Operations at Ohio Public Water Systems during COVID-19 Pandemic
Conditions may change as this situation evolves. Ohio EPA will continue to monitor the state and federal orders and will adjust our response and direction accordingly. Every effort should be made to comply with all requirements. Ohio EPA will work with systems as this situation progresses and may utilize enforcement discretion during the State of Emergency. Appropriate documentation is necessary.
The operation of public water systems by trained operators to ensure Ohioans are provided with safe drinking water is a critical public health-related responsibility. Certified operators are public health officials and should be performing their civic duty to protect public health and safety during this declared emergency. Professionals need to make sure safe drinking water is being produced and delivered to customers and sewage is being treated. Ohio EPA expects public water and wastewater systems to do their best to provide appropriate staffing for their facilities.
Recommendations for certified operators and systems:
- Have backup staff identified in the event personnel become sick.
- Perform solo visits. Practice social distancing.
- Stagger visits – visit systems in times when other individuals are not present (outside normal working hours for non-community systems)
- Have contingencies in place (appropriately certified professional backups, certified professional operators, personnel knowledgeable of the system)
- Disinfecting common surfaces before and after shift changes
Please note public water systems that are not producing water are not required to have staffing or daily visits. Wastewater systems that are not discharging have provisions that can be implemented that will greatly reduce any visit requirements.
The production and delivery of public water by community water systems is a priority. In case the tools above cannot be used, contact your Ohio EPA District representative as soon as possible and Ohio EPA will work through the situation with you. In the event all of the measures fail and public water and wastewater systems are unable to meet their requirements the Ohio EPA may use enforcement discretion in dealing with these situations.
Ohio Public Water System Operator Guidance
We are all aware that providing safe drinking water is an essential public health service. We appreciate the efforts being taken by all public water systems across the state to ensure Ohioans have continued access to safe drinking water, particularly during the COVID-19 state of emergency. We will continue to face challenges during this time and will work together to ensure systems are capable of providing service to meet this important public health responsibility.
At this time, Ohio EPA is not considering approval for reducing minimum staffing requirements. We have sent a blast email to all systems and operators of record to review their contingency plans and ensure they have adequately addressed absence of an operator. We are encouraging systems to make arrangements with neighboring utilities, professional organizations, become members of Ohio WARN, or have discussions with contract operators to provide backup operators as necessary. Ohio EPA urges systems to isolate healthy staff at their facility and take any other actions that ensure the protection of public health by providing safe drinking water.
Larger systems should consider sheltering healthy operators on site at the utility, creating operating teams and staggered shifts that minimize contact between other personnel.
Provisions in the rules allow Class 2, 3, and 4 systems to be operated for up to 30 consecutive days by an operator with one classification less than the plant. Systems that have operators that meet these parameters have the flexibility to stagger as appropriate to ensure the safety of all of their operators.
In the event a system enacts their contingency plan due to illness of their operator of record or backups, contact their your local Ohio EPA representative via email.
Ohio EPA will continue working closely with systems and will continue evaluating areas of regulatory flexibility, where possible, to assist entities in alternative approaches to maintaining compliance, such as extending reporting deadlines and exercising enforcement discretion. In situations where regulatory alternatives are authorized by Ohio EPA, water systems need to document the measures taken to ensure appropriate oversight of the water system.
We recommend people routinely check this web page for updates and new information. Ohio EPA is committed to working closely with all of you to ensure safe drinking water for Ohioans.
Designating Essential Employees and Service Provider
Ohio EPA has received questions regarding essential employees and suppliers/contractors that may be vital to ensuring water and wastewater facilities continue operating during periods of emergency.
Ohio EPA would provide the following guidance:
Municipal systems (village, county and city) should have a process in place to designate essential employees and provide credentials identifying them.
Utilities should review their contingency plans and identify material suppliers, labs, contract operators, etc. that are essential to ensuring the continuing operation of water and wastewater facilities. Once identified, utilities should reach out to those suppliers and ask them to join the Ohio Public Private Partnership(OP3) by going to the following weblink : https://homelandsecurity.ohio.gov/op3.stm and clicking the link to join the partnership. The location is demonstrated in the screenshot below.
