Continuous Improvement / SUCCESS Framework
2018 State of the Environment Report (DW)

DDW continues to develop strategies to improve the allocation of resources, improve performance, and implement innovations that advance quality, efficiency, and effectiveness. Federal funding has decreased in recent years and federal requirements have increased. Optimizing staff time and reducing costs has been a necessity as well as a top priority for the Division and has led to impressive results.

Success Story: Improvement Priority System (IPS) Workgroup

DDW assembled a workgroup in 2017 to review and make improvements to the state’s Water System Rating Criteria, also known as the “Improvement Priority System Rule” (IPS). The IPS Rule is used to track public water systems by providing a numeric score for each potential deficiency or violation based on its significance to public health.

These criteria serve as the foundation for the Division’s sanitary survey program, a review of a public water system to assess its capability to supply safe drinking water. The questions used during a survey are based on the IPS Rule. DDW identified the following issues with the sanitary survey program:

• The lack of alignment of the deficiency points related to their significance to public health
• Redundancy and accuracy of survey questions
• Inconsistencies with the IPS rule and other rules
• Problems with the software used for managing questions

Before replacing the software, DDW decided to form a workgroup to look at the IPS Rule.

The workgroup found that the IPS Rule contained many inconsistencies and redundancies, and the deficiency points were not in alignment throughout the rule or, in some cases, with respect to their public-health risk. The workgroup also determined that the rule itself is difficult to manage and maintain because when other drinking-water rules change, the IPS rule needs to be updated as well.

DDW reviewed the workgroup’s findings and decided changes were needed to the existing IPS rule to better align point values with public-health risk and the federal rating process, simplify the existing IPS rule, and improve the Division’s flexibility and efficiency in the implementation of the IPS program. DDW proposes to amend the IPS Rule to:

• Align point values so they correlate with risks to public health.
• Address the possibility that credits mask deficiencies.
• Prompt action by systems who previously carried points rather than addressing deficiencies.
• Align the IPS rule with the federal rating process.
• Streamline and simplify the point values for various deficiencies and violations so they are grouped, clearly explained, and placed in a reference-table format.

Formal public comment on the IPS rule amendment is scheduled for May 2019. DDW hopes to complete the rulemaking process in late June 2019 and begin implementation of the amended rule on January 1, 2020.

Public Drinking Water System Boundaries

The proliferation of small-scale developments without infrastructure requirements pose risks to public health and the safety of the drinking water in these developments. Master meters at these developments allow a landlord, property-management firm, condominium association, homeowners association, or other multi-tenant property to bill tenants for individual measured utility usage. These “bulk” meters are often used at planned unit developments (PUDs) or other large, multi-unit developments.

The treatment of drinking water downstream from the master meter that separates the supplying system (“parent system”) from the receiving system can present a risk to consumers. Treatment can alter water chemistry within a distribution system, creating new threats to public health that parent systems may not be aware of or able to manage.

Boundaries of the public water system (terminus) have been legally established as the meter or property line. Large distribution systems (greater than 500 feet of buried piping) beyond the master meter and not under a parent system’s control may pose risks from backflow incidents, contaminant accumulation, and high level of disinfection, by-product contaminants. Storage facilities located downstream of a bulk meter may also pose risks to drinking-water quality. Unlike the storage facilities in regulated public water systems, the facilities downstream of a bulk meter are not operated by trained certified water operators and are not subject to sampling and regular inspection requirements.

Prospective drinking water systems also present another gap in public-health protection. Many developments are built in phases that allow them to remain below the public drinking-water system thresholds of 25 persons or 15 service connections for years. Once these systems grow to the point they are subject to regulations, they often struggle to meet the current design and construction standards and require expensive after-the-fact modifications.

DDW has engaged in a multi-year, collaborative stakeholder process to identify ways to minimize the public health risks from bulk or master meters. Proposed solutions include:

• Regulation of bulk-meter systems through a permit-by-rule. Sub-public systems would not be subject to regular drinking-water sampling and reporting requirements when they maintain their “permit-by-rule” status. However, should DDW determine that a public health problem exists, the Director may revoke a system’s “permit-by-rule” status, and the system will be regulated as a public drinking-water
• Identification of the terminus of a public water system boundary. For example, if a service-connection meter does not exist, the terminus may be the legal property boundary. The intent is to leave this determination as much in the hands of the public water system as possible while still making it clear to customers who is responsible for the maintenance of their system.
• Creation of a new “prospective system” type. A prospective system is a proposed system or development that will meet the public water system (PWS) threshold at total build-out but currently does not. A prospective system’s design and construction will be required to meet the current standards from the beginning. However, it will not be required to comply with the sampling and reporting requirements until it meets the PWS threshold.

