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Legislative Update: Illinois EPA Rulemaking Activity
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Illinois Section AWWA
October 28, 2013


Illinois Section AWWA would like to inform our members of the rulemaking activity that has been initiated by the Illinois Environmental Protection Agency (IEPA). IEPA has proposed to adopt new rules pursuant to the Public Water Supply Operations Act in Part 681, and therefore is seeking to repeal the existing Part 680.

Illinois Section AWWA has summarized the proposed changes for you below as well as provided a sample letter of support that you can submit to IEPA. CLICK HERE FOR SAMPLE LETTER OF SUPPORT

The proposed rule changes were included in The Illinois Register as of Friday, October 11, 2013. Persons who wish to submit comments on the proposed rules have 45 days to do so in writing to IEPA.

Operator in Training

Under proposed rule, Part 681, a person may take the operator certification exam without any hands-on experience or time working in a water plant. After receiving a passing score, this person would be considered an "Operator in Training” for the class of the examination passed. Examination results are valid for a period of 6 years. To acquire a certificate of competency, and become a certified water supply operator, an Operator in Training would only then need to meet the required experience.

Real Life Example #1: John is looking to change careers and has heard that being a water operator is a great job. He has never been inside a water plant. John applies to take the Class D exam and passes. He is now a Class D Operator in Training. John interns at his local water plant, which is also a Class D facility. John meets the required experience for a Class D license which is 6 months. John applies for a Certificate of Competency and is approved. John is now a Class D water supply operator.

Real Life Example #2: Jane is currently working at a Class C facility with a Class D water supply operator license. Jane wants to advance and become a Class A operator someday. Jane takes the Class A exam and passes. She is now a Class A Operator in Training, and still holds her Class D license. In order to renew her current Class D license, Jane still must acquire 15 renewal training credit hours before June 30 of her renewal period. Jane applied at the neighboring utility, a Class A facility, and was able to get hired because she had proven that she had already passed the Class A exam. After 3 years of working for this facility, Jane was able to receive her Class A water supply operator license.

Under these proposed rule changes, it is not required that an Operator in Training acquire the matching license level’s renewal training credit. Illinois Section AWWA believes continuing education is invaluable and a necessity to keep up with current changes in both the industry and regulations. Therefore, Illinois Section AWWA encourages IEPA to make training credit hours a requirement for operators in training. In example 1 above, with the proposed rule changes and Illinois Section AWWA’s suggestion, John would additionally need to acquire 15 training credit hours, every three years, from the point of passing the D exam to the point of receiving a Certificate of Competency as a Class D Water Supply Operator.

Renewal Training Requirements

As of July 1, 2016, certified drinking water operators will be required to obtain at least 2/3 of their training classified as "technical training". Technical training relates to the technical aspects of water treatment and distribution, or daily duties of a water supply operator. Not more than 1/3 of the total training submitted may be non technical, relating to professional responsibilities of the operator (management classes) and/or safety.

For your convenience during 2014, Illinois Section AWWA will begin to classify training as:

  • Technical - must acquire a minimum of 2/3 of total training hours submitted. Technical training is classified as training relating to the daily duties of a water supply operator
  • Non Technical- can add up to no more than 1/3 of total training hours submitted.
    • Professional Responsibilities of the Operator- such as management training, excel classes, leadership training
    • Safety

Proof of Training Records, Record Keeping, and Audits

Under proposed rule, Part 681, water supply operators are required to maintain their own proof of training records for a period of 6 years from the date of the training (Part 680 required 4 years).

A large benefit of taking training through Illinois Section AWWA is that we do this for you. Illinois Section AWWA records attendee’s training history in their individual Illinois Section AWWA training record. Simply login at, click on Manage Profile > Professional Development, and there, you will see all of your training history with Illinois Section AWWA. With the click of a button, you can easily print or email yourself a copy of your training records. This record will include attendee name, class title, IEPA number, training date, location and the number of hours awarded.


Proposed rule, Part 681, provides the ability to impose sanctions on operators that do not follow the law. This would include falsifying records, gross negligence, misconduct or incompetency in the operation of a public water supply, willful violation of the Environmental Protection Act or any rules und this Act. Although this sanctions process already exists within Part 680, IEPA has rewritten these rules to provide more detail in the IEPA hearing process.

Contract Operators

Previously, a contract operator must maintain records to document that all contract provisions are being met. Under proposed rule, Part 681, these records must be maintained for 5 years following generation of the data. The contract operator’s records must be made available to the Agency upon request for inspection and photocopying during normal business hours.

What can you do? Act today!

Illinois Section AWWA encourages each water supply to submit comments on the proposed rules. Illinois Section AWWA supports the proposed rules with the exception that Operators in Training be required to acquire training credit hours matching their operator level.

CLICK HERE and you will find a link to a sample letter that can be personalized and submitted to Illinois Environmental Protection Agency.

The proposed rule changes were included in The Illinois Register as of Friday, October 11, 2013. Persons who wish to submit comments on the proposed rules have 45 days to do so in writing to the notice of:

Joanne M. Olson
Assistant Counsel
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19726
Springfield, Illinois 62794-9276

Illinois Section AWWA
545 S. Randall Road | Ph: 866-521-3595 | St. Charles | IL | 60174

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