20080904DEQ - facility plan.pdf

STATE OF IDAHO
DEPARTMENT OF RECEIVED
ENVIRONMENTAL QUALITY
2008 SEP - 1+ AM 8: 21 A1NVv0-ò~'-Or
C.L. "Butch" Otter, Governor
Toni Hardesty, Director
September 2, 2008
Nolan Gneitig
Morning View Water System
POBox 598
Rigby, ID 83442
Certfied Mai: 7005 1820 0004 6754 6704
Morning View Water Company Facilty Plan
Dear Mr. Gneiting:
This letter is in regard to our review of the Facilty Plan for the Morning View Water Company submittd
by Aspen Engineering on August 5, 2008. The report evaluated water system deficiencies as well as
recommendations for operations and capital improvement projects to allow the Morning View Water
System to comply with the October 25,2007 Consent Order and Idaho Rules for Public Dring Water
Systems (IRDWS).
Our review is separated into the sections: 1.) Continuing violations with the Idaho Rules for Public
Drining Water Systems, 2.) Facility Plan Comments, and 3.) Consent Order compliance.
1.) Continuing Violations of Idaho Rules for Public Drinking Water Systems.
The Deparent of Environmenta Quality (Deparent) contiues to receive pressure complaints from
water system users. As a result, the Deparent instaled a pressure recorder to assess water system
pressures. Water pressure monitoring conducted by the Deparent confirms recurg pressures below
40 pounds per square inch (psi) and non compliance with IDAPA 58.01.08.552.b.ii which sttes:
ii. Any public water system constrcted or significantly modified afer July 1, 1985, shall
maintain a minimum pressure of fort (40) psi thoughout the distrbution system, during
peak hourly demand conditions, excluding fire flow, measured at the service connection
or along the propert line adjacent to the consumer's premises.
The 2nd paragraph on Page 5 indicates the system is curently servicing 100 connections and in 2002, the
system serviced approximately 65 connections. Since 2002, the number of service connection has
increased by 35%. Although the system has two groundwater sources, the backup well canot provide
peak hour demand with the larger well out of service. Therefore, the water system does not comply with
IDAPA 58.01.08.513, which sttes:
IDAPA 58.01.08.513. FACILIT AN DESIGN STANARS - NUER OF
GROUN WATER SOURCES REQUID. New community water systems served
by ground water and constrcted after July 1, 1985, or existing community water systems
served by ground water that are substantially modified after July, 2002, shall have a
minimum of two (2) sources if they are intended to serve more than twenty-five (25)
homes or equivalent. Under normal operating conditions, with any source out of service,
the remaining source or sources shall be capable of providing either the peak hour
demand of the system or maximum day demand plus equalization storage. See
Subsection 501.17 for general design requirements concerning fire flow capacity. For the
purpose of Section 513 only, the Deparent shall consider a system to be "substatially
modified" when there is a combined increase of twenty-five percent (25%) or more above
the system's existing configuation in the following factors
01. Population Served or Number of Service Connections,
02. Lengt of Water Mains,
03. Peak or Average Water Demand Per Connection.
In accordance with IDAP A 58.01.08.100.06 Monitoring Frequency and Compliance Requirements
for Radioactivity in Community Water Systems, Morning View is required to complete quaerly
Radium 226 monitoring. The Deparent notified Morning View of the radiological monitoring
requirement in a Januar 4, 2008 correspondence. No Radium 226 sample results have been reported to
the Deparent and therefore Morning View has been assigned "Failure to Monitor" violations for the 1 sl
and 2nd Quarers of 2008 monitoring periods.
IDAP A 58.01.08.010.FEE SCHEDULE FOR PUBLIC DRIKIG WATER SYSTEMS requires all
regulated public drinking water systems to pay an annual drinking water system fee. According to our
records, the Deparent has not received payment for the 2008 annual driking water fee.
2.) Facilty Plan Comments
Page 3, Summar. The 4th paragraph shows Morning View Water Company's ADD consumptive values
as 2.6 to 3.0 times higher in comparson with metered communities. The second paragraph on page 14
shows a factor of2.9 to 3.4 times higher. Therefore, the MDD and PHD values listed on page 3 and 14
are different. Please clarify.
Page 4, Recommendations/Conclusions. The report recommends the operating pressures be adjusted to
57 psi to 67 psi and then monitor the distibution system pressures.
Page 6, History. The Deparent concurs that completion ofItems a-h listed on page 6 would assist
Morning View with compliance of the consent order.
Page 8, Existing System. The 4th paragraph indicates a total of 134 individual connections at full
development, but page 15 correctly lists 132 connections. This figure should be consistent thoughout the
report.
