Operations at Ohio Public Water Systems during COVID-19 Pandemic
Conditions may change as this situation evolves. Ohio EPA will continue to monitor the state and federal orders and will adjust our response and direction accordingly. Every effort should be made to comply with all requirements. Ohio EPA will work with systems as this situation progresses and may utilize enforcement discretion during the State of Emergency. Appropriate documentation is necessary.
The operation of public water systems by trained operators to ensure Ohioans are provided with safe drinking water is a critical public health-related responsibility. Certified operators are public health officials and should be performing their civic duty to protect public health and safety during this declared emergency. Professionals need to make sure safe drinking water is being produced and delivered to customers and sewage is being treated. Ohio EPA expects public water and wastewater systems to do their best to provide appropriate staffing for their facilities.
Recommendations for certified operators and systems:
- Have backup staff identified in the event personnel become sick.
- Perform solo visits. Practice social distancing.
- Stagger visits – visit systems in times when other individuals are not present (outside normal working hours for non-community systems)
- Have contingencies in place (appropriately certified professional backups, certified professional operators, personnel knowledgeable of the system)
- Disinfecting common surfaces before and after shift changes
Please note public water systems that are not producing water are not required to have staffing or daily visits. Wastewater systems that are not discharging have provisions that can be implemented that will greatly reduce any visit requirements.
The production and delivery of public water by community water systems is a priority. In case the tools above cannot be used, contact your Ohio EPA District representative as soon as possible and Ohio EPA will work through the situation with you. In the event all of the measures fail and public water and wastewater systems are unable to meet their requirements the Ohio EPA may use enforcement discretion in dealing with these situations.
During the State of Emergency, Ohio EPA may use our enforcement discretion, but will continue to ensure safe public water is being produced and delivered to customers in Ohio. This is a matter of public health and Ohio EPA will work with the Administration to ensure these public health officials can perform their civic duty.
- Every effort should be made to have the Operator of Record (ORC) perform visits. If circumstances arise that require another approach, please contact your district office representative by email for other accommodations.
- Have backups, stagger visits and do visits solo – avoid social interaction.
- Be sure to document operational changes and communicate significant changes to your Ohio EPA representative.
- Water systems may cease reporting minimum staffing times on their Monthly Operating Reports (MORs), but must continue to maintain log books on site.
- If the system is closed and not producing water, you do not need to visit. Just note the facility is closed.
Ohio Public Water System Operator Guidance
We are all aware that providing safe drinking water is an essential public health service. We appreciate the efforts being taken by all public water systems across the state to ensure Ohioans have continued access to safe drinking water, particularly during the COVID-19 state of emergency. We will continue to face challenges during this time and will work together to ensure systems are capable of providing service to meet this important public health responsibility.
At this time, Ohio EPA is not considering approval for reducing minimum staffing requirements. We have sent a blast email to all systems and operators of record to review their contingency plans and ensure they have adequately addressed absence of an operator. We are encouraging systems to make arrangements with neighboring utilities, professional organizations, become members of Ohio WARN, or have discussions with contract operators to provide backup operators as necessary. Ohio EPA urges systems to isolate healthy staff at their facility and take any other actions that ensure the protection of public health by providing safe drinking water.
Larger systems should consider sheltering healthy operators on site at the utility, creating operating teams and staggered shifts that minimize contact between other personnel.
Provisions in the rules allow Class 2, 3, and 4 systems to be operated for up to 30 consecutive days by an operator with one classification less than the plant. Systems that have operators that meet these parameters have the flexibility to stagger as appropriate to ensure the safety of all of their operators.
In the event a system enacts their contingency plan due to illness of their operator of record or backups, contact their your local Ohio EPA representative via email.
Ohio EPA will continue working closely with systems and will continue evaluating areas of regulatory flexibility, where possible, to assist entities in alternative approaches to maintaining compliance, such as extending reporting deadlines and exercising enforcement discretion. In situations where regulatory alternatives are authorized by Ohio EPA, water systems need to document the measures taken to ensure appropriate oversight of the water system.
We recommend people routinely check this web page for updates and new information. Ohio EPA is committed to working closely with all of you to ensure safe drinking water for Ohioans.
