Partnership for Safe Water Guidelines for Phase IV Application for the “Excellence in Water Treatment” Award (Revised December 2014)

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Objective of Phase IV

The objective of Phase IV is to provide recognition to plants that have achieved the highest possible levels of turbidity performance. Utilities that are considering pursuing Phase IV recognition must understand that they will be assessed against very stringent performance goals. Phase IV represents a much higher performance level over Phase III of the Partnership. Participation in Phase IV is voluntary and is not required for continuing participation in Phase III of the Partnership program. A treatment plant must be a Phase III (Directors Award) plant in good standing to apply for Phase IV. Plants successfully completing Phase IV will receive the “Excellence in Water Treatment” award.

Phase IV provides recognition to those plants that:

A. Demonstrate that they have addressed the parameters in the “areas for continuing improvement” and “areas of good faith effort” identified during the PEAC assessment of their Phase III activities and brought them all into an “area of strength”. It is recommended to describe how all relevant assessment areas, including those originally determined to be an “area of strength” have been maintained as “areas of strength”. Additional information regarding this step is provided in this documentation.

B. Demonstrate that they are obtaining the high levels of performance by meeting or bettering the Partnership for Safe Water Phase IV Performance Goals listed in Table 1.

C. Demonstrate the capability to maintain these levels of performance long-term by addressing the issues in the complacency/reliability guidelines presented in Table 2. This requirement is satisfied by completely addressing the set of 5 questions provided in Checklist item #9.

For Phase IV, the performance goals in Table 1 will be based on all turbidity data from individual filters collected at discrete 15-minute intervals. This is a significant change from Phase III where 4-hour data from combined filter effluent was used. This means that utilities meeting the performance goals in Phase III may not necessarily achieve Phase IV performance. In working with performance goals that are the basis for Phase IV, the Partnership for Safe Water would like those utilities participating in this phase to understand the following position statement regarding the use of numerical performance goals by the Partnership program.

All plants applying for the Phase IV Excellence in Water Treatment award shall have a goal for individual filter effluent turbidity of less than 0.10 NTU at all times from each filter. The award measure used by the Partnership for Safe Water is less than 0.10 NTU for individual filter effluent turbidity from each filter for 95% of the measurements, taken at discrete 15-minute intervals, per month.

Table 1. Partnership for Safe Water Phase IV Performance Goals General Data Monitoring Requirements  Daily raw water turbidity  Settled water turbidity at 4-hour time increments from each sedimentation basin  On-line (continuous) turbidity from each filter  One turbidity profile, that includes a backwash profile, from the filter run with the maximum turbidity value for each month (refer to Checklist item #5).  Combined filter effluent at 4-hour time intervals Individual Sedimentation Basin Performance Goals  Settled water turbidity less than 1.0 NTU 95 percent of the time when the annual average raw water turbidity is less than or equal to 10 NTU  Settled water turbidity less than 2.0 NTU 95 percent of the time when the annual average raw water turbidity is greater than 10 NTU Individual Filter Performance Goals  Filtered water turbidity less than 0.10 NTU 95 percent of the time based on values recorded at 15-minute time intervals  96th, 97th, 98th, 99th percentile values that indicate consistent filter performance  Maximum filtered water turbidity equal to or less than 0.30 NTU  The treatment plant has an individual filter effluent turbidity goal following a backwash of no more than 15 minutes of water production at a turbidity equal to or greater than 0.10 NTU Combined Filter Performance Goal  Combined filter effluent turbidity of less than 0.10 NTU 95 percent of the time. Disinfection Performance Criteria  CT values to achieve required log inactivation of Giardia and virus

Table 2. Partnership for Safe Water – Best Practices for Avoiding Complacency and Maintaining Reliability Complacency definition: Inadequate capability (i.e., skills, policies, procedures) to maintain optimized treatment performance during non-routine events and/or rare potentially serious events (RPSEs). Practices of optimized utilities to help prevent the existence of complacency at their facilities:  Maintaining utility awareness and commitment for public health responsibilities and the need to consistently achieve treatment performance goals.  Developing formal policies and procedures to implement source selection when this capability exists.  Having a means for identification and consideration of algal blooms and their impact upon plant performance and production.  For plants co-serving a system with other treatment plants, maintaining awareness and consideration of impact on other plants’ treatment performance when their plant production is ramped down during RPSEs.  Demonstrating an understanding of complacency (e.g. optimized plants do not take for granted their performance status nor deny the future potential for challenging situations and/or potential inability to successfully deal with challenging situations.  Maintaining a priority on water quality over short-term water demand needs.  Understanding of the utility’s potential vulnerabilities (e.g. an outbreak has never happened here, but could it occur in the future and how would it be addressed?).  Embracing change and developing a formal process control program that anticipates future changes.  Making data-driven process control decisions, based on established and documented processes, not made solely based on the informal, non-documented “experience of the plant staff.”  Policies and procedures exist to address all potential events that could affect water quality.  Selecting treatment technologies that are appropriate for the source water being treated, either frequently or during a very rare occurrence, identifying and controlling any potential treatment risks to the best of the utility’s ability.  Good treated water quality is primarily the result of thorough planning, documented procedures, and anticipation of all potential RPSE that may impact water quality – not non-sustainable conservative loadings on unit processes.  Using special studies/characterization technologies (jar testing, zeta potential, etc.) by staff is encouraged for problem solving to address issues that challenge the plant maintaining optimized performance.

