certification Class for your area, or simply have questions about the process, give me a call.

Contract Operator Services Between Towns/Districts

The USEPA considers a water system a ‘Community Public Water System’ if there is 15 water connections and/or 25 persons and the water and/or distribution system is cooperatively owned by the users of the system. In Wyoming, there are quite a few of these systems, and most have fewer than 50 connections. Some of these very small systems barely have the required 15 connections, which really puts a financial burden on the little district.

These very small water systems cannot afford a full-time Water Operations Specialist and have to use Contracted Operators. In a few cases, one of the system’s board members had to become certified and take care of the system. Others are able to contract an operator that works full-time for another water system. A growing option is a contract or Memorandum of Understanding between two small towns or districts, particularly with a very small consecutive water system with the town it purchases water from.

I recently assisted a small town in contracting Operational Services for a very small water consecutive water system. Through the process it became apparent that there are necessary items/ issues to be agreed upon up front to protect both entities.

First, is that the very small system is still, and will continue to be recognized as a Public Water System (PWS) by the USEPA and the Wyoming Department of Environmental Quality and will continue to be held legally liable by these government agencies. This means that if any testing they are contracting for is missed or improperly taken, the very small system is still the one that EPA will issue a Notice of Violation, or even worse, possibly a fine.

Since this small system is classified as a consecutive water system, meaning they purchase water from a nearby municipality, they are required to test and report Monthly Total Coliform, Lead and Copper, Disinfection By-Products and create & distribute a yearly Consumer Confidence Report. As for the Wyoming Department of Environmental Quality, the very small system will still be required to remain

in compliance with ALL DEQ regulations. Some of the important issues here are:

1) Wyoming DEQ Chapter 5, the requirements for having Certified Water Operators, an employee of the wholesaler will be listed as the “Responsible Charge Person” and at least one other licensed employee will be listed as “Substitute Responsible Charge Person”. Chapter 5 also regulates what is required by a “Contract Operator”. One of these regulations stipulates how often a “Contract Operator” must visit the site and another part of Chapter 5 states “Owners shall ensure that either the responsible charge operator or the substitute responsible charge operator is capable of being on-site within eight (8) hours and shall initiate the appropriate operational and technical actions within one (1) hour of being notified there is a problem at the facility. Again, even though the small system is paying the larger system for operator duties, the small system is still responsible for regulations being followed.

2) Chapter 12, the requirements for Design & Construction of Public Water systems states any changes or upgrades to the operation of the distribution system will require design review and permitting by DEQ. The very small system is held financially responsible for all of their water system’s maintenance and repairs. For liability protection for both parties, when a system repair (water leak, main line break) is repaired, the town or district supplying

the Operations Specialist is to be notified and a Certified Water Operations Specialist is to be on-site during all repairs to insure proper materials are used and repair techniques are followed, particularly the disinfection of the affected part of system. The repaired section of the system shall pass a Total Coliform test to insure no contamination entered the distribution system during the repair.

Compensation;1) An agreed on monthly amount to cover the costs the town/district will incur for basic services which include the monthly Total Coliform sampling and other periodic sampling (Lead & Copper and Disinfection By-Products) and Wyoming DEQ required “Weekly Inspection of Facility” (Chapter 5). This should cover employee time and vehicle mileage.

2) Agreed to amount for any additional or repeat sampling.

3) Costs for employee and equipment call out for off hours or weekends/holidays.

Any agreement needs to spell out that the ‘Contract’ or ‘Memorandum of Understanding’ does not relieve the very small system of any liability to their ownership of the water system or to any governing state or federal agency.

Since the water/wastewater system supplying the Operation Services will assign its employees to provide Operator Services, they are still required to continue coverage of compensation, including overtime, Worker Compensation and insurance on vehicles and equipment. To this extent, if the employee of one system is on site at the other system, who’s liable for injury, equipment and/or property damage?The agreement also needs to address an “Out” clause that allows either party to opt-out of the agreement by written notification. Most of these types of contracts allow for a 60 to 90 day notification period. The agreement should also include wording of when and how the agreement will be reviewed and updated.

This list is not all inclusive and is meant more to promote discussion between two systems. Remember that your Legal Council is the proper person for preparing a contract/MOU.

WYOWARN is a group of Wyoming water and wastewater utilities that cooperatively prepare for the next natural or man-made disaster by bridging political and jurisdictional boundaries through training, protocols and agreements so that utilities can respond to disasters by sharing personnel, tools and equipment.

Why do we need WYOWARN?Water and wastewater systems provide for public health, sanitation and safety. When water and wastewater systems fail, the well-being of communities quickly deteriorates. Without clean water and ways to remove and treat wastewater, communities become susceptible to disease and illness. The lack of water constrains emergency services such as medical response and fire fighting. In these conditions, people become frustrated and fearful.

Restoring service restores hope and the ability of a community to respond to natural of man-made disasters.Neighboring utilities already have the trained staff familiar with Wyomiing Water Quality Rules and Regulations. They are familiar with western water systems and are already prepared for and accustomed to Wyoming weather. They already have the specialized equipment needed for testing, pumping, or repairs and may have backup supplies of pipe, valves, chemicals, generators, etc., readily available.

