It was a timely conversation because here in Colorado, the Water and Wastewater Facility Operators Certification Board (board) revoked an operator’s certificates just two weeks prior to the ASDWA meeting for essentially being a “paper” operator. Three of his systems experienced disinfection or treatment violations due to his negligence. At two of these systems, Water Quality Control Division inspectors conducting a sanitary survey identified conditions that resulted in the immediate issue of boil water advisories. Furthermore, the operator never even visited one of these sites. At the third system, it was found that essential treatment equipment was not properly working. At all three sites, the operator failed to adequately train the individuals who performed routine operational duties and he failed to verify that the on-site operators were performing their tasks correctly - or at all. The operator failed to develop written delegation plans, so on-site operators had no operational limits and lacked instructions about when, or if, they should contact the ORC. As a result, uncertified operators made process control and system integrity decisions in violation of Regulation 100. One of the system administrators fittingly called this ORC “an operator in name only.”
The disciplinary action hearing concerning this operator underscored the risks to public health when a certified operator in responsible charge inadequately and/or inappropriately delegates essential ORC duties and/or fails to provide adequate supervision of the facility. In Colorado, this behavior is negligent; it is operator misconduct that can result in loss of certification.
Some other states have confronted this potential risk to public health or are planning to amend their regulations.
- In Wyoming, contract operators are now required to keep records of the amount of time they spend and the duties they perform at each contracted facility. They are also required to make a physical inspection of each contracted facility at least once a week unless an alternate schedule is approved by the state.
- Connecticut has proposed regulatory revisions that would include a section, like Colorado’s Regulation 100.12, which specifies the Chief Operator (what Colorado calls an ORC) duties. Each system would also have to provide the state with a list of non-delegable duties. Per Connecticut’s proposed revisions, the PWS Chief Operator designation would require state approval.
It is evident from the outcome of the recent disciplinary action hearing that Colorado’s current regulations provide means to address “paper” operator behavior. We intend to continue implementing and enforcing our existing requirements. New operator certification requirements are not being considered at this time.
➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison
