Understanding the
Proposed PFAS Rules
The Critical Role
of Pretreatment
Building Confidence
in RO Monitoring
Cybersecurity New
Front Line
PLUS —
Bryant L. Bench
Scholarship Winner
CAROLLO ENGINEERS VOLUME 3 2026
DESIGN-BUILD DESIGN-BUILD DESIGN-BUILD
TWO Paths
ONE Destination
TWO Paths
ONE Destination
TWO Paths
ONE Destination
TWO Paths
ONE Destination
Are you ready for your next design-build
opportunity? Our feature story looks at
two paths to readiness you can follow
to optimize this dynamic delivery
capability. Either one—when done right—
can greatly increase your organization's
chances of a successful project outcome.
This issue also explores the critical role pretreatment plays
in protecting wastewater treatment plants and receiving
ecosystems from excessive or harmful industrial pollutants.
Plus we detail some recent advancements in reverse osmosis
monitoring that help maintain system reliability when RO
data doesn't behave as expected.
In our cybersecurity article we alert you to the growing threat
posed by recent world events to US water and wastewater
systems, and outline some critical measures to safeguard
these essential public amenities from bad actors. And finally,
we proudly introduce the 2026 winner of Carollo’s Bryant L.
Bench scholarship.
From developing trends to innovative strategies, we hope
this issue informs and inspires you. Please reach out to
me or our authors with your thoughts. We’d love to hear
from you!
CURRENTS / IN THIS ISSUE
ROSA YU, PhD, PE (ryu@carollo.com)
ALAN ROBERSON, PE
On May 18, 2026, the US Environmental
Protection Agency (USEPA) proposed two new
rules that will impact the regulation of per- and
polyfluoroalkyl substances (PFAS) in drinking
water. The first would allow public water
systems to seek an extension to comply with
the maximum contaminant levels (MCLs) for
the two most common PFAS. The second
would rescind existing MCLs for other PFAS.
PROPOSED PFOA AND PFOS
COMPLIANCE EXTENSION RULE
This rule would allow utilities to seek a two-year federal
extension to comply with MCLs for perfluorooctanoic acid
(PFOA) and perfluorooctane sulfonic acid (PFOS)—both set
at 4.0 nanograms per liter (ng/L). For approved systems, the
compliance deadline would shift from April 26, 2029, to
April 26, 2031.
Why Primacy Matters. So far, nine states—Colorado,
Connecticut, Idaho, Illinois, Maryland, North Carolina,
Vermont, Washington, and Wisconsin—have incorporated
the new PFOA and PFOS standards into state drinking
water regulations and submitted primacy program revision
applications to USEPA.
Once states obtain primacy, they may choose to shorten or
end an exemption granted by USEPA.
PROPOSED NEWPROPOSED NEW
PFAS DRINKING PFAS DRINKING
WATER RULESWATER RULES
What Utilities Need to Know
EDITORIAL
DIANA LEONARD (dmleonard@carollo.com)
CONTENT EDITOR
Diana Leonard / dmleonard@carollo.com
COPY EDITOR
Mary Ann Mavrogianes
GRAPHIC DESIGNER
Silvia Higuera-Backlund
IN THIS ISSUE
Understanding the Proposed PFAS Rules
The Critical Role of Pretreatment
Design-Build: Two Paths, One Destination
Building Confidence in RO Monitoring
Cybersecurity New Front Line
Bryant L. Bench 2026 Scholarship Winner
2
4
6
8
10
11
Early Engagement is Critical
Utilities that align with regulators, secure equipment, and
communicate with customers will be best positioned for
whatever emerges from this rule-making process.
2
REGULATORY CORNER / CURRENTS
3
Extension Rule Interim Control
Measures. Systems with a PFOA
or PFOS sample at or above 12 ng/L
would be required to implement at
least two of six control measures
during the exemption period.
1 Provide water pitchers and a
two-year supply of filters certified
to reduce PFOA and PFOS levels.
2 Deliver alternative water supplies
with lower PFOA and PFOS levels
by distributing bottled water,
temporarily switching to a
new source,
or blending
water supplies.
3 Install, operate,
and maintain
point-of-use or
point-of-entry
devices certified
to decrease PFOA
and PFOS in all
customer locations.
4 Implement actions and plans to
decrease PFOA and PFOS levels
in drinking water sources via
source identification and
source control.
