Ilderton Valley's PFAS Upgrade: A License Class Debate Kit

Resolution: "The state board should reclassify the Ilderton Valley plant as Class III once its PFAS treatment goes into service, and require an operator in responsible charge who holds a Class III license."

Background. Ilderton Valley Water District is a fictional district serving about 7,400 people from one surface water plant rated at 2.4 MGD. Two licensed operators run the plant. Both hold Class II licenses, and one of them is the operator in responsible charge.

Routine sampling found PFOA and PFOS in the district's raw water. The maximum contaminant level for each is 4.0 parts per trillion. EPA set that limit in April 2024, and systems must comply by April 2029. In May 2026 EPA proposed letting eligible systems apply for a two-year exemption, to April 2031, without changing the limits, and that proposal was not final as of September 2026, so the rule is in motion rather than settled. The district has decided to install granular activated carbon contactors, and construction is underway.

The state board now has to decide how the finished plant is classified. Under the state's rules, plant classification reflects both size and process complexity. The board can leave the plant at Class II, which the two current operators hold, or raise it to Class III, which requires a harder exam and more documented years of operating experience. Neither operator holds a Class III license today.

Roles. The affirmative team of three speakers argues as state board staff and a public health advocate. The negative team of three speakers argues as the district's operators and its general manager. One student moderates and keeps time. The rest of the class judges with the rubric and votes at the close.

Format. Each team gives a four-minute constructive speech, then answers two minutes of cross-examination. After a three-minute preparation break, each team gives a three-minute rebuttal. The moderator takes a vote and asks two judges to say what decided it.

Case for reclassifying the plant as Class III:

1. Carbon treatment is not a minor addition. Contactors have to be backwashed, sampled for breakthrough, and taken out of service for media changeout on a schedule that depends on sampling results rather than on the calendar. That is process control work the current classification never contemplated. (Illustrative point created for this debate.)
2. The limit leaves little room for error. The maximum contaminant level for PFOA and for PFOS is 4.0 parts per trillion each, so an exhausted carbon bed can put the district out of compliance before anyone notices a change in the finished water. (Source: EPA PFAS National Primary Drinking Water Regulation.)
3. A higher class means a harder exam and more documented experience. A state raises the class when it wants the person signing for the plant to have been tested on more treatment chemistry and process control, which is exactly what carbon adsorption asks of an operator. (Source: BLS Occupational Outlook Handbook and state certification programs.)
4. In a fictional record written for this debate, a neighboring district added carbon without any change in classification and ran one contactor two months past breakthrough, because nobody on site had been trained to read the sampling trend. (Illustrative example created for this debate.)
5. A higher class also gives the district's operators a better-paid step on a career ladder. Operators earned a median of $60,020 per year in May 2025, and the top ten percent earned more than $91,060, so the classification change would move these positions up a pay ladder that already exists. (Source: BLS Occupational Outlook Handbook.)

Case against reclassifying the plant as Class III:

1. The people are not there to hire. About 10,000 operator openings are projected each year from 2025 to 2035, and all of them are expected to come from replacing workers who retire or leave rather than from growth. EPA estimates roughly one-third of the water workforce is eligible to retire within 10 years, and in 2016 only about 10 percent of water workers were 24 or younger. (Source: BLS Occupational Outlook Handbook; EPA Water Infrastructure Sector Workforce page; Brookings.)
2. A class change is a blunt tool. What the plant actually needs is training on carbon operation and breakthrough sampling. A process endorsement or a documented training requirement would reach that skill directly, while a class bump also tests material the plant will never use. (Illustrative point created for this debate.)
3. In many states, population served and plant size carry much of the weight in classification. Under the fictional proposal, Ilderton Valley would become the smallest Class III plant in its region, which sets a precedent for every other small system that adds treatment. (Illustrative point created for this debate.)
4. The district would likely have to contract the responsible charge role to an outside operator who visits. That moves the decisions away from the two people who know the plant, and in the fictional district's case both of them live in town. (Illustrative point created for this debate.)
5. Ratepayers carry the cost. Combined water and sewer bills rose about 24 percent from 2019 to 2024 and about 5.1 percent in 2025. A widely used rule of thumb treats combined water and sewer bills above about 4.5 percent of household income as a high burden, and the carbon project is already going on the bill. (Source: Bluefield Research rate surveys and EPA Water Affordability Needs Assessment, 2024.)
6. A fictional Ilderton Valley operator argues that she has the experience hours and needs only the exam. She asks the board for two years to earn the Class III while continuing to run the plant. (Illustrative testimony created for this debate.)