While it is already the Wyoming way to lend a hand to our neighbors when they need it, having procedures and responsibilities spelled out ahead of time prepares us for the day when we need it. That is what WYOWARN is about – preparing utilities to help each other in the event of an emergency.

Not a member yet? Join WYOWARN!1. Visit the WYOWARN website at www.WYOWARN.org and click on “Become a WYOWARN member Today!”.2. Download the Wyoming Mutual Aid and Assistance agreement.3. Obtain necessary permissions to sign the Mutual Aid Agreement4. Sign and return the agreement to:

Wyoming Association of Rural Water SystemsPO Box 1750

Glenrock, WY 82637or e-mail a scanned copy to:

markp@warws.com

Good People to do Business With: Our Associate MembersThey Support our Association. Please support them!

2M Company, IncTrevor Hergett 406-245-1490

Advanced Pump & Equipment IncBrad Eberspecher 406-586-1700

Air Diffusion Systems John Hinde 847-782-0044

Ambiente H2OSean Lynch 303-433-0364

American AVKDan Haptonstall 719-661-3333

Barco Municipal Products, IncEd Jukes 402-334-8000

BioLynceusMark Sembach 619-347-5179

Black Mountain Software, IncHeather Neff 800-353-8829

Concrete Stabilization Technologies Roy Mathis 307-322-3990

Core & MainGeorge Whittaker 406-388-5980

Cues IncAvery Wilson 407-849-0190

Curb Box SpecialistSpencer Stone 406-652-5523

Dana Kepner CompanyDan Paulson 800-442-3023

Dawson Infrastructure SolutionsKelly Dawson 303-632-8236

DN TanksKevin Peacock 855-368-2657

Dorsett TechnologiesMary Ann Smith 801-336-6962

DOWL Dayton Alsaker 307-672-9006

DPC IndustriesTony Galyon 303-536-4000

DynaLiner LLCBob Ward 970-948-7401

EJJason Hughes 303-717-1679

Energy LaboratoriesTessa Parke 800-735-4489

Engineering AssociatesDon Livingston 307-587-4911

Ferguson WaterworksDale Christianson 307-233-6395

FUSE IT Pipe and SupplyRingo Dooley 307-299-2892

Garrett Industrial Services, IncMike Garrett 928-237-0910

GettingGreatRates.comCarl Brown 573-619-3411

Great Plains StructuresGuy Pence 651-484-0111

Great West EngineeringChad Hanson 406-281-8585

Hawkins IncRoss Lehner 800-766-3209

HOA Solutions, IncJeff Hohnstein 402-467-3750

Hose SolutionsVanessa Zepeda 480-607-1507

Inberg-Miller EngineersCalvin Twiford 307-856-8136

Industrial Service & SupplyT.G. Bles 888-253-7122

Intermountain Sales, IncJoel Pauling 303-762-1070

isiWESTFrank Henderson 307-460-0125

Jorgensen Associates, P.C.Thomas Kirsten 307-733-5150

JVA, IncJosh McGibbon 303-444-1951

Kleen Pipe, LLCBrian Martinsen 307-349-7655

Larson Data Communications, IncMike Larson Sr 605-996-5642

Local Government Liability PoolMark Pring 888-433-1911

M.C. Schaff & Assoc, IncGlen Lussetto 307-358-0128

M&H Kennedy ValveDarrel Moore 970-697-8175

Maguire Iron, IncRich Kemmis 605-334-9749

Medora CorporationCraig Steve 701-290-1078

Midco Diving & Marine ServicesGreg Lakey 605-791-3030

MISCOwaterScott Perry 303-309-6150

Morrison-Maierle, IncTheresa Gunn 307-570450

Mountainland SupplyJason Faigl 307-371-9991

National Meter & Automation Ryan Fenton 303-339-9100

Neverest EquipmentJim Clarke 720-352-2382

NorMont Equipment CompanyJessie Carr 406-453-4344

North Fork Engineering LLCJon Nelson 307-326-5000

North West Pipe Fittings Paul MacCatherine 406-252-0142

One-Call of WyomingJan Warren 307-343-3435

Pace IncSamantha Colbrese 406-252-5559

Pipestone EquipmentJeremey Peterson 303-947-7220

Pittsburg Tank and Tower Patrick Heltsley 270-826-9000 x228

Premier Power Plants & PumpsTravis Hueller 307-273-9591

Process Specialties, IncErnie Estrada 303-398-0929

Process Technology, IncBuddy Alford 303-550-4255

RepMasters, IncScot Andreano 303-286-7575

Russell Industries IncTristan McKinney 307-265-9566

Santec Corporation, IncEric Ness 303-660-9211

Sargent DrillingGary McCracken 308-872-5125

SCG Enterprises, Inc Roger Shafer 303-697-9404

Sewerin/Leak Locators of MontanaMike Carothers 406-223-2508

SpectrashieldDan Sundvick 303-378-1101

Sunrise Engineering, Inc Mark Davidson 307-775-9500

TDMATom Noel 303-989-7737

Team Lab Chemical CorpTim Swanson 800-522-8326

Timber Line Electric & Control Kim Evezich 303-697-0440

Twin D EnterprisesDave Denny 866-337-9263

USABlueBookJohn Schwartz 800-548-1234

Veris Environmental, LLCMike Scharp 719-775-9870

WenckMark Stacy 970-223-4705

WLC Engineering & SurveyingShane Porter 307-266-2524

WWC EngineeringJessica Dais 307-672-0761

Wyoming Ground Water AssnJade Slaymaker 307-267-3806

Yellowstone WaterworksCavin Noddings 406-633-2316

Small Town OperatorsOperators in the small Towns of Wyoming wear many hats and have major responsibilities. Most of the time, the daily routine includes a list of mundane tasks that are more of a routine to keep the town running.