Designating Essential Employees and Service Provider (3-23-2020)
Ohio EPA has received questions regarding essential employees and suppliers/contractors that may be vital to ensuring water and wastewater facilities continue operating during periods of emergency.
Ohio EPA would provide the following guidance:
Municipal systems (village, county and city) should have a process in place to designate essential employees and provide credentials identifying them.
Utilities should review their contingency plans and identify material suppliers, labs, contract operators, etc. that are essential to ensuring the continuing operation of water and wastewater facilities. Once identified, utilities should reach out to those suppliers and ask them to join the Ohio Public Private Partnership(OP3) by going to the following weblink : https://homelandsecurity.ohio.gov/op3.stm and clicking the link to join the partnership. The location is demonstrated in the screenshot below.
In the event of an emergency declaration that limits travel, membership in the partnership will give the suppliers, labs, certified operators, etc., the ability to request approval and credentials as essential to the treatment of water or wastewater. These credentials will allow them to continue to provide the services necessary to keep water and wastewater facilities functioning.
Private utilities, contract operators and Water and Sewer Districts should take the same steps outlined above for joining OP3.
For seasonal public water systems (PWSs) that are moving their opening date and have not yet completed the startup process and submitted their startup certification:
- Notify your Ohio EPA district office that you have pushed back your opening date.
- After notifying the district office of your new opening date, complete the startup process and submit the startup certification form by the “new” opening date.
For seasonal PWSs that have completed the startup process and submitted startup certification to their district office, are currently closed due to COVID-19, AND people (staff, public, etc.) have access to the water at the PWS:
- Notify your Ohio EPA district office of your status.
- Continue to monitor in accordance with your monitoring schedule.
For seasonal PWSs that have completed the startup process and submitted the startup certification form to their district office, are currently closed due to COVID 19, AND people DO NOT have access to the water at the PWS:
- Notify your Ohio EPA district office, in writing, with documentation/explanation that no one has access to the water at the PWS.
- When your PWS reopens to public/staff access, the system should flush the distribution system and resume monitoring. Contact your Ohio EPA district office for guidance.
- If you have depressurized your system during the COVID-19 closure, the startup process will need to be performed again including submittal of a new start up certification form BEFORE opening the business.
For seasonal PWSs that have decided to not open for all of 2020:
- Notify your Ohio EPA district office, in writing, of your intent to not open in 2020.
- Submit a deactivation form to your Ohio EPA district office.
- The reason for deactivation should indicate ‘COVID-19’ on the form. The form does not need to be notarized for this specific deactivation form submittal.
When notifying your Ohio EPA district office in writing, please contact your inspector through email, since Ohio EPA staff are currently working remotely (email: firstname.lastname@example.org).
The May 6, 2020 water and wastewater examinations have been postponed and will be rescheduled once the Governor’s State of Emergency ends. Applicants have been notified of this postponement via email and will receive notification of the new examination date once it is established.
Ohio EPA is receiving inquiries regarding the cancellation of in person trainings due to precautions being taken to address COVID-19. Operators are asking what options are available to receive training necessary in the event they have a certificate that is due for renewal at the end of this year.
There is a large inventory of either correspondence or online training approved for operators to use. We maintain a list of internet and correspondence training providers at the following link: https://epa.ohio.gov/Portals/28/documents/opcert/Internet_and_Correspondence_training.pdf.
If you would like to obtain contact hours during the period precautionary measures are being taken, we would suggest contacting the training providers on the above referenced list. If you wish to develop your own internal or internet based courses you may submit an application for approval through the Ohio EPA ebusiness center. Directions for doing this can be found under the ebusiness tab on the Operator Certification webpage. Ohio Administrative Code Rule 3745-7-15 contains the criteria for approval of web based course approvals.
For more details, please visit the Operator Certification webpage.
Laboratory Collection Services
This list reflects comments received from sample collection services on March 30, 2020. As COVID-19 response evolves, we recommend calling services directly and inquiring about current procedures. Many of the services on this list indicated that they have made some changes or plan to make changes in the near future (for example, operating with reduced hours or changing drop-off procedures to allow social distancing).