Table 2 (cont). Partnership for Safe Water – Best Practices for Avoiding Complacency and Maintaining Reliability Reliability definition: The existence of backup capability (i.e., equipment or processes) and/or depth in the organization supports the plant’s goal of maintaining optimized performance during extreme water quality events. List of examples that may indicate a utility’s reliability:  Process control capabilities and knowledge, within a plant, are shared among a significant number of individuals throughout a large utility.  Presence of a utility emphasis on cross-training or staff development training.  Consistency in process control direction, even among multiple sources.  Key equipment has required redundancy.  Front line operations staff has emergency procurement capability.  Aging equipment is maintained or replaced as required to maintain functionality and performance.  Strong communication within the organization and among operational staff.

POSITION STATEMENT ON NUMERICAL GOALS (Approved April 19, 2010)

The numerical goals used in the Partnership provide a basis from which optimization is discussed by the optimization review team. It is possible to be on either side of a particular numerical goal and be considered either optimized or not optimized, depending on the particular situation. Operational limits are used as guidelines only, and are interpreted by optimization review team members to assess performance status.

The numerical goals used in the Partnership in no way imply “best practices” or represent a standard of operational practice. Rather, these goals were selected for use in the Partnership program without requiring health-based risk analysis or cost/benefit evaluation. They serve, instead, as high-level goals toward which operators can strive in a process of continuous improvement. Establishment of performance goals is a key to successful performance improvement.

Any interpretation or use of the Partnership process and its embedded numerical goals outside the Partnership process, and particularly in the regulatory process, is inappropriate, and in no way carries the endorsement, either explicit or implied, of the Partnership.

POSITION ON USE OF REFERENCE MATERIALS (Approved April 19, 2010)

Use by the Partnership of reference materials (e.g. Self-Assessment Guide for Surface Water Treatment Plant Optimization or Water Research Foundation “Criteria for Optimized Distribution Systems”) is necessary to provide the resources and tools to support its processes. The Partnership neither explicitly nor implicitly endorses the contents of these materials beyond the use to support the Partnership process.

Overall Approach and Phase IV Philosophy

The first step in the Phase IV process is for plants to register their intention to apply for Phase IV recognition. After registration, the Partnership for Safe Water Program Manager will contact the plant representative to verify the requirements for the Phase IV award. This support is intended to answer questions, address specific plant limitations, give some assurance that the utility is ready to proceed through the Phase IV process, and assist the plant with being as successful as possible with the Phase IV process.

After completion and submittal of this application package there are three levels of review. First, the package undergoes an administrative review by Partnership staff at AWWA to make sure that the application package contains all of the information needed for the other levels of review. This level of review is only for completeness and none of the plant specific information will be assessed at this point.

When the AWWA staff considers the application package complete, it will be passed on for the second level of review completed by volunteers from the Program Effectiveness Assessment Committee (PEAC). The PEAC will review the performance data and other information supplied in the application package and make a determination if the utility has met the goals of Phase IV. If the application package is deficient, the PEAC will also work with the utility to obtain any additional information.

When the PEAC’s review is completed, the PEAC will make a recommendation to the Partnership’s Steering Committee (SC). The purpose of the SC review (third level) is to ensure consistency between the PEAC reviews and to make sure that each Partnership organization (AWWA, AMWA, NAWC, ASDWA, USEPA) agrees with the decision to award the Phase IV recognition. Once the SC has considered all of these issues, they will inform the utility of the status of their application package.

General Requirements

 Participation in Phase IV is voluntary and is not required for continuing membership in Phase III of thePartnership program.    Prior to Phase IV application, the plant must have completed Phase III (received the “Directors Award” and be a current Partnership subscriber in good standing) and have addressed the “areas for continuing improvement” and “areas of good faith effort” identified by the PEAC to elevate all 14 general parameters up to an “area of strength,” including the brief narrative report as described in the following section.  It is recommended to describe how all relevant assessment areas, including those originally determined to be an “area of strength” have been maintained as “areas of strength”.    Plant must complete the Phase IV application process that includes all documents and data listed in the Phase IV minimum reporting requirements checklist.   The plant submits one year of performance data as outlined in application package described below.    The plant provides the Partnership narratives on how they have addressed the issues in the complacency/reliability guidelines. This requirement is satisfied by completely addressing the set of 5 questions provided in Checklist item #9.    The Partnership program provides no guarantee that the plant will receive Phase IV recognition 5

after completing the application process.

 Phase IV award plants must submit annual reports (as described in Appendix C - Annual Reporting Requirements) to maintain Phase IV “Excellence in Water Treatment” status and become eligible for the Partnership’s longevity awards.

Application Package Requirements

Objective of the Application Package The documents, narrative discussion, and data submitted for Phase IV of the Partnership for Safe Water provide evidence that the treatment plant is optimized. The intent of the application package is to provide the PEAC with the information they need to assess if the utility has met the intent of Phase IV and should receive Phase IV recognition. It is, therefore, in the best interest of the utility that they provide as much relevant information as possible in the application package to assist the PEAC in their review. Additional supporting information may be requested by the PEAC review committee to clarify that the submittal with the required documentation meets the optimization guidelines.

