Distribution System Regulations, Operations and Challenges

1. Distribution System Regulations, Operations and Challenges KY Water and Wastewater Operators Association 57th Annual Conference Louisville, Kentucky

2. Drinking Water Distribution System • “Distribution System” is not defined at the Federal or State level • Public water system means a system for the provision to the public of water for human consumption through pipes or, after August 5, 1998, other constructed conveyances, if such system has at least fifteen service connections or regularly serves an average of at least twenty-five individuals daily at least 60 days out of the year. Such term includes: any collection, treatment, storage, and distribution facilities under control of the operator of such system and used primarily in connection with such system; • KY distribution system sizes range from the “Big 3” to ones as small as a church or beauty shop

3. Staffing (401 KAR 8:030) Section 1(2) Staffing requirements.      (a) Water distribution systems. A water distribution system shall be operated by or under the supervision of a distribution system operator certified in a class equal to or higher than the class of the distribution system. (b) Combination water treatment plants and water distribution systems. 1. A combination water treatment plant or water distribution system shall be classified as Class IA-D, Class IB-D, IIB-D. 2. A system classified as a combination system in subparagraph 1. of this paragraph shall be operated by or under the supervision of an operator who holds a valid combination or separate water treatment and distribution system operator certificate of the appropriate class or higher and who shall be in direct responsible charge of the system. 3. A certified operator of a Class IA-D combination system shall be at the water treatment plant if water is being treated, unless the operator is performing other system-related duties.

4. Staffing (401 KAR 8:010) Section 1 (15) "Direct responsible charge" means personal, first hand responsibility to conduct or actively oversee and direct procedures and practices necessary to ensure that the drinking water treatment plant or distribution system is operated in accordance with accepted practices and with KRS 223 and 401 KAR Chapters 8 and 11.

5. System Infrastructure/Design (401 KAR 8:100) • Even if an operator is not intimately involved in distribution system design—the design affects operation and maintenance • 2007 Edition 10 States Standards • KY General Design Criteria • Infrastructure design can affect “concrete and steel” issues • Hydraulics --Storage • Pressure --Pipe material • Accessibility --Water loss/leakage • Breaks

6. System Infrastructure/Design (401 KAR 8:100) • How a system is designed also affects water quality and eventually compliance/public health • Accessibility • Water age • Storage • Disinfectant residual maintenance • Flushing • Breaks

7. Pressure • PSC Regulations 807 KAR 5:066. Water. • Section 5. Pressures. • In no event, however, shall the pressure at the customer's service pipe under normal conditions fall below thirty (30) psig nor shall the static pressure exceed 150 psig. • 10 States Standards:  Distribution System Piping and Appurtenances • 8.2.1 System Design/Pressure:  “The system shall be designed to maintain a minimum pressure of 20 psi at ground level at all points in the distribution system under all conditions of flow.  The normal working pressure in the distribution system should be approximately 60 to 80 psi”.

8. Pressure • KY Design Criteria Distribution System Pressure • Minimum system pressure for all conditions shall be 20 psi. • b. Water lines should be hydraulically capable of a flow velocity of 2.5 ft/s while maintaining a pressure of at least 20 psi. • c. When static pressure exceeds 150 psi, pressure reducing devices shall be provided on mains or as part of the meter setting on individual service lines in the distribution system. • d. The normal working pressure in the distribution system at the service connection should be approximately 60-80 psi and shall not be less than 30 psi under peak demand flow conditions. Peak demand is defined as the maximum customer water usage rate, expressed in gallons per minute (gpm), in the pressure zone of interest during a 24 hour (diurnal) time period.

9. Residential Pressure • Individual home booster pumps are not allowed or approved under 10 States Standards (Section 8.11.2) • “Individual booster pumps shall not be allowed for any individual residential service from the public water system mains.”

