2021 - Issue 1 by Texas Rural Water Association

Steps to Getting the Lead Out of the Water

Also Inside: Inside: Safe Entry and Access to Water Tanks Water University— University— Promoting Professional Growth

2021 — Issue 1 www.trwa.org

TRWA Today Established in 1969, the Texas Rural Water Association (TRWA) is a statewide nonprofit trade association with an active membership consisting of over 750 nonprofit water supply corporations, water districts, small-town water departments and investor-owned utilities. In addition, more than 200 water industry suppliers participate in TRWA activities as associate members. TRWA members provide water and wastewater service to 3 million customers throughout Texas. TRWA is dedicated to helping directors, managers, operators and office professionals provide efficient service and clean, safe drinking water to their customers. Through on-site technical assistance, education and information exchange, TRWA helps its members better meet their needs as well as the needs of their customers.

Board of Directors

TRWA Staff

Officers

President Chris Boyd Denton (District 3) Vice-President Bruce Alexander Medina (District 2) Secretary Kevin Spence Franklin (District 11) Treasurer Robert Nettles Walker (District 13) Immediate Past President Brian Macmanus Cameron (District 6)

District Directors Mark Gardenhire Shackelford (District 1) Steve Adams Brown (District 4) Dave McMurry Bastrop (District 5) Johnny Rudisill Collin (District 7) Charles Beseda Hill (District 8) Pat Allen Guadalupe (District 9) Kent Watson Brazos (District 10) Shirley Thompson Kaufman (District 12) Bill Baird Rusk (District 14)

Leadership Team Lara Zent Allison Kaminsky Larry Bell Nichol Howell Tom Shephard, CPA Trent Hightower Jason Knobloch

Executive Director & General Counsel Deputy Executive Director Technical Assistance Director Professional Development & Training Director Finance Director Assistant General Counsel Environmental Services Director

ext. 101 ext. 107 cell: 512-964-8133 ext. 134 ext. 102 ext. 106 ext. 137

Amanda Ashcraft Melody Bennett Ross Brookbank Pam Cantrell Lisa Gallo Angela Harris Miles Hartman Brittney Melancon Scott McClure Emily Young Ariane Walker

Office Manager Project Support Specialist Membership and Outreach Manager Accounting Support Specialist Meeting and Event Planner Project Support Specialist Course Development Specialist Paralegal Communications Specialist Assistant Environmental Services Director Training Support Specialist

ext. 100 ext. 130 ext. 108 ext. 139 ext. 105 ext. 131 est. 135 ext. 110 ext. 115 ext. 132 ext. 111

Thomas Acker, Jr. Michael Beadnell Nathan Cantrell Alex Eaves Roel Gonzalez Paul King Deborah McMullan Charles Perkins Bruce Pearson James Smith Quentin Turner William White Scott Willeford Gilbert Ybarbo

Instructor Circuit Rider Wastewater Technician Wastewater Technician FMT Specialist Circuit Rider Source Water Protection Specialist Circuit Rider Instructor Circuit Rider FMT Specialist Assistant Technical Assistance Director FMT Specialist FMT Specialist

Office Staff

Field Staff

cell: (512) 751-6337 cell: (512) 924-4552 cell: (512) 924-7158 cell: (512) 964-7203 cell: (512) 923-5812 cell: (512) 913-9753 cell: (512) 923-5842 cell: (512) 964-2108 cell: (512) 922-4942 cell: (512) 964-9234 cell: (512) 517-9889 cell: (512) 924-4233 cell: (512) 657-8813 cell: (512) 317-2003

Contact the Editor

Editorial and advertising inquiries may be directed to the Communications Department at editor@trwa.org. Join the conversation at: www.facebook.com/TexasRuralWaterAssn 2

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Find us at @TexasRuralWater for industry and legislative news relevant to you!

Table of Contents 10 20

Inside TRWA Letter from the President

Technical Corner: Getting the Lead Out

Letter from the Executive Director

Jason Knobloch outlines the steps that are needed to protect children, schools and communities from lead in the water.

Ask Larry

Answers to your technical questions

Source Water Protection at State Parks

Deborah McMullan along with the TCEQ discuss ways to keep groundwater safe from contaminants.

Water University: Supporting Industry Managers

From the Hole: Tales from the Road

Assuring Safe Entry and Access to a water storage Tank

Keep it Legal Answers to your legal questions

Advertiser Index

4 5 6 16 30

Bruce Pearson takes readers through the NRWA program which supports and promotes professional growth.

Michael Beadnell explores the water systems of El Paso

Erin Schmitt of Pittsburg Tank & Tower Group examines the necessary entry and exit points for safety.

TRWA Briefs

Article Update, Emerging Leaders Program Nominations, TRWA Elections, Update Your Quench Subscription, Welcome TRWA Staff

On the Cover: Double rainbow over water tower, Temple, TX., Jason Knobloch, TRWA.

Plan Ahead CALENDAR CONFERENCES:

IN-PERSON LEARNING:

March 25 - 26, 2021 RuralWaterCon 2021, Renaissance Austin

June 3 - 4, 2021 Office Professionals 2021 Marriott Plaza, San Antonio July 15 - 16, 2021 Training and Technical Conference 2021 San Luis, Galveston

March 16 - 18, 2021 Basic Water Works Operations Mt. Calm Library | 222 Allyn Ave Mt. Calm, Texas 76673

March 23 - 25 Wastewater Treatment Fire Station | 111 E Mason St Mabank, Texas 75147

OPERATOR TRAINING COURSES: Learn more about our upcoming classroom and online training options at www.trwa.org/training Quench — 2021 Issue 1 3

President’s Message Texas Rural Water, Happy New Year everyone, and let’s hope 2021 is a better year for us all! I pray everyone has a safe, healthy and more productive outcome this year.

“The staff and Board have been closely watching COVID-19 trends, along with city, state and Federal recommendations as we move forward in 2021.”

Since the Texas legislature is in full swing right now, our TRWA staff, lobbyists and Board are busy working to analyze, critique, support, defend and oppose any bills or policy actions which may be introduced could affect our members. Please stay alert for communication from staff regarding any pertinent legislation and also any requests for member assistance. One of the best ways to support TRWA is with your contribution to the Texas Rural Water Political Action Committee (PAC). Every year we identify and financially support representatives and senators who may likely have an impact on favorable legislation to our members. One hundred percent of your PAC contributions go directly to these legislators, and the more we are able to contribute, the better our impact on them. Please consider contributing to the PAC — it’s extremely important. The Board of Directors recently made the determination to return to our in-person conference schedule. There’s no doubt that we all gain so much more by being able to interact, learn and have fellowship in-person at our conferences. The staff and Board have been closely watching COVID-19 trends, along with city, state and Federal recommendations as we move forward in 2021. We will be taking the necessary precautions, including enforcing social distancing and face covering policies, at our Convention later this month. With immunizations rolling out, hopefully we’ll be able to get back to some normalcy fairly soon. Until then, stay safe, and may God richly bless each of you this year! My regards,

Chris Boyd President Texas Rural Water Association

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Letter from the Executive Director Dear TRWA Members, You are often the unsung heroes, providing safe, clean drinking water to ensure the public health of your communities despite any obstacles thrown your way. We are proud to tell your stories and represent your interests! As a member of TRWA, you also benefit from being part of a national network of rural water systems through our National Rural Water Association. While we’re working hard to ensure your interests are represented at the Texas Legislature, the NRWA lobby team is working hard to advocate for Rural Water in our Nation’s Capital. Every February, TRWA joins their efforts for the Rural Water Rally, where we meet with each member of Texas’ congressional delegation to ask for their support for NRWA’s funding priorities. This includes programs you rely on including our circuit riders, wastewater technical assistance providers, source water protection program, energy efficiency program and EPA training program; as well as the funding programs through United States Department of Agriculture-Rural Development (USDA-RD) and the State Revolving Loan programs through Texas Water Development Board. This year at our virtual meetings, we also requested support on a couple of pieces of federal legislation that would provide grant and low- or zero-interest funding options through USDA-RD for rural water systems recovering from emergency situations like we experienced with the recent winter storms, but also pandemic-related issues or other natural disasters. We will keep you updated as these measures make their way through Congress. I would like to highlight a couple of programs that are featured in this issue of Quench. One is our Emerging Leaders Program. This year we’re launching our third class. This Program recruits, trains and grows the future leaders of our industry. I will be presenting about the Program along with three of our graduates as part of the virtual track at this year’s Convention.

