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HomeMy WebLinkAbout20061010SPL to staff 1-2.pdfRECEIVED John R. Hammond, Jr., ISB No. 5470 BATT & FISHER, LLP S. Bank Plaza, 5th Floor 101 S. Capitol Boulevard Post Office Box 1308 Boise, ID 83701 Telephone: (208) 331-1000 Facsimile: (208) 331-2400 200G OCT -6 PH~: IDAHO F'UtRiC UTILITIES COMMiSSiON Attorneys for Applicant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF SPIRIT LAKE EAST WATER COMPANY, INc., FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR WATER SERVICE IN THE STATE OF IDAHO Case No. SPL-O6- SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST COMES NOW Spirit Lake East Water Company, Inc. , (" SLEWC"), by and through its attorney of record, Batt & Fisher, LLP, and hereby responds to the Idaho Public Utilities Commission Staff s First Production Requests. SLEWC reserves the right to supplement each and every answer as discovery is undertaken during the course of this case.Roxann Middleton, the Controller for SLEWC, has provided the Answers to the Requests. Request No.1: Please provide copies of all correspondence with the Idaho Department of Environmental Quality for the past 24 months. Include copies of all attachments and reports or other referenced documents. Response to Request No.1: See the attached Response No. SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - Request No.2: Please provide copies of all correspondence with the Spirit Lake East Homeowner s Association for the past 24 months. Include copies of all attachments and reports or other referenced documents. Response to Request No.2: See Response Attached Response No. Request No.3: Please provide a copy of all engineering reports prepared during the last three years regarding any aspect of the water system. This is to include the engineering study report that was jointly funded by the Homeowner s Association and the local water district. Response to Request No.3: See attached Response No. Request No.4: Please provide an Excel file or other comma delimited electronic file with all customer water usage and billing data for the past 12 months of the test year. Response to Request No.4: See attached Response No. Request No.5: Please provide complete well logs for the 12 months of the test year showing all water pumped by the wells. Response to Request No.5: See attached Response No. Request No.6: Please provide all water company electric bills for the 12 months of the test year. Response to Request No.6: See Attached Response No. Request No.7: Please describe how incoming calls from customers to the Company are handled. Include in that explanation answers to the following questions: (a) Are all calls handled by a centralized customer service call center, or are some types of calls (e., service outage or new construction) directed to a separate call center or department? (b) If some types of calls are directed outside the customer service call SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 2 center, are those calls separately measured or tracked? (c) If some types of calls are handled through an interactive voice response system without the calling party speaking to a customer service representative, are those calls separately measured or tracked? Response to Request No.7: Calls to the main office during business hours of Hanson Industries (509-922-5252) are answered by Laura Myers, receptionist. Laura directs the calls as follows: Address changes - Laura handles Accounting information, new hook-up information and general questions & complaints - directed to Roxann Middleton, controller. Emergency and maintenance issues - directed to James Kruger, certified operator. After hour calls can leave a message on answering system or if an emergency call James Kruger s cell. Request No.8: Please provide the Company s performance objectives for handling incoming calls. Response to Request No.8: To handle each call professionally. If the customer has a question, problem or request, the Company attempts to answer and/or solve the customer s questions, problems or requests. If the person they need to talk to is not available at the time a message is taken, then the calls are returned as soon as possible. Request No.9: What steps does the Company take if it fails to meet its performance objectives? Response to Request No.9: The Company to date is unaware of any failure on its part to meet its performance objectives. SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 3 Request No. 10: Please provide the number of incoming calls handled by the customer service call center by month for calendar year 2005. Response to Request No. 10: Unknown. Request No. 11: Please provide the average number of busy signals reached by parties calling the customer service call center by month for calendar year 2005. Response to Request No 11: Unknown. Request No. 12: Please provide the average handling time by month for calendar year 2005. "Average handling time" is the average amount of time (usually expressed in minutes) it takes for a customer service representative to talk with a customer plus any additional "off-line" time it takes to complete the transaction or fully resolve the customer s issue(s). Response to Request No. 12: Unknown. Request No. 13: Please provide the first call resolution rate by month for calendar year 2005. "First call resolution rate" is the percentage of calls where the transaction, inquiry or complaint is resolved upon initial contact with the Company. Response to Request No. 13: Unknown. Request No. 14: Please describe how the Company handles e-mail inquiries complaints, payment arrangements, service orders, and other routine customer transactions. Response to Request No. 14: None received via email. See also Responses to Request Nos. 7 & 8. Request No. 15: Please provide the average response time for e-mail transactions by month for calendar 2005. "Average response time" is the average number of hours SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 4 from receipt of an e-mail by the Company to sending a substantive response; auto- response acknowledgements do not count as a substantive response. Response to Request No. 15: N/A. Request No. 16: As of year-end 2005, please provide the number of authorized positions for each job title for employees working in the customer service call center. Response to Request No. 16: See Response to Request No. Request No. 17: As of year-end 2005, please provide the number of authorized positions that are currently vacant for each job title for employees working in the customer service call center. Response to Request No. 17: None. Request No. 18: Please provide the number of customer complaints received by the Company for calendar year 2005 broken into categories by topics; high bills disconnection, water quality etc. Response to Request No. 18: The Company received 2 calls regarding the quality of service and 4 calls regarding high water bills. Request No. 19: Please provide the number of non-pay disconnections by month for calendar year 2005. Response to Request No. 19: None Request No. 20: Please provide the number of reconnect ions by the end of the calendar day following disconnection for non-payment by month for calendar year 2005. Response to Request No. 20: None. Request No. 21: Please provide the phone number provided to (customers?) for billing and customer service issues. SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 5 Response to Request No. 21: 509-922-5252. Request No. 22: Please provide the phone number provided to customers for emergency repaIrs. Response to Request No. 22: 509-868-5929 (cell number for the certified operator) and 208-623-4063. Request No. 23: Please provide the total number of customers who have arrangements to pay each month under a levelized payment plan for calendar year 2005. Response to Request No. 23: None. Request No. 24: Please provide the total number of customers who requested payment arrangements during the months of May through October for calendar year 2005. Response to Request No. 24: One. Request No. 25: Please provide a copy of customer Billing Statement, Initial Notice, Final Disconnection Notice and Annual Rules Summary. Response to Request No. 25: See Attached Response to Request No. 25. Request No. 26: Please provide the date the Company mailed individual customers the Notice of Application for Rate Increase. Response to Request No. 26: August 15 2006. DATED THIS 6th day of October, 2006. SPIRIT LAKE EAST WATER COMPANY By: SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY That I have, this 6th day of October, 2006, caused to mailed a true and correct copy of the foregoing document to the following by U. S. Mail, Postage Prepaid thereon, in the following indicated manner: Weldon B. Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 West Washington Street P. O. Box 83720 Boise, Idaho 83720-0074 - ~. S. Mail Hand Delivery Facsimile SPIRIT LAKE EAST WATER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST - 7 RESPONSE NO. ~ .. STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director October 19 , 2004 CERTIFIED MAIL: 70021000000527171379 Spirit Lake East Water Company RA. Hanson 15102 E Indiana Ave Spokane, WA 99216 RE: Spirit Lake East Water System , PWS# 1280176 , Requirement for a New Well Dear Mr. Hanson: This letter is in response to the recent loss in water pressure at the Spirit lake East Water System in Kootenai County, According to conversations with your staff and some of the residents on the system , the system was either partially out of or completely out ofwater between October 4 and October 10, 2004. We understand this lengthy outage resulted from a pump failure in the only well that serves 268 customers. The depressurization of a water system not only creates an inconvenience for the users but also constitutes a publiq health hazard by subjecting the water system to the introduction of contamination into the distribution system through back siphonage and backflow. This occurs when waterlines are drained and contamination can enter the system from leaks in the lines and cross connections, such as hoses connected to sources of non-potable water. Section 58.01.08.008.01 of the Idaho Rules for Public Drinkinq Water Systems prohibits the creation of a condition that constitutes a public health hazard. The situation that occurred during the days that the distribution system was depressurized created a public health hazard. In addition, section 58.01.08.552.01.i require that any public water system shall be capable of providing sufficient water during maximum hourly demand conditions (including fire flow) to maintain a minimum pressure of twenty (20) pounds per square inch throughout the distribution system, as measured at the service connection or along the property line adjacent to the consumers' premises. The Spirit Lake East Watersystem was in violation of this section of the rules for this 6-day period as reported by several customers. Although the RA. Hanson Company made a concerted effort to remedy this situation as soon as they could , it could have been avoided if the water system had a second well capable of serving the development while this well pump was being repaired. In order to help ensure that this situation does not occur in the future it is necessary to require that your company install a second well capable of s~rving the Spirit lake East Subdivision. ...- ' Spirit Lake East Second Well Requirement CERTIFIED MAil: 70021000000527171379 October 19, 2004 Page 2 Please contact me by November 15, 2004 to discuss plans for the installation of a second well. The well site must be inspected by our department and approved in writing. addition, a Professional Engineer registered in Idaho and approved by our office prior to drilling must prepare the plans. We look forward to working with you in this effort to make this water system a more reliable and safer water system by adding a second well. I look forward to hearing from you. Sincerely, f?' Analyst Steve Tanner, Drinking Water Program Supervisor Ron Sutcliff, Idaho Attorney Generals Office J. Cooper, Idaho Public Utilities Commission - - Spirit lake East Water Company 15807 E. Indiana Ave. Spokane Valley, WA 99216 Phone: (509) 922-5252 Fax: (509) 922-5757 October 25,2004 Anthony P. Davis Analyst Department of Environmental Quality 2110 Ironwood Parkway Couer d' Alene, ID. 83814-2648 Re: Spirit Lake East Water System, PWS #1280176 Dear Mr. Davis: We received your certifrbd letter dated October 19th . We want to provide you with current information as well as to request additional information regarding the DEQ' mandate for a second well installation. First and foremost, we share the DEQ's goal of providing sa~e and clean water to the customers. We have met DEQ's requirements in the past for clean water and have responded quickly when your office advised we needed to address an issue. We have never be~n subject to any disciplinary proceeding from the DEQ or the Idaho Public Utility Commission. As of today s date, we are unaware of any current violations of DEQ rules and we believe we are in compliance, except of course for the section referenced in your letter. Second, the facts regarding the equipment failure are summarized in our letter sent out on October 20, 2004 to our customers. I enclose a copy for your review. I also enclose the front page from the latest edition of the Spirit Lake East Homeowners Association s (SLEHOA) newsletter which gives additional facts about the incident. I also enclose two letters from our customers (George and Costigan) wherein they express their appreciation for our efforts. We forward this information to clear up what happened as the rumors were not very accurate. Third , we believe we complied with the water pressure requirement during the remedial work. We continuously filled the water reservoir and turned on the pumping motors once there was a sufficient water level to supply the customers with the minimum level of water pressure. If there was not sufficient pressure (which you have heard from customers as well as us and the SLEHOA), this was due to "upstream" customers using up all the water. This is not intended to be an excuse but is a fact since we used all . - reasonable measures available to us at the time to provide safe water at the minimum pressure level with the pumping motors. Fourth, we have been working with the customers for over 1 year through the SLEHOA regarding future improvements, like the second well, to the overall system. The SLEHOA contacted North Kootenai Water District regarding its interest in serving the customer base. The District is interested but required its engineer (Welch Comer) to study the system. The study cost $5,000.00 (we paid one half) and is due in time to discuss it at the District s October 28th Board meeting. Our collective plan is to have the District review the engineer s recommendations and see if its Board of Directors is interested in purchasing the water company from us (subject to IPUC approval))f so, the customers would then vote on whether to agree to annex the area served by the water company into the District. The District will identify what improvements are needeq and advise the customers of the probable costs and probable corresponding rate increases (again subject to IPUC approval) to make the improvements. We have been very proactive in working with the customers and they have been fully advised of our goal and course of action to get the issue to a vote before the customers. Finally, we have some questions that need to be answered so that we can meet towards a resolution of DEQ' s concern: 1. What is DEQ's timeframe for a second well to be designed? installed? 2. What are DEQ's design/installation criteria? Can you provide us or refer us to the technical parameters? 3. How does our status as a "very small water system" affect us? 4 . The well is a capital improvement for which we will seek to recapture the costs through a water rate increase. If we file a rate increase with the IPUC, what is the interplay with DEQ's mandate and the application with the IPUC? Are the two schedules coordinated? 