PUBLIC DRINKING WATER Distribution System Optimization Strategies Environmental Trade Fair and Conference May 2019 Texas Commission on Environmental Quality Texas Optimization Program Charlie Middleton Hello, thank you for that introduction. Today, I will present information on distribution system optimization strategies.

Optimization Process Set goal. Repeat as needed. Develop sampling plan. Location and frequency Sample and record data. Determine baseline Baseline=normal conditions Determine triggers and actions Initiate sampling plan Sample to find areas that may differ from established baselines Review and analyze data. Troubleshoot. Identify factors that keep you from meeting the goal. Act on those factors. Modify operations, maintenance, communication Repeat as needed. Optimization means doing the very best we can with what we have to strengthen public health protection, by focusing on operations and maintenance, and goals and data. The first step in the optimization process is to set a performance goal for something you care about. Next, you need to develop sampling & monitoring plan, or revisit your existing plan. Next, figure out your baseline: determine current conditions and start tracking the data. Now that you have a data stream providing you with information, you can answer those critical questions, like “Do you meet the goal now?” If you don’t, you need to look deeply into the data to identify the factors that are keeping you from meeting your goal. Finally, when you have identified those factors, you need to control those processes. Process control is any activity required to develop a capable water system and take it to the desired level of performance. You are not done then, though. Optimization is an ongoing process. Decorative Images: A plant staff person pipetting stock solution in order to perform a jar test to make sure that the treatment process meets optimization goals. And, staff working together around a table with engineering plans, data, and reports, showing that distribution optimization is a group task, involving all the public water system's staff and management.

Why optimize drinking water? Because of the potentially devastating effect of illness. Since meeting the rules is the first step on the road to optimization, it is important to know and understand the purpose of regulations. In the broadest sense, Federal and state rules say that a public water system must provide “safe” and “adequate” water. The state and EPA go through rule making processes to make regulations that describe the specific minimum requirements for the parameters defining the terms “safe” and “adequate”. “Safe” usually refers to water quality and “adequate” usually refers to quantity. In the top left hand corner, the electron micrograph of an amoebic dystentary organism shows a globular, rounded organism with several protrusions. Dysentary can cause dehydration in infants, which can be fatal. The image of the typhoid organism in the center of the screen shows the capsule-like main portion with flagella about 5 times the length of the capsule, attached in rows of nine flagella on each side. The image in the lower right hand corner of a cholera organism shows a normal coliform like microbe, with a single flagella attached at one end. Although these organisms are invisible to the naked eye, they can have disastrous health effects.

What are we trying to optimize? We are partners in a shared goal: PROTECTING PUBLIC HEALTH Optimization (and best practices) accomplish public health protection through MULTIPLE BARRIERS to pathogens

Why optimize? We want to do a great job of protecting public health, so we are interested in optimizing barriers to pathogens (and other health risks). RISKS & BARRIERS: Source water Water treatment Water distribution Cross-connection control (the final barrier to exposing treated water to pathogens) In terms of specific distribution system barriers, here are some examples: Cross-connection control Flushing programs Disinfection Water age management (to reduce stagnation and DBPs) Pressure management (to avoid leaks)

Inadequate Treatment Multiple Risks  Source  Plant  EP  Distribution  Main breaks Poor Design  Distribution Plant Source Entry Point Inadequate Treatment Fecal Contamination  No/Poor Disinfection Cross Connection & backflow  Geological contaminants  SW GW

The Early Years Milestones 1920 – First Annual Waterworks Short School for Operators and Engineers 1935 – Social Security Act provided funding for the U.S. and State Health Departments 1937 – The first rules: Well construction, location, connections The history of optimization is the history of how we learned to keep our drinking water safe. The need for safe drinking water came before regulations. If optimization means going beyond the regulations, before 1937, all drinking water safety was optimization. Some milestones in these early years were: 1920 – First Annual Waterworks Short School for Operators and Engineers (11 registrants) 1932 – First well construction and setback requirements 1935 – Social Security Act provided funding for the U.S. Public Health Service to help fund State Health Departments 1937 – The first rules were adopted by the State of Texas