“As a member of TRWA, you also benefit from being part of a national network of rural water systems through our National Rural Water Association.”

Another program I would like to mention is our consumer magazine, which we are relaunching as an inexpensive digital offering. We are excited about the number of members who have already signed up to participate! This is a great tool for providing public outreach to your customers and educate them about our industry. Please contact us if you would like to see a copy of this top-notch publication. Thank you for your hard work and resiliency in serving water to your communities! My best,

Lara Zent Executive Director and General Counsel Texas Rural Water Association Quench — 2021 Issue 1 5

Ask Larry

A Q&A column with TRWA Technical Assistance Director Larry Bell

We have some meter boxes that do not have a meter as they were either pulled for non-payment or the owner requested them to be removed. Our engineer says we need to remove these, as we would be responsible for servicing them, including paying for upgrades, if a customer wants a meter for that box in the future. What should we do with these boxes?

This is an issue we’ve been talking to TCEQ about as far back as 2004. The closest thing we have to a bottom line here is that a system can remove the meter, but they still need to maintain capacity at that same location in case a future applicant wants to re-install another water meter there. Back in 2004, TRWA staff met with TCEQ to discuss several issues relating to their capacity regulations and interpretations. During these discussions, we talked about vacant and dormant taps to see how the agency would rule on a cost of service appeal if the system were to remove these dead taps to free up system capacity for other applicants along that water main. TCEQ staff at the time said it would be ok for a system to remove dormant or vacant taps even down to the water main, but the system could not assess any future applicant a new front-end contribution or equity buy-in fee, equipment costs to replace the assets being removed and possibly another membership fee if the system used non-refundable membership fees at those locations where these taps had been removed. They summarized that because there had been a meter at that location, the new applicant should not be responsible to pay for upgrades to the water mains because of new customers being added at other locations along that same water main. These previously existing meter locations had already paid for or 6

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been granted capacity from the water main, and therefore they should not be required to pay for system upgrades. One note here about “equipment costs to replace the assets being removed” — TCEQ explained this to include the price of a meter, tapping saddle, curb stops, meter box, service tubing and any parts which were purchased by the original applicant when the service was first installed. These items became “assets” and therefore had to be maintained and upgraded at the expense of the water system. Only the labor to reinstall the meter, a new customer service inspection fee, the BPAT test if there was a backflow assembly there before, and the refundable membership fees could be charged to the new applicant at that previously served location. Some engineers and systems took this to mean that if we remove the meters at these dormant locations, the system would not have to charge future new customers the price for upgrading their old water mains until the freed-up capacity was allocated to new active connections. The systems and engineers said that if these old dormant tap locations wanted to be re-serviced and if upgrades were required, the present landowners where service had previously existed would have to pay for those upgrades. These cost-of-service issues have subsequently been transferred to the Public Utility Commission of Texas (PUCT), which has been very pro-consumer when addressing complaints. I am not aware of any cost of service appeals dealing with this issue specifically, but systems should be aware that the PUCT might side with the customer if someone complains about being charged new fees to obtain service at a location where service previously existed.

Further, in the past we have seen many TCEQ investigators count dead taps into the system’s overall capacity requirements using the assumption that at any time in the future the system would still be responsible for supplying not only the active connections but previously existing connections also. There is nothing in TCEQ’s Chapter 290 regulations which addresses the above scenario dealing with pre-existing taps that have been removed. However, TCEQ’s 2019 guidance on determining the number of connections served by public water systems defines “active connection” to include any connection that has the capacity to receive water, even if there is no customer currently receiving water service there. Therefore, removing the meter box completely could allow the utility to reduce its total number of connections for purposes of determining the system’s necessary capacity.

Our tariff states that all line extensions and new line installation projects must go through

our normal engineering review process. Some of these projects are relatively simple, but the engineering costs can still be quite high. Can we establish a more cost-effective process for these projects? If so, how should we go about that? Does it make sense to set a minimum cost threshold for a full engineering review?

A: The simple answer is yes, you can assess

projects on an individual basis to determine the extent to which a nonstandard service request such as this will require a comprehensive engineering review. The TRWA Sample Tariff’s section on developer, subdivision and nonstandard service requirements states that “the Board of Directors of the Corporation or their designee shall interpret on an individual basis whether or not the Applicant’s service request shall be subject to all or part of the conditions of this Section.” To keep these applicants’ costs down, a good many WSCs include in their normal or standard Continued on next page

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meter application process the requirement that the applicant pay for an engineering assessment when a meter is to be installed on an existing water main. This ensures - the additional service connections will not compromise the other customers along that water main or interconnecting water mains in that area. Other systems have worked out a reasonable amount for their engineer to charge for all standard and some of shorter line extension applications. The main reason some systems still require their engineer to review all their service applications is to avoid complaints from current customers that their water service has been restricted due to additional customers being added nearby. Too many systems have been faced with unexpected system upgrade costs due to their manager, operator or a board approving new customer applications only to find out that somewhere - in the distribution system the pressure or volume of water being delivered is less than the minimums required by TCEQ Rules. By not having an engineer at least take a look at each application, the system may have to pay to parallel a water line, loop a water line or any number of other improvements to meet TCEQ requirements. If your engineer has already completed a full hydraulic study of your entire distribution system, pump stations and storage facilities, you may be able to negotiate an arrangement where the engineer simply plugs the new application location into that existing data to determine its potential impact on existing customers. The upfront investment in this engineering study could result in relatively low charges per customer for this less detailed assessment of new applications as they are submitted, and a strong understanding of your infrastructure is a good thing for a system to have for many other reasons. The problem with establishing a threshold dollar amount for these projects is - there can be a big difference in the price between some of these short line extensions due to location, ditches, creeks, highways and even other utility services in these

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areas. Let’s say you have a simple line extension requiring over 1,000 feet of new line, but there is plenty of line and pressure capacity to provide for current customers and the new applicant. The sheer length of line extension might push this over your threshold dollar amount even if no complex engineering work is needed. For this reason, I think it is impractical to use a dollar amount as the primary factor in determining the extent to which an applicant must comply with your nonstandard service requirements. In summary, the board can and should work with their engineer and operator or maintenance company to work out some reasonable costs ahead of these new applications to reduce the actual construction price new applicants will be required to pay for simple engineering studies. The board might also need to strongly consider implementing some sort of up-front capital improvement or equity buy-in fee to replace the capacity being assigned to every new applicant if they don’t already have such a fee in place. If the board does not have new applicants pay for the production or purchase water contract costs and storage being allocated to all new customers, then eventually all the current customers will have their water rates raised to pay for these type of system upgrades, which should have been paid for by the new applicants seeking new service. If you have a technical question you would like answered, please email larry.bell@trwa.org.

documents and instructions on how to self-submit certification to the EPA.

RWA is pleased to announce the launch of our Water/Wastewater Risk Assessment and Planning Tool (WRAPT)!

