2.1 OHA System Classification, Direct Responsible Charge and the Filtration Endorsement

Which Systems Need a Certified Operator?

OHA's operator rules apply to community and non-transient non-community (NTNC) public water systems. The water supplier must at all times employ, contract with, or otherwise use an operator in Direct Responsible Charge (DRC) of every distribution system and every water treatment plant. The DRC operator must be available whenever decisions about treatment processes, water quality or water quantity that may affect public health are made (OAR 333-061-0225).

Classification Rules (OAR 333-061-0220)

Small water systems

A system is a small water system when it serves fewer than 151 service connections and either uses only groundwater or purchases finished water from another public water system. Its operator needs the Small Water System (SWS) certification, or any Level 1-4 certificate.

Water distribution: Table 50

Water treatment: Tables 51 and 52

Treatment classification applies when the system is not small and a plant treats for regulated contaminants. Table 51 assigns points for each characteristic. Selected values:

Table 52 converts the total: WT1 = 1-30, WT2 = 31-55, WT3 = 56-75, WT4 = 76 or more.

Worked example

A conventional surface-water plant serves 30,000 people at 2.0 MGD. Its points add up as follows:

• Size: 3 (population gives 3, which is more than the 2 from flow)
• Surface source: 5
• Chlorination: 5
• Alum plus polymer: 2
• Mechanical rapid mix and mechanical flocculators: 3 + 3
• Rectangular sedimentation: 5
• Dual media filters: 5
• Caustic soda corrosion control: 6
• Fluoridation: 5
• Backwash residuals to lagoons: 5
• SCADA with partial control: 3

The total is 50 points, so the plant is WT2. It uses conventional filtration on surface water, so the plant also carries the Filtration Endorsement classification.

The Filtration Endorsement (FE)

Under OAR 333-061-0220(4), the FE classification applies when a plant is classified Water Treatment 2 and uses conventional or direct filtration to treat surface water or groundwater under the direct influence of surface water (GWUDI). The operator designated in DRC of that plant must hold FE certification. The exception is an operator already certified at Water Treatment Level 3 or higher, who needs no endorsement. Qualifications for the endorsement are covered in the next section.

Operators Below the Required Level: Written Protocols

A supplier may use additional operators certified below the required level, but it must write a protocol for each one (OAR 333-061-0225(2)). The protocol:

• describes the operational decisions the operator may make;
• requires notifying the DRC operator after decisions affecting process control, water quality or quantity;
• states when and how the operator must consult the DRC operator;
• accounts for the operator's certification, skills and the expected operating conditions; and
• is signed and dated by the DRC operator and the operator, and kept available for OHA inspection.

Reporting and Contract Operators

• The supplier reports the DRC operator's name to OHA and must notify OHA within 30 days of any change, using the DRC designation form.
• A supplier may contract with an individual certified operator, another water supplier or an organization (OAR 333-061-0230). A contracted DRC operator must be certified at or above the facility classification. The written contract must require the operator to be on call 24 hours every day and able to respond on site, and to take corrective action when MCLs are exceeded or minimum treatment is not maintained.
• Contracts must be signed before any service begins and submitted to OHA within 30 days of signing. They are valid only while the operator's certification is current.

Every Operator's Duties (OAR 333-061-0232)

All operators must comply with any OHA order or investigation, ensure that every document filed with OHA is true and accurate, and immediately notify OHA when they observe a rule violation that may result in a public health hazard.