5 Distribute written public education
materials to consumers on PFOA
and PFOS exposure sources.
6 Conduct community education
and outreach activities on PFOA
and PFOS in drinking water.
Note that the control measures selected
cannot include options 5 and 6 only.
Control measures for systems
with PFOA and PFOS levels above
4 ng/L but below 12 ng/L would
not be required during the
exemption period.
Jan. 1 Apr. 26 Apr. 26 Apr. 26
2027 2029 2031
Initial monitoring begins
Compliance
monitoring begins
MCL compliance begins Potential PFOA and
PFOS MCL compliance
extension
Initial monitoring must be
completed and submitted
Public notification required
for MCL violations
2019-2026
Engage early and often with
your state primacy agency.
States will ultimately decide if they
want to allow for the federal exemption. Once
states obtain primacy, they may choose to shorten
or end an exemption granted by USEPA. Early
engagement can clarify expectations and
reduce uncertainty.
Continue advancing treatment
planning and implementation.
Do not pause or delay technology
evaluation, system design, construction, or system
commissioning while these two proposed rules are
being finalized.
Consider alternative project delivery
approaches. For capital improvement
projects, advance early work packages
or pre-procurement strategies to secure long-lead-
time items and reduce schedule risk.
Plan for interim actions. Utilities
may need to identify and implement
interim measures, such as raw water
blending, powdered activated carbon application,
and other available tools. Communicate with state
primacy agencies and customers about these
interim control strategies.
Establish a public communication
and outreach plan. Seeking a
compliance extension requires formally
certifying noncompliance, which may necessitate
public perception strategies.
Proposed changes may offer more time for
PFOA and PFOS compliance, but they do not
reduce the need for planning. The period for
public and written comments has passed;
however, utilities can still implement several
proactive measures to better navigate the
evolving PFAS regulatory landscape.
ACTIONS UTILITIES CAN
TAKE TO STAY AHEAD
Carollo Can Help
Carollo can help utilities understand
the proposed rules, coordinate with
state primacy agencies, prepare
extension applications, determine
treatment needs, design treatment
systems, advance procurement
and construction strategies, and
develop public outreach to foster
consumer trust while utilities
prepare for compliance.
PROPOSED PFAS MAXIMUM
CONTAMINANT LEVEL
RESCISSION RULE
This rule would rescind the MCLs
for perfluorohexane sulfonic acid
(PFHxS), perfluorononanoic
acid (PFNA), hexafluoropropylene
oxide dimer acid (HFPO-DA), and
hazard index (HI) mixtures that
include these three compounds
plus perfluorobutanesulfonic
acid (PFBS).
This rescission will not affect the
PFOA and PFOS regulation. NA,
HFPO-DA, and PFBS would
not be regulated beyond the
final date. USEPA emphasizes
that this change is not an
abandonment of concern
about these PFAS, but rather
a restart to consider regulating
them in the future with proper
scientific review and public input.
As of January 2026, only nine
systems nationwide exceeded
MCLs for PFHxS, PFNA, HFPO-DA,
and/or HI mixtures—indicating
that only a small percentage of
systems will be able to avoid
PFAS treatment under the MCL
rescission rule.
PFAS monitoring and data reporting milestones remain unchanged
by the proposed compliance extension and MCL rescission rules.
Awareness. Organized pretreatment programs must
remain current to respond to ongoing regulations and
local ordinances, such as sewer use ordinances, enforcement
response plans, and inter-jurisdictional agreements.
Adaptability. Change is constant. This is evidenced by
the recent surge in large-scale industrial facilities such
as data centers and semiconductor facilities—as well as
the adoption of direct potable reuse in many communities.
Utilities must remain nimble to develop, evaluate, or update
pretreatment programs that reflect the current service area,
treatment train, and compliance priorities. Adaptability is
essential in responding to unexpected changes, such as
abrupt pollutant discharges, unexpected industrial
development, or upcoming water reuse needs.
It's important to recognize that wastewater treatment
plants frequently discharge to bodies of water that may
ultimately become sources of drinking water. Protecting
them is a shared responsibility—affecting utilities, dischargers,
and rate payers alike.
The Preventative Mitigation Toolbox
Industrial pretreatment programs (IPPs) are the first barrier
for publicly-owned treatment works (POTWs) to safeguard
their facilities and the receiving ecosystems from excessive or
harmful pollutants. Developing regulations and requirements
for industrial users can protect utilities from toxic or high-
strength discharges that the POTW was not specifically
designed to treat—such as heavy metals, toxic chemicals,
or corrosive acids. These harsh pollutants can corrode
pipes or destroy fragile biological processes, and eventually
reach a receiving lake or river.