The grass in the parks need to be manicured, and watered. The occasional summer water leak needs to be attended to. Sprinkler heads need some attention after the summer help runs them over with the lawn mower. (Of course, no one ever does fess up to hitting one.) The flower pots along the streets need never ending TLC to shine as a source of town pride. The occasional stray dog gets on the loose and needs to be herded up, the owners found, and a joyful reunion is most welcome. However, one the most overlooked responsibilities is Safety!

At the end of the day, safety lies at the feet of the operator. Personal responsibility is up to the individual. In small towns, how many times has an operator made bad choices? At the time, the smallest choices we may have made may not even seem like a big deal. Since you may be by yourself, and the job needs to get done, sometimes caution is thrown to the Wyoming wind. That Wyoming attitude of “Get er done” at times, may not be the best practice to follow.

A manhole is backing up, and if the issue is not corrected, the operators will face some nasty complaints from residents. So, they do the job and go down in the manhole to get the sewer flowing again. They may do this alone, since noone else is around to help. The three-person rule of entering a confined space may not be an option in some small towns. Even having a second person to help may be an issue at certain times of the day, or the early hours of the morning. They may fall into the mindset that the manhole is only five, or six feet deep “so what can go wrong”? I can just go down there for a minute, and clear the blockage. I’ll be the rock star for getting the sewer flowing again! Having the proper safety devices like a tri pod, or gas detection devices may not be their priority.

The simple task of replacing a curb stop may also be done alone. Tight spaces along alleys lead to overlooking trench safety rules. Stockpiling the spoils close to the wall of the trench for the sake of convenience comes to mind. Yes, this may save a little time, but is it worth the risk of a cave in? Have the operators even been trained in trenching and shoring? As budgets get tighter, training may take a lesser

priority to other needs of a town. The sad thing is that these are just tasks that come to mind, out of many that happen day-to-day in the Water/ Wastewater industry.

I wish I had a dollar for every time I’ve had a supervisor say “We have been doing it this way for years, and never had a problem”, “ Oh, no one told me it’s unsafe”, “ I didn’t know”, or worse, “ I don’t care – just get the job done”.

Caution is sometimes overlooked, even by our bosses, for the sake of saving money. This is where the personal responsibility of an operator comes into play. If the task at hand is unsafe in your opinion, just don’t do it. I know firsthand that is easier said than done, but at the end of the day, nothing is more important than going home to your loved ones.

The small Town of Opal lost their operator just last month. Schuyler McKnight was not on the job at the time, but while enjoying a much needed day off, suffered a fatal boating accident. Schuyler was just 21 and was off to a great career in the water / wastewater industry. He was a quick study, and was the type of person who was always looking to better himself. He was looking into becoming a Level 2 water operator, just to further his career. That’s just how he was. He always had a smile and worked as hard as he played. He will be sorely missed by the many people who knew him.

I know I sure will miss Schuyler and helping him with the occasional issues he had. It truly was my pleasure to have known him. So, if you’re on the job or enjoying a day off, always pay attention to the small things which may seem mundane, and be safe – Your life may just depend on it.

Operators Corner

Wastewater Questions by Mark Court

1. The Clean Water Act was established in what year?a. 1982b. 1972c. 1962d. 1952

2. In the event of a chlorine leak, where is it recommended that a self-contained breathing apparatus be located?

a. Outside the chlorine roomb. In the operations officec. In your truckd. With the fire department

3. Wastewater treatment plants should be protected against a maximum of a 25-year flood.

a. Trueb. False

4. Determine the percent removal of BOD in the primary clarifier if the influent BOD id 245 mg/L and the effluent BOD is 134 mg/L.

a. 30%b. 35%c. 40%d. 45%

5. Which of the following describes the meaning of F:M?a. This is a measure of free oxygen in aeration

tanks available to microorganismsb. This is a measure of free ammonia available to

microorganismsc. This is a measure of how much food is

available to microorganismsd. This is a measure of free carbon available to

microorganisms

Water Questions by Michelle Christopher

1. Dry barrel hydrants should be completely opened when in use to___.

a. Prevent the hydrant from vibrating and damaging internal componentsb. Ensure the drain valve is completely closedc. Prevent damage to the main due to throttlingd. Ensure the operating screw does not get jammed

2. Manganese greensand filtration is used to remove ___.a. Manganese, arsenic and sulfatesb. Manganese, iron and arsenicc. Manganese, iron and hydrogen sulfided. Manganese, hydrogen sulfide and other sulfates

