COVID-19 INFORMATION FOR PUBLIC WATER SYSTEMS AND AFFECTED COMMUNITIES

PUBLIC WATER SYSTEMS

COVID-19 Survey - Water System Financial Impacts and Household Water Bill Debt Accumulation

Our goal is to gather data that will inform and prioritize state response and support complimentary efforts by local and federal partners. This data will assist us to work collaboratively to ensure that we continue to meet public health needs and support systems and communities to the greatest extent possible. All results published by the Water Board using this data will be anonymized and aggregated, however all data submitted will be considered public data and not confidential.

Division of Drinking Water Ongoing Regulatory Oversight

Per the Governor’s order, DDW staff are teleworking, managing urgent issues related to COVID-19 crisis as well as maintaining routine work overseeing public water system regulatory oversight. The Field Operations Branch offices are maintaining a skeleton staff at each location. Over the past several weeks, some significant new ways of doing business have been evolving at the Water Board to ensure core program activities and responsibilities of conducting inspections, issuing permits, and conducting regulatory oversight and enforcement continue.

The provision of potable water is an essential function

Public Water Systems (PWSs) should strive to operate as normally as possible, with as few disruptions as possible. Responsibilities to the public do not stop when disaster strikes, and customers need assurance that their tap water still meets state and federal drinking water standards. PWS operations are designated as essential functions and staff and suppliers are not restricted by any current orders.

First and foremost, keep PWS staff and operators safe and healthy; they are on the frontline of delivering potable water.

Notification from the SWRCB - UPDATED AS OF MARCH 20, 2020 Compliance with Water Board Requirements During the Coronavirus 2019 (COVID-19) Emergency - the Water Boards consider compliance with board-established orders and other requirements to be within the essential activities, essential governmental functions, or comparable exceptions to shelter-in-place directives provided by local public health officials - Water Boards COVID-19 Updates.

Revised COVID-19 SWRCB Guidance Memo to PWS

The Division of Drinking Water has placed the Public Water System COVID-19 Considerations guidance document online and will maintain it at this webpage location.

Resources relating to drinking water as an essential function:

The operation of PWSs and the implementation of all associated activities, (including regulatory oversight, inspections, operations & maintenance, treatment, sampling, laboratory analysis, and others) that support the continued delivery of potable water during this pandemic are essential functions. If the provision of drinking water is curtailed it could mean the unavailability of water for maintaining sanitation, basic hydration, fighting fires, cooling, dust suppression, and water protection of public health. That service must continue.

Friday, April 03, 2020, EPA released a template for water utilities to use to provide documentation to workers that are considered essential. This documentation could provide the necessary credentials for utility employees, contractors and vendors to remain mobile during this crisis.

Recent citations identifying water as an essential function include the following:

• From the Department of Homeland Security (DHS), Cybersecurity and Infrastructure Security Agency (CISA) - Information supporting the federal designation that drinking water is an essential function is provided at the following links:
  • https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19
  • https://www.cisa.gov/water-and-wastewater-systems-sector
  • https://www.cisa.gov/publication/guidance-essential-critical-infrastructure-workforce
• Governor Newsom Executive Order N-33-20 dated March 19, 2020  - all residents are directed to immediately heed the current State public health directives, which the Governor ordered the Department of Public Health to develop for the current statewide status of COVID-19 - consistent with the March 19, 2020, Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response, found at: https://covid19.ca.gov/.
• State Public Health Officer order all individuals living in the State of California to stay home or at their place of residence except as needed to maintain continuity of operations of the federal critical infrastructure sectors, as outlined at:
  • https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19
  • https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Immunization/ncov2019.aspx
• Crisis Event Response and Recovery Access (CERRA) Framework, a voluntary guidance developed for emergency response planners at the State, local, tribal, or territorial level and outlines a process for managing access into restricted areas or emergency zones during an incident – identifies utility responders, including water/wastewater personnel, as needing Tier 1 (highest or immediate) access during and following disasters

Being an essential function, those working in the water sector must be flexible and collectively work toward solutions to accomplish the essential tasks and maintain the essential services to which we have committed and of which our communities so critically depend upon.