Certified Drinking Water Labs
This list (updated April 2, 2020) is for Microcystin, Total Coliform, Nitrate, Lead and Copper, and Operational Parameters. If you are looking for a certified drinking water lab to analyze for a contaminant not on the list, please go to epa.ohio.gov/Portals/28/documents/labcert/Combined-Lab-List.pdf.
Ohio EPA Laboratory Certification Program
Laboratory Certification staff are currently working from home. During this time, we will not be doing on-site inspections; however, please continue to submit renewal applications as required, ensuring that applications are submitted to the DWLABCERT@epa.ohio.gov email address. Applications will continue to be processed. We will extend certification and interim authorization expiration dates until such time we can perform an on-site inspection.
In order to ensure continuing production of safe drinking water and to help Ohio's certified drinking water laboratories continue required analyses during the current state of emergency, Ohio EPA Laboratory Certification (Lab Cert) is temporarily offering the following options – with approval by Lab Certification:
- If neighboring systems have analysts currently certified by Lab Cert for the same methods, they may temporarily perform analysis at labs using the same methods.
- If this occurs, documentation must be kept by the lab(s) using outside help.
- Once the emergency has subsided, a copy of the documentation must be filed with the laboratory’s bench sheets and a copy must be emailed to DWLABCERT@epa.ohio.gov.
- The previous certification of an individual to perform plant control tests [for the same method(s)] may be considered for reducing the number of samples required to obtain Interim Authorization for operational certification.
- For HABs, submit an MDL with data for each analyst seeking certification.
- If all the above scenarios are exhausted, Lab Cert has created the option of a virtual survey.
- This option requires submission of an application to “Add Analyst(s)”.
- After review and approval of the application, a virtual survey will be scheduled.
- The results of the virtual survey will be confirmed via an email.
- No certificates will be issued.
- Once travel restrictions are lifted, Lab Cert will contact you to follow up with an on-site survey (if certification is desired to be continued).
Please direct any questions to DWLABCERT@epa.ohio.gov.
For the latest information about COVID-19 in Ohio, including public health orders, please go to coronavirus.ohio.gov.
If questions/issues arise regarding required public notices for your public water system, please contact your Ohio EPA district representative and/or the respective program coordinator, in Ohio EPA's Central Office, for more guidance.
Note: Due to most Ohio EPA staff working remotely, we are asking that all 2019 Consumer Confidence Report draft reviews and/or submittals be sent via email to email@example.com. All questions regarding CCRs at this time should also be directed to that email address as well.
Modifications to Total Coliform Sample Siting Plans During COVID-19 (4-10-2020)
Ohio EPA understands that the unprecedented circumstances of the COVID-19 outbreak, including the need to restrict unnecessary travel and adopt social distancing practices, has impacted operations at public water systems (PWSs). Ohio EPA has been and will continue working to ensure that we are responsive to these circumstances by providing the needed regulatory flexibility while protecting public health and safety, including our responsibility to ensure the provision of safe drinking water to Ohioans.
One area that some PWSs are experiencing issues with is the lack of available routine total coliform sampling points. The Revised Total Coliform Rule (RTCR) requires PWSs to follow a written sample siting plan (SSP) when monitoring for total coliforms. A PWS is required to update their SSP should sampling points become unavailable and those changes may be reviewed by Ohio EPA.
Any change made to your SSP must be representative of the water quality in your distribution system including continued monitoring in different pressure zones, areas around elevated storage tanks, low use areas and extended waterline areas.
If your PWS has identified a need to modify the SSP due to the COVID-19 pandemic, the following criteria would require a submission, review and acceptance of the modification:
- A new sample site that is representative of the water, but is greater than 5 service connections, a city block or similar equivalent away from the original routine site,
- Repetitive sampling at the same sites at regular intervals (such as weekly at the same location due to limited sample sites), or
- From non-routine sample points (hydrants, outside spigots, etc.).
Submit documentation regarding the changes you are proposing to your Ohio EPA district inspector.
Please submit the following in an email to your Ohio EPA district office inspector:
- Briefly describe any methodology(ies) changes you are enacting. These may include the following: utilizing outside taps, utilizing fire hydrants, resampling at accessible taps, and additional alternatives. The sites chosen must be representative of the water quality within your distribution system.