3. What is the most common scale forming precipitate?a. MgCO3

b. MgCl2c. CaCO3d. CaSO4

4. The ____ can get soil worked up from the bottom, and the _____ can probably bring the curb stop and ______ up with it if the box is pulled from the ground, for example, by a backhoe.

a. Arch pattern box base, Minneapolis-style curb stops and boxes, service lineb. Minneapolis-style curb stops and boxes, arch pattern box base, meterc. Minneapolis-style curb stops and boxes, arch pattern box base, service lined. Arch pattern box base, Minneapolis-style curb stops and boxes, meter

5. How many pounds per day of gaseous chlorine will a disinfection system have to put out if the flow through the plant is 3.7 MGD and the dose is 2.6?

a. 641.85b. 5.86c. 11.87d. 80.23

AnswersWastewater1. B2. A3. False, Wastewater plants should be fully protected against a maximum of a 100-year flood4. D5. C Water1. B 2. C 3. C4. A 5. D lbs/day = Flow, MGD x 8.34 x Dose, mg/L 3.7 x 8.34 x 2.6 = 80.23 lbs/day

NRWA is gathering information across the country to see how many water systems have been affected or have growing concerns about Per- and polyfluoroalkyl substances (PFAS).

What is PFAS?

PFAS are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.

What are the possible health effects?

Studies have shown an association between increased PFOA and PFOS blood levels and an increased risk for several health effects, including effects on the liver and the immune system, high cholesterol, high blood pressure, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and cancer (testicular and kidney).

Where can PFAS be found?

PFAS may be in drinking water, food, indoor dust, some consumer products, and workplaces. Blood serum concentrations of PFASs are higher in workers and individuals living near facilities that use or produce PFASs than for the general population. Pathways of exposure include ingestion of food and water, use of consumer products or inhalation of PFAS-containing particulate matter (e.g., soils and dust) or vapor phase precursors.

What is being done?

On October 10, 2008, the U.S. Environmental Protection Agency (USEPA) announced a negative regulatory determination for perchlorate in accordance with the SDWA, “The Agency determined that a national primary drinking water regulation (NPDWR) for perchlorate would not present a meaningful opportunity for health risk reduction for persons served by public water systems.”

USEPA revised this determination on February 2011 with an affirmative conclusion. “EPA has determined that perchlorate meets SDWA’s criteria for regulating a contaminant -- that is, perchlorate may have an adverse effect on the health of persons; perchlorate is known to occur or there is a substantial likelihood that perchlorate will occur in public

water systems with a frequency and at levels of public health concern; and in the sole judgment of the Administrator, regulation of perchlorate in drinking water systems presents a meaningful opportunity for health risk reduction for persons served by public water systems. Therefore, EPA will initiate the process of proposing a national primary drinking water regulation (NPDWR) for perchlorate.”

Eight years later, USEPA announced a PFAS Action Plan to respond to the public interest and utilized information received. This represents the first time EPA has built a multi-media, multi-program, national communication and research plan to address an emerging environmental challenge like PFAS.

EPA’s Action Plan identifies both short-term solutions for addressing these chemicals and long-term strategies that will help provide the tools and technologies that states, tribes and local communities need to provide clean and safe drinking water to their residents and to address PFAS at the source—including before it gets into the drinking water.

The USEPA Action Plan includes: • Drinking water: EPA is moving forward with

the maximum contaminant level (MCL) process outlined in the Safe Drinking Water Act for PFOA and PFOS—two of the most well-known and prevalent PFAS chemicals. By the end of this year, EPA will propose a regulatory determination, which is the next step in the Safe Drinking Water Act process for establishing an MCL.

• Clean up: EPA has already begun the regulatory development process for listing PFOA and PFOS as hazardous substances and will issue interim groundwater cleanup recommendations for sites contaminated with PFOA and PFOS. This important work will provide additional tools to help states and communities address existing contamination and enhance the ability to hold responsible parties accountable.

• Enforcement: EPA will use available enforcement tools to address PFAS exposure in the environment and assist states in enforcement activities.

• Monitoring: EPA will propose to include PFAS in nationwide drinking water monitoring under the next Unregulated Contaminant Monitoring Program. The agency will also consider PFAS chemicals for listing in the Toxics Release Inventory to help the agency identify where these chemicals are being released.

• Research: EPA will develop new analytical methods so that more PFAS chemicals can be detected in drinking water, in soil, and in groundwater. These efforts will improve our ability to monitor and assess potential risks. EPA’s research efforts also include developing new technologies and treatment options to remove PFAS from drinking water at contaminated sites.

• Risk Communications: EPA will work across the agency—and the federal government—to develop a PFAS risk communication toolbox that includes materials that states, tribes, and local partners can use to effectively communicate with the public.

• Together, these efforts will help EPA and its partners identify and better understand PFAS contaminants generally, clean up current PFAS contamination, prevent future contamination, and effectively communicate risk with the public. To implement the Action Plan, EPA will continue to work in close coordination with multiple entities, including other federal agencies, states, tribes, local governments, water utilities, industry, and the public.

In April 2019, a key component of the Action Plan, a draft interim guidance for addressing groundwater contaminated with perfluorooctanoic acid (PFOA) and/or perfluorooctane sulfonate (PFOS), was released for public review and comment.