Last year, we announced that TRWA was in the process of developing a tool to help member water systems meet requirements set forth by the America’s Water Infrastructure Act of 2018 (AWIA). Among other provisions, the act requires community water systems serving a population of more than 3,300 to develop or update risk and resilience assessments (RRA) and emergency response plans (ERP) for their systems. This includes assessing the security of any electronic, computer or other automated systems the utility uses. Affected utilities then must review their RRA and ERP at least once every five years to determine if it should be revised. Upon completion of review, the system must submit to the Environmental Protection Agency (EPA) a certification that the documents have been reviewed and revised, if applicable. To help our member systems comply with these requirements, TRWA created WRAPT, which we began promoting in December 2020 and formally launched after the new year. WRAPT is a cloudbased program that uses logic-based questions to help systems complete their RRA and ERP. The way you answer the questions prompts additional questions for you to consider when completing the tool. Members can plug in their PWS ID to prepopulate some fields to reduce data entry, and the information you input in some fields carries throughout the tool. Once all questions are completed, WRAPT generates the reports required by the EPA that can be saved as a PDF for the system’s records. The tool also includes certification

The due dates for these certifications are based on system size. Systems serving a population of 3,30149,999 will need to complete their RRA and submit certification to the EPA by June 30, 2021. Once you’ve certified completion of your RRA, you will have 6 months from that date to complete and certify your ERP. The final ERP compliance deadline for systems in this group is December 31, 2021. Future certification deadlines will be five years after the initial certification. Systems that serve 3,300 or less population are also recommended to complete an RRA and ERP as it is a good business practice to have these developed so that you are more resilient in emergency situations. In some instances, TCEQ requires them. WRAPT is a free benefit for all TRWA utility members, and we will retain your account and securely store your information for as long as you maintain an active membership status. This will enable our users to review, revise and recertify their documents every five years to retain compliance quickly and easily. To sign up for WRAPT, email wrapt@trwa.org and we will grant you access. Once you have signed up, if you have questions about how to answer any of the questions in the tool, please contact your Circuit Rider. We are also hosting monthly information sessions on the tool for new and exiting users where our staff are readily able to demo features and answer questions. For information on the next scheduled session, visit www.trwa.org/wrapt. We are very excited to provide this new benefit to our members, and we hope this tool eases the compliance burden for affected systems. If you have questions about this article, you may email the author at Allison.Kaminsky@trwa.org or call 512-472-8591.

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Technical Assistance Corner: What Do We Need to Do to Get the Lead Out? By Jason Knobloch, Environmental Services Director, Texas Rural Water Association At the time of publication, the Biden Administration has placed a 60-day freeze on the Lead and Copper Rule revisions. The administration will take this time to review the revisions and decide how they would like to proceed. If there are any changes to the rule as it currently reads, we will address them in a future issue of Quench.

he verdict is in! As of December 22, 2020, U.S. Environmental Protection Agency (EPA) released the long-awaited final revisions to the Lead and Copper Rule. This revision is the first major overhaul to the Lead and Copper Rule in nearly 30 years and it comes with a lot of changes. To better grasp these changes, it is important to understand the intent and goals behind these revisions. The first goal is to better protect children and communities from the risks of lead exposure at schools and childcare facilities by conducting more testing at these facilities where children spend a large part of their day. The second goal is to identify where lead exists within the water system and remove it. This can be accomplished by inventorying all the potential locations where lead service lines may be and set up a program to replace them. Lastly, this rule is to provide more education and transparency to the public about the locations of lead lines and the adverse health effects of exposure. This rule will force a community water system to take actions sooner to remove lead concerns from the system. As water professionals, we cannot deny that protection of public health is a primary goal in our line of work. To ensure we are carrying out this job function effectively and efficiently, we need guidelines that are based on testing and science that give direction and set limits to what is acceptable in our water. Watching the news over the past few years and seeing cases such as Flint, Michigan, and the negative impact it had on the public, it is easy to understand why the EPA feels tightening up requirements is necessary. Unfortunately, it can 10

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cause added burdens to the daily processes of the community water system. The new rule revision will regulate 67,672 U.S. public water systems, of which 63,231 serve populations less than 10,000 people. Large PWS and cities are also impacted by this rule revision, but small and rural communities may have more difficulty complying to the new rule due to limited economies of scale and technical staff. So, what does this mean for your water system? Testing in Schools and Childcare Facilities Since children under the age of seven are at most risk of significant harm from lead exposure, EPA has included requirements that the community water system (CWS) take on the responsibility of testing elementary schools and childcare facilities. This is the first time it has been the role of a water system to test these types of facilities. Samples taken from schools are not to be included in the mandatory sample set for the system. This means that if there is high lead in the schools, this will not be included in the 90th percentile of your samples. The intent of this rule is to identify and provide education to these facilities using the technical expertise of the CWS staff. The CWS requirements for testing schools are: •

Test 20 percent of the elementary schools and childcare facilities the system serves each year over five years so that over a five year cycle all facilities are tested. The samples are to be a representative set of samples, not every point of use on the facility. After all facilities have been tested over the five-year period, no further testing will be required. A refusal or non-response to test

by the facility will be considered part of the 20 percent tested that year. •

Test secondary schools on request during that five years of mandatory testing.

•

Perform additional testing for elementary schools and childcare facilities by request after the initial round of mandatory testing.

•

Provide results and educational materials for the users of the facility and parents to communicate how to understand the test results and the impacts of lead exposure.

•

Provide information on health risks of lead in drinking water to ALL schools annually for the first five years. The system must also provide information to secondary schools on how to request testing.

•

The sample taken from the sample sites (homes/ buildings) is still required to have the 6-hour stagnation period. A few differences are that samples are now to be collected in a wide mouth bottle and it is to be the fifth-liter sample, not the first draw. The intent here is to still allow time for the public water to sit in the lines to gauge the corrosivity of the water, but instead of pulling water samples that would represent the internal plumbing, the fifth liter would allow enough water to pass to test from the service line. This seems like a benefit to the water system by not being responsible for inadequate internal plumbing, but rather testing the service lines to the home.

•

The new rule prohibits recommending flushing the lines before stagnation and cleaning or removing the screen or aerator. In locations where there is minimal use such as a single person home, it was often suggested to make sure they thoroughly ran their water the day before to flush out stagnate water. This rule prohibits that type of instruction to the homeowners.

These requirements exclude facilities built after January 1, 2014.

Sampling and Collection Procedures Within the new rule there are additional revisions made toward Water Quality Parameter sampling regarding the new find and fix approach and system size determinations. Though they are important to understand, many of these revisions pertain to specific situations; however, below are a few sampling and collection procedures that will impact all water systems. •

Currently, TCEQ requires you to use sample sites that are particularly susceptible to high lead or copper concentrations based on a tier system. The tier system is broken up into three tiers utilizing different build dates and structure types. These site selection criteria are focused on giving highest priority to sites built after 1982, but before the state lead ban in 1986. Systems were to collect 50 percent of their samples from these tiered locations. In the new rule, priorities are focused on areas with lead service lines (LSL). If a system has LSL in their system, ALL samples must be taken from those sites. If no LSL are identified, systems must collect lead from other leaded plumbing or locations with a higher potential for lead.

New Trigger Levels The new trigger level is an effort to start implementing a plan of action early instead of waiting until the action level is exceeded. A concern for EPA has been that with the various loopholes in the old rules, systems have been able to get around taking action to correct high lead and copper levels. Though this new trigger level will require a system to get a head start on taking actions, it will also end up being a new level of concern for consumers. • In addition to the 15 parts per billion (ppb) Action Level, the new rule establishes a new trigger level of 10 ppb that initiates additional planning, monitoring and treatment requirements. •

If your system exceeds the 10-ppb trigger level at the 90th percentile but is still under the Action Level, the lead monitoring frequency will be annually.

•

If your system already has Corrosion Control Treatment (CCT), you will need to evaluate and re-optimize your treatment. If you do not have CCT, you must do a corrosion control study Continued on next page Quench — 2021 Issue 1 11

and prepare for treatment to be installed if you exceed the action level of 15 ppb. Lead Service Line Inventories and Replacements

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•

All systems must develop an LSL inventory of the entire system within three years. A system must demonstrate the absence of LSL if there are none. Absence can be demonstrated through a variety of methods such as verifying materials used through old service orders, checking as-built plans, or even physically excavating the area to do a visual inspection. The option of “I don’t know” or unknown service line will be considered the same as “I have lead lines.” This inventory must be updated annually or triennially, depending on your sampling schedule. If your system has only no LSLs, you are only required to do the initial inventory and no updating is needed.

