EPA REGION 8 DRINKING WATER PROGRAM
WYOMING SYSTEMS NEWSLETTER

February 2023

INSIDE THE ISSUE

AFTER-HOURS EMERGENCY
PHONE NUMBER

STAFFING CHANGES

EPA RECOMMENDS USE OF
NITRATE LAB ANALYSIS METHOD
TO PROTECT PUBLIC HEALTH

WHAT TO DO FOR A LOSS OF
PRESSURE INCIDENT

REGION 8 DRINKING WATER
WEBSITE

MANAGING THE REPLACEMENT
OF ASBESTOS CEMENT PIPE

PROTECT YOUR SYSTEM AGAINST
RANSOMWARE ATTACKS

GROUND WATER RULE (GWR)
SOURCE SAMPLE TAP
INSTALLATION

WHAT'S IN A SAMPLE BOTTLE
NAME?

PROTECT YOUR DISTRIBUTION
SYSTEM - HOW MUCH CHLORINE
RESIDUAL DO YOU NEED?

EPA ANNOUNCES INTENT TO
STRENGTHEN THE LEAD AND
COPPER RULE

LEAD AND COPPER RULE SAMPLING
REQUIREMENTS

EPA EFFORTS ON POSSIBLE
MICROBIAL AND DISINFECTION
BYPRODUCT RULE RIVISIONS

PREPARING FOR EPA'S FIFTH
UNREGULATED CONTAMINANT
MONITORING RULE

United States Environmental
Protection Agency

Region 8

1595 Wynkoop Street

Denver, CO. 80202-1129

Phone: 1-800-227-8917

Fax: 1-877-876-9101

Web:

https://www.epa.gov/region8-
waterops


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1.AFTER-HOURS EMERGENCY PHONE NUMBER



The Region 8 Drinking Water Program has an after-hours emergency phone number! If you
experience an emergency situation during non-workday hours or the weekend, such as an issue
that disrupts your water supply or the water is contaminated with E coli bacteria or other
contaminants, please call 303-312-6327 for assistance. During Monday-Friday working hours
please contact one of our staff members for assistance.

2. STAFFING CHANGES IN EPA REGION 8's DRINKING WATER PROGR AM

3. HOW TO PREPARE FOR A SURVEY















How to Prepare for Your Water System's On-Site
Sanitary Survey

Here's what you can do to prepare for your sanitary
survey to make the process go smoother, faster and
result in fewer significant deficiencies.

Review your system's previous sanitary survey report

(surveys for Community systems are conducted every 3
years, Non-Community systems — every 5 years). Assure
significant deficiencies have been addressed.

Review the current year sanitary survey report form

attached to the email notification from the EPA Region
8 saying that your system is due for a survey this year.
You should see this email in February or March. Collect
updated contact information for your facility (mailing
address, phone number, email address). Collect
information on the number of people served by the
water system: residential/transient, and the number of
service connections (metered, unmetered).

Does your water system have a certified operator?
(Required only for Community or Non-Transient Non-
Community systems).

If your system purchases water, what is the name of
the system that supplies your water and its PWSID
number? (Who maintains the connection between the
two systems?)

If your system sells water to other systems, what are
their names and PWSID numbers? (Who maintains the
connection(s) between the systems?)

If your system has wells, are the well caps sealed (check
the compression seal, gasket or o ring, and look for

missing bolts or a disconnected conduit). Is there a
source water tap?

If your system has a spring source, do you have
construction drawings, as-built drawings, or
photographs documenting the spring construction?

Does the water enter the spring box through a
perforated pipe? At what depth? Is the hatch sealed
with a gasket? Do vents and overflows have (#24 mesh)
screens?

Review the sections of the current year sanitary survey

report form that apply to your water system and identify
any potential significant deficiencies seen in red text
on the report form and identified by an @ symbol that
you may need to address. If yours is a surface water
system, also address the issues, prior to the survey,
identified in blue and by a ₯ symbol on the survey
report. Call the EPA if you have any questions about any
potential significant deficiencies or violations before you
make any changes.