5. Will we be granted a second well permit to draw from the aquifer? 6. Are there any state sponsored finance programs for assisting us with the improvements? 7. Is DEQ the lead agency so we direct all information and responses to you? We reiterate our willingness to work with the DEQ to address the concern raised in -... your letter and ask for your assistance. ~ertJ. BOY '(/ 0 - . Vice President of Hanson Industries, Inc. ------------------------ --------- ------------- ------ -. - - -- -- . - --- --- ~~ober 2~ J --- The newsletter of the Spirit Lake East Homeowner s Association r-= Contact Information BOARD OF DIRECTORS Presldent- Mike Schmidt 623-2689 President-Bob Lloyd 623-6070 Secretary- Dan Edglnton 623-2649 Treas.- Cindy Murphy 623-6479 Members at Large- Kris Kramer Torry Tarnowski : . Lowell Hayes COMMITTEES Architectural Review SLEHA GAZETTE (Chair) David Sincerbeaux Mike Zwiebel Karen Smart Audit (Chair) Vacant Vacant Roads (Chair) Jess Blocker Scott Good Sam Hughes Vacanf Timber Lowell Hayes Vaeanf Newsletter Editors Lois Tarnowski Debbie Lawson 623-6006 623-6225 623-2064 623-2864 623-3075 623-6173 Vacant Vacanf 623-6001 755-9340 623-2087 Vacant 623-2064 Vaeanf 623-6225 623-4090 : Website- www.spiritiakeeast.org ; Please sent all correspondence to : . Spirit Lake Ea:;f Homeowner s Association PO Box 217 Spirit Lake, ID 83869 Water Emergency On SaturdaYt October 2ndt our large 10Ohp pump apparently failed. Most of us were not aware until Monday after the entire reservoir and distribution system also went dry. Beginning about 4 pm on TuesdaYt October 5th Hanson began attempting to refill our reservoir by the use of 4 OOO gallon pumper trucks while a new pumPt motort pipe and electrical cable were ordered and began arriving. Many false starts overusing the distribution system caused the reservoir to be drawn down and numerous outages again. The new pump, pipet etc. were finished being installed on SundaYt October 10th and we apparently have a complete water system again. This emergency pointed out many problems. 1. This water system serves both SLE and Treeport. We had no phone listings for Treeport. We have now requested same. 2. We have no updated and accurate phone numbers for many of o owners so were not very successful in notifying everyone of the problems. Many numbers are out of state numberst or disconnected and no longer in service numbers. We also found many with no answering service on their home phone so no message receivable. At our Novembe membership meeting we will be seeking correct phone numbers from everyone. 3. The times the distribution system was on (based on the pumper truck deliveries) we collectively used it so fast, it had to be turned off again. There appeared to be very little caution in use of limited water. People were observed with stock tanks filled and hose still running water and overflowing on the ground wasting water others could have used to shower. Some were observed watering gardens and flowers which appears frivolous after our recent rains. While the board will attempt to do a better job of notification in similar area wide emergenciest we all need to use more caution in overusing water during such an outage. Limiting length of showers or depth of filling tubs less frequent washing of clothes or other type heavy water usage would all help and could have made distribution more plausible and lasting had not the tank been drained so fast. Mike Schmidt President, SLEHA October 12, 2004 Spirit Lake East Water Company 15807 East Indiana Avenue Spokane, WA 99216 Dear Spirit Lake East Water Company, We would like to take this opportunity to commend your company on a job well done in the matter of replacing the water pwnp for the community of Spirit Lake East. We are aware that ordering, digging, unhooking and replacing a water pwnp is a huge job. We also wanted to thank you for hauling water in while you were working. \\'e appreciated it very much. Thank you for taking the time to ease the discomfort of being waterless. Lasdy, we were so pleased that our water was restored on a Sunday evening. That was above and beyond any expectation one can have when hiring out a job to be done. Thank you again for your service. Sincerely, Matthew and Colleen George 32844 NORTH TAHOE DRIVE SPIRIT LAKE, ID 83869 33588 North Kelso Drive Spirit Lake, Idaho 83869 )ctober 15 , 2004 Spirit Lake East Water Company 15807 East Indiana Avenue Spokane, Washington 99216 Dear Spirit Lake East Water Company Our thanks to Jim Krueger and the consideration that the Company expressed in providing flushing water to the system during the recent water outage. As the story unveiled in the Community, I believe we are all extremely thankful for the effort and expense exerted in restoring our water supply. - ' End: "l' ""f': \ STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY Dirk Kemplhorne, Governor Toni Hardesty. Director2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814.2648. (208) 769.1422 October 28, 2004 CERTIFIED MAIL: 7002 1000 0005 2717 1393 Robert J. Boyle,Vice President Hanson Industries 15807 E Indiana Ave Spokane , WA 99216 Re: Second Well , Spirit lake East Water Company, PWS 101280176 Dear Mr. Boyle: Thank you for your letter of October 25, 2004 concerning the second well for the Spirit lake East water system and the documentation concerning your efforts to keep the residents informed of the attempts to repair the system. We appreciate all the effort your company went , to try and keep your customers in water during the last extensive outage. By having a second well available for the system , the chance of being out of water and the ' introduction of contamination through cross connections will be greatly reduced. Our responses to the questions that you posed at the end of your letter are as follow: - - There are essentially two time frames that you need to observe in preparing to dig a second well. The first is the preparation of plans and construction specifications by a registered professional engineer licensed in Idaho. The required time frame allowed for the preparation of plans is 60 days from the receipt of this letter. This letter notifies you of this compliance requirement. Your contact person within DEQ is Mr. Gary Gaffney, PE. He can be reached at the address and phone number given at the end of this letter. The next time frame concerns the actual drilling of the well and connection to the water system. The time allowed for this activity will be 180 days from the receipt of this letter. This letter notifies you of this compliance requirement. The reason for this amount of time is to provide an adequate amount of time for Hanson Industries to apply for a drilling permit and water rights through the Idaho Department of Water Resources. The application process may be lengthy due to administrative delays currently affecting the issuance of water rights over the Rathdrum Prairie Aquifer. The criteria for construction of the well are contained in Idaho Rules for Public Drinkinq Water Systems available on the Internet at http://WNW2.state.id.us/adm/adminrules/ruleslidapa58/01 08.pdf. Also the Recommended Standards for Water Works: committee report of the Great Lakes Upper Mississippi River Board of Department of Public Health and Environmental Health Manaoers published by Health Education Services, ~.O. Box 7823, Albany, New York, 1997. Telephone (518) 439-7286 contains useful information. Your status as a very small water system does not affect this situation in any way. Spirit Lake East Second Well CERTIFIED MAil:7002 1000 0005 2717 1393 October 29, 2004 Page 2 Please contact the Idaho Department of Water Resources as soon as possible to arrange for a well drilling permit and to complete a water rights application. The northern regional office is located at 1910 Northwest Boulevard , Coeur d'Alene , 10 83814; phone (208) 769-1450. The regional manager is Bob Haynes. With respect to your questions concerning financing there are a number of programs designed to assist small water systems. The only governmental loan program I am aware of that will lend to investor owned utilities is the Idaho DEQ State Revolving Loan Program. To find out more about this program please contact John Tindall at the DEQ office in Coeur d'Alene at 769-1422. The Idaho Department of Water Resources loan program also provides financial assistance to small drinking water systems, but may not loan to il)vestor owned utilities. The contact person for this program is Brian Patton in Boise. He can be reached at (208) 287-4800. The Department of Environmental Quality will not necessarily be the lead agency in all aspects of the installation of the new well. The Idaho Public Utilities Commission and the Idaho Department of Water Resources play separate roles. The PUG will assist you in setting the rates for the recovery of costs. The Department of Water Resources is responsible fo~ issuing water rights. DEQ sets the time frame for regulatory compliance with laa s Rules for Public Drinking Water Systems and should be kept informed of your progress with these other agencies and with your progress in the construction of the second well. If you find that you are unable to meet the time frame set forth for the construction of the new well and you wish to suggest an alternative, please contact us within 10 days from the receipt of this letter. If you have any other questions or comments on this matter, please feel free to contact DEQ in Coeur d'Alene. We are located at 2110 Ironwood Parkway, phone 208769-1422. We appreciate your cooperation in this effort and we look forward to working with you and Hanson Industries. Anthon~avis Analyst Steve Tanner, DEQ/CDA John Tindal , DEQ/CDA Gary Gaffney, DEQ/CDA Ron Sutcliff, Idaho Attorney General Office Robert Haynes, IDWRlCDA CJ Cooper, IPUC/Boise B Ai' ,)'~. ~' ~i~;;;: R ";.::., ;:::, . 0:; . , : .-c." ",.:.:,:' :"" A LIMITED LIABILITY PARTNERSHIP John R. Hammond Jr.e-mail: jrh(qibattfisher.com December 1 , 2004 Anthony P. Davis Analyst DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway Coeur d'Alene, ID 83814-2648 Re:Spirit Lake East Water Company Water System Dear Mr. Davis: This letter is to advise you that Spirit Lake East Water Company ("Company ) is beginning the process for the construction of a second.well for its water system. Recently, an engineering report was prepared by Welch Comer that assessed the current Spirit Lake water system, including the need and plans for a second well. In addition, by separate letter the Company will request to be added to the Idaho Department of Environmental Quality s Priority Lists for planning grants and loans for drinking water facilities. It is our hope that the receipt of planning grants and low cost financing through the Department of Environmental Quality will aid in the completion of this project and also assist in keeping costs down for the Company and its customers. As the Company moves through this process, we will continue to communicate with you regarding progress in this matter. Sincerely, BATT & FISHER, LL John R. JRH/klhcc: Raymond Hansen Robert Boyle Ron 1. Sutcliffe FILE COpy T 208.331.1000 . F 208.331.2400 . P.Box 1308 Boise, Id 83701 . Suite 500, US Bank Plaza 101 S. Capitol Blvd. Boise, Id 83702 STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY --'------'---..-..---...,.-.-...-.-. ._no_-- --. "'....-- .. 'n' -- ,.. n_ . --.-. -."--'-- 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director December 7 , 2004 John R. Hammond Batt and Fisher llC P. O. Box 1308 Boise , 10 83701 Re: Second Well , Spirit lake East Water Company, PWS 101280176 Dear Mr. Hammond: Thank you for your letter of December 1 , 2004 concerning the second well for the Spirit lake East water system. We appreciate the efforts of the Hanson Company in beginning the resolution of the capacity and pressure problems related to the water system. We will attempt to assist you in any manner possible to obtain the necessary financial and regulatory approvals. As you know the process of application for a new well through the Idaho Department of Water Resources can present some delays. Also the mechanism for obtaining the rate enhancements through the Idaho Public Utilities Commission to pay for the water system improvements may be time consuming. Our letter of October 28, 2004 set forth some time constraints for completing design engineering and construction. If you find that you are unable to meet the time frame set forth for the construction of the new well and you wish to suggest alternative time lines , please do so at this time. Another matter of concern that was discovered in the file review that preceded the referral of this matter to the Idaho Attorney Generals Office concerned unresolved past survey deficiencies. It appears that the reservoir problems noted in the inspections of August 1995 and July 2000 remain unresolved. Is it the intent of Hanson Company to seal the tank and upgrade the roof at the same time as the installation of the new well? It may be logical to pursue these improvements at this time. We will send copies of this communication to other agencies that have an interest in the completion of this improvement project. You may wish to keep the home owners advised as a courtesy. If you have any other questions or comments on this matter, please feel free to contact DEQ RECEIVED DEC 0 9 2004 in Coeur d'Alene. We are located at 2110 Ironwood Parkway, phone 208 769-1422. We appreciate your cooperation in this effort and we look forward to working with you and Hanson Industries. Steve Tanner, DEQ/CDA John Tindal, DEQ/CDA Gary Gaffney, DEQ/CDA Ron Sutcliff, Idaho Attorney General Office Robert Haynes, IDWRlCDA CJ Cooper, IPUC/Boise Robert J. Boyle, Vice President Hanson Industries 15807 E Indiana Ave Spokane , WA 99216 Spirit Lake East Water Company 15807 East Indiana Avenue Spokane Valley, Washington 99216-1864 (509) 922-5252 PWS #1280176 January 4 2005 Anthony P. Davis Analyst Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , Idaho 83814-2648 Dear Mr. Davis: Roxann Middleton told me of your telephone call today and inquiry re: our response to your 60 day notice found in your October 2004 letter. This letter is meant to be responsive to both this recent inquiry and your December 7, 2004, letter to our attorney, John R. Hammond concerning the same. Your October 28, 2004 letter contained a request to have a completed design for engineering and construction of improvements to our system. We have retainedW e1ch Comer & Associates, Inc. to review your correspondence and to analyze the system. Upon completion of their analysis they will issue a written recommendation and timeframe to make improvements the system and to address the violation of the Department's Rules for Public Drinking Water Systems that is discussed in your previous letters. I am advised by Welch Comer that the report will be completed within the next ten (10) days. Once we are in receipt of this report we will respond in more detail to you and Mr. Gaffney. As you are aware the issues surrounding this matter are much more complex than previously indicated as it involves multiple governmental agencies with sometimes independent requirements. Thus, we believe a thorough and thoughtfully prepared engineering assessment is worth waiting for and will ultimately lead to the most beneficial result for Spirit Lake East Water Company, its customers and the Department of Environmental Quality. Thank You. Sincerely, :i~~ Vice President of Hans 'ltries , Inc. \. STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY ---- -- --- ----------- ------- ------------------------- 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director January 7, 2005 Spirit lake East Water Company Robert J Boyle 15807 E Indiana Ave Spokane , WA 99216-1864 RE: Spirit lake East Water System , PWS 101280176 Dear Mr. Boyle: Thank you for your letter of January 4 , 2005 concerning the improvement of the Spirit Lake East Water System. We will extend the previous deadline for submission of plans for construction until March 15, 2005. This should provide an adequate time for Welch Comer and Associates to prepare a report detailing what they feel is necessary for the water system and submit plans for remediation. Please ask Welch Comer and Associates to address their analysis and subsequent engineering design to Mr. Gary Gaffney at the Idaho Department of Environmental Quality office at 2110 Ironwood Parkway in CoeurAlene. - We are aware of the complexities of the issues surrounding this matter and feel that a more studied and thorough approach might better serve the residents of the water system. If you have any questions or comments , please contact either Gary Gaffney or myself at the address listed above. Our phone number is (208) 769-1422. Sincerely, :Zz7 Anthony P. Davis Analyst Steve Tanner, Drinking Water Program Supervisor , IDEO CRO Gary Gaffney, IDEQ/CRO Ron Sutcliff, Idaho Attorney Generals Office J. Cooper, Idaho Public Utilities Commission - ,~.. STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY -----------------------------------.