•

All systems with known or possible LSL must develop a Lead Service Line Replacement Plan (LSLR). The LSLR plan must include a strategy to determine all lead status unknown service lines, procedures for LSLR, customer flushing procedures for premise plumbing, and replacement goals in consultation with the primacy agency for two consecutive 1-year monitoring periods. This plan must also include a financial strategy to fund the replacement of LSL. The 10 ppb trigger level will initiate the start of the system’s replacement program.

•

The rule has a Find and Fix approach that requires systems to fully replace 3 percent of LSL per year upon a 2-year rolling average once a PWS exceeds the action level of 15 ppb at the 90th percentile. A CWS must continue to replace LSL at this rate until no exceedances are found over the next two years. The old rule required a 7 percent full or partial replacement. Full replacement means replacing the service line to the meter, as well as the customer line from the meter to the home/building. Partial replacement is replacing only the CWS service line. In the new rule, there will be no credit given toward the 3 percent replacement for partial or CWS

service line only replacements. The 3 percent replacement rule is said to replace more LSL than the 7 percent rule because it does not allow for a system to test out of the process. •

•

The rule does not require the water system to pay for replacement of a customer-owned LSL. Rather, a system’s LSLR plan should include a process for customers to pay for their side of the meter, as well as a financial assistance strategy to accommodate customers that are unable to pay to replace their portion by means of assistance through rate revenue or federal or state grants and loans (see Funding below).

in the CCR. The identifier used by the system to make public can be the choice of the system (i.e., street, block, intersection, landmark, etc.) but does not have to be the exact address. •

Deliver notice and educational materials to consumers during water-related work that could disturb LSL. If any work is being done on a main line or service line that may agitate the plumbing and loosen lead deposits into the water stream, customers are to be notified and educated in advance of the work.

•

For system-wide action level exceedances (90th percentile over 15 ppb), customers must be notified within 24 hours. For households or individual samples that exceed the ALE, customers must be notified within- three days. This is something to plan for in advance. In order to make the notifications, make sure you have the appropriate points of contact for your customers, such as email, cell phone, correct address, etc. One method being used by some systems for immediate contact is call out software or reverse 9-1-1.

Following a LSLR, the CWS must provide pitcher filters/cartridges to each customer for six months. Testing has shown that once a line is disturbed during a replacement, the lead content left in the remaining piping caused a spike in lead levels. To remedy this issue, EPA requires the pitcher or cartridge filter be given to the customer after a replacement within 24 hours. A follow up tap sample is also required at that site three to six months after the replacement.

Public Education and Notifications

Small System Flexibility

Public education is a large part of this new rule revision. As one of the goals is to empower communities through information, a CWS must: • Inform customers annually that they are served by LSL or “lead status unknown” service lines.

The new rule does allow some flexibility to small CWS serving less than 10,000 people and for all Non-Transient/Non-Community Water Systems with a 90th percentile greater than the 10-ppb trigger level. Instead of the prescribed LSLR or the addition of Corrosion Control Treatment (CCT), these systems may choose what actions best fits their needs and abilities by choosing either

•

Conduct targeted outreach to LSL customers that encourages them to participate in the LSLR program.

•

Provide mandatory health effects language in public education materials and on the Consumer Confidence Report (CCR). This language is usually a bit daunting and can cause some unnecessary concern for those that are not served by LSL, but the intent is to make consumers more aware of the health concerns of lead exposure. Notice that your LSL inventory is ready and available online or in office is also required on your CCR once completed.

•

Make the LSL inventory and locations of LSLs publicly available and direct customers on how to access all lead and copper tap sampling results

• • •

•

adding CCT, replacing Lead Service Lines, providing and maintaining point-of-use devices such as pitchers or filter cartridges for each customer, or replacing all lead-bearing plumbing material.

This may not seem like much of an option, but for small systems, the financial burden and/or maintenance of one option may not be as much of a challenge as another and the system will appreciate at least being able to choose their path to correct the issues. Continued on page 15 Quench — 2021 Issue 1 13

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Funding As with many new regulations, one initial question is “how are we to pay for this?” The requirements listed for additional sampling, adding treatments and replacing the system’s lead service lines are all costs that will be taken on by the CWS. Though most of the treatment and sampling activities will have to be included in the system’s cost of business, there are a few options for grants and loans to help with the LSLR portion. EPA has developed a guide to help small and disadvantaged communities identify potential funding sources for LSLR, which is located online at https://www.epa. gov/sites/production/files/2020-12/documents/ ej_lslr_funding_sources-final.pdf. Note, most of the funding sources within this document do not explicitly list LSLR as an eligible activity, yet LSLR still fits in the purview of multiple federal grant and loan programs.

Financing Solutions for Rural Water Systems In partnership with TRWA, CoBank can offer members specially negotiated terms.

There are many other details of this rule revision Visit www.trwa.org/cobank or that impact treatment, optimizing corrosion contact John DeLuca at 303-694-5958 control, WQP sampling and sampling schedules based on system type, size, and Action Level exceedances, but this article highlights those that WTR_ADM_TX-RWA-3625x4875.indd 1 directly impact most of our members. For more, detailed information on what is included in this rule revision, please visit https://www.epa.gov/groundwater-and-drinking-water/final-revisions-lead-andcopper-rule. Here you will find the 400+ pages of the federal register notice, along with many other useful supporting documents to help explain what is changing. If you have any questions about this article, please email the author at Jason.Knobloch@trwa.org or call the TRWA office at (512) 472-8591. If you would like onsite assistance to discuss this process and what it looks like for you, you may contact your TRWA Circuit Rider or call TRWA for FMT assistance. Additional Information can be found at: https:// www.epa.gov/ground-water-and-drinking-water/ supporting-materials-final-revisions-lead-andcopper-rule.

2/12/21 7:04 AM

Engineering Architecture

(512) 436-8571 (254) 771-2054

info@mrbgroup.com www.mrbgroup.com Quench — 2021 Issue 1 15

Keep It Legal

Answers to Members’ Questions by TRWA Assistant General Counsel Trent Hightower What is the current status of the COVID-19 vaccine roll-out as it relates to critical water system personnel?

As coronavirus cases continue to rise statewide, we have heard from several members that they are in danger of critical staffing shortages that could impact the availability of water to the communities that depend on them. Therefore, it is critical that essential utility staff be vaccinated as soon as possible. TRWA has been working with state lawmakers and regulatory agencies to see that these critical workers receive the vaccine as soon as possible. Currently, there is a disconnect between federal and state guidelines regarding who should receive the vaccine. While the federal Centers for Disease Control (CDC) has recommended that essential water and wastewater workers be included in states’ first phase of the rollout, Texas has thus far not included them in Phases 1A and 1B. As of this writing, these initial phases, which make the vaccine available to front-line healthcare workers, people 65 and older, and those with underlying health conditions, remain the only phases cleared by the Texas Department of State Health Services (DSHS). We have heard unofficially that water and wastewater operators will be included in phase 1C, though it is unclear when DSHS will move forward with that next step. Based on conversations we have had, it seems that supply is the primary hold up at the moment, and there simply aren’t enough doses available yet to expand vaccine availability right now. To keep up to date on the latest progress of the state’s vaccination effort, visit dshs.texas.gov/coronavirus/immunize/ vaccine.aspx.

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Further, Texas has convened a team of experts and state officials to guide the state’s vaccine allocation strategy. This panel needs to hear from you about the crucial need for essential water and wastewater workers to be vaccinated. You can find a list of panelists and their contact information at www.trwa. org/page/covid and click on PANEL CONTACT. Please reach out to them by phone or email to explain the current situation in your area and the consequences to your community if a majority of your essential staff become ill at the same time.

