Consider how you will continue to provide an adequate quantity of safe drinking water to customers should your primary operator(s) become sick.  

Potential Action Items:  

• Review your Emergency Response and Operations and Maintenance Plans; make sure the plans are up to date.  
• Review and update your records for existing personnel, including key duties, essential functions and training/certification records. 
• Update contact information and cell phone numbers as needed.
  Identify any gaps in personnel and assess options for obtaining additional operational staff, such as relocating and training staff from other areas, or seeking additional staff as needed. Consider the benefits of your lead operator conducting training and a plant walk through with alternate staff before an emergency staffing limitation occurs. 
• Well-written standard operating procedures (SOPs) are a critical tool that can enable a properly certified operator from a neighboring system, or inadequately certified staff to temporarily operate your water system should your primary operator(s) become unavailable. Consider the following questions:  
• Where are your SOPs?  When were they last reviewed and updated by your lead operator(s)? 
• Do SOPs contain enough detailed information to be used by the alternate staff you plan to rely upon?  Who will make decisions regarding who can use these SOPs should your primary operator become unavailable?  
• If your primary operator is quarantined, but well enough to work remotely, do you have a plan in place for them to provide verbal SOPs and guidance to alternate staff onsite at the water treatment plant?  
• In order to reduce transmission of illness amongst your existing water plant personnel, ensure that your sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.  More information about these recommendations is available from the DOH at the above link.
  

Employee absenteeism at other interdependent sectors such as transportation, shipping, industrial equipment, chemical manufacturers and suppliers may limit and/or delay your ability to obtain essential operational supplies.

Potential Action Items:  

• Review and assess your inventory of essential treatment chemicals.  Do you have up-to-date contact information for an alternate chemical supplier? Verify if this alternate supplier’s current product list includes the NSF-approved chemicals which you rely upon. 
• Review and assess your inventory of essential plant equipment (e.g. chemical feed pumps).  Are adequate backup chemical feed pumps, rebuild kits, and/or spare parts currently on site? 
• If a vendor is unable to provide a critical component for a pump, would a neighboring water system have a spare?  Consider the benefits of developing mutual aid agreements with other facilities for equipment through Pennsylvania’s Water/Wastewater Agency Response Network (PaWARN).  Are you a member of PaWARN?  For more information, please visit pawarn.org or call 717-774-8870.
• Check your inventory and expiration dates of sampling consumables (e.g. sampling reagents, bottles, etc.).  How long would your current supply of sampling consumables last?  Attempt to identify an alternate vendor that may be able to provide specific consumables necessary for compliance monitoring samples.
• Consider ordering additional supplies of treatment chemicals and reagents, keeping in mind the shelf-life and expiration dates of existing stock and any additional quantities you purchase.
• Are key staff with purchasing capability available to make purchases during afterhours or weekend emergencies?  Has the board provided prior approval for emergency purchases of supplies, chemicals and equipment?
  

​Capacity:

• Employee absenteeism or supply chain shortages at your preferred water quality testing laboratory may temporarily limit their ability to process your routine compliance samples.
• Potential Action Items:  
• Consider identifying an alternate lab that is properly accredited to meet your specific water quality sampling needs.  
• Here is the link to the Accredited Lab database:  Accredited Lab Database 
  
• Instructions for searching the Accredited Lab database can be found at:  Accredited Lab Database Instructions 

Reporting:

• Laboratories should submit DWELR correction requests via email to ra-padwis@pa.gov.
• Laboratories are to use the email addresses listed above to satisfy the 24-hour written notification to DEP. Laboratories that need to report for an Out-of-state bottled water facility should send an email to the following address: RA-EPSDWOPSSECTION@pa.gov
• If your lab is experiencing limitations in their capacity to analyze drinking water samples, please email BSDW Operations Section at RA-EPSDWOPSSECTION@pa.gov. 
• If an accredited lab is collecting routine samples on behalf of a PWS, they will need to notify and coordinate with the PWS’s responsible official if they need to identify an alternate sampling location.  The PWS is responsible for notifying DEP of changes to sampling locations.
• By the 10th of the following month, report all data to DWELR as you normally would, remembering to use the new three-digit location ID when alternate locations were used.
  
• If you have any questions, please contact the BSDW Operations Section at RA-EPSDWOPSSECTION@pa.gov.  Please be as specific as possible in the information you are requesting so that we can direct the request to the appropriate staff person.
  