A month later, USEPA released the pre-publication version of the proposed perchlorate drinking water regulation. USEPA asked for comments on a proposed Maximum Contaminant Level (MCL) and Maximum Contaminant Level Goal (MCLG) of 56 micrograms per liter. In addition, the Agency is seeking comment on three alternative regulatory options: an MCL and MCLG for perchlorate set at 18 micrograms per liter, an MCL and MCLG for perchlorate set at 90 micrograms per liter, and withdrawal of the Agency’s determination to regulate perchlorate.

The rule denies any opportunity for a small community “variance,” which is a compliance option authorized in the Safe Drinking Water Act that allows a small community that exceeds the MCL at a level that presents no harm to the public to have access to an affordable compliance option. NRWA had asked EPA to clarify the “intelligible principle” used by the Agency in implementing the decision to select perchlorate as a regulation. The proposal does not include any articulated “intelligible principle” for how EPA decided to select perchlorate for regulation. The proposed rule does not explain what principle EPA relied on to determine how to select perchlorate for a SDWA regulation.

What you can do now?

NRWA is bringing together utility systems from across the country that have concerns or have been affected by PFAS contamination. NRWA has set up a page on its website, NRWA.org/initiatives/PFAS, for systems to enter their information. This information will allow NRWA to arrange a free evaluation of the system and provide more details about efforts to recover costs for remediation and treatment from PFAS contamination.

Visit nrwa.org/initiatives/pfas/ to learn more and be a part of future efforts to recoup costs from PFAS contamination.

SIDEBAR

Top 5 facts you should know

1. PFASs are persistent in the environment, meaning they are resistant to typical environmental degradation. Water providers suffer significant operation and maintenance costs because these chemicals never degrade, making it harder to get them out of the water systems.

2. Blood serum concentrations of PFASs are higher in workers and individuals living near facilities that use or produce PFASs than for the general population. Pathways of exposure include ingestion of food and water, use of consumer products or inhalation of PFAS-containing particulate matter (e.g., soils and dust) or vapor phase precursors.

3. Studies have shown an association between increased PFOA and PFOS blood levels and an increased risk for several health effects, including effects on the liver and the immune system, high cholesterol, high blood pressure, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and cancer (testicular and kidney).

4. During manufacturing processes, PFASs are released to the air, water and soil in and around manufacturing facilities. Recently, PFOS and PFOA contamination has also been observed in facilities using PFAS products to manufacture other products (secondary manufacturing facilities).

5. PFAS has been detected in surface water and sediment downstream of production facilities and in wastewater treatment plant effluent, sewage sludge

The objective is to fill in the empty squares so each row, each column, and each 3x3 block contains the numbers 1-9 with no repeats.

WARWSDOKU

40 YEARS, AND WHAT A RIDE!Janet and I married in 1977, and since we had both grown up on farms, we decided to leave the city and begin farming 160 acres on 10 Mile Road near Casper. We began this venture without potable water. Have you ever tried to fill a cistern from a frozen spigot on the water tank?

So I became a board member in 1979 with Pioneer Water and Sewer District, which included us –15 miles from the water source. The board was hoping the system could run itself, so a packet was given to each customer to read their meter/meters, determine usage and cost, and mail in their money! Besides the board members, only ONE customer did their deed. So the board turned to me to become the manager and operator.

After the requirement of passing the certification, I did it all for the next 20 years, from manually reading the meters, monitoring the system, phone calls (sometimes unpleasant ones and at 2 am). We ran the entire system from our home, keeping all records, using my computer, equipment, etc; even using our home phone, which we let Pioneer keep when we left. Big mistake! No personal calls were transferred to us!

Most of our time was volunteered. As the system grew to 170 customers, we suggested getting a read-out system and the president said he’d be driving a pink cadillac before that ever happened.

In 1998, Janet retired from the Natrona County School District, so I suggested (no, I told her I needed a back up operator), so after sufficient studying, she received her certification. It was quite a ride driving over 100 miles to read all the meters during months when not freezing. Janet was beside herself when she opened a pit on a hot summer day and found several water snakes writhing around the cool pipes.

In 2010, we were awarded The President’s Award (they are holding them in the photo) from National Rural Water. We are still in awe of receiving this prestigous award and cannot express our thankfulness enough to the Board and Staff.

Meanwhile, I was a Ground Water Specialist for WARWS April 1994 through October 2000, and ARRA Circuit Rider June through December 2009, which was truly a wonderful ride. And I served on Wyoming Water Development Commission for eight years. My knowledge of small water systems from my days of circuit riding was very helpful at this time.

Because of our thriftiness and additional system development, we were finally able to build an office and garage on Poison

Spider Road, and eventually a water fill station. We were so proud of it, but then it meant leaving home and going to work, so we retired from Pioneer but continued with the small systems of Air Base Acres and Lakeview I&SD.

We continued the ride with small water systems. Janet had to give up the ride in 2012 for health reasons, and as of October 1, 2019, I am finally retiring.

When I turned 80, I tried to update my DEQ file and found I had been aged out by the computer!

