Important Guidance to Vermont Public Water Systems from DEC

This email was sent to public water system contacts by Jeff Girard on March 20, 2020.

Dear Public Water System Contact,

Due to the coronavirus (COVID-19) we are taking additional safety measures to protect our employees and customers and are now working remotely while focusing on keeping our normal business processes fully functional.  Please communicate with our staff electronically or via phone to the greatest extent possible since our processing of postal mail may be slowed during this period. Division staff contact information can be found online here:   https://dec.vermont.gov/water/contacts.  This email contains necessary information for how to interact with the drinking water program during this period.

Instruction to Disinfect

The Drinking Water and Groundwater Protection Division is requiring all community and NTNCs to disinfect, if not already doing so. The public needs to have confidence that their drinking water is safe and has been disinfected to inactivate any viruses or other pathogens that may be present.  We have learned that coronavirus is easily inactivated with disinfection.  Remember to take daily measurements of free chlorine residual at the end of the distribution system.

Water Conservation

During this time social isolation many of our Community Water Systems may see a higher-than-usual daily demand on their water system.  The DWGWPD encourages all community water systems to implement water conservation requests or requirements to your users.  All water systems should refer to the Water Conservation Program Section of your Operations and Maintenance Manual to implement these procedures.  

Water conservation or water restrictions can vary by water system or community and may include: 

  • Restrictions on non‐essential uses, such as lawn watering, car washing and washing sidewalks and driveways.
  • Restrictions on commercial car washes, nurseries, hotels and restaurants.
  • Restrictions on non‐recirculating car washes, laundries and decorative fountains.

Water conservation tips for homeowners can be found on EPA’s website here: https://www3.epa.gov/region1/eco/drinkwater/water_conservation_residents.html.  These tips include suggestions for shorter showers, only running dishwashers and clothes washers when they are full, and composting instead of using the garbage disposal.  Remind your users that every little bit helps and that we are all in this together.   

Lab Capacity at Department of Health Laboratory

As of the date of this email, the Vermont Department of Health Laboratory is not accepting water quality samples nor will it be sending out sample kits for the foreseeable future.  Water systems must contact other laboratories in order to obtain sample bottles and have analysis performed.  Endyne laboratory has confirmed that they are operational and have capacity to perform analysis on the samples that would otherwise have gone to the Vermont Department of Health.  Endyne’s website is here: https://www.endynelabs.com/. If you decide to utilize another lab, it must be certified for the analytical method being used.  A list of certified labs is available here: https://www.healthvermont.gov/sites/default/files/documents/pdf/PHL_DW-Certified-Labs.pdf.

Electronic Submissions of Source and Construction Permit Applications, Bottled Water applications, Operator Certification Renewal

To the maximum extent possible, we are asking systems to submit documents electronically.  For source and construction permit applications, Bottled water documents, and operator certification renewals and payments, please see the link below, from which you can register an account in order to submit both documents and associated fees. https://anronline.vermont.gov/?formtag=DWGWPD_Intake

Electronic Submission of other documents

To the maximum extent possible and for the time being, we are asking systems to submit all other documents electronically as well.  This includes sampling plan forms, public notice documents, sanitary survey response letters, and water quality results, to name a few.  These documents should be emailed to the responsible staff who will process the documents accordingly.  For a listing of Division staff and their respective responsibilities, the staff contact information can be found online here:   https://dec.vermont.gov/water/contacts

Impacts to Water Quality Sampling

It is expected that all sampling will be performed on time and will meet the objectives of each regulation and conform to the Water System’s obligations under the Water Supply Rule.  If you are unable to access approved sampling locations, the following is guidance on how to proceed. We understand that much of the current situation remains unknown and may change quickly. We will reach out to water systems with any updates as they become available.

It is expected that water operators will exercise good judgement in their discretion of where to sample for all water quality sampling and that the objectives of the regulations in the Water Supply Rule and Safe Drinking Water Act are met if an approved location is not able to be accessed for sampling.  If you have further questions about sampling, please see the Division contact page and contact staff directly: https://dec.vermont.gov/water/contacts

Revised Total Coliform Monitoring:  Your approved sampling plan has approvals for alternative sites, and these should be used if you are unable to access the primary site.  If your plan does not have these approved alternate locations, or if the alternate location is also not accessible to collect a sample, you may collect the sample at the nearest available sampling location that is representative of the water quality in that part of the distribution system.  This may mean going next door, across the street, or in another part of the building that you are able to access. This permission will last as long as the Governor’s Emergency Proclamation and does not require prior approval from the Division.  The same applies to repeat sampling locations in the event of a routine sample positive sample. Please be sure to write on the Chain of Custody/Laboratory form where the sample is actually collected.