------.--------- ---------.--------.-------- -------------- --- --- 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 January 24 2005 Dirk Kempthorne, Governor Toni Hardesty, Director Robert J. Boyle Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E. Indiana Avenue Spokane, WA 99216-1864 RE:Spirit Lake East Water System Analysis (October 2004 draft) Dear Mr. Boyle: On November 22, 2004 a copy of the above reference draft document as prepared by Welch Comer and Associates for North Kootenai Water District was submitted to DEQ. Since this submittal, you notified us in a letter dated January 4, 2005 that you had retained Welch Comer and Associates to analyze this water system and issue written recommendations for improvements needed to bring the Spirit Lake East public drinking water system into compliance with the Idaho Rules for Public Drinking Water Systems (Rules). Please note that the January 15 2005 deadline proposed in your letter for the engineer to submit the written analysis and recommendation has passed without this office receiving the promised report. We have reviewed the draft October 2004 report and would like to offer at this time a number of comments as follows: 1. The final report must be stamped, signed and dated by the Professional Engineer responsible for preparation of the engineering document. 2. Until the water system improvement are completed and this system detennined in compliance with the Rules, DEQ recommends that the Spirit Lake East Water Company agreed to not make any new service connections to the water system. The report indicated that the system was intended to serve up to 366 lots, currently has about 260 active connections, and has the potential to serve up to 106 additional users. 3. It is important to repair the water meter installed on the discharge of the existing water well and to take readings from this meter monthly during average water demand and weekly during peak water demand periods. This data should be compared to information taken by the operator of water pumped by the three booster pumps and by the individual service meters to determine whether the unaccounted for water use is excessive indicating the need to search for and repair leaks- in the distribution system. This project should be included on the list of recommended improvements. 4. The reason why the latest submersible well pump only lasted six years needs to be detennined. The possibility of excessive pump cycling caused by improper hydropneumatic tank system operation should be explored. 5. The solution tank serving the hypo chlorination system needs to be equipped with a vent to outside the pumphouse in order to reduce electrical corrosion effects. 6. The report should discuss the possibility of connecting to a nearby water system with capacity to provide emergency supply as an option for having a secondary water source. - . RE: Spirit Lake East Water System Analysis (October 2004 draft) January 24 2005 Page 2 - - 7. The reason why the hydrogeologist, Dr. Dale Ralston, recommended in part 6.1.1 against drilling a second well anywhere but on the existing well lot needs to be included. 8. The existing well needs to be on a well lot with at least 50 feet from the well to property lines. If this well has insufficient distances as suggested in part 6.1.1 , additional area will need to be secured so that the well lot is acceptable. 9. The report should include a discussion of the costs associated with upgrading the system to provide fire protection. The duration and rate of flow needs to be established by the local fire district. 10. The electrical system improvements in part 6.1.3 should be included in the list of reconm1endedimprovements. 11. The report indicated that additional Water Rights were needed if a second well was drilled. This process should be started with the Idaho Department of Water Resources now to prevent it from postponing any proposed drilling of a second well during the next few months. 12. We agree that the crack in the top of the water tank needs to be repaired now in order to restore the full capacity of the water tank. Whatever process employed to repair the crack needs to use material in contact with the drinking water that is listed in NSF Standard 61-Drinking Water System Components. 13. The part 6.1.3 proposed 68,000 gallons of new water storage proposed at the north side of the development to provide improved equalization storage. It was not clearly identified in the report whether this tank was an elevated tank, standpipe tank or otherwise. 14. A discussion should be included regarding the advantages of the 205-gpm minimum capacity well versus the 400-gpm capacity well needed for future growth. The costs to operate the smaller well versus the larger well should be discussed. 15. Part 6.4.1 mentions that the pipeline system serving the development may be expected to last from 40 to 60 years and is presently 20 years old. The report should discuss the need to initiate a water distribution system replacement fund now so that these water mains can be replaced in the future without a large financial burden to the users or owner. 16. The recommended improvements in Table 8-1 and 9-1 should be listed according to importance funding or the improvements should be discussed, and a time schedule should be suggested for completion of the engineering report; submittal of construction plans and specifications for each improvement; start of construction of each improvement; and completion, startup, and submittal of as-built plans for each improvement. Thank you for having this draft report submitted. We will expect to be receiving a response from your engineer to these comments and a copy of the promised analysis and recommendation report in the near future. This is necessary so that you cam meet the March 15 , 2005 deadline for submittal of plans and specifications for construction of the necessary and agreed upon system improvements. Zi;~Y'iJvh Gary J.;g;fney, ~IE. c: Steve Tanner & Anthony Davis, DEQ, CdA Necia Maiani , Welch Comer and Associates, 1626 Lincoln Way, CdA (#8357 with Specs S-200 &SLE pws file) - ,~.. DEPARTMENT OF ENVIRONMENTAL QUALITY ----------'----------------------- -------___-_n_ ___------------------------------------------- - - - - .- ----------. February 18, 2005 Robert J. Boyle Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E. Indiana Avenue Spokane, W A 99216-1864 Dirk Kempthorne, Governor Toni Hardesty, Director 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 RE:Spirit Lake East Water System Improvements Dear Mr. Boyle: This office received a letter from your attorney, John Hammond, Jr. with theBatt & Fisher Law Offices dated February 10, 2005 discussing an alternative proposal for making improvements to the Spirit Lake East water system. As you know, following a depressurization episode last year, DEQ had directed the Spirit Lake East Water Company (SLE), as owner of this public drinking water system, to secure a second source of water by drilling a second ground water well. We have reviewed the letter enclosed with your attorney s letter and which an engineering report dated January 6, 2005 from Steven Cordes, P.E. of "Welch Comer and Associates. DEQ agrees with the recommendations in this report and would like to propose the following actions taken by SLE for bringing this system into compliance with the Idaho Rules for Public Drinking Water Systems as follows: 1. Storage Tank Repair & Dialer Installation: Before March 30th, the engineer submits for DEQ approval a written proposal for repairing the leak in the existing 192 000 gallon capacity reservoir and installing a dialer system that alerts the operator by telephone lines that there are system malfunctions. The repair needs to be done using NSF Standard 61 listed products and in compliance with the manufacturers recommendations. We would expect SLE to agree to have the tank repair and dialer installation completed before May 15 2005. In addition, DEQ has observed during recent sanitary surveys that the condition of the reservoir cover has deteriorated. There is a need to make improvements to the roofing surface in order to prevent leakage through the seams in the Span-deck precast concrete roofing panels into the tank. This can result in contamination of the drinking water. DEQ recommends that the existing asphaltic sealant material be removed and the design engineer develop a plan to place a sloping monolithic concrete slab on top of the existing roof panels. Mr. Cordes has indicated he agrees with this assessment. This roof rehabilitation action needs to be submitted for DEQ approval along with the wall leak repair proposal. 2. Standby Power and Spare 'VeIl Pump: It is reasonable to stock a replacement well pump and to install standby power capable of operating both the well pump and the booster pumps needed to maintain full service during power outages. Before March 30th, the system engineer needs to submit to DEQ evidence that requests for proposals have been issued to suppliers for a duplicate well pump and for a standby power unit capable of operating both the well pump and booster pumps at one time. DEQ would expect SLE to agree to have the spare well pump on hand and the standby power generating system in place and operational before May 15 , 2005. - RE: Spirit Lake East Water System Improvements February 18, 2005 Page 2 The letter from your attorney indicated that SLE is willing to immediately proceed with fixing the water tank, purchasing and installing a 250 KV standby generator system, installing a dialer system, and purchasing a standby well pump. Repairing the surface of the tank roof must be included with work needed to repair the water reservoir. In addition, the letter indicated that SLE will agree to start a cross-connection control program, promote proper septic tank maintenance, and develop a wellhead protection program (contact Yvonne Pettit at this office). DEQ agrees with these proposed improvements and recommends that you direct your engineering consultant to immediately proceed with the efforts as outlined above. One point still needs to be made regarding a second source of water on this system. The engin~ering report indicated that a second well would cost about $200 000 and would not prevent depressurization events like those that happened in October and December of 2004. While DEQ agrees with these points, we feel that having a second water source for a public drinking water system supplying water to about 600 people in 268 homes is important to maintaining system integrity. Besides the obvious lack of water pressure, losing pressure in a water system exposes the users to health risks associated with consumption of contaminated water. This happens when the system is re-pressurized and water that had infiltrated into the system during the loss of pressure is conveyed to the users. Since the letter from your attorney pointed out that SLE has a history of relatively low cost water charges DEQ feels it is time that financing and funding plan be adopted by SLE to sets aside funds raised by increasing the monthly user charges and placing these funds into a dedicated account earmarked for installing the second water source. Based on the estimated costs, it would be reasonable to expect an increase in user charges to take about five years to fund a second well or source. Prior to March 15 , 2005 , DEQ also expects that a written response from the engineer be provided to the sixteen comments listed in our January 24, 2005 letter on the draft preliminary engineering report. Before March 15 2005, DEQ would like a reply from you restating and accepting the conditions as outlined above. If you want to propose alternative compliance dates or actions to the actions outlined herein, your response should describe and justify those changes and propose reasonable and alternative compliance dates. Failure to respond to this proposal might result in this office disapproving the SLE water system, imposing a moratorium on new connections, reimposing the sanitary restrictions on undeveloped lots in the subdivision and referring this situation for formal enforcement actions. We prefer not to be forced into this type of approach and hope you recognize the concessions offered in this letter by providing us with an acceptable commitment for bringing this water system into compliance with the Idaho Rules for Public Drinking Water Systems );;;' !a-~. Gary J. G~fney, P. ~ () Steve Tanner & Anthony Davis, DEQ, CdA Steven Cordes, Welch Comer and Associates, 1626 Lincoln Way, CdA John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308, Boise, ID 83701 Ron Sutcliffe, Deputy AG, DEQ, Boise ... \!i. HANSON HANSON INDUSTRIES, Gary J. Gaffney Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 15807 East Indiana Avenue, Spokane, WA 99216 (509) 922-5252' Fax (509) 922.5757 E.mail: admin~hansonind"com March 14 2005 Dear Mr. Gaffney: I received your letter dated Febmary 18 wherein the DEQ responded to Mr. Hammond's letter and also addressed several issues. We are pleased that DEQ has agreed with our proposed improvements to the water system. In response to your letter the following information is provided. 1. Submittal.The engineering submittal due March 31 , 2005 by Welch Comer & Associates will address and resolve the deficiency identified by DEQ. We are prepared to (a) repair the tank leak with a XYPEX product (b) repair the roof with matching material or with an exterior type XYPEXproduct (c) install a standby generator (d) install an autodialer in the tank ( e) secure a stand by pump for inventory (f) start a cross connection control program (g) start a well head protection program (h) install a chlorine tank vent to the exterior of the pump house and (i) repair the well meter if necessary and read it weekly during peak demands and monthly during average usage demands. We believe these measures as indicated by the forthcoming engineering submittal, sat~~fies completely the deficiency. - ' 2. Time Deadlines. At this time we believe that the timelines for the submission of plans are reasonable but we feel that allowing for all work to be completed by July 15, 2005 will accommodate any unforeseen delays. 3. DEQ Review of Draft Report. Our engineers will respond to those items in your January 24th letter which relate to our current, and only, submittal to the DEQ on the deficiency. The other items raised in your letter address matters which are directly related to a draft report prepared for the North Kootenai Water District. This draft report was prepared for discussions between this company and NKWD during its early interest in acquiring the water company. I do not know why the engineer forwarded it onto DEQ since we did not I The only deviation from your letter of February lSth is that SLE wishes to attempt to repair the existing roof on its reservoir tank rather than proceeding with the more extensive repair proposed in your correspondence. In the event that the existing roof cannot be adequately repaired as SLE has proposed the Company will work with its engineer and DEQ on a mutually acceptable repair plan. Gary Gaffney March 14 2005 Page Two request DEQ review as it was premature at that time. Your comments will be studied for future improvements to the system. 