We’ve loved working with WARWS – they are the BEST! They are SUPER. It’s been a wonderful ride.

Please welcome the new operators—Jerome and David Scholtz and Bob Meloy.

Information, Motivation and Locomotion;Making Projects Happen

Cost-to-serve Rates? Really?The meeting convened. The city’s rate analyst insisted, “Your water and sewer rates are fair. They are ‘cost-to-serve’ rates.” I just know it hacked him off that he had to say it.

I was not convinced.

I’m the rate analyst for a group of disgruntled homeowners served by the city. Neither the city nor its analyst would show me the data and assumptions the rates were built upon. If I can’t view their data and assumptions and check their math, how can I prove or disprove the “cost-to-serve” claim, much less the “fair” claim?

Warning, I’m going a little wonky now.

The analyst’s rate study report stated that he classified costs at the rate class level, but not at the customer level. That is bad. Then it gets worse. The report also revealed that, in order to even out cash flow, the city had him design rates that would recover 95 percent of its costs from a minimum charge and five percent from unit charges.

Unfair! Unfair! Unfair! And by his own admission, certainly not cost-to-serve at the customer level. Rate fairness happens at the customer level – customers pay bills, rate classes don’t.

Maybe the city’s analyst and I can work it out. I hope so.

You may think, “I don’t need to know about this ‘cost-to-serve’ rates stuff.” But you do. Either you should be calculating cost-to-serve rates, or you need to occasionally hire a rate analyst to do it. If you have an analyst do it, you need to make sure those rates are fair to customers, not just rate classes. Consider this:

• If your utility’s rates are high enough to fully fund the utility’s operations, pay for repair, replacement and capital improvements, and build responsible reserves, you have cost-to-serve rates on a utility-wide basis. Martha Stuart would say, “That’s a good thing.” But it’s not enough.

• If your utility is self-supporting and it does it by recovering the right amount of money from each rate

class (groups of ‘similar’ customers), you have cost-to-serve rates at the rate class level. But they probably still are not fair to customers.

• If your utility is self-supporting and does it by recovering costs proportionately from each customer, now you have cost-to-serve rates where it counts – at the customer level. You are on your way to adequate and fair rates.

Back to the city’s rates, recovering 95 percent of its costs with a minimum charge will definitely even out cash flow. That’s good for the city, but bad for low-volume customers.

Water and sewer utilities do not accrue costs that way. Even water and sewer utilities operating in bad circumstances have variable costs – commodity-related costs – that take up 50 percent or more of the total costs. That means 50 percent or more of the revenue should come from unit charges, not five percent. To price fairly, the rate structure should follow the cost structure. I’ll explain.

In every water-based utility, there are high-volume customers and low-volume customers, “bigs” and “smalls.” When you arbitrarily call 95 percent of costs fixed and recover them with minimum charges, you force a lot of smalls to subsidize the few bigs’. Those rates might be cost-to-serve at the class level, but not at the customer level where fairness counts.

So, let’s imagine you are the most cold-hearted utility manager or board president alive. Fairness means nothing to you. Still, you should not want those 95-percent fixed rates. Why?

Fixed costs are related to the fact that someone is a customer – think billing, general administration.

Variable costs are related to the volume of service received – think electric, treatment chemicals.

Note to those who do rate studies:When you classify costs, don’t stop at the rate class level. Classify to the customer level and calculate rates accordingly. Sure, if the town or district wants tailored rates, tailor the rates. But do it from the level of the customer. That way, everyone can see who the winners and losers will be when the rates stray from the cost-of-service structure.

Do the MathIf the average monthly cost per customer is $30.00, at a generous split of 50 percent for fixed costs and 50 percent for variable costs, the minimum charge would be $15.00 and unit charges would total $15.00. For the “little old lady, widowed, retired, living alone on Social Security,” who uses one-fifth as much water as the average customer, her bill would be $15.00 minimum and $3.00 in unit charges, for a total of $18.00.Switch the cost structure to 95 percent fixed and these are the new splits:Average customer – $28.50 minimum charge and $1.50 in unit charges for a total, again, of $30.00.“Little old lady…” – $28.50 minimum and $0.30 in unit charges for a total of $28.80. Call costs 95 percent fixed and the “little old lady…” is subsidizing high-volume customers by 10-bucks per month. Is that fair?

“Slow-pay” and no-pay” customers are concentrated on the low-volume side of use. When you boost their minimum charge to subsidize high-volume customers, you create more slow-pays and no-pays. That creates an attack for even the coldest heart because now you must chase after more smalls, at big expense, to get small money. That’s bad business.

Who are these “slow-pay, no-pay smalls?” Sure, some have no conscience about stealing from others. That’s not right. Get after them!

But some are the “little old lady, widowed, retired, living alone on Social Security?” Your bad rates kicked her into the slow-pay, no-pay group. She is already cutting her pills in half. Now you are hassling her for fees she can’t pay and really shouldn’t have to pay.

When the local paper runs stories about how the mean old utility manager or president is beating up on little old ladies, game over! You are down the road!

Take it from this rate analyst; cost-to-serve rates at the customer level will get you well on your way to rate structure fairness. Adopt rates that are both adequate and charge people fairly, and a different kind of analyst might ask you this, “And how did that make you feel?”