Because many pollutants adhere to solids during the
wastewater treatment process, high-influent loading can
cause excessive pollutant concentrations in the biosolids as
well, making the disposal of municipal sludge increasingly
difficult or even impossible.
Alleviating these issues is especially important for water
reuse or recycling programs.
Local limit maintenance. One of the most common tools
in a utility’s pretreatment toolbox is maintaining local limits
that reflect the current service area and its limitations. Local
limits regulate industrial discharges to protect treatment plant
infrastructure, improve worker safety, and secure environmental
compliance. They should be evaluated every National Pollutant
Discharge Elimination System (NPDES) permit cycle or when
significant modifications or end uses change at the POTW.
Industrial protocols. Industrial dischargers have a
primary impact on pretreatment programs. Protocols
are a requirement of a federally-approved IPP and include
frequent inspections, updated permits, and recurring
industrial waste surveys.
CURRENTS / PROJECT UPDATE
4
OLIVIA TAHTI (otahti@carollo.com)
KRISTEL BAUMGARDNER-KRANZ, PE
MARY KATE FORKAN
SYDNEY PAZERA
THE IMPORTANCE OF
A well-defined pretreatment program
sharpens the tools needed to protect
POTWs and mitigate potential problems if
discharges in the collection system go awry.
PRETREATMENT
Pretreatment in the wastewater cycle helps safeguard
facilities, receiving ecosystems, and residential,
agricultural, and industrial recycled water users.
From the smallest towns to the largest cities, wastewater treatment
plants are an essential element of effective water management—
purifying wastewater before it's returned to the environment,
preventing the spread of waterborne pathogens, and safeguarding
aquatic ecosystems. Communities rely on these facilities to help
protect their quality of life. But what protects your treatment plant?
in Protecting Wastewater
Treatment Facilities
For OCUD, the maximum
allowable headworks loading
analysis helped determine
that existing local limits were
adequate for all three plants.
allowable headworks loadings (MAHLs)—back-calculated
from OCUD’s existing local limits to the AAPLs—to determine
if the existing local limits were enough to protect each plant.
Challenging Project Meets a Tight
Schedule in the Sunshine State
The Orange County Utilities Department (OCUD) in central
Florida reached out to Carollo to re-evaluate its industrial local
limits as part of its NPDES permit renewal. Typically, local limits
re-evaluations are scoped for around six months for a single
treatment plant. However, for this project OCUD required a
meticulous evaluation of a large water quality dataset from
three water reclamation facilities (WRFs) and a key report
delivered to a state agency in just two months.
The work addressed four major components:
1. Compliance history.
2. A headworks loading comparison of existing local
limits and pollutants of concern.
3. Identification of new pollutants of concern.
4. Potential WRF design or operational modifications.
The team also evaluated historical water quality data, NPDES
permit requirements and modifications, disposal practices,
flow data, and design-based loading capacities at each WRF.
To be effective, a local limits evaluation typically includes
a headworks loading analysis. If the pollutant load at the
headworks is greater than the treatment process can
remove, a more stringent local limit may be required.
Historical water quality and flow data provided a basis to
calculate average annual pollutant loadings (AAPLs) for
each local limit pollutant entering each WRF every year for
a four-year period. This enabled comparing the maximum
While neither pollutant had existing local limits, the
evaluation recommended they be considered during
OCUD’s next local limits evaluation.
Carollo’s review of OCUD’s priority pollutant scans at each
WRF identified a total of 11 new pollutants of concern but
determined that no immediate action was currently required.
Because pretreatment projects require extensive review,
this project is still in negotiations with the state of Florida.
No two local limits evaluations are alike. Each pretreatment
program has different industrial users, relevant end uses,
and opportunities for improvement. Tailoring solutions for
each utility requires diligence, foresight, and expertise—all
of which are specialties of Carollo's pretreatment team.
■ All existing local limits protected each WRF.
■ Two pollutants of concern showed MAHL exceedances:
Ò Total Kjeldahl Nitrogen (as N).
Ò Total dissolved solids (TDS).