Page 8, Supply. The 7th paragraph indicates two 1000 gallon pressure tas but the tanks' capacity are
listed elsewhere throughout the plan as 900 gallon pressure taks. This figue should be consistent
thoughout the report.
Page 9, Pressure Zone. The Deparent concurs with the recommendation of adjusting the pressure
settings at the pump building to increase pressure to a minimum of 40 psi in the distribution system.
Page 10, Pressure Zone. The Deparent concurs with the recommendation of eliminating the individual
booster pumps and installing variable frequency drive for each well pump.
Page 11, Pressure Zone. The Deparent agrees with the recommendations of periodic flushing of dead
ends and developing a wrtten plan identifying flushing locations and results into the operations plan. A
cross connection plan is needed as well.
Page 19, Current System Evaluation. The Deparent concurs with the recommendation of monitoring
pressures at residences.
Page 20, Water Quality and Regulations. The Deparment agrees with the recommendation of monitoring
and quantifying sand production and the capability of the sand separator to remove sand. The Deparent
continues to receive water quality complaints with respect to sand in residents' water. If the existing sand
separator canot demonstrate effective sand removal, another sand separator or sediment fiter may be
necessar to remove sand content in the water supply.
Page 21, Capital Improvement Program. The Deparent concurs with the recommended improvement
listed in this chapter to ensure Morning View has adequate capacity to operate as a sustainable water
system.
3.) Consent Order Compliance
Morning View is currently in compliance with Sections 9.d., 9.e., 9.f., and 9.g. of the Consent Order.
However, Morning View remains in non-compliance with the following items of the Consent Order:
9.a. Morning View was required to schedule a sanita surey and provide a written response
to the Deparent indicating the actions taen to address significant deficiencies noted on the
October 9, 2003 surey. A sanitar survey conducted by the Deparment on July 10,2008
indicated that the significant deficiencies have not been corrected. The preliminar inspection
form was provided to you at the conclusion of the sanita surey. The Deparent sent you the
sanita survey report on August 7, 2008. Implementation of the items listed on Page 4A of the
Facilty Plan would address sanita survey deficiencies.
9.b. Morning View is required to provide quarerly public notices to each residence on the
System informing residents of the Deparent's disapproval of the System and identify the
violations that have not been resolved. Proof of each quarerly notification provided to Morning
View's residences is also required to be submitted to the Deparent. Records indicate the last
notification submitted to the Deparent on March 18, 2008. Notification for the 2nd Quarter of
2008 was not submitted to the Deparent as required. The notification for the 3rd Quarr of
2008 must be submitted no later than September 30,2008.
9.c. Morning View was required to submit a written plan no later than Januar 24, 2008
detailing how a minimum pressure of 40 psi wil be maintained throughout the distrbution
system. This plan was to include the results of a local pressure monitoring study. The water
pressures recorded from the pressure gauge on the pressure tak in the wellhouse is not
representative of the distribution system's pressure. Although pressure recorded in the well house
was greater than 40 psi, pressure data collected by the Deparent in the distribution system
showed 40 psi is not constatly maintained. To date, Morning View's writtn plan has not been
received by the Departent.
9.h. Morning View was required to submit a plan no later than November 24, 2007 that would
ensure that all dead end mains within the System are equipped with a means of flushing and that
all such dead ends are properly flushed. The map in Appendix A of the August 5th Facility Plan
show five (5) flushing hydrants and three (3) dead ends not equipped with flushing hydrants.
Installation of a flushing valve on the dead end on 3950 East and 6-inch pipe for the completion
ofa loop in Morning View Acres NO.3 would satisfy Item 9.h.
The primar basis for the Consent Order between Morning View and the Departent was the system's
noncompliance with maintaining a minimum water pressure of 40 psi in the distribution system and
continued sanita survey deficiencies. The Facility Plan identified many recommendations to improve
operation and regulatory compliance of the water system. Morning View needs to implement these
recommended improvements.
Please contact me to arrange a compliance meeting for a discussion on the appropriate path forward and
timely resolution ofthe outstanding items ofthe Consent Order and noncompliance with the Idaho Rules
for Public Drinking Water Systems. We suggest you bring your engineer to the meeting.
Please contact me at 528-2650 within 7 days of receipt of this letter.pr ~
Gr~
Acting Regional Administrator
C: Bar N. Burell, Water Quality Division Administtor
Bryan Zibbell, Drnking Water Program Enforcement Coordinator
Lsmce Nielsen, Drnking Water Progr Manager
Ray, Keating, Eastern Idaho Health Deparent
Naysha Foster, Jefferson County Planning & Zoning Administrator
Chrs Hecht, Public Utilties Commission
Dennis Dunn, Idaho Water Resources
Ryan Lofts, Aspen Engineering