Our system recently had a customer inquire whether we had a line near property they intended to purchase. Our staff provided him with a map showing a line nearby. After the purchase, however, we discovered that our map was inaccurate and there is not currently a line in the vicinity. This individual is upset and claims that he would not have purchased the lot had he known. What is our potential legal exposure here and how should we handle such inquiries to avoid this situation in the future?

As a general matter, this is one reason why it is critical that utilities keep up-to-date records of the location of their infrastructure. Having detailed, current maps is the first step to avoiding this issue altogether. However, that isn’t always possible given limited resources, the age of many lines and the fact that staff turnover and disparate recordkeeping practices over time can create uncertainty around this topic. This isn’t a situation governed by the Public Utility Commission of Texas (PUCT) or the Texas Commission on Environmental Quality (TCEQ). The landowner might file a complaint with the PUCT alleging that the cost of obtaining service is

too high, but the agency would be evaluating that on an objective standard of whether that cost is reasonable given the actual location of the lines and the expense necessary to extend service to the property. The fact that the purchaser had a different understanding of that situation at the time he purchased the land shouldn’t be an issue as far as the PUCT is concerned. He might, however, have a claim against the utility in civil court under a theory that he detrimentally relied on a representation or promise made by the system when he decided to purchase the property. The success of that argument would likely be factspecific, depending on the degree to which the system made any representations, whether those representations were made in writing, and whether the purchaser conducted his own reasonable due diligence in determining the availability of water service nearby. I spoke with one attorney who represents many of our members, and he has recommended that his clients place a clear disclaimer on any maps they give to potential purchasers explicitly stating that technical staff will need to determine the location of lines in the field to be sure - the lines are where the maps say they are. He recommends - all maps contain the following disclaimer to avoid this situation in the future: Please Note: This map is for general informational purposes ONLY. _________ WSC/SUD makes no representations as to the actual location of water service lines, meters, valves, or other water service devices or service lines depicted on this map. Interested parties may not rely on this map for any purpose whatsoever and the actual location or existence of any water service lines, meters, valves, or other water service devices must be independently verified by __________ WSC/SUD staff, in the field, prior to same being deemed correct and reliable.

A customer of our water supply corporation has requested that we move a flush valve, line and meter to a different location on their property.

After doing some research, we discovered that we don’t currently have an easement for their property at all. How should we handle this?

When a utility discovers - it doesn’t have an easement for a property - it has been serving for many years, the parties generally find themselves in a bit of a standoff. While utilities may require an easement as a condition of service up front, the PUCT will not support disconnection if a landowner refuses to grant one after service begins. This means - the utility’s infrastructure is technically trespassing on the property, but the landowner would have a difficult time enforcing a trespass action while also insisting - the utility serve them. When a landowner refuses to grant the easement once the oversight is revealed, the utility must therefore wait until the property changes hands to acquire the easement when they can require it as a condition of service from the new owner. The situation you described, however, could provide you with a rare opportunity to obtain the easement now. The TRWA Sample Tariff provides that the relocation of services shall be allowed, provided that the new location remains on the property being served, the member pays the actual cost of the relocation, and the member grants a current easement for the proposed location. If your tariff contains similar language, you could require the easement as a condition of moving the line to their desired location. If they balk at granting the easement, you are under no obligation to move the service and can continue operating under the “standoff” situation outlined above until the property is purchased by a new owner.

This will be our water supply corporation’s first annual meeting during the COVID-19 pandemic. With social distancing and limited gatherings still recommended, are candidates for director still required to obtain signatures of 20 members to appear on the ballot? Continued on next page

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During the pandemic, traditional methods of gathering signatures may be less available, with many utility offices being closed to the general public and large community gatherings being less well-attended or cancelled altogether. This means candidates for office may have to work harder this year to gather the necessary signatures by soliciting them more directly on a one-on-one basis.

By way of background, this provision only applies to candidates for director positions at water supply corporations with more than 1,500 members. Water Code Section 67.0052(a) requires director candidates for these systems to submit with their application a petition signed by 20 members requesting that they be placed on the ballot. Unfortunately, while the governor has relaxed other legal requirements to deal with the pandemic, such as those relating to phone or videoconference open meetings, he has not done so with this provision, which has very narrow applicability only to water supply corporations.

If you have a legal question you would like answered, please email legal@trwa.org.

The TRWA PAC Needs Your Support This year’s Texas Rural Water Political Action Committee (PAC) fundraising campaign is already underway, and there are several ways you can help! TRWA has set a strategic goal to raise $50,000 for the PAC in 2021, which we aim to achieve through sponsorships, in-kind donations and through fundraising events at RuralWaterCon in March and our Training and Technical Conference in July.

at RuralWaterCon, to be held in Austin on March 2426, 2021. Those who contribute by March 10 will also be printed in the RuralWaterCon official program! Sponsorship levels and gifts are as follows:

The Texas Rural Water PAC is the bipartisan state and federal political action committee of TRWA. PAC contributions are pooled to make impactful contributions to state and federal legislators in Texas — men and women who understand the issues facing water and wastewater utilities. The Texas Rural Water PAC Board reviews legislators' effectiveness, committee assignments and voting records to determine who to support.

For pictures of these items, visit the “Legislative” tab on our website or look for them in our Weekly Pipeline eNewsletter.

The first way you can support the PAC is by becoming a sponsor! Each year, TRWA members make individual contributions to the fundraising campaign. By contributing, you can affect the political process and ensure Texas Rural Water is fairly and effectively represented. PAC Sponsors will be able to display their pride in Rural Water with sponsorship gifts and will also receive recognition in Quench and 18

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• • •

Gold Level: An individual contribution of at least $300 — Bluetooth wireless illuminating earbuds Silver Level: An individual contribution of $200 to $299 — High Sierra 22" duffel bag Bronze Level: An individual contribution of $50 to $199 — Roll-up picnic blanket with carrying strap

By law, only monetary contributions from individuals may be used by the PAC; corporate or district contributions are prohibited by law to be used for this purpose. Suggested contribution amounts are guidelines, though any level of contribution is appreciated. Individuals may legally contribute up to $5,000 per calendar year. To make a contribution, please visit our website at www.trwa.org and click on the "Legislative" tab to find our online contribution form, or you may download a form and mail it with a personal check payable to the Texas Rural Water PAC to 1616 Rio Grande, Austin, Texas 78701.

The second way you can support Texas Rural Water PAC is by making an in-kind donation to be featured at the RuralWaterCon PAC auctions. A silent auction will be held throughout the convention in the exhibit hall and online for our virtual package attendees; and a live auction for premium items will be held Thursday, March 25, during the President's Banquet. D e si gn - C o n str u c t Wa ste w a te r Tr e a t m e n t

We encourage members to donate unique and locally-sourced items for the auction. It is important to note that if the donated item is from a district or a corporation, the item's winning bid must be at least three times the cost of the item for proceeds to fully benefit the PAC according to law. If you would like to donate an item, please send a photo and description of the item to editor@trwa.org. If you will be attending the convention in-person, you may drop off your donation at the PAC booth when you arrive. Otherwise, we will include your item in our virtual auction and will make arrangements with you after the event is over to coordinate delivery of your item. All donations are appreciated. The third way you can show your support is by attending our PAC fundraising events! At convention, you can bid on silent auction items throughout the event and you can attend the President's Banquet to participate in our live auction. At Office Professionals Conference, we will be selling TRWA-branded items to raise money for PAC. If you will be joining us in Galveston in July for our Training and Technical Conference, we will be holding our annual Family Fun Fish Fry on July 14th. All registration fees paid with a personal form of payment will go toward the PAC. The Texas Rural Water PAC's strength lies in the involvement of water professionals like you. By pooling your contributions with those made by hundreds of other TRWA members across the state, we can make the voice of our industry in Texas even stronger. Join the Texas Rural Water PAC team and help us advocate for the future of Texas rural water!