For water systems that have above-ground storage
tanks (ground level or elevated), EPA doesn't require its
surveyors to climb storage tanks. We do not provide the
necessary safety training nor safety equipment. Be
proactive and review the "Storage Tank - Above
Ground Rooftop Component Checklist for Finished
Water Tanks" at https:/ /www.epa.gov/region8-
waterops (click on Reporting Forms, click on Sanitary
Surveys) and inspect each of your storage tanks'
components prior to the survey. For each question on
the checklist please provide photos illustrating heights,
screen mesh size, etc. for each feature, and include the
storage tank name and the facility ID specified on
your water system's schematic (e.g. ST01).

Each storage tank should be cleaned every 3 to 5 years.
However, if it has been more than 10 years this will be
identified as a significant deficiency and you will be


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asked to provide a "Finished Water Storage Tank
Inspection/Cleaning Checklist" completed by either
the water system staff or a tank cleaning contractor. If
you wish to take care of this prior to the survey, you may
obtain a copy of the checklist at
https: / /www.epa.gov/region8-waterops (click on
Reporting Forms, click on Sanitary Surveys) and
document information for each of your system's storage
tanks that are due for cleaning prior to the survey. The
questions on this checklist are the same as on the
"Rooftop Component Checklist" above, in addition to
questions about the tank overflow, tank drain and what
was found during the cleaning. Again, photographic
documentation is required along with the answers to
each question on the checklist.

Be sure that you have updated sampling plans available
for:

Revised Total Coliform Rule (RTCR) sampling
locations.

Many Community and Non-Transient systems should
have updated monitoring plans for:

Disinfection Byproduct Rule monitoring
locations and

Lead and Copper Rule sampling sites.

Prior to the survey, visit all of the locations the surveyor
will visit and make sure you have access to all of the
facilities:

Obtain land owners' permission for you and the
surveyor when traveling on or across private property.

Make sure there are no rodents encamped on or
around well heads, pumps, sample taps, etc.

Make sure backflow prevention devices have
been tested within the last year.

If you have any questions, need a survey report or report
form, contact Lucien Gassie, 303-312-6620,
gassie.lucien@epa.gov.

4. WHAT TO DO FOR A LOSS OF PRESSURE INCIDENT

What to do for a Loss of Pressure Incident

Distribution systems can lose pressure for various reasons that include water main breaks, equipment failures, losses of
power, etc. The loss of pressure in a drinking water distribution system may cause a net movement of water from
outside the pipe to the inside through cracks, breaks or joints in the distribution system. Backsiphonage is also a
condition resulting from low or no pressure. Such system failures carry a high potential for fecal contamination or
other disease-causing organisms to enter a distribution system and can cause serious health concerns for people who
drink the contaminated water. Pressure loss is defined as a distribution system pressure of less than 20 pounds per
square inch (psi).

Measures to Take in the Event of Partial or Full Pressure Loss at a Public Water Supply System

The response to pressure loss and the remedial action that follows will vary depending on the situation. However,
listed below are the actions that an operator should take in the event of a loss of pressure in the distribution system
that is likely to last longer than one hour:

1.	If the area of lost pressure can be valved off and contained, you should isolate this area from the rest of the
system. This may limit the degree of contamination and the number of service connections affected by the loss
of pressure.

2.	Immediately notify the EPA Region 8 Drinking Water Program.

•	Public Water Systems (PWS) in Wyoming: call 303-312-6791

•	If outside of normal business hours, call the after-hours emergency and holiday phone
number: 303-312-6327

•	Be prepared to describe: what happened, when, where, and the scope of the problem (if known).

3.	We recommend that you notify the laboratory that you use to alert them regarding the emergency and to obtain
bacteriological sampling bottles, materials, and instructions (for taking "special" bacteriological samples).