I hope you could smile and tell them, “Good, real good.”

Carl Brown is President of GettingGreatRates.com, which specializes in rate analysis for water, sewer and other utilities. The firm serves as the RATES Program rate analyst for the Colorado, Kansas, New Mexico, North Dakota, Virginia and Wyoming Rural Water Associations. Contact: (573) 619-3411; Carl1@gettinggreatrates.com

The Association partnered with GettingGreatRates.com to offer rate setting help through the Wyoming RATES Program https://gettinggreatrates.com/consulting/WyRates.pdf. Kathy Weinsaft of the Association helps with basic rate setting. I handle the tough ones. Give Kathy or me a call if you need.

Looky LooThat is what I become in Fall, which is undoubtedly my favorite season. Part of the reason for that is I live in a state like no place else on earth. One of the best ways to see it is by exploring its scenic byways. Nothing compares to a Wyoming road trip. The Rocky Mountains and the High Plains meet right here in Wyoming, resulting in stunning views in every direction. Wyoming has over 20 scenic byways that twist, turn, and climb through some of the state’s most breathtaking landscapes. In alphabetical order here are a few of my favorites.

Battle Pass

This 57-mile paved highway follows Wyoming Highway 70 through Medicine Bow National Forest and over the Sierra Madre Mountain Range. Starting in Encampment, Wyoming, Battle Pass Scenic Byway wanders through a number of ghost towns and passes the field known for the famous 1841 battle between fur trappers and Native Americans.

Bear Tooth Scenic Highway

Bear Tooth Scenic Highway follows US-212 as it winds through Shoshone National Forest. Nearly 39 miles of this

68-mile drive are in Wyoming, with sections crossing into Montana.

Plan to spend about three hours driving this beautiful road and leave plenty of time for stops at numerous trailheads and lookout points along the way. I took my friend and co-worker, Donna Uribe, on this drive one fall day and though she had lived in the state for decades she turned and looked at me and said, “I had no idea Wyoming had something this beautiful.” You haven’t seen Wyoming if you haven’t traveled the Bear Tooth.

Big Horn Scenic Byway

This is my old stomping ground from when I lived in Sheridan. This scenic byway begins in Shell, Wyoming, and travels along US-14 for 58 miles before connecting with Medicine Wheel Passage, which is located just southwest of Dayton, Wyoming. The Byway passes through Bighorn National Forest, past Shell Falls and over Granite Pass, featuring views of vast ranchlands, limestone outcroppings and various mountain peaks along the way. Be sure to make time for stops at scenic overlooks, trails and other enjoyable outdoor areas. The fishing along here is always great and the temperatures are always cooler if you happen to be having a hot fall day that you are trying to escape.

Our Western Heritageby Kathy Weinsaft

Bear Tooth Scenic Highway

Black Hills Scenic Byway

Located in northeast Wyoming, this scenic drive travels through the Black Hills region that spills into South Dakota. The byway begins in Newcastle, Wyoming, and continues for 78 miles toward the South Dakota border, offering a glimpse of the region’s complex geology. Discover the lesser-known Black Hills of Wyoming by stopping to hike, mountain bike, fish, or just get outdoors along the way. You can also explore ghost towns and museums as part of your Black Hills experience. For sure, do not miss hiking around Devils Tower. It was this country’s first National Monument and it was immortalized in Close Encounters of the Third Kind.

Chief Joseph Scenic Byway

Located in northwest Wyoming, this scenic drive begins near Yellowstone National Park’s eastern border and travels southwest through Shoshone National Forest and the Absaroka Mountains. The 47-mile drive along Wyoming Highway 296 boasts prime wildlife viewing and outdoor recreation opportunities to those who stop along the way.

Chief Joseph Scenic Byway was named after the chief of the Nez Perce Tribe, as the region was home to this Native American group before they left in an attempt to flee the U.S. Cavalry. I have traveled this byway at least a 100 times to visit friends of mine in Montana and I never get tired of the views.

Medicine Wheel Passage Scenic Byway

Located in north-central Wyoming, the Medicine Wheel Passage travels along Wyoming Highway 14-A, offering views of the Big Horn Basin and Absaroka Mountains. It was the first Scenic Byway I traveled in this beautiful state and one of the reasons I knew I had to move here from Missouri.

This scenic drive passes Wyoming’s Medicine Wheel Historic Landmark and celebrates the state’s rich Native American history along the way. I try to visit the Medicine Wheel yearly, but the time that it is accessible is pretty short. It usually is open to visitors sometime around the 4th of July and often is still snow packed. If I am traveling west from here, I usually connect the 27-mile drive with Bighorn Scenic Byway to extend my route.

Oregon Trail Scenic Byway

This is a drive I almost always take visitors from back east so they can experience America’s westward migration firsthand on this 57-mile drive through the same region Oregon Trail travelers journeyed over 100 years ago. The Oregon Trail Historic Byway begins east of Guernsey in southeast Wyoming and follows US-26 to the Wyoming-Nebraska border. Stop along the way to see preserved wagon ruts and explore Ft. Laramie National Historic Site. What a cool place and our State Parks have just done a terrific job of preservation and interpretive history.