4. Second Well Source . We request the DEQ's assistance in working with the Idaho Public Utilities Commission (IPUC) for approval to create a reserve fund through rates for the installation of the second well. Please contact me directly and/or our engineers re: the submittal. Thank you for your assistance in this matter. ~~1t Robert J. Boyle Vice President of Hanson Industries, Inc. - - C: Welch Comer & Associcftes STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway' Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 April 22, 2005 Robert J. Boyle Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E. Indiana Avenue Spokane, W A 99216-1864 Dirk Kempthome, Governor Toni Hardesty, Director RE:Spirit Lake East Water System Improvements Dear Mr. Boyle: On March 15 2005, this office received a letter from you providing information on your proposal for making improvements to the Spirit Lake East water system. Your letter responded to my February 18, 2005 letter with a commitment to complete the following nine (9) water system improvements before July 15, 2005: a. Repair of tank wall leaks. b. Repair of tank roof.c. Installation of a standby generator.d. Installation of an auto-dialer. e. Purchase of a replacement well pump for standby with the existing well.f. Starting a cross-connection control program. g. Starting of a wellhead protection program.h. Installation of an exterior vent from the chlorine solution tank. 1. Repair of the water meter on the well discharge line. On March 24 2005, this office received a submittal from Steve Cordes, P.E. ofWe1ch Comer and Associates consisting of a proposal for the "Spirit Lake East Water System Maintenance and Repair" project and plans and specifications for supply and installation of a standby power generator on the Spirit Lake East water system. We have reviewed these two proposals and have the following comments Spirit Lake East Water System Maintenance and Repair:This proposal dated March 2005 as stamped by Philip Boyd, P .E. of We1ch Comer and Associates identified three items of repair or modification work. Two items involved work on the existing 190 000-gallon concrete ground-level water storage reservoir. Areas of the tank walls subject to leakage will be resealed with application of Xypex sealant products first on the tank interior and then on the tank exteriors. The existing roofing surface material will be entirely removed and the joints between the pre-cast concrete roof deck sections will be re-sealed using the same Xypex product used on the tank wall cracks. As the third item, the chlorine solution tank located in the pumphouse will be equipped with a vent hose extending from the tank to outside the building. Although the exact Xypex product to be used was not identified in the submittal, the Xypex Corporation has several protective barrier materials listed by NSF/ANSI under Standard 61 (Drinking Water System Components - Health Effects) that would be acceptable as sealant on this tank. A copy of the listing is enclosed. As long as the Xypex sealant used is NSF/ANSI Standard 61 listed as required by Idaho drinking water rules and is specifically identified with as-builts, use of this product to seal the tank walls and roof is acceptable to DEQ. ~.. RE:Spirit Lake East Water System Improvements April 22, 2005 Page 2 The proposal outlined a construction procedure that keeps the water reservoir in service while the work is being done inside and on top of the tank. Since there are no guarantees or provisions specified that would ensure a reliably safe drinking water supply could be maintained while workers are inside and on top of the tank removing debris, applying the sealant, and removing waste products, the proposed practice of maintaining service through the tank while the work is being performed is not acceptable to DEQ. An alternative method for maintaining the water system in operation while the water reservoir is isolated from service and repaired needs to be developed. DEQ suggests that temporary water storage capacity be mobilized to the site to replace the tank while it is out of service and being repaired. Please note that the product requires a minimum cure time of three days and set time of twelve days so it will take at least a month to complete the repair. Before the tank work is started, DEQ will need to approve an alternative construction method involving taking the tank out of service. When the tank walls are repaired and sealant has fully cured, the tank needs to be filled to the overflow elevation and tested by examination for leakage. Although not mentioned in the proposal, the absence of any observable wall leaks as certified by the design engineer is considered by DEQ to constitute acceptable seal. . Because the inside sealant is more effective, we recommend that the inside sealant be applied and accepted before any external sealant is applied. The slope of the roof should be measured and examined to ensure that it is sufficient to prevent ponding of water on the roof. Water accumulation on the roof can result in the seals at joints failing due to freeze effects. If the roof can structurally handle additional loading as verified by your engineer and the existing slope is insufficient, DEQ recommends that consideration be made to placing a capping concrete layer on top of the resealed roof. Standby Power Generator:Plans and specifications as prepared by Terry Stulc, P.E. of Trindera Engineering and submitted by Welch Comer and Associates on March 24, 2005 for supply and installation of a standby power generator next to the Spirit Lake East water system pumphouse have been reviewed. This installation consists of a diesel engine-driven generator and associated items all intended to operate the submersible well pump and three existing booster pumps on this system during power failures. The submitted plans and specifications were found to be acceptable and are hereby approved for construction purposes in accordance with the Idaho Rules for Public Drinking Water Systems and Section 39-118 of Idaho Code. The system auto-dialer needs to send a phone signal to the system operators whenever the standby generator is automatically activated. Inspection of installation of the power generator approved herein must be done by an Idaho licensed Professional Engineer (P.) or by someone under the direct supervision of a P.E. If major modifications to this accepted design are necessary, the design engineer must secure DEQ approval of the changes prior to implementation of the changes. Section 39-118 of Idaho Code requires preparation of complete and accurate as-built plans as certified by the inspecting engineer. The as-built plans need to be submitted to DEQ for review and approval within thirty (30) days of completion of construction. Since the 400-gallon fuel tank for the diesel engine will be double-walled with interstitial monitoring for leakage, it is acceptable to DEQ. However, you should contact the Panhandle Health District (Rick Barlow at 415-5200) to ensure compliance of this fuel tank with the Critical Materials Ordinance applicable for installations located over the Spokane Valley - Rathdrum Prairie Aquifer. RE: Spirit Lake East Water System Improvements April 22, 2005 Page 3 Outstandinf! Compliance Items:Of the nine items listed above as a-, the recent submittals have addressed four of the items - items a-c and h. Compliance with the remaining items prior to your commitment date of July 15 , 2005 still needs to be accomplished with the following actions. d. Installation of an auto-dialer. This can be accomplished by working with your electrical engineer who can oversee installation of an auto-dialer system used to alert the operators during problems. e. Purchase of a replacement well pump for standby with the existing well. Submittal of evidence of purchase of a standby submersible pump and motor capable of replacing the existing well pump with storage of the pump on-site. f. Starting a cross-connection control program. Submittal of a draft cross-connection .control ordinance to Tony Davis at this office including an implementation schedule for the system operator to conduct inspections of existing installations and locations needing installation of backflow devices (irrigation systems mostly) g. Starting of a wellhead protection program. Submittal of a plan to Yvonne Pettit at this office for implementation of a wellhead protection program at Spirit Lake East. i. Repair of the water meter on the well discharge line. Submittal of evidence that the water meter has been repaired, is operating properly, and the operator is taking periodic flow data. In summary, DEQ has accepted the proposed water tank wall and roof repairs conditioned on taking the tank out of service while the repairs are completed. Installation of the vent tube on the chlorine solution tank is also acceptable. Plans and specifications for supply and installation of the proposed standby generator have been approved as long as the installation includes an auto-dialer message sent to the system operators whenever an automatic switchover to the generator is done during power outages. And finally, five compliance items as listed above still need to be implemented or completed before July 15 , 2005. ;:;;;'ffn ~ Enclosure (NSF Xypex listing) Steve Tanner & Anthony Davis, DEQ, CdA Steven Cordes & Phil Boyd, Welch Comer and Associates, 1626 Lincoln Way, CdA Terry Stulz, Trindera Engineering, 1859 Lakewood Drive, Suite 103, CdA 83814 John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308, Boise, ID 83701 Harry Hall, IPUC, P.O. Box 83720, Boise, ID 83720-0074 Ron Sutcliffe, Deputy AG, DEQ, Boise John Balbi, 31772 N. Kelso Drive, Spirit Lake, Idaho 83869 (#8577 with Spirit Lake East pws file) '!,"i HANSON HANSON INDUSTRIES, INC. Gary J. Gaffney Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 - . 15807 East Indiana Avenue, Spokane. WA 99216 (509) 922-5252' Fax (509) 922.5757 E-mail: admin(g)hansonind.com June 1 2005 Re: Spirit Lake East Water Company Dear Mr. Gaffney: We have been working with our engineers on the items raised in your April 22 2005 response to us. We want to update you and request your review of our desire to modify the timing of the outage of the water tank. It is easier to follow if I list each area of improvement: 1. Water Tank Repair: interior.We are researching the best way to maintain water pressure and storage during the mandated outage of the tank while we perform the interior patch with the Xypex product. As you can imagine, it is not easy to maintain the same level of service without the use of the tank, especially during the Summer. As a result, we are requesting your permission to perform the tank work after Labor Day which we feel is a prudent scheduling with the demands of Summer usage. Please advise on this request. 2. Water Tank Repair: roof.Weare researching your request to place a concrete cap on the top ofthe resealed roof. We are also looking into a standard metal roof product to accomplish the same goal with less loading. However, the roof has not indicated any significant ponding in the past. 3. Generator.We have solicited bids from qualified contractors to perform the work. This work will be scheduled with other items for a more efficient mobilization into the site. 4. Auto Dialer.We have solicited bids for the purchase and installation. We have ordered the new telephone line. 5. Well Pump. We will purchase one for inventory. 6. Cross Connection Program. We will submit a draft to Mr. Davis. 7. Well Protection Program.We will submit a draft to Mr. Davis. 8. Vent.It will be installed. 9. Master Meter. A new one will be installed. Please advise us after you have reviewed this information. Thank you. Sincerely,1K~~~ Vice President/Owner of Spirit Lake East Water Company STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY -------_.._------_.--------------------------------.-.----. -- -'----"----""-"''.'---- 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 June 13 , 2005 Robert J. Boyle Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E. Indiana Avenue Spokane, W A 99216-1864 Dirk Kempthorne, Governor Toni Hardesty, Director RE:Spirit Lake East Water System Improvements - Revised Compliance Schedule Dear Mr. Boyle: We have reviewed your June 1 , 2005 letter regarding the status of completion of the nine items previously agreed upon in our April 22, 2005 letter to you as necessary improvements to the Spirit Lake East water system. Based on your proposal, DEQ will modify the improvement and compliance items as follows: Repair of tank wall leaks and repair of tank roof: To provide more time for you to design an acceptable repair procedure and avoid supply difficulties associated with taking the tank out service during the summer when demand for water is high, you have proposed postponing work on the water reservoir until after the summer peak usage period. This modification is acceptable to DEQ with the following schedule and conditions: Prior to July 15, 2005: An outline needs to be submitted for DEQ evaluation of the revised schedule and methods that will be employed for taking the water tank out of service for repair of the walls and roof while maintaining a safe and adequate water supply. DEQ will respond to this submittal so that an acceptable plan is in place and ready to go prior to September 1 2005. Prior to September 1, 2005: Written notice needs to be provided by the operator to all system users describing the proposed water tank construction work and schedule (as approved by DEQ) and discussing additional monitoring that will be done during and at the end of the repair period to ensure safety of the water supply. A copy of this notice needs to be provided to DEQ. Prior to November 1,2005: A summary report describing the final results from the tank and roof repair work needs to be submitted to DEQ for evaluation and approval. Installation of a standby generator, installation of an auto-dialer, purchase of a replacement well pump for standby with the existing well, starting a cross-connection control program, starting of a wellhead protection program, installation of an exterior vent from the chlorine solution tank, and repair of the water meter on the well discharge line. Your letter indicated that items #3-9 were progressing as planned and should be completed prior to July 15, 2005 as you had previously promised. Please notify DEQ with an alternative proposal if any of the modifications described in this letter are unacceptable. Otherwise DEQ will await submittal of the revised tank repair plan and submittal of evidence that individual items 3-9 have been completed. These submittals are due to DEQ on or before July 15 2005. SiI)cerely, LA vo~0, (l , Gary J. ~~fney, P. . ,~.. RE: Spirit Lake East Water System Improvements - Revised Compliance Schedule June 13, 2005 Page 2 Steve Tanner & Anthony Davis, DEQ, CdA Steven Cordes & Phil Boyd, Welch Comer and Associates, 1626 Lincoln Way, CdA Terry Stulz, Trindera Engineering, 1859 Lakewood Drive, Suite 103, CdA 83814 John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308, Boise, ID 83701 Harry Hall, IPUC, P.O. Box 83720, Boise, ID 83720-0074 Ron Sutcliffe, Deputy AG, DEQ, Boise John Balbi, 31772 N. Kelso Drive, Spirit Lake, Idaho 83869 tG\-- ~~. H~NSON ! HANSON INDUSTRIES, INC.15807 East Indiana Avenue, Spokane, WA 99216 (509) 922-5252' Fax (509) 922-5757 E.mail: admin~hansonind.com July 13 , 2005 Gary 1. Gaffney Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d'Alene, ID 83814-2648 RE: Spirit Lake East Water Company ("Company Dear Mr. Gaffney: This is a status report following DEQ's June 13th letter. 