COVID-19 Response, Questions and Guidance for Public Water Systems
Information from the DNR Drinking Water and Groundwater Program
The DNR ("department") is getting inquiries regarding COVID-19 and procedures public water systems should take now that the outbreak has reached Wisconsin and is in our communities.
The department is actively monitoring and involved with the Wisconsin Emergency Management Agency and its state partner agencies and will provide additional updates as needed to our public water systems.
We are all aware that providing safe drinking water is an essential public health service. We appreciate the efforts being taken by all public water systems across the state to ensure our consumers have continued access to safe drinking water, particularly during the COVID-19 state of emergency. We will continue to face challenges during this time and will work together to ensure systems are capable of providing service to meet this important public health responsibility.
The department recommends that all water systems review and update their emergency operation plans as appropriate. Things to consider are developing mutual aid agreements with neighboring utilities, WIWARN, WRWA, AWWA or other organizations to provide backup operators as necessary, isolating healthy staff at your facility and any other actions that ensure the protection of public health by providing safe drinking water.
The department will continue working closely with systems and will continue evaluating areas where additional compliance assistance is necessary, such as alternatives to routine compliance sampling locations in the distribution system. In situations where alternatives are authorized by the department, water systems need to document the measures taken. All mailings from DNR staff to you will be electronic at this time.
The department recommends the following resources for those of you looking for more information specifically related to COVID-19. The state of Wisconsin will take measures as needed to protect public health and ensure the provision of safe quantities of drinking water.
- Wisconsin Department of Health Services
- Centers for Disease Control and Prevention (CDC)
- Johns Hopkins University & Medicine
- Public Service Commission of Wisconsin (PSC)
- Wisconsin Water and Wastewater Agency Response Network (WIWARN)
- American Water Works Association (AWWA)
- Association for State Drinking Water Administrators
- U.S. EPA
- U.S. EPA Memorandum
- World Health Organization
We recommend people routinely check this page for updates and new information. The department is committed to working closely with all of you to ensure safe drinking water for the state of Wisconsin.
If you have any further questions, please feel free to contact DNR by emailing DNRDrinkingWaterCOVIDfirstname.lastname@example.org.
Date/Time Host Topic, Recording & Other Information May 14, 2020 DNR Live Meeting April 21, 2020 DNR Live Meeting April 16, 2020 DNR Live Meeting April 7, 2020 EPA Webinar COVID-19 Planning and Response April 2, 2020 DNR Live Meeting
- General Operations
Operations at Public Water Systems during COVID-19 Pandemic
Conditions may change as this situation evolves. The department will continue to monitor the state and federal orders and will adjust our response and direction accordingly. Every effort should be made to comply with all regulatory requirements. The department will work with systems as this situation progresses and will provide compliance assistance during the Public Health Emergency. Appropriate documentation is necessary.
The operation of public water systems by trained and properly certified operators to ensure consumers are provided with safe drinking water is a critical public health-related responsibility. Certified operators are public health officials and should be performing their civic duty to protect public health and safety during this declared emergency. The department expects public water and wastewater systems to do their best to provide appropriate staffing for their facilities.
Recommendations for Operations Due to COVID-19
- Have appropriately certified backup operators identified in the event personnel become sick, specifically the subclass(es) needed for your system and treatment technologies. Wisconsin Rural Water Association (WRWA) has a list of certified operators available to fill in for water systems in the event mutual assistance is needed.
- Surface water or complex groundwater treatment facilities may want to consider sheltering healthy operators on site at the utility and creating operating teams to minimize contact between other personnel.
- Practice social distancing to the greatest extent possible. Minimize the number of people, including co-workers, that you come into contact with when conducting your daily work activities. Stagger shifts and breaks to minimize contact between other personnel and remain in your designated work location for meals. Avoid entering any office, shop or treatment plant areas that are not required to perform your job duties.
- Have contingencies in place in the event any water system staff fall ill (designated administrative backups who have necessary computer system access; certified operators; personnel knowledgeable of the water treatment, storage and distribution system).
- Disinfect common surfaces before, during, and after shift changes (desks, doors, handles, tools/equipment).
- Ensure proper air ventilation at water system facilities, so potentially contaminated air is not recirculated within.
- Building closures/reopening: Ensure that buildings water systems are safe to use after a prolonged shutdown to minimize the risk of Legionnaires' disease and other diseases associated with water. Review the CDC's Guidance for Building Water Systems prior to reopening.
- Noncommunity water systems: Schedule visits to respective systems in times when other individuals are not present (i.e., outside normal working hours).
Resource: EPA Pandemic Incident Action List
The production and delivery of safe drinking water by public water systems is a priority. In case the tools above cannot be used, contact your local DNR field representative as soon as possible, and the they will work through the situation with you.
The Wisconsin Section of the American Water Works Association (WIAWWA) is coordinating with FEMA and the U.S. EPA to provide 80,000 reusable cloth masks to the State of Wisconsin for distribution specifically to water and wastewater utilities to help slow the spread of COVID-19. They will be available for pickup at one of the locations listed below AFTER submitting a request form here.