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Source Water Protection at Texas State Parks By Deborah McMullan, Source Water Protection Specialist, Texas Rural Water Association; and Mason T. Miller, TCEQ Water Supply Division

n 2019, the Texas Rural Water Association (TRWA) partnered with the Texas Commission on Environmental Quality (TCEQ) Water Supply Division, and Texas Parks and Wildlife Department (TPWD) to begin implementing Source Water Protection (SWP) efforts at state parks.

festivals as soon as the COVID-19 closures are over. TRWA looks forward to taking part in these and assisting to educate the public on how surface waters within state parks are vulnerable to contamination, as well as how the public can assist in protecting these water sources now and for the future.

In October 2019, TCEQ staff traveled to Guadalupe River State Park in Kendall County to meet with TPWD Park Rangers and TRWA Source Water Specialists to implement a SWP program. As part of the program, an inventory of the park’s surface water intake on the Guadalupe River and four groundwater wells was conducted.

TRWA and TCEQ are currently working with TPWD to select state parks for SWP Plan development during 2021.

This SWP project proved to be very rewarding and opened the door for other state parks to participate in the program. In October 2020, TRWA again partnered with TCEQ and TPWD to implement a SWP plan for Choke Canyon State Park in McMullen County. An inventory of the surface water intakes on Choke Canyon Lake and terminal reservoir located within the park were completed. Guadalupe River State Park and Choke Canyon State Park staff participated in training sessions hosted by TRWA. During the trainings, the staff discussed how contaminants can reach the source water, ideas for public education and best management practices that could be implemented. Both state parks placed Drinking Water Protection area signs at each groundwater well, surface water intake and park entrance to help educate park visitors that they were entering a SWP area and to be mindful of their activities. As a future educational effort, both parks are planning to host environment

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TPWD Choke Canyon State Park Rangers Receive Drinking Water Protection Area Sign from TRWA's Deborah McMullan.

TPWD Choke Canyon State Park Ranger and TCEQ's Mason Miller installing Drinking Water Protection Area Sign.

Water University: Supporting Managers Today and Tomorrow By Bruce Pearson, Instructor, Texas Rural Water Association

ater University is a program housed under accepted the proposal by the three states. the National Rural Water Association Florida, Kentucky and Texas further emphasized (NRWA) to assist and enhance the need for a Study Guide to be written in order to the capabilities of professionals in our industry. achieve the objectives that had been outlined and Its purpose is to provide training, knowledge a test of competency that would be designed and and skills to aspiring managers and further administered by the NRWA. By successfully passing their careers. Whether an individual is in the the exam, the student would receive a certificate early phases of a leadership role, a mid-level from the NRWA. To achieve the objectives, the management position or a more executive three states further promoted the Study Guide to management level, this program is have three sections. They were designed for everyone. The original Financial, Technical and Managerial concept began with a meeting in Sustainability and Capacity Denver, Colorado about 12 years Instructor’s Guide ago sponsored by the National Their intent was to design the Rural Water Association and with Study Guide for acceptance by the the Executive Directors of the state NRWA and provide a test bank of rural water associations. Texas questions. All of these points of attended that meeting. emphasis were also accepted by the NRWA. Background After the initial meeting, a subsequent meeting was held by the Executive Directors from Florida, Kentucky and Texas in an effort to support this endeavor. As discussions between the three took place, their emphasis was on providing training, knowledge and skills at all levels of the management hierarchy. In doing so, two objectives were discussed and agreed upon; (1) provide the tools necessary for managers to be successful, and (2) a competency that could be acknowledged throughout the industry. Their decision was to promote a program to the NRWA whereby the capabilities of training, knowledge and skills could be achieved, and a competency could be established for recognition. Within this concept was the promotion of designing a Utility Management Certification process. The NRWA

The Purpose

The guide or manual provides managers and students interested in management with the tools they need to effectively manage water and wastewater utilities and develop capacity based on federal standards across the country. The information in the guide is intended to be augmented by state-specific rural water associations or state primacy agencies. By completing the guide and passing the exam, managers will demonstrate competency and gain knowledge that will enhance their effectiveness. It will also provide added value in managing their systems. Additionally, the certification will give governing bodies of water and wastewater utilities a qualification tool and a demonstrated standard from which to advertise and hire more qualified Continued on next page Quench — 2021 Issue 1 21

professionals. This will hopefully lead to better utility management and compensation criteria for the industry.

The Project and Design Shortly after acceptance, Florida, Kentucky and Texas secured the services of a technical writer and the project began. In addition to the guide and the test bank of questions, the three states agreed to provide a PowerPoint Presentation and Handouts for states that desired to host instructor-led certification programs for operators and/or managers. The guide was completed and published in 2010. The PowerPoint Presentations, Handouts and test bank of questions were completed shortly after and all were accepted by the NRWA. Texas took the lead in compiling all the information and has been publishing and selling copies of the study guide nationwide.

Updated Edition In 2020, discussions were held among several states about the need for updating the guide. A project began in the second half of the year with Texas Rural Water taking the lead on this important endeavor. Rural water association staff from Florida, Kentucky, Idaho, North Carolina and Utah have been instrumental in completing the project to this point. The first phase is almost finished with the edits and reviews due as of the time of this writing. Another phase of the project has been to review the test bank of questions. The PowerPoint Presentations and the Handouts will also be reviewed and be revised, as necessary. These documents will be completed and turned over to the NRWA shortly

after the revised guide has been completed by Texas. During early discussions of the new project, the need to develop an Instructor’s Guide was discussed and agreed upon by the states. Texas will also take the lead on this phase.

Certificates In the past 12 years, many individuals throughout the industry have taken the course or individually studied the material in the guide and have passed the competency exam and received their certificate. Although it is not a requirement for licensing in Texas, the certificate does provide managers, as well as aspiring managers, a nationally recognized credential. An important point — TRWA developed its own Utility Management Course with a manual tailored to include Texas laws and regulations. This is a necessary course for some operator licenses in the state, and continuing education credits can be obtained toward renewing licenses as well.

Access Once the updates are completed, TRWA will publicize the launch of the updated edition. For more information about the guide, the course and the exam, visit the TRWA website at www.trwa.org. Once on the site, visit the Training tab and choose “Water University” from the dropdown menu. By completing the Study Guide, passing the competency exam and receiving their certificate, industry managers at all levels will gain a new credential and level of proficiency as a professional in the water and wastewater industry. If you have any questions about this article, contact the author at bruce.pearson@trwa.org or call (512) 922-4942.

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From the Hole: Tales from the road by Michael Beadnell, Circuit Rider for Texas Rural Water Association West Texas, El Paso County

n my new Circuit Rider role, one of my goals has been to create an updated log of addresses, phone numbers, emails and the names of the lead operators of all the member systems in my assigned area. In December, I identified seven of our members I had not yet visited in the West, and I planned to see them before the new year. With that in mind, I calculated the online distance from the Cameron home office to the farthest the great state goes to the west, then pointed the Association’s vehicle toward El Paso. I determined that departing Monday morning at 7:00 a.m. would put me around Mason just in time for my first Zoom meeting of the day. Once the process was explained, Zoom meetings in a pickup truck have not been a big issue. That is, until I rolled into Mason! I could not for the life of me tether my phone onto the internet no matter how hard I tried. With no other option but to reschedule the meeting until I could get to a hot spot in El Paso later in the week, I carried on with my journey. I calculated the site of the next Zoom meeting, which would be at a rest stop in Ozona. Entering the Guadalupe Mountain range, the phone tethered just fine this time, and I was easily able to connect to my team meeting with the TRWA Technical Assistance Department. The big news in December was the completion of our new Water/ Wastewater Risk Assessment and Planning Tool (WRAPT). WRAPT was created to help member utilities comply with mandates set forth in the America’s Water Infrastructure Act of 2018. The tool is a cloud-based software that members can use to create their Risk and Resilience Assessments and Emergency Response Plans by answering a series of dynamic, logic-based questions. Once completed, WRAPT generates the finished reports so users