It is, after all, part of our Western Heritage

Seminoe to Alcova Scenic Backway

The 64-mile Backway in south-central Wyoming starts in Sinclair and travels north to Alcova, although I usually drive it from Alcova to Sinclair. It weaves through prairie, desert and climbs the Seminoe Mountains along the way. Bring a fishing rod and bathing suit, as this road passes several reservoirs, including Pathfinder Reservoir, Seminoe Reservoir and Alcova Reservoir. There are also some kick butt wonderful places for a picnic.

Wind River Scenic Byway

Could any fall be complete without a drive through the canyon? The Wind River Canyon Scenic Byway travels 34 miles along US-20 between Thermopolis and Shoshoni. The drive follows a path through Wind River Canyon that was once used by Native Americans and pioneers before continuing through the Wind River Indian Reservation. You can enjoy fishing or rafting along the Wind River before ending the trip with a hot springs soak in Thermopolis. Don’t forget to visit the Dinosaurs while you are there.

There you have just a few of the beautiful drives available to you this fall. Plan a drive along these Wyoming roads to immerse yourself in wild beauty and history.

Scrawny Girl’s Elixir of Lifeby Michelle Christopher

Growing up, I was told that coffee would stunt my growth. Then I realized that I was going to remain short, regardless of coffee consumption. This was about the same time I met John, who became my husband. He grew up in a family that knew the real story on coffee – it is the elixir of life.

Early morning? Coffee. Late night? Coffee. Chilly afternoon? Coffee. Ran out of syrup mid-camping trip? Boil down the coffee and add brown sugar. So, shortly after we began dating, I headed off to college in an 84 Ford pickup, the front seat full of books, a hoya plant, and a 4-cup coffee maker with freshly ground beans – John’s good luck gift. (Yes, this was before Keurig, yes, I’m old, and Keurig will be the demise of polite society – if not merely the landfills!)

College is where I learned about the magic of the arabica bean. That tiny coffee pot got me through many late nights, furiously tapping away in the computer lab, early morning welding classes and driving across the state of Wyoming through ever-present snowstorms after a long weekend.

After we married, I learned a better way to make coffee – the percolator. Our percolator has survived 20 years, four moves across Wyoming, and countless camping trips. It still proudly sits on my stove, waiting to be called into action. Percolator coffee is an art form I learned from my husband’s grandfather while hunting elk. His technique was to fill pot with water, add grounds to the basket and set the perc on the back of the wood stove, where it would slowly perc all day, and all night. Grounds and water were added on an as needed basis, probably in that order. By the end of the week, the proverbial horseshoe would not only float, but dance a jig atop the densely caffeinated brew.

While backpacking, we lower the bar for coffee, using the tea-bag variety, because they are light weight, and I don’t feel bad tossing the used bag in the fire. Before coffee bags were a thing, we used a mesh tea-ball, and flipped a coin for who had to drink the dregs. We once met a hiker who carried a French press, but it seems like more weight and bulk than I want to carry. Regardless of weight, however, I have not, nor will I ever lower myself to drink the instant powdered swill masquerading as instant coffee.

When we are truck camping, hunting or enjoying a slow start to the weekend, we relish the ritual of coffee. The smell and taste evoke fond memories of grandparents, friends, wild adventures and conversations around campfires past.

Camp Coffee (for a 12-cup perc, so it will probably serve 2):Start campfire and set up the grate for the coffee pot. Ideally, the grate should be placed where you can access the handle easily without singeing the hair off your knuckles or hope that your significant other remembered to pack the welding gloves. There should be flames directly beneath the percolator though, or it may be a very long time before you get any coffee!

Fill percolator with water, slightly below the height of the perc basket. I know everyone says to use cold water. However, they are assuming you have access to hot tap water out of a faucet. Hot water from a tap has sat in the water heater, so it may take on taste or odor issues depending on the last time the water heater was flushed. But, if you’re camping, just fill the pot with water – it’s probably cold anyway.

If you have the grounds basket, add 1/3-1/2 cup coffee grounds. I am a fan of medium-dark roast coffee. Mild coffee is too acidic, and French roast tastes burnt. I’ve actually been known to re-roast coffee beans in my cast iron skillet to get the appropriate color. Throw the beans in a dry skillet over medium heat, stir until they crack, and continue stirring until they are the color you’re looking for – I have a swatch I use to color test. Once the beans are the appropriate color,

Self portrait

grind them coarsely. The holes in the perc basket generally allow some grounds to pass, even at the coarsest grind, so you could buy the fancy percolator filters, or just stick a plain coffee filter in the basket. Or not. Depends if you enjoy chewing grounds! Place percolator on the grate, and watch. When the coffee is the desired color, remove from heat, and allow the grounds basket to finish draining before you pour the first cup.

Some purists believe the only way to make camp coffee is cowboy style. Cowboy coffee is perc coffee without the grounds basket. Fill the pot with water, add coffee, boil to your desired color. When the coffee is the right color, remove from the heat, and add a tiny bit of cold water. The coffee will stop boiling, and the grounds will settle to the bottom.

Enjoy what remains of summer and fall in the wilds of Wyoming!

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