The Phase IV Excellence in Water Treatment Award application will be reviewed by Partnership for Safe Water Program Effectiveness Assessment Committee (PEAC) representatives. The PEAC review team will not have access to the plant’s original self-assessment report and is limited to an evaluation of the materials submitted to determine the plant’s optimization status with regard to the Partnership’s Phase IV performance goals and optimization criteria. The guidelines contained in this document represent the minimum requirements to apply for the Phase IV Excellence in Water Treatment Award. The following general recommendations are provided to plants applying for this award:

 Provide information and data to support statements made in the application. Examples of supporting information may include SOPs, data log sheets, and special studies, where applicable, that help to substantiate the plant’s optimization status.

 Be as detailed as possible – remember that reviewers are not able to visit the plant in person, so it is helpful to provide sufficient information to help reviewers understand as much about plant processes and operations as possible.

 An example Excellence in Water Treatment Award application is available as a reference to utilities applying for Phase IV recognition and may be a helpful resource, available by contacting the Partnership.

 Excellence in Water Treatment award winners represent some of the best-run water treatment facilities in North America. As you are preparing the Excellence in Water Treatment Award application, consider the information needed to make and support the case that the facility is one of the best in North American – or worldwide!

Contents of Application Package

Organize the Phase IV application package using the Document Check List (Appendix A). It is suggested to use tabs or numbered chapters to clearly identify each item in the list. The reviewers can more easily complete the review if the application is organized in this manner. What follows below includes a detailed description of the required material for each section and a summary of expectations. The sections are described in the order in which they are included in the Document Check List and are typically presented in the Phase IV application.

Plant Turbidity Performance Data (Checklist Items #1-3)

The major consideration for determining if a plant is eligible for Phase IV recognition is if it is meeting the performance goals shown in Table 1.

Checklist Item #1 - Raw Water Turbidity Data

Raw water turbidity data for the most recent 12-month period ending no more than 2 months prior to the report submission date must be submitted using the Partnership for Safe Water data collection spreadsheet software. Either the single-entry per day or 6-entry per day versions of the software are acceptable for this submission. The entire page (shown in Figure 1) that includes the table of monthly plant statistics must be provided (not just the saved “Spike Counter” file that is sent to AWWA for the annual report). Explain the source of the data included in the spreadsheets (maximum values, specific times, other).

Checklist Item #2 - Individual Sedimentation Basin Performance Data

Given the important nature of the sedimentation process in a multi-barrier approach to particulate removal, turbidity monitoring of individual sedimentation basin effluent is required for treatment plants seeking Phase IV recognition. However, some treatment plants may seek Phase IV recognition even though they do not strictly meet the Partnership for Safe Water performance goals for individual sedimentation basins. Sedimentation is an important process in a multiple-barrier approach. The burden is on the utility to convince the Partnership that the sedimentation basin process is optimized. Documentation used for this purpose may include the results of special studies, additional data from plant operation under a variety of conditions, plant design criteria, and data showing the impact on filter performance. Plants planning to apply for Phase IV recognition that do not meet the Partnership’s sedimentation basin turbidity performance goals are strongly encouraged to contact the Partnership Program Manager for additional guidance prior to beginning the Phase IV process.

Direct filtration treatment plants (or other configurations lacking a sedimentation process) are not required to submit settled water turbidity data. It is recommended to include a brief statement in the Phase IV application describing why settled water turbidity data is not included in the application package and how the flocculation process has been optimized to produce particles of a quality that result in an optimal and consistent filter effluent turbidity.

Checklist Item #3 - Combined Filter Effluent Turbidity Performance Data

Combined filter effluent turbidity data for the most recent 12-month period ending no more than 2 months prior to the report submission date must be submitted using the Partnership for Safe Water data collection spreadsheet software. Either the single-entry per day or 6-entry per day version of the software may be used for this submission. The entire page (shown in Figure 1) that includes the table of monthly plant statistics must be provided (not just the saved “Spike Counter” file that is sent to AWWA for the annual report). The 95th percentile values for each month must satisfy the performance goals shown in Table 1. Any monthly values that do not meet the goals must be accompanied by a narrative explanation that describes the circumstances and justifies Phase IV conformance despite these results. Explain the source of the data included in the spreadsheets (maximum values, specific times, other).

Figure 1 - Example Turbidity Data Collection Software Output

Checklist Item #4 - Individual Filter Effluent Turbidity Performance Data

To receive Phase IV recognition, the plant must meet the Partnership’s individual filter effluent turbidity performance goals and also demonstrate consistent filter performance. This is demonstrated by indicating how turbidity spikes immediately after a filter is placed in operation, especially following backwash, are minimized. The performance goals from Table 1 will be used by the PEAC to assess success at minimizing turbidity spikes when the filter is brought back on line after backwash or when filter-to-waste is terminated. Recall the following:

 Maximum value goal anytime during any filter run of less than 0.30 NTU  The treatment plant has an individual filter effluent turbidity goal following a backwash of no more than 15 minutes of water production at a turbidity equal to or greater than 0.10 NTU

The other intent of providing individual filter monitoring data is to assess if changes to the plant’s flow, to meet demand or during filter backwash, impact the performance of the filters. This information will also be used to assess if malfunctioning rate-of-flow controllers are degrading filter performance. In addition, individual filter effluent will more closely indicate optimized coagulant control.

Monthly Individual Filter Statistics (Checklist Item #4)

Plants must report on the performance of each filter for each month during the 12-month reporting period. Performance is based on turbidity values taken from each filter at 15-minute intervals with percentile statistics (95th, 96th, 97th, 98th, 99th percentile values) calculated for each month. The plant will use its own computer programs to generate the report.