- Provide a list of new sampling sites/taps and provide an updated map which identifies their locations. If supplying a map is not available, then identifying which sample sites are unavailable and which sites/taps are the replacements. If maps are available, please include them.
- If your methodology includes utilizing the same available taps repeatedly, provide the sampling frequency at those taps, i.e. weekly, biweekly.
If your methodology includes sampling at outside taps, whether at new sites or at your original TC sampling sites, Ohio EPA encourages you to flush and utilize appropriate sample collection methods including disinfection of the tap. The sampler should ensure they are obtaining an adequate chlorine residual prior to sampling and be cognizant of weather conditions when sampling from an outside tap. Identify the sample is from an outside spigot on the lab submission sheet reported thru eDWR.
Ohio EPA does not recommend TC sample collection at hydrants. If your methodology includes the use of fire hydrants, Ohio EPA encourages you to utilize hydrants that are routinely exercised to prevent malfunctioning of a seldom used hydrant and possibly causing a bigger problem. Please note you will need to provide an identifier for each hydrant used because most hydrants do not have an associated address; include that identifier on the reporting submission sheet reported thru eDWR.
RTCR requires a total coliform SSP identify the 3 repeat locations for each routine site used. In lieu of identifying specific sites, a PWS can specify criteria for selecting sampling sites on a situational basis in an SOP. Please submit an email with “Updated Sample Siting Plan.” Your submittal will be reviewed by your Ohio EPA inspector.
Required Public Water System Monitoring (4-3-2020)
Public Water Systems are required to conduct routine compliance monitoring at the water treatment plant and in the distribution system. As of today, U.S. EPA has not provided any relief on federal requirements; however, Ohio EPA is considering the potential COVID-19 exposure risk to homeowners and water plant personnel, and is offering the following recommendations and options for flexibility.
4-3-2020: For systems that are completely closed for the entire monitoring period, contact your district representative. Water samples for systems that are completely closed for the monitoring period will not be required. However, prior to re-opening and serving water to the public, a special or routine total coliform sample must be collected with negative results.
Disinfection By-Products (DBP)
DBPs – Most systems are scheduled for the first 2 weeks of a month during each quarter, so the number of systems that have not sampled in the 1st quarter of 2020 due to COVID-19 concerns is hopefully small; however, distribution crews should focus on emergencies, line breaks, maintaining chlorine residuals, and Total Coliform sampling.
- Public water systems can utilize alternative sampling locations, such as sampling at locations close to the usual sample locations that are accessible, at hydrants, pump stations or tanks. Please contact your district office representative via email and Ohio EPA will work with you on a temporarily revised sampling plan.
- To find a temporary revised sample monitoring plan, please go to: https://epa.ohio.gov/ddagw/pws#113432745-monitoring-and-reporting, scroll to the "Stage 2 Disinfection Byproducts Rule" section, and find the template for the Public Water System's source and population. Once the form is filled out, please contact your Ohio EPA district representative for further guidance.
Lead and Copper (PbCu)
- Special purpose monitoring for main breaks. Public water systems can offer filters to address lead and copper concerns during main replacements/breaks/disruptions and will not be required to take special purpose lead and copper samples so long as filters are offered.
- Routine PbCu monitoring. Systems have until June 30 to complete six-month monitoring period sampling, so sample collection could be delayed until closer to the end of the monitoring period. If you do collect a sample and the lab provides you with the results, then consumer notice would be required. A total of 92 systems are required to report during this period.
- Routine water quality parameter monitoring. Sampling at a hydrant nearest to the normal sampling point would be acceptable. Contact your District Office via email if there are any changes.
Bacteria and Chlorine Residual
Public water systems can temporarily modify sample siting plans to minimize contact with the public. Notify your district representative via email of these changes. Chlorine residual monitoring can be collected at a hydrant, pump stations and elevated and ground level tanks; however, these locations should not be primary alternative selections to routine monitoring locations. Hydrants could produce false positive bacteria results that public water systems would need to address. As always, when sampling for coliform bacteria, community public water systems and non-transient non-community public water systems with population >1,000 must collect chlorine residuals.