​Contacting DEP in a timely manner:

• It is very important to note that PWSs must contact DEP within one hour of discovering circumstances which may affect water quality or quantity.  This includes a failure, significant interruption or breakdown in key water treatment processes or a lack of resources that adversely affect operations, such as staff shortages, notification by the power utility of planned lengthy power outages or imminent depletion of treatment chemical inventories. 
• For any imminent threat (Tier 1) situation, the water supplier must also consult with DEP within 24 hours and issue Tier 1 public notification (PN) within 24 hours. To meet this reporting requirement, this webpage provides a list of emergency response contact numbers in your area.  

Public Notification (PN):

• Despite your best efforts, a breakdown in treatment may occur.  Accurate and timely communication with your customers is paramount, now more so than ever.  
• Is your SOP regarding issuance of PN up to date?  
• If you use an “auto-dialer”, when was the last time you updated customer phone numbers?  
• Do you have PN templates available and ready to be completed?  
• Some example Tier 1 PN templates can be found here: Tier 1 PN forms (scroll down to the Tier 1 PN forms; there are templates for specific situations such as high turbidity or failure to maintain adequate disinfection). 

Additional Information for Tier 1 and Tier 2 Public Notices: 

• It is important that consumers pay attention to public notices and not assume that every notice is due to COVID-19.  Therefore, until further notice, any Tier 1 or Tier 2 PN that is issued should include the following additional information:
• At the top of each notice (in both English and Spanish) add the appropriate statement for the notice you are issuing:
• Boil Water Advisory: This BWA is NOT related to Coronavirus.  Este aviso de hervir agua no está relacionado con el coronavirus. 
• Do Not Drink: This Do Not Drink notice is NOT related to Coronavirus.   Este aviso de no tomar no está relacionando con el coronavirus.
• Do Not Use:  This Do Not Use notice is NOT related to Coronavirus.  Este aviso de no usar no está relacionado con el coronavirus.
• Tier 2 Notice: This Public Notice is NOT related to Coronavirus.  Este aviso público no está relacionado con el coronavirus.
  
• For a Do Not Use notice, consult with DEP prior to adding the information below.  For all other notices, include under the “What You Should Do” section: 
• “According to the Centers For Disease Control (CDC), “COVID-19 has not been detected in drinking water.  There is no evidence showing anyone has gotten COVID-19 through drinking water, recreational water, or wastewater. The risk of COVID-19 transmission through water is expected to be low.”
• Therefore, this water can be used for handwashing.  As a reminder, CDC recommends “Wash your hands often with soap and water for at least 20 seconds especially after you have been in a public place, or after blowing your nose, coughing, or sneezing.”
  

During this situation, Community Water Systems (CWSs) should take appropriate steps to ensure continued operations with a focus on treatment efficacy for pathogens.  This includes properly operated filtration and/or disinfection practices under the Surface Water Treatment Rule (SWTR) and the Groundwater Rule (GWR).  It is expected that the treatment technique requirements under these rules will also provide protection against the Coronavirus. 

It is also important for all PWSs to continue to monitor and report as required under both the federal and Pennsylvania’s Safe Drinking Water regulations.  This includes maintaining treatment and ensuring sample collection and analyses are conducted as required. 

At this time, there are no exemptions for required monitoring, except for Noncommunity Water Systems (NCWS) that are not operating; NCWS are not expected to conduct routine monitoring while closed. There are however, some instances where water systems are allowed to identify alternate monitoring locations to collect the samples for required monitoring.

Alternate monitoring locations are allowed for the following:

1. Coliform & distribution system disinfectant residuals: PWSs must continue to collect the minimum # samples required (as specified in their RTCR/DRR sample siting plans), but alternate locations are allowed if a site is unavailable due to business closures/restricted access. 

• The PWS may identify an alternate sampling location that is most representative of the water quality at the unavailable routine location.  An alternative location can include an outside tap or other location that is lower risk for the sampler. Note that coliform-positive results and any follow-up actions required because of positive results (such as Assessments) will not be invalidated as a result of using an alternate location.  For alternate sampling locations located more than 5 service connections from the routine site: PWSs should designate a unique three-digit location ID number between 500 and 699 for the alternate location to be used for reporting to the Department.
• Use the same 3-digit code as the coliform sample to report both disinfectant residual measurements for routine and check samples.
• For further questions on monitoring, please contact your local DEP SDW staff.
  