In the event of an emergency declaration that limits travel, membership in the partnership will give the suppliers, labs, certified operators, etc., the ability to request approval and credentials as essential to the treatment of water or wastewater. These credentials will allow them to continue to provide the services necessary to keep water and wastewater facilities functioning.
Private utilities, contract operators and Water and Sewer Districts should take the same steps outlined above for joining OPP3.
During the State of Emergency, Ohio EPA may use our enforcement discretion, but will continue to ensure safe public water is being produced and delivered to customers in Ohio. This is a matter of public health and Ohio EPA will work with the Administration to ensure these public health officials can perform their civic duty.
- Every effort should be made to have the Operator in Responsible Charge (ORC) perform visits. If circumstances arise that require another approach, please contact your district office representative by email for other accommodations.
- Have backups, stagger visits and do visits solo – avoid social interaction.
- Be sure to document operational changes and communicate significant changes to your Ohio EPA representative.
- Water systems may cease reporting minimum staffing times on their Monthly Operating Reports (MORs), but must continue to maintain log books on site.
- If the system is closed and not producing water, you do not need to visit. Just note the facility is closed.
Required Public Water System Monitoring
Public Water Systems are required to conduct routine compliance monitoring at the water treatment plant and in the distribution system. As of today, U.S. EPA has not provided any relief on federal requirements; however, Ohio EPA is considering the potential COVID-19 exposure risk to homeowners and water plant personnel, and is offering the following recommendations and options for flexibility.
4-3-2020: For systems that are completely closed for the entire monitoring period, contact your district representative. Water samples for systems that are completely closed for the monitoring period will not be required. However, prior to re-opening and serving water to the public, a routine total coliform sample must be collected with negative results.
Disinfection By-Products (DBP)
DBPs – Most systems are scheduled for the first 2 weeks of a month during each quarter, so the number of systems that have not sampled in the 1st quarter of 2020 due to COVID-19 concerns is hopefully small; however, distribution crews should focus on emergencies, line breaks, maintaining chlorine residuals, and Total Coliform sampling.
- Public water systems can utilize alternative sampling locations, such as sampling at locations close to the usual sample locations that are accessible, at hydrants, pump stations or tanks. Please contact your district office representative via email and Ohio EPA will work with you on a temporarily revised sampling plan.
Lead and Copper (PbCu)
- Special purpose monitoring for main breaks. Public water systems can offer filters to address lead and copper concerns during main replacements/breaks/disruptions and will not be required to take special purpose lead and copper samples so long as filters are offered.
- Routine PbCu monitoring. Systems have until June 30 to complete six-month monitoring period sampling, so sample collection could be delayed until closer to the end of the monitoring period. If you do collect a sample and the lab provides you with the results, then consumer notice would be required. A total of 92 systems are required to report during this period.
- Routine water quality parameter monitoring. Sampling at a hydrant nearest to the normal sampling point would be acceptable. Contact your District Office via email if there are any changes.
Bacteria and Chlorine Residual
Public water systems can temporarily modify sample siting plans to minimize contact with the public. Notify your district representative via email of these changes. Chlorine residual monitoring can be collected at a hydrant, pump stations and elevated and ground level tanks; however, these locations should not be primary alternative selections to routine monitoring locations. Hydrants could produce false positive bacteria results that public water systems would need to address. As always, when sampling for coliform bacteria, public water systems must collect chlorine residuals.
Distribution fluoride monitoring may be suspended but must continue at the entry point to distribution.
Manganese Monitoring in Surface Water System
Ground Water systems with Iron and Manganese removal should continue to monitor for iron and manganese. Surface water systems not feeding permanganate and with historical results below the secondary MCL of 0.05 mg/L may cease weekly manganese sampling. Please contact your district office representative via email to verify your ability to cease sampling.
Harmful Algal Bloom Monitoring
Ohio EPA is evaluating potential monitoring flexibility under OAC 3745-90-03
Reporting related to MCL, HAL or ALE exceedances and surface water monthly operating reports (MORs) should meet current requirements. However, Ohio EPA will be flexible with other reporting requirements and non-surface water MORs may be submitted by the end of the month if results are within acceptable ranges.
Conditions may change as this situation evolves. Ohio EPA will continue to monitor the situation and will adjust our response and direction accordingly.