This graph shows the death rate for typhoid fever in the United States from 1900 to 1960. In 1900, the death rate from typhoid fever was about 30 deaths per 100,000 people. In about 1908, water systems started chlorinating to kill pathogens, including typhus. After chlorination started, the incidence of typhoid dropped, to about 8 deaths per 100,000 population in 1920 to about zero in 1948. This graph was provided by the U.S. Centers for Disease Control and Prevention, Summary of Notifiable Diseases, 1997. This graph shows the death rate for typhoid fever in the United States from 1900 to 1960. In 1900, the death rate from typhoid fever was about 30 deaths per 100,000 people. In about 1908, water systems started chlorinating to kill pathogens, including typhus. After chlorination started, the incidence of typhoid dropped, to about 8 deaths per 100,000 population in 1920 to about zero in 1948. This graph was provided by the U.S. Centers for Disease Control and Prevention, Summary of Notifiable Diseases, 1997. It provides an illustration that efforts to regulate drinking water and efforts to successfully protect public health can be effective, as typhoid was essentially eliminated in the U.S. by 1950.

EPA’s role After EPA’s creation in 1970, EPA played a greater role in drinking water regulation and optimization EPA established general requirements for all states, in addition to specific regulatory requirements: Capacity Development Operator Licensing & training EPA started helping states to help optimize public water systems

Texas Optimization Program The Texas Optimization Program (TOP) started in 1995 The primary goal of the TOP is to help Surface Water Treatment Plants reduce the turbidity (cloudiness) in treated water Turbidity includes pathogens like Cryptosporidium Initially, Texas regulators worked with the EPA to refine the Composite Correction Program: Comprehensive Performance Evaluations

Why not stick with surface water plants? The large number of groundwater systems Most disease outbreaks occur at groundwater systems Impact of disease outbreaks can be devastating! With the historical optimization focus on removing pathogens from surface water, you may ask why groundwater or distribution system optimization is important. Surprisingly, the most recent waterborne disease outbreaks have been caused by inadequately treated groundwater. And, there are about 20 times as many groundwater treatment plants than surface water treatment plants. Regardless of the water source, a disease outbreak is something that can be devastating: we want to protect against those.

Why optimize ground water and distribution systems? Wells can be vulnerable Especially to viruses Distribution systems are vulnerable Even if the water is perfect If you put clean water in a dirty glass, the water is no longer clean You may be distributing water from a wonderful, pristine well, or from a fully optimized surface water treatment plant. In that case, why worry about the distribution system? The issue is that the distribution system is a human-engineered system, and we know that those can be imperfect. If your distribution is a “dirty glass” it can actually degrade that pristine source water, even to the point of causing disease outbreaks. Regulations are a starting point for optimization. Some your normal regulatory activities will be a big help when you start your optimization program. Decorative Images: Image of anabaena bacteria which can grow in poorly maintained distribution systems, and which can be addressed through a successful distribution optimization program and an image of a badly corroded pipe showing how a poorly maintained pipe can be an environment where bacteria can grow.

Monitoring Plan Let’s talk about the monitoring plan.

Regulatory Controls to Help Optimize: Monitoring Plan Organizes information in one place Describes water quality monitoring Disinfection residual monitoring Disinfectant Level Quarterly Operating Reports Coliform monitoring Disinfection byproduct monitoring Distribution programs have monitoring, reporting, and recordkeeping requirements. For drinking water quality, the Monitoring Plan is a place where a PWS can organize all of the monitoring information in one place. It describes your water quality monitoring for residuals, coliform, and everything.