Disinfection Byproducts Monitoring: every effort should be made to adhere to the approved sampling plan.  If this is not possible, please contact Amy Galford to discuss sampling options.  Amy can be reached at amy.galford@vermont.gov or 802-585-4891.

Lead and Copper Rule Monitoring: Lead and Copper samples are required to be collected from approved sites which meets the Tier criteria established in the federal regulation.  If your system does not have an approved sampling plan, contact Amy Galford. When sampling for lead and copper, make sure only to sample at occupied locations that have seen recent, normal use.  Do not wait until the end of the monitoring period to collect your samples.  Systems need to sample at approved locations only; if there are not enough approved sampling locations, please contact Amy Galford (contact info above) to discuss sampling options.

Entry Point Monitoring: It is the expectation that the entry points to the distribution for entry point monitoring (VOCs, SOCs, PFAS, Radionuclides, etc.) will remain accessible to operators.  Should this not be the case, please contact Janelle Wilbur at Janelle.wilbur@vermont,gov to discuss other sampling options.

 

Operator Certification

Operator Certification Renewal:  We are actively working with the Vermont Rural Water Association to continue to provide required trainings, likely with some or all trainings in the foreseeable future being provided online.  While we understand that not everyone has access or the ability to stream training sessions, we are hoping that this will still be a viable option for many operators.  As you are aware, certified water system operators are required to submit to the Secretary, at least 30 days before the expiration date of their operator certificate, a completed application on the form approved by the Secretary, including any fee due, and certifying that the continuing education requirements of Section 12.11 have been fulfilled.  Because of the current state of emergency caused by the COVID-19 pandemic, the Department of Environmental Conservation recognizes that it may be difficult to complete the continuing education requirements prior to the submission of the application.  In recognition of this situation, if you are unable to complete the continuing education requirements, please submit the application and indicate that you have been unable to complete those requirements.  DEC will deem all such applications administratively complete and will extend the certification.  All operators who submit such an application shall submit an amended application within 120 days from the date that the state of emergency is lifted verifying that they have completed the continuing education requirement, unless they have done so earlier.

Operator Certification Exams: The operator certification exams scheduled for May 1, 2020 have been indefinitely postponed. We hope to be able to reschedule the exams and will be in contact further once we have more information.

Main Phone Line Coverage

During this time, the main phone line will not be routinely staffed. Instead, voicemails left for this number will be routed to the appropriate staff member.  It is encouraged that you attempt to contact the responsible staff directly. We will do everything we can to respond in a timely manner and appreciate your patience.

VT WARN:

DEC Staff are working in collaboration with EPA Region 1 and the Vermont Rural Water Association (VRWA) to revitalize and activate VT WARN. It is expected that VT WARN will be able to provide a pool of available operators and essential equipment should the need arise to assist other communities.

VRWA is compiling a list of water and wastewater operators who are willing to serve as substitutes in the event that a system’s personnel become sick.  Please contact VRWA for more information at: https://vtruralwater.org/vt-warn/

Customer Communication
If you read the resources linked below, you will see that COVID-19 has not been detected in drinking water.  The Centers for Disease Control and Prevention (CDC) states that conventional treatment methods that use filtration and disinfection should remove or inactivate the virus that causes COVID-19. So long at the water system is operating in compliance with its Permit to Operate, there should not be any risk through drinking tap water.  The State is looking to provide outreach on this topic to the general public, however, directly working with your customers would go a long way to address concerns and improve consumer confidence.

2019 Novel Coronavirus (COVID-19) Resources for Drinking Water System Owners and Operators

For additional information on COVID-19, please follow the links below.
Vermont Department of Health
American Water Works Association (AWWA) 
Coronavirus Webpage
Association of State Drinking Water Administrators (ASDWA) 
COVID-19 Resource Page
CDC 
Water Transmission and COVID-19: Drinking Water, Recreational Water, and Wastewater—What You Need to Know
COVID-19 Preparedness for Water and Wastewater Systems