2. TTHM/HAA5 (DBPs): Alternate sampling locations are allowed if routine sites are unavailable due to business closures/restricted access.   However, if the routine location is not available during the 7-day window specified in the monitoring plan, but is available sometime during that same calendar month, the PWS should sample from the identified routine location within the same calendar month.  If the routine location is unavailable during the calendar month identified in the monitoring plan, the PWS should select an alternate location.

• If the alternate location is representative of the same water as the unavailable location, use the same location ID as the routine sample site identified in the monitoring plan.
• If no alternate locations are available that are representative of the same water, the PWS needs to identify an alternate site that is representative of a high TTHM location or high HAA5 location, dependent on the reason for the original site.  For alternate sampling locations: PWSs should designate a unique three-digit location ID number between 500 and 699 to be used for reporting to the Department. 

Within 48 hours after having to collect coliform, disinfectant residual or DBP samples from an alternate location, the PWS should notify its local DEP Safe Drinking Water staff in writing (via email) to explain the circumstances that required the use of an alternate location. If you do not have an email address for the local DEP SDW staff, send the notice to the appropriate regional office email address: 

SERO:  EP-SDW-SERO-Notes@pa.gov     
NERO:  EP-SDW-NERO-Notes@pa.gov
SCRO:  EP-SDW-SCRO-Notes@pa.gov
NCRO:  EP-SDW-NCRO-Notes@pa.gov
SWRO:  RA-EPSWSDW@pa.gov
NWRO:  EP-SDW-NWRO-Notes@pa.gov

To identify which region your PWS is located, please visit the DEP Regional Offices webpage. 

Continue to monitor as required:

• Nitrate/Nitrite: Continue to monitor as required.
• Lead & Copper (LCR): Continue to monitor as required. System operators should be able to maintain social-distancing guidelines while dropping off and picking up sample bottles.
• IOC/VOC/SOC/RAD: Continue to monitor as required.
• Performance monitoring specified in a permit (to ensure treatment efficacy): Continue to monitor as required.
  

1. To the extent feasible under current circumstances, the Board encourages you to please consider online (e.g. web-based and correspondence) training courses to maintain your continuing education credits. Please note that there are currently an abundance of approved online training course options, including the following:   

• a. A drinking water operator in Pennsylvania can choose from 309 DEP-approved online courses which offer a total of 1,463 contact hours;
  
• b. A wastewater operator in Pennsylvania can choose from 317 DEP-approved online courses which offer a total of 1,261 contact hours; and
  
• c. For web-based and correspondence course options, please carefully review the “Message from DEP’s Operator Certification Training Section – Distance Learning Options for Continuing Education.”
  

2. Operators whose water and/or wastewater license expires on June 30, 2020 and are unable to obtain continuing education due to extenuating circumstances caused by COVID-19 must submit a request for extension until August 31, 2020. Upon submission of a valid request, DEP will grant the requested and limited extension to obtain all necessary continuing education credits. Extenuating COVID-19 circumstances include working extra hours, substituting for other operators, you or a family member experiencing illness, and/or limited internet access to online training courses. The Board is offering this extension option in order to assist you in maintaining your license. If you choose to apply this continuing education extension to your license, you must send an email with a short summary documenting your request along with your Client ID and Certificate number to RA-OperatorWebsite@pa.gov prior to June 30, 2020. Additional fees will not be charged for this continuing education extension. Please be aware that continuing education credits obtained from June 30, 2020 through August 31, 2020 will only be applied to your current cycle; these same credits will not be applied to your next license cycle which would end on June 30, 2023. If you have questions, please call the Operator Certification Board Secretary Laura Chambers at 717-772-5158.

Please note that the Operator Certification Board may update this message if necessary as the COVID-19 situation evolves.  Please check this website routinely for updates.

Web-based Course Providers:

• 360 Water
  
• American Water Works Association (AWWA) 
• CEU Plan
  
• EnviroSci Corporation
  
• FEMA National Incident Management System (NIMS)
  
• JADE Learning
  
• Pennsylvania AWWA 
  
• Pennsylvania DEP 
  
• Pennsylvania Rural Water Association (PRWA)
  
• Sacramento State – Water Programs (“Sac”)
  
• Vector Solutions
  

Correspondence Course Providers:

• Mike Nelson Consulting
  
• Sacramento State – Water Programs (“Sac”):  
  
• Skillworks
  
• Technical Learning College
  
• Water System Solutions, Inc
  

Additional resources specific to the water sector:

• Water Environment Federation (WEF) – The Water Professional’s Guide to COVID-19     
  
• EPA Pandemic Incident Action Checklist