Distribution fluoride monitoring may be suspended but must continue at the entry point to distribution.
Manganese Monitoring in Surface Water System
Ground Water systems with Iron and Manganese removal should continue to monitor for iron and manganese. Surface water systems not feeding permanganate and with historical results below the secondary MCL of 0.05 mg/L may cease weekly manganese sampling. Please contact your district office representative via email to verify your ability to cease sampling.
Reporting related to MCL, HAL or ALE exceedances and surface water monthly operating reports (MORs) should meet current requirements. However, Ohio EPA will be flexible with other reporting requirements and non-surface water MORs may be submitted by the end of the month if results are within acceptable ranges.
Conditions may change as this situation evolves. Ohio EPA will continue to monitor the situation and will adjust our response and direction accordingly.
Backflow Prevention Program During COVID-19 (4-6-2020)
The PWS should continue to make every effort to comply with Ohio EPA regulations (Ohio Administrative Code (OAC) 3745-95), and any subsequent backflow prevention program related ordinances, standards or operating procedures. PWSs that are unable to comply with a requirement of the rules should:
- Notify their district representative of the situation or rule variation
- Submit a request for regulatory flexibility through Ohio EPA's Regulatory Flexibility form that can be found at https://epa.ohio.gov/covid19. Information to include in the request:
- State the specific regulatory or permit requirement which cannot be complied with
- Provide a concise statement describing the circumstances preventing compliance
- State the anticipated duration of time that the noncompliance will persist
- State the mitigative measures that will be taken to protect public health and the environment during the need for enforcement discretion
- A central point of contact for the PWS, including an email address and phone number
- The PWS should continue to administer their backflow prevention program by properly prioritizing degrees of hazard and situation specific levels of risk, evaluating service connection status, and documenting connections that become inactive.
- In the event a backflow preventer is not accessible for scheduled testing/inspection due to facility specific access restrictions, temporary closure, or other reasons relatable to COVID-19, documentation of the reason for not completing required tests/inspections should be provided by the customer and maintained by the supplier of water. The PWS must document what will be done to resolve the issue and follow through with the customer to ensure the test/inspection is completed as soon as it becomes possible.
- Service connections may be denied water service, or may continue to be denied water service, by the supplier of water in accordance with OAC 3745-95-08 in order to protect public health. Water service reconnection requirements and disconnection restrictions relative to HB 197 pertain to situations of customer non-payment only.
- If water service is being restored to a customer in accordance with HB 197/March 31, 2020, Director’s Emergency Orders, and the service is for a business or residence with an auxiliary water source(s), any backflow and potential contamination issues must be mitigated, and backflow prevention devices must be tested and found to be in working order prior to reconnection in accordance with OAC 3745-95.
- Many personnel accepted to test/inspect backflow preventers are considered “essential” service providers during the COVID-19 health crisis. If personnel availability is a concern, the PWS should work with the service provider to inquire about their “essential” designation status. The system should encourage their service providers to sign up for membership in the Ohio Public Private Partnership (OP3) at https://homelandsecurity.ohio.gov/op3.stm. Once they are a member they will be able to receive instructions on how to receive essential employee credentials.
March 24, 2020 - Due to the recent restrictions from COVID 19, hard copy detail or general plans will not be received by Ohio EPA. A Public Water System, or their representative, should only mail the fee upon request of the Agency. The detail plans, general plan, Water Supply Data Sheet and/or specifications can be submitted to DDAGW.Engineering@epa.ohio.gov either directly if less than 25 MB or through Liquid Files. If sending plans through Liquid Files you will be asked to provide an email address for an Ohio EPA staff person, please use firstname.lastname@example.org. Directions for submitting docs via LiquidFiles is available on YouTube.
If you currently have plans submitted, you can use the DDAGW.Engineering@epa.ohio.gov to inquire on the status or email the staff engineer directly who is reviewing them. If you are submitting a revised set of plans in response to comments, then please direct them to the staff person who signed the comment letter. If a fee is outstanding, the Agency will reach out to obtain it.
Once Ohio EPA is back to normal operation, this message will be removed and the previous procedure will be back in place.
If you need to submit a plan package via liquid files, please visit https://fileshare.epa.ohio.gov/message/new.