EPA Resources – Incident Action Checklist - The USEPA developed a great tool and guidance for PWSs to consider in facing the challenges of Pandemic incidents, including the current COVID-19. The Incident Action Checklist (IAC) - Pandemic Incidents provides activities the water sector (drinking water and wastewater systems) can consider to prepare for, respond to, and recover from a pandemic crisis. It is one out of the 14 "rip & run" style checklists to help with emergency preparedness, response, and recovery activities for incidents such as pandemic, power outage, cyber, floods, and wildfires. The IACs are found on the USEPA webpage here - https://www.epa.gov/waterutilityresponse/incident-action-checklists-water-utilities. The USEPA conducted a webinar training on their Incident Action Checklist - Pandemic Incidents on April 7, 2020 that included a presentation from a small Midwest water system on what procedures and considerations they implemented in the face of COVID-19. The recording of the webinar can be found here - https://attendee.gotowebinar.com/recording/2756167094154416139.  The Pandemic IAC has multiple COVID-19 and emergency preparedness resource links available on the first and last page. The USEPA offers much guidance and resources to consider in meeting the challenges of COVID-19 that can be found here - https://www.epa.gov/coronavirus.

Communicating with Customers

Communicating with customers that their tap-water is safe to drink is critical. With shelter-in-place orders in place across California, people should know that they do not need to leave their homes to get bottled water when their tap water is readily available and safe.

• Customers should get their drinking water information from the PWS. The PWS is best equipped to provide honest and correct information regarding the water supplied to customers. Use email, bill mailers, and other established methods to communicate with and reassure customers on the status of the drinking water.
• Review emergency notification plans and ascertain that methods of communicating an emergency, like a boil water notice or water main break, are up to date and verify that the DDW District Office or county Local Primacy Agency contact information is correct. Verify contact information with all partners and stakeholders. If there is a problem with the water system, customers must quickly be made aware that the problem does not equal a risk of COVID-19 infection. For instance, if the PWS must issue a boil water notice due to a main break or detection of E. coli, the notice should be clear about the cause of the problem and should state that the problem is NOT related to COVID-19.
• There is no evidence that COVID-19 survives the disinfection process for drinking water or wastewater. California’s comprehensive safe drinking water standards include disinfection processes for drinking water which are extremely effective against viruses, including coronaviruses such as COVID-19.
• As of March 3, 2020, the World Health Organization said the “presence of the COVID-19 virus has not been detected in drinking-water supplies and based on current evidence the risk to water supplies is low.”
• Consider setting-up ways for customers to pay their water bill without violating the shelter-in-place order.

Monitoring and Sampling

Water and wastewater are critical infrastructure, and the maintenance of continuity of operations at PWSs is a critical essential function. Therefore, PWSs need to operate as normally as possible, performing all required monitoring and sampling, and continuing to provide potable water. The following are examples of actions that PWSs are expected to continue.

• Routine bacteriological monitoring must be continued, even if the PWS shuts down temporarily (e.g. school, restaurant). Continued bacteriological monitoring will help ensure that drinking water is safe to drink and allow for easier resumption of activities once the emergency has passed. If the PWS plans to shut down for a longer period and cannot conduct required monitoring, contact the DDW District Office or county Local Primacy Agency (LPA). Written approval from DDW or the LPA will be needed before the water system re-starts operation.
• Nitrate and nitrite are acute contaminants. Conducting increased source water monitoring, treated water sampling, and providing nitrate treatment must continue on the required schedule.
• The testing of water from treatment processes required to meet a drinking water standard is critical to ensure the water delivered to customers meets drinking water standards and must continue.
• Remain in contact with the accredited laboratory that regularly conducts analysis for the PWS to ensure that adequate capacity exists to process any samples. Investigate other local laboratories to ensure backup options are available.
• Find laboratories available to take new samples.
• For Routine Reduced Lead and Copper Rule monitoring, the triennial sampling can be collected between June 1 and September 30, so sample collection could be delayed until closer to the end of the monitoring period.  All samples need to be collected by September 30 so give adequate time to work with your customers on sample collection. 
• Sample collection sites for routine distribution system samples for the Total Coliform Rule, chlorine residual monitoring, Lead and Copper Rule water quality parameter monitoring, or Disinfection By-Product Rule monitoring may be temporarily modified to minimize contact with the public and maintain social distancing.  The PWS may not reduce the number of sites sampled. Requests to modify sample site locations must be reviewed and approved by the local DDW District Office or LPA representative prior to making changes to the approved sites. 

The Division of Drinking Water (DDW) recognizes that PWSs may face challenges during this crisis, including staffing and resource shortages.  If you have any specific issues that may interfere with your ability to maintain continuity of operations, including monitoring, testing, and treatment, please contact your local DDW District Office or LPA representative.