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4.	In order to protect your customers, immediately issue a Tier 1 Public Notice (PN) that includes a Loss of
Pressure Boil Water Advisory. If boiling the water is a hardship for customers, consider providing bottled water
or another alternate water supply to customers.

5.	Locate/identify and fix the problem that caused the pressure loss.

6.	When system pressure is restored to normal, disinfect and flush the affected distribution system in accordance
with AWWA Standard C651 as necessary.

7.	After the excess chlorine has been flushed out of the water supply, ensure that chlorine residuals have returned
to normal levels. Collect and submit to the lab a Total Coliform (TC) bacteriological sample from both
upstream and downstream of the affected area of the distribution system. Maintain the boil water advisory until
two consecutive days of "safe" TC samples have been collected or until EPA notifies you that the boil order
can be lifted. These samples should be designated/marked as "special" samples on the lab slip.

The EPA may issue an Emergency Administrative Order (EAO) for incidents that can result in contamination in or
near a public water system that may pose an "imminent and substantial" endangerment to human health. If an EAO is
issued to the system, owner, the operator must follow all the requirements (e.g., issue a Tier 1 Boil Water Advisory
Public Notice, complete corrective actions, disinfect and flush the system, collect special total coliform samples) listed
within the EAO.

Prepare for the Unexpected

Every water utility should have an Emergency Response Plan (ERP) that addresses emergencies, such as loss of
pressure, with a checklist of steps to take. The ERP must be exercised periodically in order for all personnel to be
familiar with it. Regular maintenance and timely implementation of sanitary survey recommendations may also help in
preventing or reducing emergencies.

5.DO YOU KNOW THAT EPA HAS A DRINKING WATER WEBSITE?

Do you know EPA has a Drinking Water Website?

We do! EPA Region 8 has a website for drinking water system operations in Wyoming and on Tribal lands, and it has
many resources you may need or find helpful. The website is divided into six sections: (1) Water Systems (2)
Emergency Preparedness (3) Reporting Results (4) Regulations and Compliance (5) Monitoring and Sampling and (6)
Operations and Assistance.

Some key highlights of the website by section include the following:

Water Systems

•	Access to Drinking Water Watch, the tool that enables you
and the public to view data EPA maintains about your
water system

Emergency Preparedness

•	What to do it you have a loss of pressure

•	Access to a boil water advisory template when an E.coli maximum contaminant level (MCL) exceedance occurs

Reporting Results

•	Access to reporting forms for changes to water source, treatment, water system facilities, system contacts
and/or management, as well as seasonal operations

•	Access to consumer confidence report certification forms, emergency response plan templates, lead and copper
tap sample site plan template, maximum residual disinfectant level form, basic information form for new public
water systems, sampling forms, public notification templates, sanitary survey forms, and many others

Regulations and Compliance

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•	EPA's regulated analytes list

•	Tips to stay in compliance

Monitoring and Sampling

•	List of certified laboratories

•	Sample collection guide

Operations and Assistance

•	Preparing for a sanitary survey and tech tips

•	Presentations from training conferences.

Our staff contact list is available in the yellow "Need Help" box on the right-hand side of the home screen.
Please take a look and contact us about any other needs.

6.MANAGING THE REPLACEMENT OF ASBESTOS CEMENT PIPE

Managing the Replacement of Asbestos Cement Pipe

The use of asbestos cement (AC) pipe (or transite pipe) in drinking water distribution systems was once common in
the U.S. It was installed as early as the 1930s with the peak of installation and use between the 1950s and 1960s. EPA
estimates that 15% of water distribution pipes are asbestos cement. Due to the serious health risks associated with
asbestos exposure, the EPA attempted to ban all asbestos containing products on the market in 1989. While that was
ultimately overturned, the use of AC pipe was largely discontinued at the end of the last century due to health concerns
associated with the manufacturing process and the possible release of asbestos fibers from deteriorated pipes. In 2019,
the EPA promulgated a Significant. New Use Rule under the Toxic Substances Control Act to ensure that any
discontinued uses of asbestos cannot re-enter the marketplace without EPA review, including asbestos cement pipe
and fittings.