1. Sale of Assets. A new, important issue is that the Company is in active negotiations to sell substantially all of its assets to Phil Boyd. It is our understanding that Mr. Boyd met with you this week at your office and advised you of these negotiations and to discuss the future improvements. Upon successful completion of these negotiations the Company and Mr. Boyd will file a joint application with the IPUC for review and approval of the transfer of ownership. Notice will also be provided to DEQ pursuant to the Public Drinking Water Rules. We will also provide notice to the customers in conjunction with the application to the IPUc. Mr. Boyd will be participating in detail on all issues affecting the Company. Please consider this letter as our authorization to DEQ to inform and advise him of all aspects re: the Company. Mr.Boyd and his firm Welch Comer & Associates, have been advising the Company on the improvements to the system. The information concerning the improvements has been researched and agreed upon jointly between the Company and Mr. Boyd. 2. Tank Repairs . Mr. Boyd and the Company will be submitting the methods proposed to take the tank out of service. Mr. Boyd has designed the use of alternate tank(s) to be temporarily connected to the system when the existing tank is taken out of service for repairs- Mr. Boyd will meet with DEQ to discuss the logistics of this operation with you. The Company and Mr. Boyd will provide written notice to all customers prior the work as well as provide DEQ with evidence of the proper repairs at their conclusion. 3. Generator.The generator is a long lead item and we expect it to be delivered no later than September 30 (as per the supplier). However, Mr. Boyd is working on electrical code requirements with Mr. Loudon in the Coeur d' Alene office which could impact the schedule independent of the backlog with the generator manufacturer. We will advise you of the impact of these interdependent aspects once the electrical issues are resolved. 4. Auto Dialer. We have installed a dedicated telephone line for the auto dialer. The bids to provide and install the device have been received and are ready to award. However, the autodialer and the auto transfer switch for the generator must be installed together. Thus, we expect the autodialer to be operational after the generator is delivered and installed by approximately October 15. 5. Well Pump . The well pump bids have been received and awarded. The pump is due for delivery no later than August 30. The motor from the failed pump is still operational and is in inventory. 6. Cross Connection Program. A draft program is enclosed for DEQ's review and comment. 7. Well Protection Program. A draft program is enclosed for DEQ's review and comment. 8. Chlorine Vent.Mr. Boyd has designed the correct method of venting and it will be installed in July. 9. Master Meter.The meter was repaired in June and is fully operational. We have been continuously working with our engineers towards the resolution of the work mandated by DEQ. In addition, because Mr. Boyd is negotiating to purchase the system we will be working together to install the improvements. Mr. Boyd has been working diligently with the manufacturers and has encountered some delays due to the construction season and one of a kind specifications regarding the generator. Nonetheless, we will monitor these delays and seek to install the improvements as soon as practicable in accordance with our correspondence. Thank you. - - Sincerely, Robert 1. Boyle Vice President C: Phil Boyd - - STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director July 21 2005 Robert J. Boyle, Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E Indiana Ave Spokane, W A 99216-1864 RE:Spirit Lake East Water System Improvements Dear Mr. Boyle: We have reviewed your July 13, 2005 letter providing a status report on completion of the nine items agreed to on April 22, 2005 as necessary improvements to the Spirit Lake East water system. In addition, werecently met with Phil Boyd as the project engineer to discuss these same items. During this meeting we were notified by Mr. Boyd that, independent of his role as the project engineer, he was considering purchase of the Spirit Lake East water system. Reflective of your letter and the June 13, 2005 modifications to the schedule for completion of the system improvements, the status of the nine improvement items is as follows: Repair of tank wall leaks and repair of tank roof: Prior to September 1, 2005: We have not received a description of the specific methods thatwill be employed for taking the water tank out of service for repair of the walls and roof while maintaining a safe and adequate water supply. During the meeting with Mr. Boyd, he indicated a plan was being developed to provide temporary water storage vessels at the well site so that the existing reservoir could be taken completely out of service for the repairs. Although you missed the July 15, 2005 deadline for submitting this plan, we still require that an outline of methods and times for the tank repairs be submitted for DEQ evaluation. An acceptable tank repair plan needs to be submitted, accepted by DEQ, and ready to go prior to September 1 , 2005. After the plan is accepted, written notice needs to be provided by the operator to all system users (with a copy to DEQ) describing the proposed water tank construction work and schedule. This notice needs to include a discussion of additional water quality monitoring that will be done to ensure safety of the water supply. Prior to November 1, 2005: A summary report describing the fmal results from the tank and roof repair work needs to be submitted to DEQ for evaluation and approval. If the tank repair work cannot be completed before November, you need to now propose additional time. Installation of a standby generator: You have not complied with the agreement to have a standby generator in place prior to July 15 2005 because you indicated there is a long lead time for delivery of this item. Original notice of this requirement was issued in January of 2005 which should have provided ample time to have the generator in place and operational prior to July 15 2005. Your letter indicated the generator is expected to be delivered no later than September 30, 2005. Installation of an auto-dialer: You have not complied with the agreement to have an auto-dialer installed prior to July 15, 2005. Your letter indicated that a telephone line for the dialer had been installed and an installation contract for the dialer was ready but since the generator transfer switch RE: Spirit Lake East Water System Improvements July 21 2005 Page 2 and dialer had to be installed at the same time, this item would not be completed until October 15 2005. Purchase of a replacement well pump for standby with the existing well: You have not complied with the agreement to have a replacement well pump on site prior to July 15, 2005. Your letter indicated that you have awarded a bid for a replacement pump and that the motor from the old well pump and the new pump will be on si~e no later than August 2005. Cross-connection control program: A copy of the "Cross Connection Control Program" for the Spirit Lake East Water Company dated July 15 20055 was submitted. We have reviewed this manual and found it to be acceptable. We recommend implementation of this program as required by IDAP A 58.01.08.550.07 and consider this item complete once the program has been adopted. Wellhead protection program: This program description has been referred to Yvonne Pettit at this office for review and comment. Installation of an exterior vent from the chlorine solution tank: You have not complied with the agreement to have the exterior vent installed prior to July 15, 2005 but indicated the vent would be installed before August 2005. Repair of the water meter on the well discharge line. Your letter indicated that the water meter has been repaired and is in operation. The system operator should now be recording the volume of water pumped from the well in order to document water demand characteristics on this system. We recommend at least monthly readings during off peak periods, weekly readings during irrigation season, and daily readings during hot summer days. This data is vital in demonstrating the adequacy of this well in supplying the future needs of this system and in justifying your proposal that a second well was not necessary on this system from a water production basis. This item is completed. In summary, it appears that you were unable to complete items # 1-5 and 8 on schedule but have proposed alternate completion dates. Items # 6, 7, and 9 appear to be completed pending comments on the wellhead protection plan. During our meeting with your engineer, we asked, in light of the further delays as reflected above, that you prepare and distribute to the system users a newsletter informing the residents of actions being taken to upgrade the water system to avoid outage problems and comply with recent sanitary survey recommendations. We continue to recoI'n.thend that a newsletter be distributed and suggest that the notice of tank repair work, schedule, and monitoring required by items 1-2 above be incorporated into the newsletter. Z:~Q !o/Gary lKaffuey, P.E. Uc: Steve Tanner & Anthony Davis, DEQ, CdA Steven Cordes & Phil Boyd, Welch Comer and Associates, 1626 Lincoln Way, CdA John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308 Boise, ID 83701 Harry Hall, IPUC, P.O. Box 83720, Boise, ID 83720-0074 John Balbi, 31772 N. Kelso Drive, Spirit Lake, Idaho 83869 """ STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director August 1 2005 Mr. Bob Boyle Spirit Lake East Water Company 15807 East Indiana Avenue Spokane Valley, Washington 99216 Dear Mr. Boyle: This letter is a follow up to the telephone conversation we had last week regarding a Drinking Water Protection Plan for the Spirit Lake East Water Company. A5 I mentioned in our conversation, I have reviewed the Wellhead Protection document that was submitted to the DEQ for Spirit Lake East Water Company. Although the draft of your Wellhead Protection Plan did incorporate some of the components ofa Drinking Water Protection Plan, there are two primary elements that are missing; the Management Plan and the Contingency Plan- According to the Idaho Drinking Water Protection Plan guidance Protecting Drinking Water Sources in Idaho August 2000 there are eight required elements in developing a Drinking Water Protection Plan. If a plan is found to satisfy all eight elements, then the community will be recognized by the state of Idaho DEQ as having a "State Certified Plan . The eight required elements are: Element 1 Description of Planning Team Participant Roles and Duties Element 2 Delineation of the Drinking Water Protection Element 3 An Inventory of Potential Sources of Contamination Element 4 Management Tools and Protection Measures that will be pursued to manage Potential Sources of Contamination Element 5 A Contingency Plan Element 6 A Protection Strategy for New Wells or Intakes Element 7 A Public Participation and Education Component Element 8 An Implementation Strategy (what will be done, when will it be done, and by whom) You have indicated that you are interested in developing a Drinking Water Protection Plan for the Spirit Lake East Water Company so I have contacted Melinda Harper with Idaho Rural Water Association to assist you in developing a plan for your system. If you have any further questions or concerns about the Drinking Water Protection Plan process, pLease contact Melinda Harper or me for assistance. Sincer rar~P'M tL~~7~g Water Protection Specialist Idaho Department of Environmental Quality Coeur d' Alene Regional Office Email: yvonne.pettit~deq.idaho.gov c. Steve Tanner Tony Davis Gary Gaffney Melinda Harper . . STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director August 8, 2005 Mr. Robert Boyle Hanson Industries, Incorporated 15807 East Indiana Avenue Spokane Valley, Washington 99216 Dear l'v1r. Boyle This letter is in response to our meeting on August 2 2005 , regarding a Drinking Water Protection Plan for the East Spirit Lake Water Company public water system. As I stated in the meeting, in the state ofIdaho a Drinking Water Protection Plan is a voluntary effort implemented at the local or community level. However, the Idaho Department of Environmental Quality strongly encourages all public water systems to develop a Drinking Water Protection Plan as a means of addressing the water quality issues that concern their systems. During our meeting you mentioned that Hanson Industries is considering selling the Spirit Lake East Water Company. Given this infonnation, both Melinda Harper, with Idaho Rural Water Association, and I think it would be more beneficial for the Spirit Lake East Water Company to pursue the development ofa Drinking Water Protection Plan with the new owner of the system. This would give the new owner and the homeowners association the opportunity to work together on developing and implementing a protectionplan for their system. "'. Mr. Boyle, thank you for giving Melinda Harper and me the opportunity to meet with you to discuss drinking water protection. We look forwar,q.to working with Spirit Lake East Water Company in the future. Once the new owner is in place, Melinda Harper or I will be contact the Spirit Lake East Water Company regarding a Drinking Water Protection Plan. Sincerely, v nne Pettit inking Water Protection Specialist Idaho Department of Environmental Quality Coeur d' Alene Regional Office Email: yvonne.pettitifYdeq.idaho.gov c. Steve Tanner Tony Davis Gary Gaffney . ,~, Memorandum Date:August 30, 2005 Gary Gaffney at Idaho DEQTo: From:Bob Boyle at Hanson Industries 15807 E. Indiana Avenue, Spokane Valley, W A 99216 USA CC: RE: (509) 922-5252 (Office) 922-5757 (fax); email: bboyle~hansonind.com Spirit Lake East Water Company In your July 21 st letter you requested a newsletter updating our water customers. 'rVe have been contacted by the Board of Directors of the Spirit Lake East Homeowners Association, the Board of Directors of Treeport and the Water Committee of the Spirit Lake East Homeowners Association to discuss certain important issues. The key person for these groups is Mr. John Balbi who advised that he will contact me after a joint meeting to schedule a conference re: their topics. Since we are unaware of the agenda or topic(s), we will wait until we meet and confer with them before sending out a newsletter update. In this way, the infonnation will be recent and more current than doing one now and one later. - - I will provide you with a copy of the newsletter. 0 1/07/94 (ji'HANSON 15807 East Indiana Avenue, Spokane,WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin(g)hansonind.com September 12 , 2005 Gary Gaffney Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Gaffney: In our telephone conference last week, you asked for an update following your letter dated July 21 for the outstanding issues: 1. Purchase of Water Company. Phil Boyd is not going to purchase the company due to his commitments to his professional engineering company. He is still our engineer involving DEQ and the improvements but was also working with you and us as the new buyer/owner to improve a system that he approved of. His decision about two weeks ago has caused us to review the work with the schedule. 