The other statistics (96th-99th percentiles) are required to be calculated and submitted in the application package. These additional measures will be examined by the PEAC to establish performance consistency and confirm a high level of plant control. The PEAC may inquire for further explanation if the higher percentile values depart significantly from the 95th percentile. An example of one type of acceptable report format is shown in Figure 2. This example is for a plant with twelve filters for a single month.

The Partnership prefers filter statistics to include the count of the number of readings within turbidity ranges (as shown in Figure 2). Although this presentation is not required it is strongly recommended. The statistical percentile values are required.

The turbidity values used for this calculation must be at 15-minute intervals for each filter for each month. The values must be discrete and not averages or other types of adjusted turbidity values.

Figure 2 - Individual Filter Performance Statistics Example

Monthly Individual Filter Percentile Statistics - Minimum Required Format

Filter ID 95th 96th 97th 98th 99th Maximum Filter 1 0.059 0.060 0.060 0.061 0.061 0.218 Filter 2 0.053 0.054 0.055 0.055 0.060 0.191 Filter 3 0.054 0.054 0.055 0.056 0.060 0.189 Filter 4 0.038 0.038 0.039 0.040 0.044 0.161 Filter 5 0.043 0.043 0.044 0.045 0.051 0.168 Filter 6 0.056 0.056 0.056 0.058 0.061 0.079 Filter 7 0.058 0.058 0.059 0.060 0.063 0.100 Filter 8 0.032 0.033 0.033 0.033 0.036 0.050

Checklist Item #5 – Turbidity Profiles for Monthly “Worst Filter Run”

The Partnership is based on the premise that the plant performance is only as good as its worst filter. To prevent Cryptosporidium from passing through the plant, the worst filter must be optimized for this purpose. The PEAC, therefore, requires that the application package must include one filter profile for each month (during the 12-month reporting period) that the plant is in operation. These filter profiles should be representative of conditions surrounding filter operation over an entire filter run that includes backwash and start-up and should note the use of any techniques used to manage filter ripening spikes, such as filter-to-waste. It is assumed that the plant has continuous on-line turbidimeters on each filter and has the capability to prepare a trend chart of the performance for the entire filter run. The filter profile must contain data points that have been collected a maximum interval of five minutes.

The filter selected for a month will be the filter that had the highest validated maximum turbidity readings for that month. For example, if the plant’s IFE turbidity data indicated that Filter 1 had the highest turbidity reading for the month, then a profile would be required for this filter. The profile must be for an entire filter run. Including the one-hour period immediately prior to and following the filter run is helpful in providing PEAC reviewers with contextual filter performance information.

Figure 3 shows an example filter profile from SCADA data collected over the course of the plant’s worst filter run (based on turbidity) during November 2009. Note that all events that occurred during the filter run, such as the backwash initiation, filter to waste period, and time when the filter was place into service are all clearly labeled on the graph, and a descriptive narrative statement is included describing plant events that occurred to contribute to this filter run being recognized as the worst for the given month. Multiple parameters are combined on a single graph for this example. This is not required for filter profiles submitted but provides the reviewers with additional information about the nature of the filter run. The minimum recommended parameters to include on a filter profile are turbidity (required) and one of the following: headloss, filter flow rate, or effluent valve position. Particle count data may also be included in the filter profile. If multiple parameters are submitted on a single graph, please ensure that the graph is easy to read and that scaling for each parameter is clearly visible along the Y-axis of the graph.

It is helpful to provide the narrative explanation of filter run events on the same page as the filter profile, as indicated in the example below. A description of the events that occurred during the filter run is required, including the highest turbidity reading, even in cases where a filter run was considered to be representative of “typical” performance.

The plant may use any method considered feasible and reasonable to demonstrate to the Partnership that they can meet the above criteria. The only requirement is that the filter profile be based on samples taken at 5-minute intervals (or more often). Each plant is unique and will have different filter monitoring systems (e.g., SCADA, monitors with recorders, monitors only, etc.) that makes providing specific universal requirements difficult. The following are presented as possible alternatives for supplying the required filter profiles:

 Trend charts developed from SCADA systems.  Trend charts from an EXCEL spreadsheet derived from SCADA data

The PEAC may request additional filter profiles or related information to help substantiate that Phase IV optimization guidelines have been met.

Figure 3 - Example of Filter Profiles

Checklist Item #6 – Plant Schematic

Plants should include a current plant schematic to satisfy this checklist item requirement. The plant schematic is an important tool that provides the review team with the information necessary to understand and visualize the plant’s treatment process. The plant schematic should be as detailed as possible and include chemical addition points. If the process configuration has changed significantly since completion of Phase III, the plant schematic at the time of the Phase III submission should also be included for comparison purposes. In cases where the plant process configuration has significantly changed, please 12

ensure that a description of the changes and the current treatment process is provided in the narrative included with Checklist Item #6. If treatment process changes were undertaken to optimize performance, briefly describe the drivers for the change.

Checklist Item #7 – Copy of the Phase III Summary Report

A copy of the Phase III response letter, if available, indicating the status of Phase III report evaluation parameters should be included in the Phase IV report. If this letter is not available, please contact the Partnership for Safe Water for further instructions.

Checklist Item #8 - Changes to Address Phase III Findings

As part of the Phase IV application, the utility must demonstrate that they have used the results of Phase III to make changes and further enhance their plant’s operation and/or administration that could potentially lead to further improved performance.