10. Storage • Balancing act between sufficient volume for demand, fire protection and regulations • DOW and PSC have an “average 1 day production” volume for storage • When does a system reach a point of “too much storage”? • Why is more storage/larger storage needed? • Issues with water age which leads to water quality problems (chlorine residuals, DBPs, tastes, bacteriological, nitrification) • Target 72 hour full turnover • Monitoring program (on-line instrumentation??) • Storage can also occur in oversized mains with little demand

11. Water Main Breaks (401 KAR 8:150) • Section 4. Disinfection of Treatment and Distribution System Facilities, New and Repaired Water Lines. (2) Line repairs due to breaks or ruptures. • Key items • Main break log required for all breaks • DOW notification if • Pressure in the area of the break falls below 20 psi or • Each system needs to define “area of the break”—Have a plan • The break takes longer than 8 hours to repair beginning when the system becomes aware of the break • All breaks require bacteriological samples • Not all breaks require BWAs

12. Flushing • Distribution system flushing is “recommended” • But a planned, correctly implemented program can prolong the life of a system and improve water quality • Key words—”planned”, “correctly implemented” • Can include “spot” flushing for isolated issues (customer inquiries) or for dead ends • Should not be for achieving compliance (i.e., flushing DBP sites 2 days before sample collection) • Coordinate with producer/purchasers

13. Water Loss/Water Audits • There are no KY regulations on how to assess water loss or conduct water audits • Water produced/purchased not sold or appropriately used is essentially lost revenue • No system can afford to waste money and that is what happens when water usage is not known • Tracking water loss is an eye-opening experience • Have to know where the water is going before you can proceed • Water loss does not equal leak detection • Water loss is not a “one size (%) fits all” program • Water loss is not solely the responsibility of the distribution operator

14. General Provisions (401 KAR 8:020) • Broad general requirements for all PWSs • Cross-connection control • No by-pass without Cabinet approval • Proper operation and maintenance of facilities • Report and record-keeping • Routine • Emergency • Advisories • Maps (sample sites) • O&M Manuals

15. General Provisions (401 KAR 8:020) • Broad general requirements for all PWSs • Flushing recommended • No introduction of a “substance that may have a deleterious physiological effect” • Use of certified labs • Use of approved chemicals • Proper disposal of chlorinated water • Water loading stations

16. General Provisions • Cross Connections • “A cross-connection shall be prohibited” • “Every public water system shall determine if or where a cross-connection exists and shall immediately eliminate it” • It means you have to have a plan or process for the identification and then the correction • Plan implies “written” (based on degree of hazard) • Correction/elimination implies “authority to do so”

17. General Provisions • Consumer (Boil Water) Advisories • Notification of customers, DOW and the public health department • 8:020 has direction on when to issue and how to notify DOW and the public heath agencies • DOW has revised the BWA Guidance Manual

18. Regulatory (SDWA) Compliance • Water quality compliance includes • Total coliform rules (monthly) • Disinfectant residual maintenance (daily/monthly) • Lead and copper (every 3 years June-September) • Disinfection by-products (quarterly/annually) • Public notification (when required) • CCRs (annually by July 1) • Asbestos (1st 3 years of a 9 year cycle) • MOR (monthly)

19. Regulatory (SDWA) Compliance • Also includes such requirements as • Lead Reduction in DW Act • Effective January 4, 2014 • Capacity Development • Technical/managerial/financial stability • Source water assessment • Potential EPA regulation/requirements • Tank maintenance rule

20. Regulatory (SDWA) Compliance • Maintaining compliance means having • Up to date sample sites and plans • Up to date maps • Standards (construction/instrumentation/material) • SOPs • Sampling, BWAs, notifications • Valve exercise, hydrant inspections, tank maintenance • Funding • Rates, budgets, grants, loans • Planning • Short term, long-term

21. Customer Relations • Who is your “customer”? • Paying water users (residential and commercial) • Wholesale purchasers or producers • PWS staff and management • Political management • Regulatory agencies • Fire departments • Tariffs/ordinances, bills, contracts, bid documents • Transparency • Workable

22. Customer Relations • Who is your “customer relations” staff? • Front line staff typically is the meter reader or distribution crew

23. Questions?? Comments?? Julie W. Roney Drinking Water Program Coordinator/DOW Julie.Roney@ky.gov 502/564-3410