can review the information and keep the documents for their records. The tool also includes certification documents and instructions on how to self-submit certification to the EPA. If you are interested in signing up for this free member benefit, email WRAPT@trwa.org or visit www.trwa.org/wrapt for more information. Another topic of discussion that day was that NRWA extended single system remote assistance through April, meaning the Circuit Riders may continue to perform remote visits with the systems in our designated areas. While many of us are happy to continue to make onsite system visits, many systems are not accepting nonessential visitors at this time, so the ability to perform remote visits during the pandemic is needed. Still a good distance away to being officially west of the Pecos River, I was anxious to get back on the road after the meeting. To be honest, I had never been to El Paso. When in the military, I wanted to serve in Fort Bliss for my last reenlistment, but the recruiter talked me into Fort Hood, so I was excited to see what I had been missing. I rolled in late Monday night to realize I was in a different time zone — being on Mountain Time meant I could watch the rest of the football game! Water is West Texas’s most valuable resource, yet the water levels in the Southwest desert communities have been declining at an accelerating rate for several years. When you use groundwater faster than it is naturally replenished, the freshwater layer is depleted. West Texas Groundwater is pumped from the HuecoMesilla Bolson Aquifer. The area of this aquifer Continued on next page Quench — 2021 Issue 1 23

does not connect with any other major aquifer in Texas. Fresh groundwater stored in the aquifer system is bordered by regions of brackish to saline groundwater, and nearly 90 percent of the water pumped from the aquifer is used for public supply. Water levels have declined several hundred feet primarily due to municipal pumping. Located in the far northeast section of El Paso quietly stands one of the most unique facilities in the world built to conserve the precious water supply. The Fred Hervey Water Reclamation Plant, named after a former mayor of El Paso, is one of the first in the nation to treat reclaimed water to drinking water standards. Fred Hervey uses the reclaimed water to replenish the Hueco-Mesilla Bolson Aquifer through injection wells and infiltration basins. Since 1985, the plant has returned nearly 30 billion gallons to the Aquifer. The morning after arriving in El Paso, I traveled 32 miles southeast to El Paso County WCID #4 in Fabens. There I met with General Manager Jose Ramirez and was extremely well received. Jose and I went over some concerns I had that are coming down the pipeline. Fabens is on top of regulatory challenges, but I shared with Jose some quick and easy ways to better meet compliance, and together we assembled a 7-step program. We left only the reviewing and fine tuning of the program to his staff. Next, Jose and I were joined by the system’s field manager, Martin Madrid, and we looked over the treatment infrastructure. Fabens has a state-of-the-art groundwater treatment plant. Brackish and saline water high in gases and minerals is pumped from the Hueco-Mesilla Bolson Aquifer. To begin with gas and mineral removal, potassium permanganate is injected. The water turns purple and the iron turns yellow, then it is sent through filters. After the water passes through the filters the water loses its purple hue and clears up. Then one part is sent through a gallery consisting of cartridge filters and membranes and then gets a PH adjustment. The other part of the water receives that same PH adjustment only. In the final process of this plant, chlorine is added, the blended water is sent to storage, and then finally sent to customers. 24

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Jose and Martin suggested we meet up with their engineer Horacio to visit one of the district’s best customers — the Cattleman’s Steak House at Indian Cliffs Ranch. Cattleman’s was voted best steak in the country by People magazine and the manliest restaurant by Men’s Health. I got there first, so I took some time to look around. The steakhouse is situated on an authentic ranch that will take you back to the Old West as it truly was. I passed the rugged terrain of mountains and desert, then to ruins of one of the famous Overland Trail stagecoach stops. It has a lake, a zoo, a maze, old West memorabilia, including an antique wagon collection, and a western town all viewable by taking the many trails and dirt roads scattered across the ranch. I later found out I was not supposed to go on these trails without a guide. Working the circuit had built up quite an appetite, so when the fellas finally showed up, we had a nice dinner that truly satisfied this cowpuncher. All in all, it was a pleasant and successful trip to West Texas, and I’m glad I finally got the chance to visit El Paso and the surrounding areas. As always, I will now close out my column with a math question for you to solve: If a distribution system carries 2,500,000 pounds of water per day, how many people are represented? This question involves a population equivalence formula, a formula that helps us size our lines and determines the amount of water needed to meet the demands of our customers and our treatment facilities. The population equivalence formulas are 1) Each house has 3 people, 2) Each person needs 130 gallons of water per person per day, 3) Of the 130 gallons of clean water, 100 gallons of wastewater is collected from each person per day, 4) Each person contributes 0.17 pounds of BOD per day (the strength of our wastewater). Try to solve the problem yourself, and then turn to page 30 of this magazine for the answer. If you have questions for me, please email michael. beadnell@trwa.org or call 512-924-4552.

J. F. FONTAINE & ASSOCIATES, INC. CONSULTING ENGINEERS RURAL WATER SYSTEM ENGINEERING SINCE 1962 700 N. Sycamore St. P.O. Box 4187 Palestine, Texas 75802

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Assuring safe entry and access to a water storage tank By Erin Schmitt, Media Director/Technical Writer, Pittsburg Tank & Tower Group

n old, riveted tank — often referred to as a “tinman” because of its resemblance to the famous “The Wizard of Oz” character — was badly in need of a paint job. Tinmen are elevated tanks, which carry more risks compared to ground tanks since there’s a greater fall risk. It also means that any entry or exit points into the tank are much further from the ground. This tank, located in California, only had one entry or exit point — a roof hatch. To safely complete a paint job or any maintenance or repair work that requires entering the tank, there should always be at least two ways of ingress and egress. So, to finish the tank job, the contracted company installed an OSHA-compliant manway on the tank’s shell. The manway became the entry and exit for both the paint crew and their equipment, while they used the roof hatch mainly for necessary ventilation. It’s crucial to have large enough access points, a rescue plan in place, rescue supplies at hand, and for people responding to have undergone training for an unplanned water storage tank rescue. Manways and hatches are access points for inspections, repairs and maintenance. Rescuers must have easy access through manways or hatches so they can extract the person within a reasonable amount of time and prevent further injury if someone has had a medical emergency while inside the tank. Accidents require investigations-and inspectors cite code violations in their official reports. The tank owner or operator could then potentially be held

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liable for federal and state fines or be on the line for damages if there’s a successful civil suit filed. Routine inspections from a state fire marshal on fire protection tanks could also yield fines for the tank owner if their tank is not up to code. It’s better to make sure a tank is up to code before an accident happens versus waiting until after the fact. Two shell manways must be provided within the first ring of a tank shell, according to American Water Works Association Standard 7.4.4. One manway must be at least 30” in diameter and circular. The other manway has to be at least 24” if it’s circular or 18” x 22” if its elliptical. If the access cover weighs more than 50 pounds, it should have a hinge or davit arm. Manways should be located 180 degrees from each other. In a medical emergency, time is critical. For example, if someone suffers a heart attack, rescuers will want to lift the person through the closest access point. Being able to rescue a person quickly could make the difference between life and death. If there’s only one access point, and, especially, if the one access point is blocked by equipment, it could waste precious time. Painting requires blast hoses, paint sprayers and often a fan to filter the air and keep the fumes down. All of this equipment must fit inside the tank so it can be repainted. If a tank is being sandblasted, a dust sock may

be used at the manway to catch any sandblast debris. Hoses, fans, ventilators and socks block or at least impede entry or exit, making it necessary that another access point be available. Some companies won’t accept work unless there are certain safety measures in place on a storage tank. It’s not worth the risk of having their employees paint or repair a tank without a viable exit. Ground storage tanks are less hazardous to enter and exit because the manways are closer to ground level. For elevated storage tanks, any rescue attempts would require the rescuer to access the elevated structure before entering the tank. There should be two openings on a tank roof. Ideally, that would be two hatches, both at least 24” wide; however, one can be a vent if the vent is removable and provides a large enough opening. An interior ladder is helpful to gain safe access if any work is performed inside the tank. That includes maintenance, repairs or a routine inspection that’s not utilizing a robot. OSHA-compliant ladders must have standoffs every 10’ on center and cable type ladder safety devices. A cable slide is connected to the cable and the slide is hooked onto a climber’s harness. Ladder guards prevent intruders from easily accessing the tank. Round ladder rungs don’t offer an edge or grip of any kind, but anti-skid rungs do. They must also be at least 16” wide and should have antiskid rungs to prevent slips and trips.