In developing Phase III, the Partnership realized that there are inherent limitations with an off-site review of a Phase III completion report by the PEAC. These limitations are related to the problems of completely understanding the unique situation at the plant based on the review of a Phase III completion report. For this reason, the Phase III process does not provide specific recommendations, but points the plant into general areas where the PEAC was particularly impressed or had concerns. Upon receiving their Phase III recognition, the utility also receives a list of 14 general parameters that have been placed into the categories “area of strength”, “areas of good faith effort” and “areas for continuing improvement.”

The intent of this section of the application package is to make sure that the plant has used the Phase III findings and, as appropriate, made the necessary changes towards continuous water quality improvements. This section of the application package should include discussions of how the plant has addressed the parameters in the “areas for continuing improvement” and “areas of good faith effort” identified during the PEAC assessment of their Phase III activities and brought them all into an “area of strength.” The contents of this section should include:

 Description of how all “areas of good faith effort” and “areas for continuing improvement” have been brought to “areas of strength” (required). o A summary of progress relative to specific Phase III action items, or actions identified after completion of the self-assessment report, may be helpful to provide.

 It is highly recommended that utilities consider providing a similar detailed description of how areas originally assessed to be “areas of strength” in the Phase III report have been maintained as areas of strength during the time that has elapsed since the Phase III process has been completed (recommended).

 Brief narrative statement that addresses the following areas (required): o Changes to plant processes that have occurred since Phase III report completion o Changes to plant administration that have occurred since Phase III report completion. o General description of how the plant has maintained “areas of strength” since completion of the Phase III report. o Reaffirmation of the utility’s commitment to maintaining Partnership performance and optimization goals. The utility may wish to summarize its performance goals in this section of the report or include plant operational criteria (such as filter backwash criteria) to communicate this information to the review team. 13

o Plants that operate unattended are not excluded from applying for Phase IV recognition but should consider using this narrative statement as a means to describe the controls associated with unattended operation that are implemented as a means of protecting public health.

The utility also has the option of disputing the findings of the PEAC with an explanation of why a particular rating for a parameter was inappropriate or difficult to translate into specific changes at the plant. The PEAC, however, will be the final judge that decides if the Phase III findings have been adequately addressed by the utility.

The Partnership would like for the utility to provide the best explanation possible of the changes made or the rationale why the utility did not agree with a specific parameter. This section should also include any discussions with the PEAC with regard to the Phase III results or during the Phase IV facilitation process. It is highly recommended to contact the Partnership Program Manager for additional input if the utility plans to dispute any of the Phase III report review findings.

Example: Plant Changes to Address Phase III Findings

In this example, the package that the utility received with its Phase III recognition, the PEAC had identified four parameters in the area “areas of strength”, nine in the area “good faith effort” and one in the area “areas for continuing improvement.” The utility would then need to provide a discussion of what they have done to address the “good faith effort” and “areas for continuing improvement” parameters.

If the utility disagrees with the PEAC on any parameters, they would include their rationale for changing the rating. The following is an example of how the utility could demonstrate that they addressed the parameter in the “areas for continuing improvement” category. A similar discussion would be provided for each parameter not listed as an “areas of strength”. As stated previously, it is highly recommended that utilities consider describing how Phase III “areas of strength” have been maintained as areas of strength since completion of the Phase III report. However, this is not a requirement.

In this example, the parameter to which the PEAC assigned an “areas for continuing improvement” rating was Understand/Explain Performance Deviations. The following are examples of the discussions that could be included in the application package:

 The plant staff reviewed the definition of this parameter and discussed what the PEAC could have seen in their completion report that would have led them to not rank this parameter higher. The definition of this parameter is as follows:

Understand/Explain Performance Deviations - The participant has demonstrated the capability to discuss deviations from optimum performance goals in a logical and convincing manner. The submittal should demonstrate an understanding of deviations and should impart an urgency to rectify deviations, both short term and long term. A lower rating should be given if no mention is made to address performance deviations in the data submitted.

 Plant staff then reviewed the performance data submitted with their completion report and the relevant sections of the self-assessment guide. The data showed an increase in the finished water turbidity for a 6 week period in June, and it was determined that the report had not included any explanation of this event.

 Plant records were reviewed to assess why this increase in turbidity occurred. This resulted in the following findings:

- There were equipment problems with the streaming current monitor (SCM) used to make process control decisions and no backup unit was available.

- The plant superintendent did not realize that this performance deviation had occurred and that there was no formal process to report performance deviations.

- The plant staff had no alternative process control procedures for unusual situations where the SCM did not provide sufficient process control to maintain optimum finished water quality.

 Based on this assessment following receipt of the Phase III report, the utility took the following steps:

- Purchased a spare SCM as a backup to the primary SCM. - Established a process where the plant staff met when there were turbidity performance deviations above 0.10 NTU to discuss actions to be taken immediately to address the performance problems. The performance deviations, actions taken as the result of the meeting and documentation of the current levels of performance were then discussed with the plant superintendent. - Revised jar testing SOP and established a training program for all plant operators in its use. - Required a jar test every week by each shift (at minimum), and based on raw water quality changes of a defined magnitude, to confirm the coagulant dose set by the SCM.