Dead-end main Flushing Let’s talk about dead end main flushing

Distribution Rules to Optimize: Dead End Main Flushing Dead End Main (DEM) flushing. Rules: 30 TAC §290.44(d)(6) Plan to eliminate dead ends, flush valves 30 TAC §290.46(l) Flush all dead-end mains monthly Public health purpose: By having and following a monthly dead-end flushing program, you ensure fresh water reaches potentially stagnant areas. You find potential problems, like nitrification. Monthly dead-end flushing has been a regulatory requirement since 1956. By having and following a monthly dead-end flushing program, you ensure fresh water reaches potentially stagnant areas. For optimization, consider Unidirectional Flushing (UDF). The reason for flushing dead-end mains is to ensure that fresh water is everywhere in the system, and that sediment is removed. Systems should indentify hydraulic dead ends, and consider monitoring and recording more than the data required by regulations, for example volume of water flushed, appearance, residual before and after flushing, date of flushing and location. ========================================================= Reference: “§290.46(l) Flushing of mains. All dead-end mains must be flushed at monthly intervals. Dead-end lines and other mains shall be flushed as needed if water quality complaints are received from water customers or if disinfectant residuals fall below acceptable levels as specified in §290.110 of this title.” “§290.44(d)(6) The system shall be designed to afford effective circulation of water with a minimum of dead ends. All dead-end mains shall be provided with acceptable flush valves and discharge piping. All dead-end lines less than two inches in diameter will not require flush valves if they end at a customer service. Where dead ends are necessary as a stage in the growth of the system, they shall be located and arranged to ultimately connect the ends to provide circulation.” “§290.46(f)(3)(A)(iii) the date, location, and nature of water quality, pressure, or outage complaints received by the system and the results of any subsequent complaint investigation; §290.46(f)(3)(A)(iv) the dates that dead-end mains were flushed; §290.46(f)(3)(A)(v) the dates that storage tanks and other facilities were cleaned; §290.46(f)(3)(A)(vi) the maintenance records for water system equipment and facilities.”

Distribution Rules to Optimize: Dead End Main Flushing Effective DEM flushing program: Sample--at least monthly Dead ends, tanks in distribution Communicate potential problems to management Keep adequate records to be able to identify potential problems Integrate disinfectant residual sampling with dead-end main flushing program Find beneficial uses for flushed water An effective DEM flushing program includes sampling each dead-end main at least monthly. It is a good idea to include tanks in this sampling plan. When any issues are found – for example when you can’t bring the residual up through flushing – those issues should be elevated to the system’s managers. Clearly, you should keep adequate records. With good record keeping, you will to be able to identify potential problems. Some opportunities for optimization include integrating disinfectant residual sampling with dead-end main flushing program and finding beneficial uses for flushed water

Disinfection Let’s talk about disinfection

Distribution Rules to Optimize: Disinfection Maintain minimum/maximum disinfectant levels throughout the entire distribution system. Public health purpose: Minimums Minimize growth of biofilms, and stop the regrowth of microorganisms in distribution biofilms. Inactivate pathogens. Maximums Potential taste and odor complaints No-observed-effect level in animals of 40 mg/L As it relates to public health protection, the purpose of maintaining minimum/maximum disinfectant levels throughout the entire distribution system in order to stop the regrowth of microorganisms in distribution biofilms, minimize growth of biofilms, and inactivate pathogens. As far as the maximums are concerned, the EPA rules reference taste and odor from high chlorine, and some animal studies. No human epidemiological data shows concern from the levels of chlorine or chloramine normally used in distribution systems. ============================================================ Reference: EPA says (in the Stage 1 Disinfectants and Disinfection Byproducts Rule preamble): “EPA believes that the MRDL of 4.0 mg/L for chlorine is appropriate to control for potential health effects (MRDLG is 4.0 mg/L) from chlorine while high enough to allow for control of pathogens under a variety of conditions. EPA also believes that compliance based on a running annual average of monthly averages of all samples, computed quarterly is sufficient to allow systems to increase residual chlorine levels in the distribution system to a level and for a time necessary to protect public health to address specific microbiological contamination problems and still maintain compliance. If a system has taste and odor problems associated with excess chlorine levels it can lower its level of chlorine. Since there may not be any health effects associated with taste and odor problems, EPA does not have a statutory requirement to address this concern.”

Distribution Rules to Optimize: Disinfection Note: Distribution system map and list of sites and frequency are part of Monitoring Plan. Sites representing the entire distribution system. Frequency: Weekly for systems with population <750. Daily for systems 750 or greater population Including weekends. Disinfectant Level Quarterly Operating Reports Submit quarterly (community) Just like most PWS sampling, you need to document the sample sites and frequency of disinfectant monitoring in your Monitoring Plan, including a map and list of sites. Systems should not look to remove sample sites from their Monitoring Plan that produce consistently or occasionally low residuals, but should investigate and if possible fix the cause of the issue in these areas. Sampling has to cover the whole system. In a tiny, compact system, you might be able to say that one site represents the whole system However, in most systems, and especially where there are multiple pressure planes, you probably need more than one site. Our guidelines are just like for coliform—any system should be able to identify five sites. Systems larger than 750 sample at sites representative of the distribution system daily, smaller systems sample weekly at sites representing the system. The data are sent to TCEQ on the DLQOR for communities and nontransient noncommunity systems. Transient noncommunity systems retain the information on site for review during Comprehensive Compliance Investigations.