The masks will be available for pickup at three locations: Stevens Point, Cudahy and Madison. Ten masks are allowed for each employee working in the drinking water and/or wastewater industry. These masks are not available to other city agencies or to the general public. Masks come in bags of five and will only be distributed in multiples of five. These are cloth masks that can be washed and reused up to 15 times. Please note these are not N95 masks.
To monitor and account for the distribution of the masks to drinking water and wastewater utilities we ask that you fill out the request form. More information is located on the Wisconsin Section of the American Water Works Association (WIAWWA) website.
The DNR has entered phase 1 of its COVID-19 Bounce Back Plan. The Drinking Water and Groundwater program will be resuming field work, including compliance inspections. DNR drinking water staff will be scheduling pre-inspection calls with facilities to gather some information that had been collected in the past during on-site visits, as well as on-site visits. The calls will include discussing any concerns systems may have about on-site visits and protocols that may be needed to complete all aspects of a compliance assessment. DNR staff will be expected to utilize PPE such as masks and following social distancing protocols during on-site visits.
If you have upcoming due dates for corrective actions/deficiencies identified in the department's most recent sanitary survey and you will not be able to complete the required work as a result of the state's COVID-19 response, contact your DNR representative for consideration of an extension. Your request must be sent prior to the due date in order to avoid a violation.
Public Water Systems are required to conduct routine compliance monitoring at the water treatment plant and in the distribution system. As of April 3, 2020, U.S. EPA has not provided any relief on federal rule requirements; however, the department is considering the potential COVID-19 exposure risk to homeowners and water system personnel and is offering the following recommendations and options for flexibility.
DISINFECTION BY-PRODUCTS (DBP)
Public Water Systems required to monitor for DBPs have quarterly, annual or triennial monitoring schedules. Most systems on annual and triennial monitoring include a monitoring period in the summer months, typically July, August and September. Systems on quarterly monitoring schedule have a designated 11-day monitoring period to collect the DBP samples. Public water systems required to monitor for DBPs should continue to collect their DBP monitoring samples during their designated monitoring period and at the designated monitoring locations or with the use of the options listed below in consultation with their field representative.
- Public Water Systems can utilize alternative sampling locations, such as sampling at locations close to the usual sample locations that are accessible, at hydrants, pump stations or tanks. Please contact your field representative via email and the department will work with you on a temporarily revised sampling plan.
- Public Water Systems may elect to forgo DBP sampling this quarter and base the annual average on three quarters. Note, a missed quarterly DBP monitoring requirement will generate a monitoring violation.
LEAD AND COPPER (PBCU)
- Special purpose monitoring for main breaks. Public water systems can offer point-of-use filters to address lead and copper concerns during main replacements/breaks/disruptions and will not be required to take special purpose lead and copper samples so long as NSF/ANSI 53 certified point-of-use filters and 3-months of replacement filters are offered.
- Routine PbCu monitoring. Systems have until June 30 to complete standard (six-month) monitoring period sampling, so sample collection could be delayed until closer to the end of the monitoring period. Please Note: If an action level exceedance occurs, water quality parameters must also be collected by June 30. When the lab provides you with the results of any samples collected, consumer notice is still required.
- Routine water quality parameter monitoring. Sampling at a hydrant nearest to the normal sampling point would be acceptable. Contact your field representative via email if there are any changes.
BACTERIA AND CHLORINE RESIDUAL
Public water systems can temporarily modify monitoring site plans to minimize contact with the public. Notify your field representative via email of these changes. Chlorine residual monitoring can be collected at a hydrant, pump stations and elevated and ground level tanks; however, these locations should not be primary alternative selections to routine monitoring locations. Hydrants could produce false positive bacteria results that public water systems would need to address. As always, when sampling for coliform bacteria, public water systems must collect chlorine residuals. Sampling more frequently at fewer locations to achieve the required number of samples is allowed on a temporary basis while this pandemic is occurring.
Operators should attempt to meet reporting requirements related to Maximum Contaminant Levels (MCLs) or Action Level Exceedances (ALEs) and electronic monthly operating reports (eMOR). Violations for failure to report these will continue, however, the department is available to assist you if you contact us.
During the Public Health Emergency, the department will help public water systems comply with the regulations to ensure safe water is being produced and delivered to customers in Wisconsin. This is a matter of public health, and the department will work with elected officials to ensure these public health workers can perform their civic duty.
- Read the information in the General Operations section.
- Every effort should be made to have the Operator-in-Charge (OIC) perform facility visits. If circumstances arise that require another approach, please contact your field representative by email for other accommodations.
- Be sure to document operational changes and communicate significant changes to your field representative.
- May Operator Certification exams: The exams scheduled for May 6, 2020, have been canceled and six statewide exam sites have been reserved for August 5, 2020. Visit the DNR exams page for further updates.
- Operator Certification renewal: On Friday, April 17, 2020, Governor Evers’ signed Emergency Order #30 (EMO 30) which suspended specific sections of ch. NR 114, Wis. Adm. Code covering waterworks, water systems, septage and wastewater operators. Specifically, requirements regarding expiration of certifications every three years and continuing education credits have been suspended for those with active certifications on March 12, 2020, through the duration of Executive Order #72. The department is working to determine a period of time after EMO 30 expires that operators will have to obtain any remaining continuing education credits needed to renew their certification.-->
- Operator Certification renewal - May 14, 2020 Update: in order to allow operators that would have had their certifications expire during the public health emergency to concentrate on their essential duties, the department is extending the deadline to renew certifications to November 1, 2020.