KEY FINDINGS
PRETREATMENT IN ACTION How OCUD Applied These Principles to Protect its Facilities
The Carollo pretreatment team has refined all the tools
necessary to close the loop between scientific analysis,
wastewater treatment facility planning and design, and
potable reuse implementation to protect POTWs, their
receiving waters, and the communities they serve.
5
6666
POISED FOR DELIVERY
TWO PATHS
TO DESIGN-BUILD
SUCCESS
Public agencies are increasingly turning to design-build (DB) to save
time, control costs, and attract skilled builders in a tight market. Based
on Carollo's experience, one DB pattern stands out—the agencies
excelling in DB aren't necessarily the ones bringing the most DB
experience to the table. They're the ones who show up ready.
One of the most common miscon-
ceptions about the DB delivery
method is that it is primarily a
procurement choice. Match the
project to the method, select a
team, sign the contract, and the
benefits follow. But in practice,
DB project benefits accrue
from capability deeply rooted in
organizational readiness.
When teams haven't built that
capability, the familiar challenges
emerge: slower decisions; mis-
aligned expectations between
owner, engineer, and contractor;
unclear roles; and uncertainty
about who owns which risk.
The method itself doesn't resolve
these challenges. Discipline and
alignment do. Teams that make
timely decisions, integrate construc-
tion thinking early, and stay aligned
when conditions shift are the ones
who realize DB's full value.
EARNING READINESS
THROUGH EXPERIENCE
1
PATH
Applying Lessons Learned
in Baytown, Texas
The Baytown Area Water Authority (BAWA) is
expanding its East Surface Water Treatment Plant
(ESWTP) from 6 to 12 mgd via progressive DB.
The expanded plant will meet growing water
demands, enhance system reliability, and
support regional planning.
This smaller-scale DB project is drawing
on lessons learned by team members
involved in other DB projects in the region,
including the 320-mgd expansion of Houston's
Northeast Water Purification Plant.
While the ESWTP is more than an
order of magnitude smaller than
the $2 billion Houston project,
the team is leveraging best
practices—such as educating
stakeholders, using
standard-form
contracts, leaning
into collaboration,
and establishing
proven conflict resolution
strategies—to shape the BAWA project.
Expected to be operational by the summer
of 2028, the project's success will not hinge
on its smaller size, but rather on the applied
discipline developed on larger, more complex
work. The BAWA team has engaged stakeholders
early. Local construction realities have informed
design. Decisions are moving quickly. Second-
guessing is rare.
For utilities and partners who have delivered
DB before, this discipline is one of the strongest
arguments for starting with a successful project
and building from there.
TWO
PATHS
ONE
DESTINATION
CHITRA FOSTER, PE, DBIA (cfoster@carollo.com)
PAUL WALKER, PE
It Pays to Invest Early
Working alongside many utilities
that have implemented DB projects,
Carollo has seen readiness built two
ways. Some agencies earn it through
experience—developing discipline
across a series of projects. Others
build it purposefully—structuring
the organization, governance, and
decision-making before the first DB
project begins. Both paths work.
Both rely on intention.
DB is a Delivery Capability,
Not a Procurement Decision
More than just infrastructure, BAWA's
ESWTP expansion is about planning
ahead, collaborating openly with multiple
partners, and building with purpose.
CURRENTS / FEATURE STORY
7777
Planning for Flood Control
Preparedness in Hurricane Country
The Harris County Flood Control District took
a different route. On the Gulf Coast, disasters,
storms, and the ensuing flooding events are
a seasonal certainty. For Texas' third-largest
county, waiting until after the next hurricane
to plan its first major DB program would be
politically and operationally untenable.
In 2025, the flood control district established
a Collaborative Delivery Task Force,
bringing together engineering, construction,
infrastructure, procurement, O&M, and the
county attorney’s office to execute a holistic
playbook to tackle the issue. Ongoing
work includes:
■ Compliant contract templates purposed
from the county's existing general conditions
and skillfully adapted to DB by the county
attorney's office.
■ Workflows—vetted through the flood control
district's purchasing and legal departments—
to streamline procurement.
■ Staff training programs and industry
engagement to build organizational fluency.
Currently the effort involves launching this first
progressive DB project as a pilot to stress-test
the playbook. It's a proactive, politically-aware
approach that positions this agency so that
when federal disaster recovery funds arrive,
the Harris County Flood Control District is
ready to deliver competitively, transparently,
and at speed.