Breakpoint curve: Example IF: Total Chlorine = 1.5 mg/L Total Chlorine Free Chlorine 2 Free Ammonia Mono-chloramine 1.5 Chlorine Residuals: Total and Species (mg/L) 1 This is a picture of the breakpoint curve. It explains why systems that use chloramines have to sample more than just Total Chlorine. If you just sampled for Total Chlorine, you would not know exactly where you are on the curve – there are three possibilities. Therefore, you must also sample for free available ammonia as nitrogen, monochloramine, and free chlorine. A bright pink dotted horizontal line is on the graph at 1.5 milligrams per liter. This line has three bright pink circles on it at the three points where it crosses the total chlorine residual line. What this shows is that if all you know is the total chlorine residual, there are three possibilities for where you are on the curve. This answers the question posed on the previous slide: No, you don’t have enough information if all you know is the total chlorine residual. Cl2:NH3-N ratio

Backflow prevention and Cross Connection Control Let’s talk about backflow prevention and Cross Connection Control Programs.

Regulatory Controls to Help Optimize: Cross-Connection Control Program A physical connection between any source of water treated to a lesser degree in the treatment process. Backflow: The undesirable reversal of flow in a potable water system. Backpressure: A pressure higher than the supply pressure that would cause backflow. Backsiphonage: Reduced or negative pressure in the supply piping. A Cross Connection Control Program protects against the intrusion of pathogens through cross connections, backflow, backpressure and backsiphonage. Every water system is required to have a backflow and cross connection control program. A healthy BF/CCC program can ensure safety from many types of possible contamination. The first step in having a good CCCP is to coordinate the different areas involved in the issue: The utility personnel who operate the distribution system, the plumbing inspection department, possibly code enforcement, fire protection, and backflow prevention service providers. PWSs should also ensure they have the authority to implement a CCC program using CSAs or an ordinance. Also mention looking for new hazards, tracking when BPATs tests are due, monitoring internal programs, and monitoring air gaps where they have been allowed, i.e private wells.

Underlying concepts Optimization means paying attention Operations focus For example: Doing preventive and corrective maintenance ensures that expensive equipment will last longer Monitoring, retaining, analyzing, and mapping data Baseline: Knowing where you are starting from: Determine what normal conditions are, which may or may not be current conditions Establishing triggers and actions for changing conditions after data analysis Troubleshooting: Only change one thing at a time Figure out what the result of that one change was before making the next one Document procedures to ensure consistent quality After thinking about the scope of regulation that exists, let’s return to the concept of optimization. In the concept of doing a great job of distributing drinking water, optimization means paying attention—Paying attention to potential risks from backflow or cross connection, paying attention to sampling results, and so on. It is especially key to focus on operations, because that is where success is cheapest – and can actually save money. For example: paying attention to preventive maintenance schedules ensures that expensive equipment will last longer, just like changing the oil in a car. Sometimes we don’t want to measure something, because we don’t want to advertise that things are not as good as they could be. But just think of it like a “before” picture. When we know where we are at, it is easier to get to our destination. Therefore, monitoring, retaining, mapping and especially analyzing data now will help you know where you are starting from. When you get ready to make a change based on your data analysis, use the principles of troubleshooting--only change one thing at a time and figure out what the result of that one change was before making the next one. Document procedures to ensure consistent quality

Underlying concepts Optimization means having a goal Regulations are a starting point Meeting the regulations ensures a basic level of compliance and public health protection. Optimization means focusing on the public health purpose behind the rules Industry best practice Meeting the regulations is a start – that is a passing grade. Optimization means having a goal that focuses your organization on the public health purpose behind the rules – not just regulations, but also industry best practice.

Underlying concepts Optimization needs the 3 Cs: Communication, coordination, and cooperation Routine communication minimizes misunderstanding. Cooperation keeps us moving in the same direction. And, coordinating resources saves cost. Optimization needs the 3 Cs: Communication, coordination, and cooperation. Routine communication minimizes misunderstanding. Cooperation keeps us moving in the same direction. And, coordinating resources saves cost. It is fun to do a great job together.

Contact Information Charles.Middleton@tceq.texas.gov (512)239-4724