 This activity was documented and made part of the Phase IV application package. Plants that have completed the self-assessment report many years in the past are not limited to the scenarios or action items described in the original report and are encouraged to share more recent examples of how the plant has addressed these specific performance areas. Plants may consider referencing performance limiting factors and/or action items referenced in annual report submissions in the Phase IV completion report.

Checklist Item #9 – Complacency and Reliability Narrative

This portion of the application package is intended to give the PEAC reviewers information that they can use to assess the utility’s capability to maintain the levels of performance demonstrated in the data submitted over the long term. The reviewers will complete this assessment by reviewing the responses and supporting information provided by the utility to address the following five questions against the issues presented in complacency/reliability guidelines presented in Table 2.

To address this checklist item, please provide a narrative statement addressing the following 5 questions. Be as descriptive as possible in providing these responses, and include supporting data as needed. The utility may wish to relate responses to specific complacency and reliability items included in Table 2. In reviewing these narratives, the PEAC will be looking for information that gives them confidence that the utility understands these issues and has seriously considered them.

1. During the last 10 years, explain how the plant personnel staff responded to the last major episode of poor water quality (preferably an event that caused poor finished water quality) including what process control procedures and special studies were completed. Also explain what you learned from that experience and what changes were made in plant operations to respond to these situations in the future. Use raw and finished data profiles as part of a detailed

discussion of the event. Demonstration of developed process control skills is particularly important to describe.

2. If the plant did not encounter any major episodes of poor water quality, how would the plant staff respond to deteriorating finished water quality during unusual changes in raw water quality that have never been experienced before? This narrative should explain how the plant personnel would deal with a situation where all of the usual process control procedures do not maintain optimized performance. This narrative should present a clear strategy for dealing with this situation including how and who would implement it.

3. How would the plant staff be directed to respond in situations where the system was experiencing peak water demand, but they thought that plant flows needed to be reduced to maintain optimized performance? This narrative could include any formal policies around this area and case histories of how the utility has responded to these situations in the past.

4. Provide examples that demonstrate the plant staff’s ability to perform special studies to solve water quality problems. This narrative could include formal special study procedures and case histories of how the plant staff has resolved water quality problem in a structured systematic way.

5. Provide a narrative on how the plant has addressed the reliability issues in Table 2. This could include a listing of key process equipment and how redundancy has been provided. A discussion of the age of the key equipment could also be provided and why its age does not impact the plant’s ability of maintaining optimized performance.

Checklist Item #10 – Data Collection and Quality Control

Conclusions about the performance of the plant and its component processes must be based on accurate and verifiable data. The plant must provide documentation (as a minimum submit the example individual filter effluent turbidity checklist in Appendix B – but additional supporting information may be provided and is encouraged) or similar information regarding the type of instruments that are being used to provide any data provided in the Phase IV application. This section should also describe the plant’s sampling turbidity sampling locations, rationale for selection, and whether they are approved by a local regulatory agency. The documentation should describe the frequency of instrumentation calibration and offer standard operating procedures regarding the removal of data due to instrument malfunction or other issues. The plant must provide adequate information on instrumentation and quality control to assure the PEAC that formal procedures are in place and are followed to ensure that the data is of the highest quality. Please note that turbidity data submitted should be discrete data points and not averages.

Checklist Item #11 – Explanation of Turbidity Spikes

Phase IV treatment plants operate individual filters to produce turbidity less than 0.10 NTU at all times. The Partnership understands that it is not practical, however, to strictly demand this performance. The performance goal is therefore established as less than 0.10 NTU for 95% of the measurements taken at 15-minute intervals. Phase IV applicants should explain any turbidity values above 0.10 NTU if they may indicate a trend that could jeopardize conformance with the individual filter turbidity goal. It is recommended that Phase IV applicants consider providing an explanation for all individual filter effluent turbidity values that exceed the 0.10 NTU goal.

Turbidity values above 0.30 NTU may indicate that a filter is not optimized for particle removal. The Partnership requires the written explanation of all individual filter turbidity (taken at 15-minute intervals) values greater than 0.30 NTU. The burden is on the plant to adequately explain these values and any 16

measures taken to prevent their recurrence. In some cases, the plant should provide additional information or data to support the explanation.

Using Administrative Policies as an Operational Strategy Utilities must demonstrate that the plant can continuously produce water from every filter that satisfies the Partnership turbidity goals. Utilities may use administrative policies (such as plant shut-down) to satisfy the Partnership goals. However, the plant may need to give specific examples where the policies have been used in the past to establish the needed credibility.

Checklist Item #12 – Rationale for Phase IV Excellence in Water Treatment Award

Plants should provide a brief narrative explaining why the plant should be recognized as one of the best performing plants in the global water community and receive the Partnership’s Excellence in Water Treatment Award.

Checklist Items #13 and 14 – Cover Letter and Statement of Compliance

Plants should submit the report with a cover letter indicating the name of plant, name of utility, contact name and contact details for the primary contact associated with the report submission. The cover letter or report should include a Statement of Compliance, indicating that the plant has remained in compliance with all applicable surface water treatment regulations during the 12-month period immediately preceding report submission.

Note - Plants with Particle Count Data

A utility that is submitting a Phase IV application package is not required to submit any particle count data, but is strongly encouraged to do so if this information is available to support the information provided in the application. Utilities with particle count data may wish to consider incorporating this data with the filter profiles in the Phase IV submission, although alternate means of communicating particle count data to the PEAC reviewers are acceptable. Particle count data, along with turbidity data, provides the strongest evidence possible that a plant is meeting the optimization goals. The intent of this section is to ensure that utilities understand how they can use particle count information to supplement the turbidity data in the Phase IV application package. A utility that has particle count data is encouraged to use this data to demonstrate enhanced particle removal over what is possible with turbidity data alone.