However, the department is encouraging the renewal of certifications as soon as possible if not limited by pandemic operations.
- Waterworks, Water System and Wastewater Operators: Renew electronically.
- Septage Operators: Complete and submit hardcopy operator renewals that were previously mailed.
- Wisconsin Rural Water Association (WRWA) staff are available to provide technical assistance and have a list of backup certified operators. This can be an arrangement where they are available by phone for water system staff/operators to consult with or even observe via smart phone applications.
- If a public water system is closed and not producing water (i.e., noncommunity water system), you do not need to visit. Just note the facility is closed.
The department's Laboratory Certification staff are currently working from home. During this time, we will not be performing on-site audits; however, we are accepting applications at this time and applications will continue to be processed.
A list of laboratories approved to perform drinking water testing is provided by the Laboratory certification & registration program (LabCert), in the Tests Certified by Laboratories list spreadsheet.
- Once the file is open, choose "Drinking Water" under the MATRIX column to obtain the list of drinking water approved laboratories and the tests and methods for which they are approved to perform.
Once travel restrictions are lifted, LabCert staff will contact laboratories that are due for an on-site audit to schedule them.
Please direct any questions to Tom Trainor via email at Tom.Trainor@Wisconsin.gov.
- Engineering/Plan Review
In response to the public health emergency, we are updating the plan and specification submittal process for community water system improvements that are required under ch. NR 811, Wis. Adm. Code, to the following:
- Effective March 12, 2020, all community water system improvements must be submitted digitally.
- Send an email directly to DNRPublicWaterPlanReview@Wisconsin.gov, containing:
- Subject line:
- Water System name;
- Project type (water main, well rehab, tank painting, well site investigation report, etc.);
- External web link in which digital plan review submittals can be accessed and downloaded (e.g., ftp website, Microsoft OneDrive, Citrix Files, Dropbox, etc.)
- Do not include any attachments on the email.
- Subject line:
You will receive an automated email indicating that your email has been received. A plan review engineer will be assigned and will conduct the review of your project as normal. You can check the status of your submittal, the project ID and the assigned plan reviewer at any time on the Public water system plan review page using the 'Plan Review Web Query' tool. Please note, all staff are currently working remotely. As a result, email correspondence with the plan reviewer is preferred over phone calls.
Additionally, all reports, correspondence, etc. to be submitted to DNR field representatives should be emailed to them directly, until further notice.
- Effective March 12, 2020, all community water system improvements must be submitted digitally.
Operations at Wisconsin's public water systems during the COVID-19 pandemic will continue. There is no evidence to suggest that this virus is spread via drinking water. While the COVID-19 virus has not been detected in drinking water, conventional water treatment methods that use filtration and/or disinfection, such as those in most municipal drinking water systems, should remove or inactivate the virus that causes COVID-19.
The DNR will continue to monitor the state and federal orders and will adjust our response and direction accordingly. Every effort is being made to comply with all safe drinking water requirements.
- Building Closures/Reopening/Flushing
Building and business closures for weeks or months reduce water usage, potentially leading to stagnant water inside building plumbing. This water can become unsafe to drink or otherwise use for domestic or commercial purposes. WI DNR recommends that building owners and managers take proactive steps to protect public health by minimizing water stagnation during closures and taking action to address building water quality prior to reopening. The following links provide guidance related to water quality regarding building closures and reopening.
- US Environmental Protection Agency (US EPA)
- Center for Disease Control (CDC) Guidance on Re-opening of Building Water Systems
- American Water Well Association (AWWA) return to service guidance
- Milwaukee Water Works Guide to Safe Reopening of Buildings
- Green Bay Water Utility Flushing Guidance
- Madison & Dane County Public Health: Tips for Re-Opening After Closure
Will violations for monitoring violations still occur?
The U.S. EPA says violations will still occur. They are working on a special flag to identify that it was related to COVID-19.
Will systems still be required to monitor at closed locations?
Do your best, however do not risk exposure at locations with people maintaining isolation. Alternative sites in the same pressure zone can be used when necessary.
Will laboratories remain open during this time?
The department has been in contact with laboratories and most are still receiving samples. If your lab is not accepting samples, please use the lists on the Wisconsin DNR accredited laboratories page to find another lab for your drinking water samples.
Should we increase our chlorine levels at this time?
No. Normal disinfection treatment is designed to kill viruses.
My business is not operating right now due to COVID-19. Do I have to collect samples?
If your business is currently temporarily closed, please contact your DNR representative to discuss your monitoring requirements.
Where can I find more information regarding the March 26 Temporary COVID-19 Enforcement Policy provided by EPA?
Visit the EPA's Frequent Questions About the Temporary COVID-19 Enforcement Policy webpage dedicated to the content of this policy, which provides a variety of explanations regarding the content of that temporary policy.