BUILDING READINESS
BY DESIGN
2
PATH
Agencies with DB experience should use it deliberately. Assign
people who have done it before. Carry forward what worked.
Give a smaller project the same rigor as a larger one, and
favorable results tend to follow.
Agencies preparing for their first DB program should understand
experience isn't a prerequisite. Utilities that thrive on their first
program are the ones who prepare as if it were their tenth—with
governance defined, stakeholders aligned, risk allocation clear,
and construction perspective built in from day one.
Design-build rewards the teams who are READY.
Plagued by flooding in the Houston
area for nearly a century, the
Harris County Flood Control District
is actively working with project
partners to plan for its first county-
wide DB flood control strategy.
For agencies preparing for their first DB program, readiness depends
on a handful of deliberate actions taken before procurement begins.
POSITIONING FOR READINESS
AS A FIRSTTIME DB UTILITY
Define how decisions get made, and by whom.
DB moves quickly. Mapping decision authority,
approval paths, and escalation routes early keeps
the project moving forward.
Engage the right stakeholders.
Legal, operations, executive leadership, and technical
staff all benefit from being at the table from the start.
Clarify risk tolerance.
Understanding what risks the agency and contractor
will each hold, and where the engineer fits in, removes
one of the biggest sources of DB friction.
Bring construction thinking into design.
DB's value emerges when designers understand how
projects get built. Constructability reviews and early
contractor input make that real.
Set expectations for team collaboration.
Defining how the owner, engineer, and contractor
will communicate, resolve issues, and align on goals
is a foundation to build on.
The common thread across all five actions: none of this requires
prior DB experience. It requires awareness and intention.
KYLE THOMPSON, PhD, PE (kthompson@carollo.com)
YOKO KOYAMA, PE
ANDREW SALVESON, PE
CURRENTS / PROJECT UPDATE
8
How can utilities
achieve more reliable
and cost-effective
RO performance
results—even when
data doesn't behave
as unexpected?
8
Reverse osmosis (RO) systems are among the workhorses of potable
reuse, helping provide reliable pathogen removal when treated
wastewater is advanced to drinking water quality. Under ideal conditions,
RO can achieve greater than five log removal values (LRVs)—which means
it can provide multiple orders of magnitude of pathogen reduction. But
confirming monitoring results in real time can be harder than it sounds.
RO systems can
achieve high LRVs,
but it's challenging
to verify when
real-time monitoring
can't distinguish actual
integrity changes from
ordinary variability.
The stakes are high. As regulatory
expectations for pathogen removal
continue to increase, especially
under emerging direct potable reuse
frameworks, utilities need alarms
that are both fast and trustworthy.
A Balancing Act
A monitoring system must detect genuine
losses in RO integrity quickly, but it must
also avoid overwhelming operators with
false alarms that interrupt operations
without improving reliability.
That balance becomes difficult when the
statistics behind the alarm system do not
match actual data behavior. Traditional
RO monitoring thresholds often assume
LRV data follows a normal, bell-shaped
distribution. With that assumption,
operators can set thresholds based
on standard deviations and expected
probabilities. The problem is that real RO
data often doesn't follow that script.
A recent Carollo-led research effort challenged a fundamental water quality
monitoring assumption—namely that sensor data follows a normal distribution.
Funded by the US Department of Energy through the National Alliance for
Water Innovation (NAWI), this work introduced a new statistical framework that
significantly improves how utilities can interpret RO performance issues and
respond to potential integrity issues.
At OCWD, RO surrogate LRVs show that real-time monitoring data often
departs from a neat bell curve, which can undermine alarm thresholds.
High Stakes, Imperfect Data
Utilities don't usually measure pathogen removal
directly every minute of the day. Instead, operators
rely on surrogate water quality parameters,
including conductivity, total organic carbon (TOC),
and emerging indicators—such as adenosine
triphosphate (ATP) or fluorescence—to determine
how well membranes are performing. These signals
are valuable, but they are also noisy, variable, and
sometimes unpredictable. At very low concentrations,
even small measurement errors can create outlier
LRV values, making it difficult to know whether an
alarm reflects a real integrity issue or just unruly data.
WHEN DATA BREAKS THE RULES: WHEN DATA BREAKS THE RULES:
9
Across datasets from three reuse systems,
Carollo's research team found that most
surrogate LRV datasets were left-skewed,
bimodal, or non-stationary. Even when
data were averaged over longer periods,
many variables still remained non-normal.