DDW will continue to work with water systems, local health departments, land-use authorities, and other stakeholders to find viable solutions before commencing the formal rulemaking process in 2019 to address these issues.

Compliance Monitoring Data Portal

The Compliance Monitoring Data Portal (CMDP), developed by EPA, enables drinking-water utilities and laboratories to report data electronically to DDW, resulting in fewer errors and greater efficiency. The portal increases data accuracy and completeness and will decrease the reporting burden for DDW staff.

Utah was the first state in the nation to adopt the CMDP and utilize the new EPA CMDP protocol. Staff has been working hard to support laboratories and encourage them to use this portal to upload compliance data to the Division. DDW has 11 labs online and currently receives 84 percent of its data through the portal. Staff plans to bring more labs and water systems onboard during the coming year.

Electronic Sanitary Survey

Each year, DDW staff, along with local health departments, conduct sanitary surveys of public drinking-water systems. The sanitary survey is a review of a public water system to assess its ability to supply safe drinking water and evaluate the condition of existing infrastructure. DDW, or a local health department on behalf of DDW, visits the water system, educates the operator about proper monitoring and sampling procedures, and provides technical assistance. Sanitary surveys are a proactive public-health measure and an important component of the Safe Drinking Water Act.

In 2018, inspectors began working with the new software to simplify the sanitary survey process. The electronic sanitary survey streamlines data collection by linking to existing databases through a tablet or cell phone. Inspectors can pull data from the Safe Drinking Water Information System (SDWIS) to pre-populate the survey template with water-system data. This allows inspectors to access engineering exceptions, cross-connections, program information, and source protection plan status. The change will increase productivity as survey results can be completed the same day rather than taking days to complete.

Ongoing Continuous Improvement Projects

Engineering Plan Review

Process improvements have increased the percentage of plan approvals and plan submittal waivers issued within 45 days of receipt of the initial engineering plan or request. Staff continues to promote plan-review waiver status for eligible water systems and submit waiver requests for engineering projects. Plan-review waivers save staff time and offer eligible water systems a way to fast-track projects. The team also leveraged existing resources to provide increased benefits to the public at a lower cost. Their hard work led to a 20 percent improvement in program efficiencies.

Engineering plan review improvements underway include:

• Development of engineering templates that integrate changes and updates across sections and offer comprehensive checklists of items that must be completed before plans are sent to the director of DDW for approval
• Improved fact sheets, checklists, and flow charts for various types of reviews to help those outside the agency understand expectations, and those inside the agency use a standardized review process that ensures consistency and quality
• Active marketing of plan review waivers to eligible systems

Rule Implementation

The Division is trying to reduce the number of false Notice of Violations (NOVs) issued due to incorrect data. Improvements include:

• Better rule implementation through more timely compliance determinations
• Increased outreach to water systems, both online and through phone calls, to inform them of their monitoring requirements
• Data cleanup in the Safe Drinking Water Information System (SDWIS) to minimize errors

Operator Certification Exams

DDW has saved staff hours by migrating from paper to online exams and streamlining the exam process. Improvements include:

• Forms to gather updated contact information and feedback to improve the exam process/experience
• Online training materials
• An automated system to remind operators when they need to renew their certification and the process they need to follow to renew
• Automated renewals for operators

Reminder Emails Electronic Calls and Hints (REECH) Alert System

DDW rolled out its REECH alert system in 2016 to automate the process for notifying operators about certification renewals, upcoming trainings, or required sampling. Similar systems used in other states have reduced drinking water violations. For example, REECH looks through the Division’s database to see which samples are due and initiates emails, phone calls, and text messages to remind the system and the operator about the samples. The alert system continues to send reminders until DDW receives the required samples. REECH can also be used in an emergency to provide information to customers about boil orders or updates on drinking-water contamination.

Online reports

Five standard reports are now available online for each water system. These public water system reports are one of the most popular resources on the DEQ web site, providing public water systems with information on how the state identifies water-system elements, monitoring requirements, bacteriologic sample results, operator certification expiration dates, and continuing-education credits.

Data input from onsite inspections

Staff can now input information found during onsite inspections into handheld tablets that can be uploaded directly to DDW’s database. This streamlines the previous process, which required staff to handwrite field notes that were later entered into the office’s database.

Geographic or administrative grouping of water systems for site inspections

By organizing regularly required site inspections into geographic or administrative groupings, DDW makes more efficient use of Division personnel. Geographic grouping lets inspectors travel to sites located near each other and inspect all the water systems in the group in one day, saving travel time. By administratively grouping commonly owned or commonly managed water systems, DDW makes site inspections more convenient and efficient for both staff and owners.

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