Continued Operations

Water systems need to take steps to assure their continued operation. Water systems that anticipate any difficulty with future operations or in meeting permit and regulatory requirements, including all testing requirements, need to contact their District Office immediately. Also consider:

• Communicate with neighboring PWS about resource sharing and mutual aid, particularly if a small PWS with few operators or use contract operators, and consider registering with CalWARN (www.calwarn.org), a statewide mutual assistance organization.
• Review and update any operations plans and provide instruction and training to operators to help improve redundancy.
• Ensure that any necessary chemicals or equipment are readily available and stockpile any extra materials as needed. Contact normal suppliers to verify that supply chains are still intact and their staff and operations are equally aware and prepared Encourage their likewise preparedness.
• Make sure important records are available to staff and consider storing those documents electronically and in a place that can be accessed outside of the workplace.

Continuing Cross-Connection Control Programs

Many of the greatest risks to human health from unsafe water have come from backflow events and inadequate or failed cross-connection control. Maintaining a cross connection control program is considered an essential function for the protection of the distribution system from contamination. The following activities should be maintained during the COVID-19 crisis:

• Any newly discovered cross connections must be corrected immediately to protect public health: locking out water meters while corrective actions are being taken would be appropriate if it is needed to prevent distribution system contamination.
• Backflow prevention device testing should continue as scheduled when possible. However, since testing is an annual requirement, PWS’s should consider providing flexibility to customers on device testing due dates, provided testing can be completed within the calendar year.
• Failed devices should be repaired or replaced immediately. PWS’s should consider providing assistance to customers to ensure testing and corrective actions can be completed in a timely manner, for example, device repair and replacement services when testers or contractors are not available, or customers are unable to coordinate.
• Recycled water use site cross connection tests should continue as scheduled when possible, but flexibility should be considered, provided they are completed within the calendar year.
• Backflow testers are essential workers, whether they are PWS employees, are contracted by the PWS, or are hired directly by customers.
• Most backflow devices should be in areas where maintaining safe social distance would not be a concern. For devices where a safe distance cannot be maintained (for example, interior devices) consider deferring those tests until later in the year and moving up other, safer test locations.
• If the PWS has customers that directly hire a backflow tester, typically from a provided list, and they cannot afford to pay for testing due to economic hardship, investigate having the PWS directly contract for the testing of those devices and recover payment through regular billing.
• In accordance with Governor Gavin Newsom’s Executive Order, customer shutoffs are prohibited due to nonpayment. The PWS should exhaust every avenue before shutting-off someone’s water during this emergency, and should do so only when the water system is under direct threat of potential backflow due to identification of a direct cross connection or failed backflow device that is not promptly corrected.

Reactivating Service and Operations

Some water systems may have shut down temporarily during the COVID-19 crisis. Similarly, some buildings and large service connections may have shut down or significantly reduce water use. Shutting down may result in various threats to water quality, such as depressurization, stagnation, loss of disinfectant residual, leaching of metals, and growth of harmful microorganisms such as Legionella. Public water systems that have shut down or plan to shut down should observe the following guidelines:

• Notify your DDW District Office/Local Primacy Office before shutting down or as soon as possible after shutting down.
• After a shutdown, you must obtain approval from DDW/LPA before resuming service as a public water system. Communicate with your DDW District Office/LPA as soon as you anticipate starting up to receive instructions on startup requirements.
• DDW has published Instructions for Seasonal Water System Shutdown and Start-up. These procedures specify inspection, flushing, disinfection, and sampling of water system facilities, and will be necessary to be implemented for water systems that shut down due to the COVID-19 crisis.
• The seasonal water system procedures include a certification form that may be used to notify DDW of a shutdown and to obtain DDW approval for startup.
  • Shutdown Notification & Start-Up Certification Form

Buildings and large service connections that shut down or significantly reduced water use have an increased risk of Legionella growth and leaching of lead and copper. Water systems should inform their customers of these risks and advise them to thoroughly flush stagnant water lines prior to restoring full operation if they have closed or reduced water usage. Customers should be directed to appropriate guidance, including:

• United States Centers for Disease Control and Prevention (CDC), Guidance for Building Water Systems
• Washington State Department of Health, COVID-19 Guidance for Legionella and Building Water System Closures
• ESPRI Building Flushing and reducing risk to staff
• EPA - Information on Maintaining or Restoring Water Quality in Buildings with Low or No Use
• Purdue University videos and resources – on the webpage, click on the COVID-19 Response in the middle of the page.
• AWWA and IAPMO released "Responding to Stagnation in Buildings with Reduced or No Water Use"