2. Repair of Tank. After much deliberation among ourselves, the manufacturer and our engineer, we proceeded with an exterior repair using the Xypex product. We believe this is the most prudent and safe method for three basic reasons: (a) it eliminates the chance for system contamination as the lines are depressurized to effect the switch over to temporary tanks and then back again; (b) it eliminates the need for a 30-day water outage to our customers with the associated risks with temporary lines, storage, etc.; (c) the product works well in such exterior situations. We will be using the same repair techniques as before, only on the outside, with the Xypex product. The repair is being done in phases with the first phase/patch put in place last week and the remaining work to follow. This work is scheduled for completion by September 30 2005. As a result of the exterior repair, we did not forward a specific plan for taking the tank out of service and insuring water through the temporary tank(s) and line(s). A full description will be provided as requested by DEQ as set forth in section 4 below. 3. Tank Roof.The roof repair is underway as of this date and should be completed by September 30, 2005. A band of metal flashing was also added around the perimeter (held in place by over 300 screws) to prevent any wind from peeling back the roof material. 4. Tank Repair Reports. I will forward these reports once the repairs to the tank and roof are completed. 5. Standby Generator.We are still looking at various sources for delivery prior to September 30 2005. - - 6. Auto dialer. The device has been ordered. The telephone line is installed. It should be operational by September 30, 2005 but may need to be integrated with other improvements before being fully functional. 7. Standby Pump with Motor.It was purchased and in inventory. 8. Cross Connection Program. It will be instituted after on-going discussions with the Spirit Lake East Homeowners Association Water Committee. 9. Wellhead Protection Program. It is not required by DEQ. 10. Exterior Vent.The work is on-going and should be completed by September 2005. Also, maintenance work was performed on the lines inside the pump house to remove encrusted chlorine. 11. Newsletter.We (as well as the DEQ) have been advised from the Spirit Lake East Homeowners Association Water Committee (chaired by John Balbi) of its interest in discussing acquisition of the water company/system. We have asked our expert in the regulatory field, John Hammond of Boise, to contact Mr. Balbi and go through the issues. We are awaiting the results from this discussion which would involve the PUC re: its approval of the transfer. As a result, the newsletter will be distributed once we have the route mapped out re: the Water Committee and its involvement (or not) with the DEQ and the PUC for acquisition. We can advise the customers through the Water Committee of the repairs being done through September, particularly of the decision not to take down the water tank for 30 days. 12. Pump House. A portion of the roof was removed and replaced with new metal roofing. Also, general maintenance and painting is underway and should be completed by September 30, 2005. 13. Tree Trimming.General tree trimming is underway to provide better clearance zones around the power lines and fence line. This work should be completed by September 30, 2005. Robert 1. Boy Ie if' ft~ Vice President '-/ - - STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY -------------------------- 2110 Ironwood Parkway' Coeur d'Alene, Idaho 83814-2648' (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director September 20, 2005 Robert J. Boyle, Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E Indiana Ave Spokane, W A 99216-1864 RE:Disapproval of the Spirit Lake East Water System Dear Mr. Boyle: We have reviewed your September 12, 2005 letter providing a status report on completion of the nine items agreed to on April 22, 2005 as necessary improvements to the Spirit Lake East water system. Your letter indicated you had started work on repair of the water storage tank without providing DEQ with a - plan for taking the tank out of service during the repair work. Your letter indiCated you are attempting to do the repairs from the exterior of the tank walls and roof. Besides the fact we were not consulted regarding this change, it is not clear how you will ensure the safety of the drinking water from contamination during this repair activity. A notice should have been issued by you to all users that this work is starting describing your plan for monitoring the safety of the drinking water and including a notice to not use the water for drinking water purposes during the repair. It is not clear why you now consider an external crack repair to be effective when originally it was proposedto repair wall cracks from the tank interior and exterior. It is not clear how will you prevent the materialremoved from the roof joints or the applied Xypex sealant material from passing into the water inside the tank. The repair plan approved on April 22, 2005 called for removing the existing roof surface material down to the concrete with the joints between the pre-cast concrete roof deck sections re-sealed using the same Xypex product used on the tank wall cracks. Reference in your letter to installation of a band of metal flashing to prevent peeling back of roofing material suggests that another repair method not approved by DEQ may have been employed. It may prove necessary to fully remove whatever you are doing now in order to provide a full and lasting roof seal. How do you plan now to test the effectiveness of the tank repair work? The deadline for completing the tank repairs is September 30, 2005. Your letter indicated that you are no closer to having a standby generator installed at this site although the agreement was that you would have a generator in place prior to July 15 2005. The same applies to havingan auto-dialer alarm system in operation. Your letter indicated a standby well pump and motor were purchased but did not state that the replacement well pump was on site ready for use as agreed. This was also promised to be done before July 15 2005. Your letter indicated that you have not installed an exterior vent hose from the cWorine solution tank as promised would be done over two months ago. RE: Disapproval of the Spirit Lake East Water System September 20, 2005 Page 2 A review of your recent actions regarding this situation shows that you have consistently failed during the last nine months to fully comply with agreed upon compliance dates, not taken timely actions needed to address system deficiencies and defects, required almost monthly reminders from the DEQ office regarding your commitments, refused to notify the users regarding the status of the system, and ignored many requirements established by this office regarding compliance of the system with the state drinking water rules. In consideration of your inability to correct these deficiencies prior to the assigned dates and in a manner approved by DEQ, the public drinking water system serving Spirit Lake East is hereby disapproved per IDAPA 58.01.08.007.01 and .02 (Idaho Ru1es for Public Drinking Water Systems) As an immediate consequence of disapproval of this water system, you are hereby required in accordance with IDAPA 58.01.08.007.07 to issue public notification of the system disapproval to all users on your water system. This notice must be issued by mail to all users within ten (10) days of the date of this letter describing your plans and completion schedu1e for repairing the storage tank, installing standby power . facilities, provide a replacement well pump and motor; and complete the auto-dialer system and chlorine vent. A copy of the draft (for approval) and final public notification must be submitted to DEQ to demonstrate your compliance with this requirement. Another consequence of this disapproved designation needs to be mentioned. If we receive a home loan inquiry from a lending institution regarding the status of the Spirit Lake East drinking water system, we must provide notice that the water system is disapproved. In addition, disapproval of the water system is a step this office takes before initiating a formal enforcement referral to our Boise offices. Disapproval of the Spirit Lake East drinking water system has been brought about due to public health risks prolonged by your delay in correcting system deficiencies identified after the system was completely out of water from October 4-10, 2004. jj~' 9 " Gary J. Gaffney, P. Steve Tanner / Anthony Davis / Suzanne Scheidt, DEQ, CdA Steven Cordes & Phil Boyd, Welch Comer and Associates, 1626 Lincoln Way, CdA John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308, Boise, ID 83701 Harry Hall, IPUC, P.O. Box 83720 , Boise, ID 83720-0074 John Balbi, 31772 N. Kelso Drive, Spirit Lake, Idaho 83869 Jerri Henry, DEQ-Boise September 26, 2005 Gary Gaffney Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Gaffney: I am providing you information re: the repairs mandated in your September 20 2005 letter for our meeting this Wednesday. We can discuss these items in an agenda format to assist us in addressing all the issues. 1. Roof Repair: portions of the damaged roof were removed to 16" and replaced by gluing down and then the same type shingles were placed over the repair shingles and glued down. A band of metal sheeting (about 1"2" inch thick) was placed around the perimeter of the roof to prevent wind from peeling it back. This is how the roof was damaged. The roof was water tested for one hour (generating over 2" of water onto the roof and flowing off of it) and there were no leaks detected into the tank from the roof. The water inside the tank was not subject to any possibility of contamination from the roof repairs since the solid concrete top was not breached in the repairs or previously by the peeled back shingles. Our engineer, Phil Boyd, can provide further technical details at our meeting. 2. Tank Repair: the exterior tank repair will be discussed in detail at our meeting. Water quality tests were taken before and after the repair and showed no presence of coliforms. A copy of the reports will be provided at our meeting. Although we did not repair the tank internally as was agreed upon earlier, we believe this method of repair was far safer than the health risks associated with taking the tank down and providing temporary water storage. In addition, if this repair is effective, the costs are minimal which in turn will benefit our ratepayers. Lastly, the internal repair was premised upon a third party buying the system who preferred the repair be performed in this manner. Our engineer, Phil Boyd, can provide further technical details at our meeting. 3. Standby Power: we have possession of a genset capable of satisfying the need for pressure. I need to discuss this issue at length at our meeting. 4. Pump and Motor: we have the inventory pump and motor in place in the pump house. . ..- -~.. STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty, Director October 6, 2005 Robert J. Boyle, Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E Indiana Ave Spokane, WA 99216-1864 RE:Spirit Lake East Water System Dear Mr. Boyle: Last week, we met to discuss your efforts to address the nine items that resulted in disapproval of the Spirit Lake East drinking water system on September 20. Since that time, I have sent out a detailed summary of the meeting and DEQ's position regarding the status of these same nine items. To further clarify the steps necessary for you to restore the approved designation to the Spirit Lake East water system, please consider .the following: 1. Storage Tank Wall Repairs: We understand the tank will be filled to above the repair level and observed from the outside for leakage. We will need a report from your engineer indicating the outcome of the work completed on the exterior tank wall using the Tamms coating product. acceptable repair is when no leakage is visible. We continue to believe that the interior of the tank needs to be closely inspected and cleaned. The engineer agreed to inspect the tank and report to DEQ concerning his professional opinion on the condition of the interior of the tank and the need for further inspection and cleaning. We would expect that wall repairs, leak testing of the tank, and inspection of the interior of the tank can be completed and reported to DEQ before October 31 , 2005. If internal inspection and cleaning of the tank are necessary as we suspect, a reasonable timeframe for completion of this work needs to be proposed to DEQ. 2. Tank Roof Repairs: Although we would have preferred a more thorough roof sealant repair effort the work done to patch the existing roof overlay material might prove successful. We recommend that work to eliminate leaks through the roof and into the tank be tested by a sampling program of the stored water. If the chlorination system could be changed to inject into the discharge side of the booster pumps, the system operator could conducting a sampling effort to detennine roof repair success. We suggest that the effort involve a weekly total coliform sampling of water pumped from the well and of water stored in the tank during a six-month period. If the samples show a consistent absence of bacteria growth in the tank, the roof tank repairs can be considered successful. This effort should not be undertaken until the interior of the tank has been inspected and, if necessary, cleaned. If this proposal is not acceptable, the engineer needs to propose an alternative technique that will demonstrate that the tank roof repairs have been successful. If you agree with this proposal, you need to indicate in writing to DEQ before October 31 , 2005 how and when the testing will be conducted and completed. - -~: Spirit Lake East Water System Jctober 6, 2005 Page 2 3. Standby Power Generator: Mr. Hanson agreed to have the standby generator installed and operational before October 31 2005. IDAPA 58.01.08.550.03.r requirements quoted in the meeting notes need to be satisfied with this installation. When this unit is operational, DEQ should be notified and we will conduct an inspection of the installation. 4. Auto-dialer: Since the auto-dialer system is installed and operational, this item is satisfied. 5. Spare Well Pump & Motor: Once this equipment is on-site, this item will be satisfied. 6. Cross-connection Ordinance: We agreed to additional time for you to implement this program. 7. Wellhead Protection Plan: We agreed with your decision to postpone this program. 8. Chlorine Solution Tank Vent: This vent is installed and the item now satisfied. 9. Flow Meter: The engineer needs to provide DEQ with a report that the propellers in the well discharge flow meter have been repaired and the meter is now capable of recording flows accurately. It was agreed that elapsed time meters would be installed on the controls for each of the three booster pumps and on the well pump when the standby power generator electrical work was being done. Disapproval Notice: We have received a report from you that a disapproval notice approved by DEQ was issued on September 30 to all system users. A copy of this notice needs to be submitted for DEQ records. Chlorine Residual: It is not clear from our records whether the system operator is periodically measuring and recording the chlorine disinfectant concentrations from locations rotated throughout the water distribution system. Since this water system appears to have been required to disinfect due to frequent bacteriological contamination, this practice needs to be initiated or continued. The operator needs to submit chlorine monitoring results to DEQ on a monthly basis. Please have the operator contact Tony Davis at this office to establish specific chlorine residual monitoring frequency and reporting requirement for the system. In summary, it appears that commitments.\wve been made or proposed for five of the nine items (1 , 2 , 5 and 9) with completion before October 31 . 2005. The remaining four items are either completed now or being postponed. As soon as the five pending items are completed or resolved, we will want to visit the system to examine the improvements. When all compliance items are resolved, we will be prepared to re- approve this water system. Sincerely, ~t/.ffu 1:.