DWGPD Order to Disinfect during COVID-19

The following is an email message sent to community and NTNC water systems on March 25, 2020.

To: Water System Operators and Water System Administrators and Staff
From: Drinking Water and Groundwater Protection Division

Re: Answers to Common Questions Pertaining to the Division’s Order for the Continuous Disinfection of Source Water for all Public Community and Non-Transient Non-Community Water Systems

On March 20, 2020 the Drinking Water and Groundwater Protection Division (Division) instructed all Public Community and Non-Transient Non-Community (NTNC) Water Systems, if they weren’t already doing so, to begin operating their permitted disinfection treatment facilities. This directive is based on an abundance of caution during the COVID-19 virus pandemic to ensure that the general public has a level of assurance that the water coming out of their taps is safe. Given the rapidly changing nature of the COVID-19 virus pandemic, the Division is concerned about a range of potential impacts related to operation of public water systems and protection of public health during this outbreak.  A properly operated disinfection treatment facility provides an additional layer of public health protection for the water system’s users, and the Division believes this additional protection is prudent and appropriate at this time. This pandemic has the potential to affect us all, especially those in our communities that may be immunocompromised. This measure will help to increase the public’s confidence in their drinking water supply. Below you will find the Division’s response to some of the overarching questions pertaining to the requirement for continuous disinfection:

Why has the Division issued this order?  
The Division issued this order to further protect water system users. If a user has COVID-19 virus, disinfecting the system will ensure that person’s immune system is not further compromised due to other pathogens that may be present in the drinking water. To clarify, disinfection is not being required because COVID-19 virus is in the drinking water. The COVID-19 virus has not been detected in drinking-water supplies. Based on current evidence, the risk to water supplies is low. This measure is being required out of an abundance of caution.

Can a water system operator be present at public water systems during social distancing requirements?
Yes. During the pandemic, it is important that public water system operators continue to operate and maintain their water system(s).  Operators should be mindful of following the social distancing recommendations from the Center for Disease Control (CDC). The operator should be allowed to enter the building after hours, to maintain social distancing.  Combining daily operational tasks with any water quality sampling should done to minimize presence at a water system, while still maintaining full active management of the public water system’s operation. The request for social distancing to reduce the incidence of COVID -19 should not realistically interfere with proper operation of a public water system, which is also of primary importance to public health.  Refer to Subchapter 21-12, Section 12.2.2 (b) of the Vermont Water Supply Rule (Rule), which lists the responsibilities of a public water system operator who has been put in responsible charge of the water system.

What is the timing of disinfection system activation?
Action should be taken as soon as possible.

Can I serve water if I cannot disinfect? If so, why the requirement?
It is important that systems continue to provide public drinking water services, which are vitally important to good hygiene measures.  To be clear, all public community and Non-Transient Non-Community (NTNC) water systems are required to have permitted disinfection treatment systems (refer to Subchapter 21-7 of the Rule).  Inability to operate disinfection treatment represents a significant sanitary deficiency for the Water System.  Any parts that are needed to make disinfection operable should be obtained as soon as possible. Please contact Vermont Rural Water or the Division immediately if you are unable to continuously disinfect. For those systems that cannot disinfect at the present time because they have only recently become public water systems and are currently coming into compliance, please work with Division staff to safely provide drinking water during this time.

Is UV suitable?
Yes. The approved, permitted disinfection treatment associated with a specific public water system is suitable for use, including previously permitted UV systems.  Per Subchapter 21-4 of the Rule, a public water system construction permit must be obtained before modifying a public water system’s infrastructure, including treatment components.

How long will this go on?
The timeline for all public community and NTNC systems to continuously operate their disinfection treatment is unknown; disinfection treatment should be operated until the Division notifies you otherwise in writing.  This is a rapidly changing environment and challenging for everyone; we will provide updates regarding this timeline as the situation evolves.

My facility is currently closed, does the Water System need to shock the well?
No, if the facility is not currently operating as a public water system, then disinfection is not required. Shocking wells is not required or recommended at this time.

Will my system need to monitor for Disinfection Byproducts (DBPs) if we don’t normally chlorinate and turn it on as a result of this directive? 
Not at this time.  Since this is a short-term directive, not expected to last for many months or longer, DBP sampling as a result of this directive will not be required.

Who is paying for the Water System to activate this?
The water system is responsible for routine costs associated with operating its disinfection treatment. The Rule clearly requires all public community and NTNC water systems to have the capability of providing disinfection treatment, and to operate the treatment when directed to do so by the Division (refer to Subchapter 21-7.2.2 of the Rule). Providing disinfection treatment is a fundamental principle of public health protection and a regulatory requirement for operating a public water system (community and NTNC systems).

What if the Water System can’t find a proper source of NSF approved chlorine?
The system’s approved Operations and Maintenance Manual should be referred to identify a vendor for hypochlorite solution.  Vermont Rural Water Association may also have information about vendors for public water systems.  All disinfectants and chemicals applied to the water must be NSF approved, as required by Subchapter 21-7 and Appendix A Part 4.3 of the Rule.  Vendors for public water systems have not reported supply issues. Inability to operate disinfection treatment represents a significant sanitary deficiency for the Water System.

Won’t requiring chlorination create more concern for customers?
The Division understands this concern. If customers express apprehension regarding operation of disinfection treatment, water system personnel should seize the opportunity to educate the users about the public health protection afforded by properly operated disinfection treatment. Chlorination sufficient to maintain a free chlorine residual to the ends of the distribution system is all that is required by the Subchapter 21-7 and Appendix A Part 4.3 of the Rule. For most groundwater systems it should be feasible to operate the disinfection treatment system with residual disinfection concentrations that are near the typical free chlorine taste and odor threshold of 0.5 mg/L.

Do not reply to this message. Please contact Dana Nagy at 802-477-3418 or dana.nagy@vermont.gov with questions.

Follow-up email sent March 27:

Recently you received information from the Drinking Water and Groundwater Protection Division including the directive to provide continuous disinfection at your public drinking water system.  For those that have been inquiring or wondering:  The requirement to provide continuous disinfection will stand until the end of the Governor’s Emergency Declaration.  Currently that is anticipated to be April 15, 2020, however, it may be extended as necessary.

As a reminder, information pertaining to the COVID-19 virus is available on the Division’s website, here: https://dec.vermont.gov/water/COVID-19-Response-and-Resources