Much of our drinking water infrastructure has reached or is nearing the end of its useful life and approaching the age at
which it needs to be replaced. AC pipe has a typical design life of 50 years. As AC pipes are managed and replaced,
special care is required to prevent the release of hazardous asbestos fibers.

The Asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, subpart M, sets
forth requirements intended to minimize the release of asbestos fibers during renovation and demolition activities
involving the handling of asbestos. Pipe replacement is considered a renovation activity which is subject to these
requirements.

Prior to the renovation or demolition of a facility, including activities involving AC pipe, the Asbestos NESHAP
requires the removal of all regulated asbestos-containing material (RACM). RACM includes any existing friable
asbestos material or material which would likely become friable during the course of the planned demolition or
renovation operations. That is, any asbestos-containing material that can be crumbled or reduced to powder by hand
pressure must be safely removed prior to conducting activities that would break up, dislodge, or similarly disturb the
material or preclude access to the material for subsequent removal.

Conventional and acceptable work practices to replace AC pipe include open-cut trench and abandonment in place.
Open trenching is the practice under which the entire AC pipe is excavated, wet-cut into 6- and 8-foot sections using a
snap cutter or similar tool, wrapped for containment, and removed for disposition at an approved disposal location.
Asbestos cement pipes may also be abandoned in place with the new pipeline laid in a separate area.

While pipe bursting and breaking are popular methods for various types of pipe replacement projects in general, pipe
bursting or breaking AC pipe is not permitted under the Asbestos NESHAP. Pipe bursting or breaking of AC pipe
renders the AC pipe friable, leaving friable pipe fragments consisting of RACM underground. This method does not
comply with the requirements of the asbestos NESHAP and has not been approved by EPA.

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EP \ has approved a closed trench method for AC pipe replacement, which may be used as an alternative to the open-
cut trench and abandonment in place approaches allowed under the Asbestos \ I-.SI 1 \1\ This EPA-approved
alternative work practice standard is known as Close Tolerance Pipe Slurrification (CTPS). CTPS utilizes trenchless
technology and does not leave friable asbestos in the ground. CTPS involves grinding the AC pipe while
simultaneously injecting fluid to form a: liquid cement slurry which is vacuumed out through vertical access points. The
new pipe is pulled into the existing pipe cavity directly behind the grinding apparatus. A skim coat of nontriable
cementitious asbestos-containing material is left and solidifies on the outside rim ot the new pipe. For more
information on the CTPS method see https:/ Ayww.epa.gov/stationary-sources-air-pollution/notice-final-approval-
alternative-work-practice-standard-asbestos. For more information about the asbestos NESHAP, visit
https:/ /www.epa.gov/stationary-sources-air-pollution/asbestos-national-emission-standards-hazardous-air-pollutants.

If you have any questions, please contact the Chemical Phase II/V Rule Manager Kendra Morrison, at
morrison.kendra@epa.gov or (303) 312-6145.

7.protect your system against ransomware attacks

I

The number and size of ransomware incidents have
increased significantly and strengthening our nation's
resilience trom cyberattacks —in both the private and
public sector — is a top priority of EPA. The U.S.
government is stepping up to do its part, working with
like-minded partners around the world to disrupt and
deter ransomware actors. These efforts include
disrupting ransomware networks, working with
international partners to hold countries that harbor
ransomware actors accountable, developing consistent

policies towards ransom payments and enabling rapid
tracing and halting of virtual currency payments.

All organizations must recognize that no entity is safe
from being targeted by ransomware, regardless of size or
location, and tins is especially important with the
security of water systems. But there are immediate steps
you can take to protect your facilities, as well as your
customers and the broader economy. Much as our
homes have locks and alarm systems to meet the threat
of theft, we urge you to take ransomware crime seriously
and ensure your water system's cyber defenses match the
threat. Below you will find the U.S. government's
recommended best practices — we've selected a. small
number of highly impactful steps to help you focus and
make rapid progress on driving down risk.