~ Steve Tanner / Anthony Davis / Suzanne Scheidt, DEQ, CdA Steven Cordes & Phil Boyd, We1ch Comer and Associates, 1626 Lincoln Way, CdA John Hammond, Jr., Batt & Fisher LLP, P.O. Box 1308, Boise , ID 83701 Harry Hall, IPUC , P.O. Box 83720, Boise, ID 83720-0074 John Balbi, 31772 N. Kelso Drive , Spirit Lake, Idaho 83869 Jerri Henry, DEQ-Boise Stephanie Ebright, DEQ, Boise ~.. ~'i ~ANSON 15807 East Indiana Avenue. Spokane,WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin~hansonind.comGary J. Gaffney October 28 , 2005 Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Gaffney: Please find a status update on the nine items of work. 1. Storage Tank Wall Repair. This work was completed and reviewed by our engineer, Phil Boyd. 2. Tank Roof Repair. This work was completed and reviewed by Mr. Boyd. 3. Standby Power Generator. The unit is in-place and our industrial electricians are in the process of completing the connection. This electrical work will continue on during the first week in November. During this work, the electricians will have to shut off the power intermittently for safety reasons but we will not let the system fall below 20 psi. We will advise you upon completion. Also, the new concrete pad and housing was completed before the genset was installed. 4. Auto Dialer. Installed and accepted. 5. Spare well pump & motor. The pump in on site. The motor will be onsite on Monday, October 31. 6. Cross Connection Program. This program will be implemented at a later date. 7. Wellhead Protection Program. This program will be implemented at a later date. 8. Chlorine Solution Tank Vent. Installed and accepted. 9. Flow Meter. The propellers in the discharge flow meter are installed. The three hour meters are installed. - - The September 30th Disapproval Notice was provided to DEQ on Monday, October 3. Please advise if you did not receive a copy. The chlorine monitoring results have been provided each month to DEQ by the testing laboratory. Please advise if you have not been receiving them. We will request a walk through of the improvements at a mutually convenient time. Sincerely, C) l\. Raymond A. Hanson Chainnan .. ~.. STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY Dirk Kempthorne, Governor Toni Hardesty. Director2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814.2648. (208) 769-1422 November 5 , 2005 CERTIFIED MAIL: 7000167000056151 4465 Raymond Hanson, Owner Spirit Lake East Water Company 15807 E Indiana Spokane, WA 99216 RE: Sanitary Survey, PWS# 1280176, Spirit Lake East Water System Dear Mr. Hanson: Thank you for providing the assistance of Jim Kreuger for the inspection of the Spirit lake East water system. We found that the water system was not in compliance with Idaho Rules for Public DrinkinQ Water Systems . The problems that we noted are as follow: Administration1. The operator did not possess a "Distribution 1" certification from the Idaho Bureau of Occupational Licenses.2. A Total Coliform Monitoring Plan was not on file with DEQ. Well A smooth nosed sample tap is required on the discharge to the well. The existing sample tap was a plastic tube clamped to a galvanized pipe. The well could not be pumped to waste prior to the first service connection. There is no well log on file with DEQ. The vent screen on the well was connected with duct tape. It must be permanently clamped with a steel clamp. The flow meter should be read on at least a weekly basis. Reservoir1. The repairs to the cold joint on the side of the reservoir appeared to extend more than half of the way through the concrete. The impacts of removing this amount of concrete on the strength of the reservoir ' side walls are unknown. An evaluation performed by a professional engineer must be prepared that will certify that the tank will not fail. The reservoir cannot be isolated from the water system without depressurization of the distribution system. It appears that the piping that would allow the reservoir to be bypassed has been removed. CM: 7000 167000056151 4465Spirit Lake East Sanitary Survey Report November 4. 2005 Page 2 10. The leaks in the reservoir wall had not been completely repaired at the time of inspection. There did not appear to be a sill at the reservoir discharge to prevent sediments from flowing into the booster station. Prior surveys have identified a problem with pumping sand from the well. The two overflows from the reservoir were not 24 mesh screens or a weighted flapper valve with expanded metal screens. The overflow was only protected by a screen with %-inch openings. This could allow insects and small rodents to access the reservoir. The overflows were not 12 to 24 inches above the ground surface. The overflows do not discharge onto a splash plate. The reservoir did not appear to have a drain. Water was impounded on the roof of the reservoir. A registered professional engineer must certify that the current roof is not leaking. The reservoir needs cleaning. Pump House1. Three of the bladder ta~s appeared to be waterlogged and in need replacement. The well house needs cleaning and organization. All fuels, paints and solvents must be removed from the pump house. All threaded taps in the pump house must have backflow prevention devices. An electrical fan for fresh air ventilation must be installed in the pump house. Routine maintenance schedules should be established for servicing the pumps. Disinfection1. The tap used to fill the hypochlorite tank was not protected by a backflow prevention device. Rubber gloves and eye protection should be provided to the operator for use during the hypochlorite tank filling. The chlorine test kit used by the water system was inadequate for measuring chlorine in the drinking water. It was designed to be used in swimming pool applications. A smooth nosed monitoring tap is required after chlorine injection. Free chlorine residuals should be measure daily. Distribution System1. A cross connection control program must be implemented.2. The valves in the distribution system should be exercised at least two times peryear. A leak detection program must be implemented. The flow meter should be read frequently and compared to the meter readings to determine if water loss is less than 15%. Spirit Lake East 1 Sanitary Survey Report November 4, 2005 Page 3 CM: 7000 167000056151 4465 The water mains should be flushed annually. The dead end water mains must be flushed two times per year These deficiencies should be addressed in a plan of correction (POC). This is document that you must prepare and send to DEQ within 45 days of the date of this notification. This document should be a narrative that lists the deficiencies , how you plan to address them, and the date by which they will be corrected. You should be realistic in the estimated time that it will take to achieve compliance so that extensions are not necessary. If you have corrected any items within the 45 day period, just, note that the repairs have been accomplished. Corrective actions on items that are currently under a compliance order from DEQ cannot have their dates for remediation altered using the Plan of Correction process. In this case the repair of the leaks in the reservoir wall, the installation of an adequate seal on the reservoir roof, and the installation of the generator are unaddressed deficiencies that are subject to enforcement action. If you have any questions, please contact me at DEQ. We are located at 2110 Ironwood Parkway; phone , (208) 769-1422. Anthony P. avis Analyst c: Steve Tanner, DEQ/CDA . 15807EasllndianaAvenue,Spokane WA 99216 (509) 922-5252. Fax (509) 922-5757E-mail: admin(gJhansonind.com December 21 , 2005 Anthony P. Davis Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d' Alene, ID 83814-2648 RE: Spirit Lake East vVater Company PvVS # 1280176 Dear Mr. Davis: vVe have reviewed your letter dated November 5 , 2005 re: your inspection of the water system. vVe will respond to your comments in the order of your letter. Administration 1. Operator License. Mr. Knlger s license application is scheduled to be reviewed by the Board of Drinking Water and Wastewater Professionals on January 18 , 2006. Please see enclosed letter. 2. Coliform Monitoring. We have complied historically with testing at least once per month for years. If this is insufficient, we request additional information re: DEQ's requirements. vV e 11 1. Sample Tap. We have a Teflon tube (not plastic) attached to a galvanized pipe which results in no contamination of the samples. Please advise if this is insufficient. 2. Well Pumping. There is a discharge elbow on the pipe to hook a hose - onto and take out the waste. The pump also-swivels to pump out waste. This configuration satisfies DEQ's requirement. 3. Well Log. We have included a copy of the well log. ~.. DEQ Response December 21 , 2005 Page Two 4. Vent Screen. It has been permanently clamped with a %" metal umon. 5. Flow Meter Reading. vVe read the flow meter with our regularly scheduled chlorination refill. Reservoir 1. vVall Repairs. We retained Wambeke Engineering to assess the strength of the wal~~ias requested by DEQ. The stnlctural engineer concluded" . . . the sfr~ngth of the reinforcing bar at this level exceeds the applied loads by a reasonable factor of safety." A copy of this report is included. 2. Isolation. The connections to allow bypass are still in place and can be reconnected with a 3" mbber hose. The only way to completely isolate would be to remove one of the distribution pumps. 3. Wall Repairs. The repairs have been completed since your inspection. 4. Sill. We will review the blueprints to ascertain the presence or absence of this sill. - 5. Overflows. The two overflows now have 24 mesh screens underneath the screen. 6. Overflows Clearance. The overflows are now 12" above the ground surface once we cleared away the surface vegetation. 7. Splash Plate. We will install a concrete splash plate with our regularly scheduled maintenance in JanuaryfFebmary 2006 or as the weather permits. 8. Drain. We will review the blueprints to ascertain the presence or absence of a drain. 9. Roof. vVe followed the procedure recommended by our civil engineer and found no leaks. This was the water test followed by visual inspection. 10.Cleaning. We do not know why DEQ is recommending cleaning. Please advise what DEQ is concerned about. DEQ Response December 21 , 2005 Page Three Pump House 1. Bladder Tanks. The remaining 17 tanks are adequate for their use within the system. Please advise why DEQ wants these 3 tanks repaired/rep laced. 2. House Cleaning. All fuels, paints and solvents have been removed. 3. Backflow Prevention Devices. All threaded taps now have backflow prevention devices. 4. Electrical Fan. A fan has been installed. 5. Pump Servicing. Each pump was overhauled in November and we are tracking the number of hours each pump is in use. Disinfection 1. Tap for hypochlorite tank. A backflow prevention device was installed. 2. Operator Protection. We have nlbber gloves and eye protection on site with an eye flush kit within 5 feet of the hypochlorite tank. - 3. Test Kit. vVe have had a Bach DR 2000 testing meter on site since 1990 and this is the primary testing device. The other test kit is carried by the operator for immediate field testing and is not relied on as the primary testing device. 4. Tap. Please advise why a smooth nose monitoring tap is required since the existing tap is working safely. 5. Residual Testing. We do the chlorine residual testing with our regularly scheduled chlorine refill. This occurs every two weeks and has worked safely for years. Distribution System 1. Cross Connection Program. vVe previously were advised by DEQ that the implementation of the program already approved by DEQ could . wait until a new owner was approved and in place. 2. Valves. We turn the valves with each meter install/hook up or as deemed necessary by our contractor or the operator. DEQ Response December 21 , 2005 Page Four 3. Leak Detection Program. We have read the master meter every two weeks. Water loss is determined each quarter with the meter readings. This has been sufficient to determine system water use. 4. (5) Main Flushing. vVe would have to shut down the entire water system to perform annual testing. This would cause problems with our customers and the system. We request procedural help/advice from DEQ on how to do this. 5. (6) Dead End Mains, vVe flush the dead end water mains during our regularly scheduled meter readings. vVe will advise you of our findings and/or completion of the outstanding items from your list. Sinc ~rtJ.BOYle Vice President WAMBEKE ENGINEERING Daniel Wambeke, P. E. 2913 East 6151 Court Spokane, WA 99211 Telephone: 509-443-6186 . Fax: 509-448-6582 . dwambeke (fj?msn.com November 16, 2005 Mr. Raymond A. Hanson HANSON INDUSTRIES, INC. 15807 E. Indiana Avenue Spokane, VVA 99216 SUBJECT: SPIRIT LAKE EAST VVATER STORAGE TANK, SPIRIT LAKE , ID Dear Mr. Hanson: You commissioned me to analyze the reinforcing steel in a portion of a 50' diameter x 14' wall height concrete water tank constructed in the late 1960's in northern Idaho. This tank has a freeboard of 11" below the roof. The hydrostatic pressure at a level 44" below the roof or 33" below the top of the water level is 171.6 PSF. This results in a hoop tension at this level of (50/2) * 171.6 = 4290 Ib./ft. At this elevation, the tank has a 4" thick wall with #2 bars ~ 2 %" o. c. the hoop tension per bar at this level is 893. lb. Assuming that these bars are equivalent to today s ASTM A653 Grade 40, Fy = 000 psi reinforcing bar, the applied tension is 45.5% of the ultimate strength of .the bar. Using ultimate strength design, the factor of safety of 197 exceeds the normal load factor of 1.7 for live loads. In conclusion, the strength of the reinforcing bar at this level in the tank exceeds the applied loads by a reasonable factor of safety. Please feel free to contact me if you have any additional questions about the strength of this water tank at this level. A~ b/Jl DVV:dw Daniel VVambeke, P. E. 'f' , . Designer of Small Structures Po~t Frame Buf!fJiqgs Foyndatlons, Light Gauge Steel Framing and Grain Storage Systems , ... -, ' STATE OF IDAHO BUREAU OF OCCUPATIONAL LICENSES Owyhee Plaza 1109 Main St, Suite 220 Boise, Idaho 83702-5642 (208) 334-3233 FAX (208) 334-3945 Mail ihol'crihol.idaho.!!ov Website www.ihoLidaho.!!ov December 13, 2005 JAMES R KRUGER 227 E GARLAND SPOKANE W A 99207 - --_.....---- -------- ._--- -- -- _.- .-'.---- . RE:Board of Drinking Water and Wastewater Professionals Application Dear Mr. Kruger: Please be advised that the Bureau of Occupational Licenses has received your application for Drinking Water Treatment I licensure. Your application will be processed for the Board's review. The Board of Drinking Water and Wastewater Professionals will review applications at their meeting that is scheduled for January 18, 2006. You will be notified regarding the Board's determination following that review. . 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' ; :Wa t~'L : :::. .;-~~~~ :!