When standard statistical tools are applied
to non-normal data, the result can be
systematic error, including more false
alarms than expected.
A New Approach:
The Shewhart Sign Chart
To address this challenge, the
research team applied a nonparametric
statistical method known as a sign
test. When implemented in a rolling
fashion, this becomes an exploratory
and supplemental method known as
a Shewhart sign chart. This approach
does not assume the data are normally
distributed. Instead, it evaluates whether
the median of recent data points is likely
above or below a target value.
The idea is surprisingly intuitive.
Each data point is treated like a simple
"above or below" result, similar to a series
of coin flips. A single low reading does
not automatically trigger an alarm. But if
multiple values fall below the threshold
within a rolling window, confidence
increases that system performance has
shifted in a meaningful way. This makes
the method less sensitive to isolated
outliers and more focused on patterns
that may indicate a true change
in RO performance.
POTENTIAL BENEFITS
Implementing the Shewhart sign chart resulted in potential monitoring benefits
observed across the multiple datasets evaluated. These included:
For most surrogates evaluated, it reduced alarm
events by at least 50 percent compared to simple threshold-based alarms on individual
data points.
With a
rolling window of 12 data points, the method has the potential to detect RO integrity issues
in as few as three consecutive measurements. Assuming hourly or minutely data points, this
means the response may be faster than daily integrity testing or daily averaging approaches
currently used for indirect potable reuse.
The approach also produced fewer than one alarm
per week across the evaluated datasets, a frequency that may better align with operational
needs—reducing unnecessary intervention while maintaining vigilance.
From Research to Full-Scale Evaluation
This work has progressed from statistical research to a prototype demonstration
using data from California's Orange County Water District (OCWD) full-scale RO
systems. OCWD and Carollo have developed a cloud-based research dashboard
combining high-frequency RO data with real-time statistical calculations, including
the Shewhart sign chart. The prototype allows these exploratory statistical
indicators to be viewed alongside existing RO performance metrics, providing
additional context for evaluating whether an apparent change may represent a
meaningful process shift.
OCWD's prototype
cloud dashboard
demonstrates
combining RO data,
real-time calculations,
and operator reporting
into a practical
monitoring workflow.
The Shewhart sign chart uses a rolling sign test to avoid reacting to isolated
outliers while still identifying exceedances that may signal a real process shift.
Multiple exceedances
in a window trigger
an alarm
Single outliers did
not trigger alarm
with n ≥ 12
Same LRV threshold as
normal-based alarms
Broader Industry Implications
Although this research was developed for RO
monitoring, its implications reach well beyond
membrane systems. Other water quality datasets
are also often non-normal, heterogeneous,
and shaped by sensor limitations and process
variability. Carollo has already begun transferring
this methodology from RO monitoring surrogates
to wastewater effluent nitrate for other clients.
The takeaway is simple: better decisions
start with better assumptions. When monitoring
methods reflect the way real-world data actually
behaves, utilities can reduce unnecessary alarms,
respond more confidently to potential performance
changes, and build more resilient treatment
operations. In other words, sometimes the
smartest way to monitor RO performance is
to stop expecting the data to be normal.
CURRENTS / WHAT'S NEW
Develop an Operational
Technology (OT)
Governance Program.
Establish policies, roles,
and oversight for operational
technology cybersecurity.
Segment IT and OT
Networks. Separate
networks to limit
lateral movement and
contain potential threats.
Replace and Harden Legacy
Supervisory Control and Data
Acquision (SCADA) Hardware.
Upgrade outdated systems and
ensure secure configuration
of all assets.
Deploy Continuous
Network Monitoring and
Asset Management.
Detect
anomalies early and maintain
visibility of all assets.
Implement Role-Based
Access Controls and
Multifactor Authentication
(MFA).
Ensure only authorized
users have appropriate access
to critical systems.
Strengthen Physical
Security Controls. Protect
facilities, equipment, and access
points with layered physical
security measures.
NORM ANDERSON, PE, CISSP, GICSP (nanderson@carollo.com)
SHAWN CORRIGAN, CEM, CBDP, ENV SP
Reliability, resilience, and public
health have always been the
core missions of public utility
systems. For the last 20 years,
cybersecurity has steadily risen
as a concern. Yet today, amid
escalating geopolitical tensions,
cyber threats still pose immediate
risks, demanding proactive
planning and proven strategies
to protect critical operatons.