What We Urge You to Do Now:

Implement the five best practices from the
President's recent Executive Order: These five best
practices can provide high impact: multifactor
authentication (because passwords alone are routinely
compromised), endpoint detection and response (to
hunt for malicious activity on a network and block it),
encryption (so if data is stolen, it is unusable) and a
skilled, empowered security team (to patch rapidly, and

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share and incorporate threat information in your
defenses). These practices will significantly reduce the
risk of a successful cyber-attack.

Backup your data, system images and
configurations, regularly test them and keep the
backups offline: Ensure that backups are regularly
tested and that they are not connected to the
organization's network, as many ransomware variants try
to find and encrypt or delete accessible backups.
Maintaining current backups offline is critical because if
your network data is encrypted with ransomware, your
organization can restore systems.

Update and patch systems promptly: This includes
maintaining the security of operating systems,
applications, and firmware, in a timely manner. Consider
using a centralized patch management system; use a risk-
based assessment strategy to drive your patch
management program.

Test your incident response plan: There's nothing
that shows the gaps in plans more than testing them.
Run through some core questions and use those to build
an incident response plan: Are you able to sustain
business operations without access to certain systems?
For how long?

Check Your Security Team's Work: Use a third-party
pen tester to test the security of your systems and your
ability to defend against a sophisticated attack. Many
ransomware criminals are aggressive and sophisticated
and will find the equivalent of unlocked doors.

Segment your networks: There's been a recent shift in
ransomware attacks — from stealing data to disrupting
operations. It's critically important that your water
system functions, and other operations are separated and
that you carefully tilter and limit internet access to
operational networks, identify links between these
networks and develop workarounds or manual controls
to ensure networks can be isolated and continue
operating if your business network is compromised.
Regularly test contingency plans such as manual controls
so that safety critical functions can be maintained during
a cyber incident.

Ransomware attacks have disrupted organizations
around the world, from hospitals across Ireland,
Germany and France to pipelines in the United States
and banks in the U.K. The threats are serious, and they
are increasing. We urge you to take these critical steps to
protect your systems and the American public. The U.S.
government is working with countries around the world
to hold ransomware actors and the countries who

harbor them accountable, and we stand ready to help
you implement these best practices.

Additional Resources

FACT SHEET: President Signs Executive Order
Charting New Course to Improve the Nation's
Cybersecurity and Protect Federal Government
Networks CISA - Ransomware Guidance and Resources
Recommended Mitigation
(https: / /www .whitehouse.gov/briefing-
room/statements-releases/2021 / 05 /12/fact-sheet-
president-signs -executive-order-charting-new-course-to-

improve-the-nations-cybersecurity-and-protect-federal-
government-networks /).

Additional EPA cybersecurity best practices for the
water sector can be found at the following links: EPA
Cybersecurily Best Practices for the Water Sector
(https:/ /www.epa.gov/waterriskassessment/epa-
cybersecurity-best-practices-water-sector)

CISA's Cross-Sector Cybersecurity Performance Goals ¦
https://www.cisa.gov/cpg

CISA's Cyber Hygiene Services —
https://www.cisa.gov/cpg

Questions about water security can be sent to Region 8
Water Security Coordinator, Nam Jirik at
jirik.nara@epa.gov

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8 .GROUND WATER RULE (GWR) SOURCE SAMPLE TAP INSINUATION

9. DRINKING WATER WATCH HAS A NEW HOME!
10. HOW MUCH CHLORINE RESIDUAL DO YOU NEED?

11 DRINKING WATER SAMPLING - BEST PRACTICES

12. RTCR SAMPLE SITE PLAN

13a. LEAD AND COPPER RULE INVENTORY

PLACEHOLDER ARTICLE

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