Utilities that have made the decision to install particle counters typically have already met the Partnership’s turbidity performance goals and are aware of the benefits of particle counters to further enhance their abilities to maximize particle removal in their plants. The intent of encouraging a utility to include their particle count information in the Phase IV application is to allow the PEAC to assess if the information is being used for process control decisions and that the maximum value is being obtained from their commitment to particle counters.

Figure 4 illustrates a filter profile from a plant that is using particle count data for process control. The filters from this plant consistently have low particle counts along with meeting the Partnership turbidity goals. Note that significant events throughout the filter run are labeled on the filter profile and that separate a separate y-axis is used for turbidity and for particle counts.

Figure 4 - Use of Particle Count Data and Turbidity Data to Document Optimized Performance

Filter 3 Profile - May 18/19

0.5 25

Turbidity

Particle Counts

0.4 20

0.3 15

Ad Clarifier 1 1 washed Clarifier Ad

Filter 1 washed 1 Filter

Alum pump misfeedingpump Alum

Ad Clarifier 2 2 washed Clarifier Ad

Filter 3 washed 3 Filter

Filter 5 washed 5 Filter

Filter 3 returned to service to returned 3 Filter

Turbidity (NTU) Turbidity Total Counts >3um (#/mL) Counts>3um Total 0.2 10

0.1 5

0 0

9:54 0:00 0:54 1:48 2:42 3:36 4:30 5:24 6:18 7:12 8:06 9:00

15:00 15:54 16:48 17:42 18:36 19:30 20:24 21:18 22:12 23:06 10:48 11:42 12:36 13:30

For Further Information on Applying for Phase IV, contact:

Partnership Coordinator Partnership for Safe Water American Water Works Assoc. 6666 W. Quincy Ave. Denver, CO 80235 Phone: (303) 347-6169 FAX: (303) 794-6303 e-mail: [email protected]

Completed applications should be mailed to the above address.

Appendix A Partnership for Safe Water Phase IV Application Document Check List Minimum Requirements The requirements listed below are the minimum that will be accepted before the PEAC can begin its review for Phase IV recognition. The plant is encouraged to provide any additional information that may be helpful for the PEAC to understand any unusual data or plant situations. The burden is on the plant to provide adequate information for the PEAC review. The PEAC may request, at their discretion, any additional information it may need to fully assess the performance of the plant to satisfy Phase IV requirements.

1. Plant raw water turbidity results for the most recent 12-month period using the Partnership data collection software (example shown in Figure 1).

2. Plant settled water turbidity results from each settling basin (or clarifier) for the most recent 12-month period using the Partnership data collection software.

3. Plant filtered water turbidity results from the combined filtered effluent for the most recent 12-month period using the Partnership data collection software. Explain source of the data (maximum values, specific times, other).

4. Individual monthly filter turbidity statistics tables similar to shown in Figure 2 for the most recent 12-month period. Explain any missing data (data gaps). Explain source of the data (maximum values, specific times, other). Comment on percentile values above 95th that indicate some turbidity values above 0.10 NTU.

5. One turbidity profile, that includes a backwash profile, from the filter run with the maximum validated turbidity value for each month. The profile should be accompanied by a narrative description of any unusual turbidity values.

6. Current plant schematic diagram. Note changes from Phase III report.

7. Copy of the Phase III summary from the PEAC that indicates “areas of strength”, “areas of good faith effort”, and “area for continuing improvement” for the 14 scoring categories.

8. A narrative that describes how each of the general parameters from the PEAC Phase III summary report that were judged as “areas of good faith effort” and “areas for continuing improvement” have been elevated to an “area of strength.” This includes the brief (<5 page) narrative statement as described previously In addition, It is recommended, though not required, to also address those parameters originally scored as “areas of strength”.

9. A narrative that answers the questions on complacency and reliability.

10. A narrative that describes the plant procedures for sample collection and quality control (including information similar to Appendix B) to ensure data integrity.

11. A narrative explanation of all individual turbidity values that exceed 0.30 NTU from each filter for the most recent 12-month period.

12. A brief narrative that explains why this plant should be recognized as one of the best run plants in the global water community and receive the Partnership’s award for “Excellence in Water Treatment.”

13. A cover letter that included contact information, name of plant, utility name, and provides the name, telephone number, and e-mail address of the primary contact.

14. A written statement that the utility has not received a notice of violation for any applicable regulation during the 12-months prior to the award application date.