10
Recent attacks have
successfully targeted
multiple water systems
using internet-accessible
programmable logic
controllers (PLCs), causing
loss of functionality, shifts
to manual operations,
and significant financial
impacts to utilities.
HOW ATTACKS
IMPACT OPERATIONS
Internet Exposure.
PLC are accessible
from the internet.
Unauthorized Access.
Attackers gain entry.
Configuration Change.
Critical settings
are modified.
Operational Disruption.
Treatment process
are affected.
Manual Operations.
Operators must respond
to maintain service.
OPERATIONAL
IMPACT
FROM AWARENESS TO ACTION
Many utilities have completed risk and cybersecurity assess-
ments. Implementing them should focus on key priorities.
1 4
2 5
3 6
REPORT
SUSPICIOUS ACTIVITY
NOTIFY
CISA
*
• FBI
STATE + LOCAL AUTHORITIES
*
Cybersecurity and Infrastructure Security
Agency
NEW FRONT LINE
ELIMINATE Direct Internet Exposure
Keep PLCs, human-machine interfaces (HMI),
and OT assets off the internet. Use virtual private
networks (VPNs), gateways, and firewalls with strong
authentication and logging.
SECURE PLC Configurations
Place controllers in “run” mode when not programmed
and regularly verify settings, IP addresses, and
program files.
STRENGTHEN Authentication
Replace default passwords with strong credentials
and deploy MFA wherever possible.
PREPARE for Recovery
Maintain clean, tested backups of PLC logic, HMI
applications, network configurations, and engineering
files—stored offline and protected from ransomware.
PRACTICE Incident Response
Maintain current emergency procedures, manual
operating capabilities, vendor contacts, and reporting
protocols for rapid recovery.
Each initiative should include a defined scope, implementation plan,
budget, and clear responsibilities. Well-structured programs achieve
measurable improvements.
SPOTLIGHT / CURRENTS
11
11
Conner graduated in June with a
bachelor's degree in environmental
engineering from the University
of Nebraska Omaha (UNO), where
he was recognized with the 2026
Undergraduate Major Award
for Environmental Engineering.
In August, he returned to UNO to
pursue a master's degree—supported
in part by Carollo's Bryant L. Bench Scholarship.
A key part of Conner's education over the past
four years has been his work with Engineers
Without Borders on a bridge project in Zambia.
His involvement spanned the entire engineering
process, from community engagement, project
development, and grant procurement, to design,
government approval, and construction oversight.
The experience provided hands-on exposure to the
real-world challenges and rewards of engineering
while making a meaningful impact on the
local community.
Conner credits experiences like these for shaping
his can-do philosophy.
2026 RECIPIENT
CONNOR NEVILLE
At times, engineering work can be overwhelming.
It can be difficult to see the end. I simply remind
myself that even when you're in the weeds, you can
figure it out and persevere. This scholarship is going
to make my life much easier in grad school and allow
me to focus on what's most important."
CYBER THREATS ARE AN
EXTENSION OF GEOPOLITICAL
CONFLICT. WATER SYSTEMS
ARE PRIME TARGETS.
2008 • USEPA publishes a 10-year roadmap to secure
control systems in the water sector.
2018 • America’s Water Infrastructure Act (AWIA)
expands resiliency requirements and places an
emphasis on cybersecurity.
TODAY • Nation-state actors increasingly target
critical infrastructure, posing real cyber threats to
utilities every day.
Many of the most effective protections are straightforward
and achievable.
The Bryant L. Bench Scholarship was launched in honor
of Carollo’s former water practice director, Bryant Bench,
whose innovative treatment concepts helped improve
drinking water quality across the country. The scholarship
is a one-time $10,000 award that students can use to
complete or further their education in their chosen field.
SCHOLARSHIPSCHOLARSHIP
CAROLLO ENGINEERS VOLUME 4 2025
800.523.5826 / carollo.com
Talk is easy. Impact is earned. At Carollo, we approach innovation as something to be built, tested, and
proven in the field, not just imagined. From breakthroughs like XBAT, Blue Plan-It®, and I-FLOAT® to integrated
AI/ML solutions, we focus ingenuity where it matters most: solving water challenges for our clients and
communities. The result is progress you can measure in real terms—protecting public health, strengthening
ecosystems, and delivering resilience that lasts. That’s Carollo Innovation.
Innovation
is just a buzzword.
Until it has proven impact.