Ask Larry

Ask Larry A Q&A column with TRWA Technical Assistance Director Larry Bell

:Is a public water system required to maintain a certain number of operators per the number of connections served?

A: The magic number of connections for determining the number of required licensed operators is 1,000 – once a system reaches that size, it is required to have at least two licensed operators on staff. For purchased water and groundwater systems, each of those operators must hold at least a Class “C” license and work at least 16 hours per month at the system’s treatment or distribution facilities (or their production facilities, in the case of groundwater systems). Surface water systems must employ at least one operator with a Class “B” or higher surface water license, and the other may hold a Class “C” or higher. Each operator must work at least 32 hours per month at the systems’ production, treatment, or distribution facilities, and both must complete TCEQ’s Surface Water Production I and II courses.

When I have asked TCEQ staff whether larger systems of, say, 2,000 or more connections need to have more licensed operators on staff, they say it depends on the system and cite me to their Rule 290.46, which contains the two-operator minimum requirements discussed above. I have advised systems that it is a best practice to err on the side of caution and maintain at least one additional Class “C” or higher operator in case the other two get sick or are otherwise absent at the same time. That way the other licensed operator can do the necessary process control and oversee all plant operations until one or both other licensed operators return to work. Managers and boards may want to consider adding an additional operator for every additional 1000 connections until you have 8-10 operators. Each water system is a little different when it comes to the number of operators needed due to the type of treatment required, level of system automation, etc. In the long term it’s probably best if you find a permanent operator of your own or contract with a company that provides those services, but there are some things you can do in the meantime to comply with TCEQ rules until you get that situation squared away. First, if you have a good relationship with a neighboring system who maintains more licensed operators than is required by TCEQ rules, it may be worth asking them if they can help you out until you’re able to hire another properly licensed operator yourself. As I mentioned previously, TCEQ recognizes part-time operators who work at least 16-hours per month as meeting their licensing requirement. This allows systems the flexibility to share their operator with their neighbors. Sometimes this may include an agreement that the operator’s primary system receive some form of reimbursement for time spent away from their normal duties there.

Other systems allow their operator to “moonlight,” or work normal hours there and then work after hours to assist a neighboring system until that system can secure its own operator. I have also seen systems enter into contracts with neighboring systems to implement a rotating schedule for their shared operator, like what an operations company would implement. This way, the operators are still completely working for your system, but the system is being paid a contracted amount for a specific period.

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Our system is looking at our longterm needs and we are trying to decide if we need a new well or possibly just additional storage and boosters. What kind of due diligence do you recommend we engage in as we go about deciding? A: A suggestion I usually give systems is that they obtain a system hydraulic analysis, which is conducted by the system’s engineering company. These studies usually include population projections, household income, current capacities, and a whole lot more based on the areas the board wants to be included in the study. Your engineering firm would need to confirm the system’s maps are current based on information provided by the system’s staff. Every public water system in Texas is required to maintain current maps and drawings of all new construction, meter installations, storage facilities, pumping capacities, and any other production or treatment facilities which have been completed since the system maps were last updated by the system or its engineer. The hydraulic analysis will show

the current distribution, production, treatment, pumping, and storage areas which must be improved to meet current TCEQ Regulations, and which areas are deficient and in need of upgrades. Another resource that could assist you in making this decision, if you qualify for it, is a USDA Rural Development SEARCH Grant, which stands for Special Evaluation Assistance for Rural Communities and Households. This program helps very small, financially distressed rural communities with predevelopment feasibility studies, design, and technical assistance on proposed water and wastewater disposal projects. Most state and local governmental entities and nonprofits in rural areas with a population below 2,500 qualify for assistance, subject to certain income thresholds for the residents of the area.

I'm thinking about how to promote and enforce water conservation in new developments. Are there any laws or regulations that would allow us to require developers to use effluent water from our wastewater plant near the development for irrigation purposes? A: For most TRWA members, who tend to be water supply corporations and districts, I am not aware of anything that allows you to require this for new development, but you can make it more cost effective for them to do so because wastewater effluent should be less expensive than treated drinking water. The cities I have seen do this tend to implement wastewater reuse only for certain types of facilities like golf courses, ball fields, subdivision common entranceways and common areas, and other multi-use open spaces. One additional plus side of this for a utility that provides wastewater treatment, is that this setup provides them with an alternative means of disposing of a percentage of their treated wastewater effluent and limiting their stream discharge volume. Some developers may have had a good experience with irrigating with effluent and be more open to it than others. If it’s an option for developers and they are interested in “going green,” they might take you up on it. Again, the important thing to note here is that the decision should be left up to the developer and not presented as a requirement. Some entities even suggest a parallel distribution system if there is sufficient or abundant wastewater effluent close by. Sometimes these irrigation taps are not metered, and sometimes they are used to recover some of the maintenance and operations costs associated with the distribution system, pump stations and even some of the wastewater permitting and operations cost. If you have a technical question you would like answered, please email larry.bell@trwa.org.