Appendix B

Partnership Phase IV individual filter effluent turbidity evaluation checklist

Turbidimeters on-line for each filter? YES ____ NO ____

Number of turbidimeters in use on filters

Turbidimeter Make (example: Hach, GLI, etc):

Turbidimeter Model (example: 1720E, etc) Note: List all types of turbidimeters in use on filters

Tapping location relative to filter effluent valve: BEFORE ____ or AFTER ____ or OTHER (describe)

Tapping location relative to sampling of filter to waste stream: DOES ____or DOESN’T ____ SAMPLE Filter-To-Waste

Tap sampling location on pipe: Vertical ____ Diagonal-up ____ Diagonal-down ____ Horizontal ____ Bottom ____

Turbidimeters close to sample tap: YES ____ or NO ____ If NO, explain:

Turbidimeter Calibration with: Formazin ____ or USEPA approved pre-mixed ____

Turbidimeter Calibration Frequency at least quarterly: YES ____ or NO ____ If NO, explain

Turbidimeter verification according to manufacturer’s recommended method: Yes ____ or NO ____

Turbidimeter verification frequency at least monthly: YES ____ or NO ____

If NO, explain

IFE turbidity value reported based upon:

Bubble reject mode: enabled ____ or disabled ____ Signal average (seconds): 6 ____ or 30 ____ or 60 ____ or OTHER Print frequency (minutes):

Data transmitted via:

SCADA: YES ____ or NO ____ (describe: ) Other Software: YES ____ or NO ____ (describe: ) Stripchart: YES ____ or NO ____

Data transfer to Spreadsheet via: Manual entry: YES ____ or NO ____ Direct link with SCADA: YES ____ or NO ____ Direct link with signal output module: YES ____ or NO ____ Direct link with other software: YES ____ or NO ____ Other:

If SCADA used, describe SCADA polling interval: IN SECONDS ____or IN MINUTES ____ If frequency in minutes, then how many?

Describe the data manipulation, if any, performed manually, or by the signal output module, SCADA, or other software prior to placing a value into final percentile spreadsheet:

Describe how often “print frequency” data is collected for use in the spreadsheet: (example: data is “printed” by turbidimeter every 1 minute, continuously scanned by SCADA within seconds polling interval, and placed into a SCADA file using real time values every scan, this file is then used by a program to grab data from this file every 15 minutes, this data selection is initiated at 00:01 hours and continues every 15 minutes thereafter. This “15 minute data” are transferred via a direct link software to excel, where it is written to floppy disk and then copied to final spreadsheet for percentile determination.):

Did the final submitted percentile calculations include the following 15 minute data values?

First data value after a wash: YES ____ or NO ____ Data values during a wash: YES ____ or NO ____ Data values during documented maintenance activities: YES ____ or NO ____

Does your utility do the following: Assign one person to track IFE turbidity values on a monthly basis? YES ____ or NO ____ Document time interval post backwash peak is above 0.10 NTU? YES ____ or NO ____ Document all maintenance (calibrations, verifications, flushing) related turbidity spikes? YES ____ or NO ____

Other information - Please be sure to describe any data invalidation guidelines and/or procedures used by the plant to evaluate questionable data points (additional supporting information in addition to this form may be included):

Thank-you for taking the time to complete this form, accurate answers will allow the Partnership Committee reviewing your report to understand the relationship of your submitted data to optimization. 21

Appendix C Excellence in Water Treatment Award Annual Reporting Requirements

After receiving Phase IV recognition, the utility will be required to submit performance data annually to renew their Phase IV status. Submit the most recent 12-month period performance data as described in the Phase IV Application guidelines. A written interpretation report should examine plant performance trends, year over year, and verify that optimized performance (meeting all of the Phase IV performance goals) has been maintained. Explain any settled or finished water turbidity values that exceed Partnership Phase IV goals and steps that have been taken to prevent these occurrences in the future. State that the plant has remained in compliance with all applicable regulations since the last annual report. If the plant received a notice of violation, send a copy and explain the circumstances.

Submission of the Phase IV annual report will also satisfy the annual reporting requirements for maintenance of the plant’s Directors Award for the Treatment Plant Optimization Program.

At a minimum, the annual report must include the following:

1. Plant raw water turbidity data for the most recent 12-month period.

2. Plant settled water turbidity results from each settling basin (or clarifier) for the most recent 12- month period using the Partnership data collection software.

3. Plant filtered water turbidity results from the combined filtered effluent for the most recent 12- month period using the Partnership data collection software.

4. Individual monthly filter effluent turbidity statistics tables, as indicated in the Phase IV application guidelines, for the most recent 12-month period. Clearly explain the source of the turbidity data (maximum values during the sampling period, reading taken at specific times, or other data sampling method).

5. One turbidity profile, that includes a backwash profile, from the filter run with the maximum validated turbidity value for each month. The profiles should be accompanied by a narrative description of any unusual turbidity values. Unusual turbidity values are any values above 0.10 NTU. A comprehensive narrative explanation is required for any values above 0.30 NTU.

6. A brief narrative that includes: explanation of performance trends; verification that Phase IV goals continue to be attained; explanation of each individual turbidity excursion above the Phase IV goals; explanation of measures to ensure that exceedances do not occur in the future; descriptions of recent operations, process or source changes and plans for the immediate future and how these have affected or may affect plant performance.

7. A brief narrative that explains why this plant should continue to maintain its status as one of the best run treatment facilities in the industry and receive a one-year renewal of “Excellence in Water Treatment Award” status.

8. A cover letter that includes a written statement that the utility has remained in compliance with all applicable surface water treatment regulations.

Appendix D Partnership for Safe Water Individual Sedimentation Basins Performance Guidance for Plants Not Meeting Turbidity Goals

Does Individual Sedimentation Basin Turbidity YES Performance Meet Proceed with Phase IV Partnership Goals? application and review process

Provide Additional Documentation: special studies, administrative policies, performance data, and historical data.

Are Additional Data and Documentation NO Adequate to Substantiate Optimization as determined by the PEAC review team?

YES

PEAC Review Team will proceed with review of application.