Steel that interacts with water without a protective barrier — think a tank liner for a storage tank — starts to rust and corrode over time. If the rusting isn’t addressed, the ladder may deteriorate and become unsafe to climb. The ladder may become disconnected from its standoff, which is what connects the ladder to the tank shell. If that happens, it could damage the interior paint or even puncture a hole in the tank. In colder climates, there’s also the potential for a tank to freeze, causing the water to expand, - creating so much pressure that appurtenances can break off and damage the tank. These factors must be weighed when deciding whether to place a ladder inside a tank. As with anything, a little maintenance can go a long way. Of course, there are tanks still in operation built before current standards were adopted. But, for safety reasons, the tanks should be upgraded to comply with modern standards as repair work is done.

Code Updates In-Service Cleaning If you are interested in having us as your partner, feel free to contact one of our department representatives below NEW TANKS — Rick DiZinno (270) 826-9000 ext. 2601 EXISTING TANKS — Jordan Pyles (270) 826-9000 ext. 4601

Quench — 2021 Issue 1 27

TRWA Briefs Previous Article Update In 2019, Quench published an article about irrigation systems. TCEQ had decided to explore whether there was a need to reclassify those systems i.e., health hazard or non-health hazard. Recently, the TCEQ Commissioners voted to leave a potable irrigation system as non-health hazard unless it has chemical injection, in which case it would be classified as a health hazard. This means there was no change in the classification. However, the Commissioners did make numerous changes to the Irrigation Rule 344. The most notable was that Atmospheric Vacuum Breakers can no longer be installed on irrigation systems. A Pressure Vacuum Breaker would be the assembly of choice in those applications. The Rule was voted on in July 2020. For more information access the TCEQ website at www.tceq.texas.gov and type Rule 344 in the search box.

Calling All Texas Rural Water Emerging Leaders Are you an energetic and engaged water/ wastewater utility professional? Don’t miss your chance to participate in TRWA’s professional development and networking program, the TRWA Emerging Leaders Program (ELP). This program is designed for up-and-coming leaders in the Texas rural water industry and combines remote and inperson training specifically designed to enhance leadership, engagement and advocacy. Applications are now being accepted for what will be our third class of Emerging Leaders. Program participants will spend nine months earning leadership development credits for attending live training sessions, webinars, interacting through an online forum, completing monthly assignments and receiving one-on-one coaching from established industry leaders. Participants will also develop and execute an individual local leadership project. In addition to formal professional development, 28

Quench — 2021 - Issue 1

participants also benefit from networking opportunities that enable them to connect with influential leaders in the industry. Program alumni continue to have heightened engagement with TRWA. Our graduates serve on our conference planning committees, are invited to speak at conferences, volunteer at TRWA events and contribute to Quench. We even have program graduates that now serve on the TRWA Board as Directors and Alternate Directors. Program details and applications can be found at www.trwa.org/ELP. We will be accepting applications until April 16 and the program will begin in June. Please contact us at leadership@trwa.org if you or someone you know would be a good fit for this program.

Notice About TRWA Elections In early January, we sent out our annual notice of election for TRWA Board Director and Alternate Director positions, along with Qualification and Consent forms to certify candidates to run in the election. Districts 1, 4, 6 and 14 were to hold regular elections in 2021, with special elections possible in Districts 7 & 8 to fill vacant Alternate Director seats. The deadline to submit Qualification and Consent forms was January 29. We have reviewed all submitted forms and have verified there are no contested races for the seats up for election this year. Per our Board Policies (2.5), we will not print a ballot and an election will not be held in a district in which the races have single unopposed candidates. As such, we will not be issuing absentee ballots by mail or holding elections at the Annual Convention in March. If you have any questions, please contact info@trwa.org.

TRWA Briefs Update Your Quench Subscription for 2021 Don’t forget to review your Quench subscription information and make any necessary changes when you renew your TRWA membership for 2021. Your membership with TRWA will continue to include complimentary subscriptions to Quench: •

Regular Utility Members: Up to five complimentary subscriptions

•

Associate Members: One complimentary subscription

Included in each renewal packet is a list of who we have from your system currently receiving a copy of the magazine. If you have not updated your

information, it will list the main address for your system to which we have been sending your five complimentary copies. If your system purchased additional subscriptions for an annual fee of $30, we will continue to send magazines to those individuals in 2021 and issue an invoice unless we hear otherwise. If you would like to make any changes to your subscription list, please send them in at your earliest convenience. You may do this with your renewal, by email to editor@trwa.org or via our online form, located under the “Publications” tab on our website. If you have any questions, please contact us at editor@trwa.org or 512-472-8591.

TRWA Welcomes New Staff TRWA would like to welcome Scott McClure to its communications team. Scott replaces Kelsey Copeland as our new Communications Specialist. He comes to TRWA with 25 years of association experience, including his last position as Communications Director for The International Order of the Golden Rule, an association of independently owned funeral homes. Scott resides in Austin, Texas with his wife of 19 years, Natalie, and their two children, Christian (17) and Michelle (16). If the house weren’t full enough, their family includes two dogs (Eddie and Jazzy) and two cats (Spike and Murray). Scott and his wife enjoy cooking, traveling, and entertaining their COVID-safe pod.

TRWA is pleased to introduce Roel Gonzalez as our latest addition to the Environmental Services Department’s FMT Assistance Team. In his new position, he will be providing on-site financial, managerial and technical assistance to systems located in South Texas. Roel brings 13 years of experience as a Water Plant Operator, has a Bachelor of Arts from Texas A & M Kingsville and an Associate’s degree in electronics. When not at work, he enjoys competitive door decorating and Pumpkin carving in his community and won 3rd place in his age bracket in his city’s 5K race. Roel enjoys watching WWE professional wrestling and has had photos taken with wrestlers Becky Lynch and Sasha Banks. He and his wife Shirui are devoted church goers and reside in Alice, TX.

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In Memoriam Texas Rural Water lost a longtime friend and supporter, David (Dave) Barnett, in December after a very brief illness. He was 80 years old. Dave was the long time Board President for Cedar Oak Mesa WSC in Wimberley. During his 15 years’ service, he was passionate about running an exemplary water system and was instrumental in the system being awarded several grants which gave Cedar Oak Mesa the resources to maintain the quality of service afforded to their members. With his leadership, a very small rural system has been able to be financially and physically sound and prepared to handle emergencies and upgrades. He will be greatly missed by the system’s employees, customers and Texas Rural Water. Our prayers are with his loved ones. Answer to "From the Hole" math question from page 25: In Quench 2020 Issue 5, you were challenged to find the weight of water in a pipe, which we determined by first finding the cubic feet of the pipe, multiplying the cubic feet by the number of gallons that a cubic foot holds, and then finally multiplying the gallons by 8.34 to find the pounds of water. Here we determine gallons by dividing the pounds 2,500,000 by 8.34: 2,500,000 pounds (÷) 8.34 pounds per gallons = 299,760.192 gallons Next, you divide that number by the population equivalent that equates 130 gallons per person: 299,760.192 (÷) 130 = 2305.84763 gallons You can round that figure to the whole number of 2306 to get your answer.

Quench — 2021 - Issue 1

Advertiser Index

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RuralWaterCon

2 21

March 24-26 | Austin, TX

Water. The Source of Life.

2021 - Issue 1

Articles inside

Technical Corner: Getting the Lead Out

Assuring Safe Entry and Access to a water storage Tank

TRWA Briefs

Source Water Protection at State Parks

Water University: Supporting Industry Managers