/' '; :: 7'-T/' r" STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY ------- 2110 Ironwood Parkway' Coeur d'Alene, Idaho 83814-2648' (208) 769.1422 Dirk Kempthorne, Governor Toni Hardesty, Director December 28 , 2005 Robert J. Boyle, Vice President Hanson Industries Inc 15807 E Indiana Spokane WA 99216 RE: Spirit Lake East Water Company Plan of Correction Review Dear Mr. Boyle: Thank you for your letter of December 21 , 2005 in response to our survey report of November 5 , 2005. It is our assumption that this letter was intended to serve as the . required Plan of Correction for the survey deficiencies. We will respond in the order of our survey letter. Administration The operator did not possess a "Distribution 1" certification from the Idaho Bureau of Occupational Licenses. The operator, Mr. Jim Kreuger, is required to have a certification for "Distribution 1" This is different than "Treatment 1" ,gnd why we specifically mentioned "Distribution 1" in our November 5th, 2005 letter. A Total Coliform Monitoring Plan was not on file with DEQ, A Total Coliform Monitoring Plan is simply a map or document that lists where the monthly water samples will be taken on an annual basis. There should be a minimum of 6 different sites located at different points throughout the distribution system that are sampled sequentially. Well A smooth nosed sample tap is required on the discharge to the well. The existing sample tap was a plastic tube clamped to a galvanized pipe. Spirit lake East Water Company Plan of Correction Review December 28, 2005 Page 2 A smooth nosed sample tap is required on the discharge of the well and at any point within the pump house where water samples are to be taken. A Teflon tube is not adequate. The well could not be pumped to waste prior to the first service connection. We reexamined the pictures taken during the survey and could not identify a "pump to waste." This isa pipe that is capable of handling the entire discharge of the well located at some point prior to the entry to the distribution system. We identified a couple of points in the pump house that could be easily adapted to allow the well to pump to waste but there is a difference between have the potential to pump to waste and the actual ability to accomplish the activity on demand. You still need to construct the pump to waste valving and piping. There is no well log on file with DEO. We received and filed the well log that you sent. This item is satisfied. The vent screen on the well was connected with duct tape. It must permanently clamped with a steel clamp. The steel clamp on the vent screen will meet our requirements. The flow meter should be read on at least a weekly basis. Reading the flow meter with the chlorine tank refill will be considered adequate at this time. Reservoir The repairs to the cold joint on the side of the reservoir appeared to extend more than half of the way through the concrete. The impacts of removing this amount of concrete on the strength of the reservoir side walls are unknown. An evaluation performed by a professional engineer must be prepared that will certify that the tank will not fail. We accept the certification of the reservoir wall strength by Mr. Wambeke P . The reservoir cannot be isolated from the water system without depressurization of the distribution system. It appears that the piping that would allow the reservoir to be bypassed has been removed. You may have misunderstood the requirement that the water system must have the ability to isolate the reservoir from the water system without depressurizing the Spirit Lake East Water Company Plan of Correction Review December 28 2005 Page 3 distribution system. You must be able to isolate the reservoir for maintenance and repairs while at the same time pressurizing the distribution system with the well pump. It appears that the valving and piping to do this was in place at some point in the past but it was removed. This capability must be restored. The leaks in the reservoir wall had not been completely repaired at the time of inspection. Please arrange for a joint inspection of the reservoir wall leak repair. The reservoir must be completely full at the time of inspection. There did not appear to be a sill at the reservoir discharge to prevent sediments from flowing into the booster station. Prior surveys have identified a problem with pumping sand from the well. This survey deficiency has not been adequately addressed. The two overflows from the reservoir were not 24 mesh screens or a weighted flapper valve with expanded metal screens. The overflow was only protected by a screen with %-inch openings. This could allow insects and small rodents to access the reservoir. This deficiency appears to have been satisfied. The overflows were not 12 to 24 inches above the ground surface. This deficiency appears to have been satisfied. The overflows do not discharge onto a splash plate. This deficiency does not appear to have been satisfied. A Plan of Correction requires a specific date for repair to occur. The reservoir did not appear to have a drain. We did not notice a drain for the reservoir at the time of inspection. It would have been very evident. You may wish to add a valve after the larger booster pump in the vault with a constructed discharge to the surface to meet this requirement. The pump could then be used to drain the reservoir. This deficiency does not appear to have been satisfied at this time. Water was impounded on the roof of the reservoir. A registered professional engineer must certify that the current roof is not leaking. ~.. Spirit Lake East Water Company Plan of Correction Review December 28, 2005 Page 4 We did not find that your engineer, Mr. Wambeke, had certified that the roof was not leaking. This deficiency does not appear to have been satisfied at this time. 10.The reservoir needs cleaning. The inspection on November 5th revealed deposits of sediment on the floor of the reservoir. Historic survey reports and notes in DEQ files indicate that the well produces sand and sediments. Sediment deposits in reservoirs are unsanitary in that they provide harborage for bacteria arid shelter from chlorination for these bacteria. This deficiency does not appear to have been satisfied at this time. Pump House Three of the bladder tanks appeared to be waterlogged and in need replacement. If you feel that 17 bladder tanks will serve 250 or more residences please have your engineer certify this design modification. Maintenance of the bladder tanks is a routine item and , unless otherwise specified , you must maintain the physical facilities. This deficiency does not appear to have been satisfied at this time. The well house needs cleaning and organization. All fuels, paints and solvents must be removed from the pump house. This deficiency appears to have been remedied. All threaded taps in the pump house must have backflow prevention devices. This deficiency appears to have , ~, een remedied. ,;;" An electrical fan for fresh air ventilation must be installed in the pump house. This deficiency appears to have be~n remedied. Routine maintenance schedules should be established for servicing the pumps. This deficiency appears to have been remedied. Disinfection The tap used to fill the hypochlorite tank was not protected by a backflow prevention device. This deficiency appears to have been remedied. Spirit Lake East Water Company Plan of Correction Review December 28, 2005 Page 5 Rubber gloves and eye protection should be provided to the operator for use during the hypochlorite tank filling. This deficiency appears to have been remedied. The chlorine test kit used by the water system was inadequate for measuring chlorine in the drinking water. It was designed to be used in swimming pool applications. The chorine test kit that we observed was only adequate for measuring chlorine levels in swimming pools. We will check the primary kit when the reservoir is inspected. A smooth nosed monitoring tap is required after chlorine injection. A smooth nosed monitoring tap is required before and after disinfection. We did not notice a monitoring tap after the chlorine injection point on the discharge of the well. This deficiency does not appear to have been satisfied at this time. Free chlorine residuals should be measure daily. Idaho s Rules for Public Drinking Water Systems require that free chlorine residuals be measured and recorded daily. The residual must also be recorded on the form that is submitted to the lab with the monthly Coliform test. This is necessary to insure that the chlorination equipment is working properly. This monitoring could be done at the tap of one of the residents of the water system. This deficiency does not appear to have been satisfied at this time. Distribution System A cross connection control program must be implemented. The water system was found to be deficient in the requirement for a cross connection control program in the survey of the year 2000 and the item was not remedied. It was again found to be deficient in the survey of 2005. A buyer has not been identified , nor a time frame for change of ownership defined. This deficiency does not appear to have been satisfied at this time. The valves in the distribution system should be exercised at least two times per year. There appeared to be a misunderstanding about this item. The valves that should be exercised are the ones located in the street that can be used to isolate different segments of the distribution mains for maintenance and repair activity. This does not include the valve for the individual service connections. Spirit lake East Water Company Plan of Correction Review December 28, 2005 Page 6 A leak detection program must be implemented. The flow meter should be read frequently and compared to the meter readings to determine if water loss is less than 15%. Water loss in the distribution system must be less than 15%. A comparison of the master meter and the collective usage at the individual home owners' meters is one way of determining loss. If the water loss is less than 15% this deficiency has been satisfied. The response did not indicate what the percentage of water loss was. The water mains should be flushed annually. The water system should not be shut down to be flushed. Water velocities of 2.5 feet per second in water mains are recommended to re-suspend sediments and discharge them to the surface. This is done using flushing hydrants. This deficiency does not appear to have been satisfied at this time. The dead end water mains must be flushed two times per year. This deficiency appears to have been remedied. We hope that this response has been useful in clearing up confusion in the preparation of the Plan 'of Correction. Would you please modify your responses to attain compliance with Idaho rules for Public Drinking Water Systems? We will grant an extension for you to prepare an adequate plan of correction until January 15 , 2006. If you have any questions, please contact me at DEQ. Ironwood Parkway; phone , (208) 769-1422. We are located at 2110 Sincerely, z!i :22-- Anthony P. Davis Analyst Steve Tanner Gary Gaffney, DEQ/CDA Idaho Public Utilities Commission. John Hammond - -~..\! ! HANSON HANSON INDUSTRIES, INC.15807 East Indiana Avenue, Spokane. WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin(ij)hansonind.com January 13 2006 Anthony P. Davis Department of Environmental Quality State ofIdaho 2110 Ironwood Parkway Coeurd' Alene, ID 83814-2648 Re: Spirit Lake East Water Company Dear Mr. Davis: Please find our responses to DEQ's comments dated December 28, 2005 to our Plan of Correction. \Ve respond in the order of the survey letter. Administration 1. Mary Miles at the Idaho Bureau of Occupational Licensees assured Mr. Kruger that the license hearing on January 18 is for a Distribution 1 license. The letter dated December 13 was in eITor. 2. The Total Coliform Monitoring Plan will be provided on or before February 3. Well 1. A smooth noses sample tap is in place and operational. 2. The pump to waste piping is scheduled to be in place and operational on or before February 3, depending on the availability of parts. - ' Reservoir 2. The piping to allow the reservoir to be bypassed will be in place and operational or before February 3 , depending on the availability of parts. 3. DEQ can inspect the reservoir repairs with the generator. They are complete. 4. Examination of the as built blueprints shows a 1 112inch sill at the discharge point. 7. A splash plate is in place and operational. 8. Upon examination, the reservoir does have a 6" drain. 9. \Ve asked our engineer to certify the roof. He replied that we had tested the roof per his recommendation and it did not leak nor does it now. He said he could not certify the roof will never leak nor would any another P.E. DEQ may inspect the roof again with us since the engineer said his profession would not do so. 10. The reservoir floor will be cleaned of sediments on or before February 3. Pump House 1. The bladder tanks will be in place and operational on or before February 3 depending on the availability of parts. ~.. Disinfection 4. The smooth nosed monitoring tap will be installed with the new piping on the reservoir bypass on or before February 3. 5. The free chlorine residuals program is currently in place. Distribution System 1. DEQ is aware of the Home Owner Association interest in potentially acquiring the system due to DEQ's active involvement with it. Is DEQ requiring us to implement the Cross Connection program now without further exploring the sale/purchase to the homeowners? If so, does the DEQ mandate the installation of backflow preventers at the customer s expense if the customer refuses to install one as per the program? We are requesting DEQ's help in implementing the program as we may encounter resistance from the customers but probably not so with DEQ's assistance from its mandate. 2. Our contractor does exercise the valves as well as the valves for the individual service connections. 3. vVe are currently gathering the data to detennine our water loss. 5. The water mains are flushed annually using the blowoffvalves throughout the system, not just the dead end main. We misunderstood the question. Your comments were very helpful in understanding and then addressing DEQ' requirements to resolve the issues. Thank you. - - Sincerely, 1tJ!f ~ - - NsON 15807 Easl Indiana Avenue. Spokane.WA 99216 (509) 922.5252' Fax (509) 922.5757 E-mail: admin~hansonind.com January 16 2005 Gary J. Gaffney Department of Environmental Quality State of Idaho 2110. Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Gaffney: We request re-instatement to an Approved status following the satisfactory completion of the issues raised in theDEQ correspondence of September 20 , 2005 and subsequent communication during the resolution of the nine deficiencies giving rise to the disapproval. The last item completed was the installation and testing of the standby generator in January 2006. Sincerely,~J~Robert J. Boyle -- Vice President .. " STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY Dirk Kempthorne, Governor Toni Hardesty. Director2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814.2648. (208) 769-1422 January 24 , 2006 Robert J. Boyle Vice President of Hanson Industries, Inc. Spirit Lake East Water Company 15807 E Indiana Ave Spokane, WA 99216-1864 RE:Spirit Lake East Water System Improvements Dear Mr. Boyle: This letter is in response to your letter to Gary Gaffney of January 16 , 2005 in which you requested reapproval of the Spirit Lake East Water System. Although progress had been made in addressing many of the deficiencies, others that are significant remain unaddressed. We therefore cannot approve of the water system. The evaluation of the water system actions as they pertain to Idaho s Rules for Public Drinkinq Water Systems is as follows: The disapproval of the Spirit Lake East water system was based on the unacceptable response to 9 items listed for you by Gary Gaffney in a letter of April 22, 2005. They were: 1. Repair of leaks in the wall of the reservoir. 2. Repair of reservoir roof.3. Installation of a standby generator to provide power to the water system pumps during power failures.4. Installation of an auto-dialer to notify the operator when problems occurred at the water system facilities. 5. Purchase of a replacement pump for the well to minimize the length of time that the water system would be out of water should equipment fail. 6. Initiating a cross-connection control program.7. Initiating of a wellhead protection program. .8. Installation of an exterior vent from the chlorine solution tank. 9. Repair of the water flow meter on the well discharge line. Our analysis of Hanson Industries remediation of these problems is as follows: Item #1: The repair of the leaks in the wall of the reservoir must be observed by DEO staff. To be acceptable there cannot be any leakage evident when the tank if completely full. If there is no leakage then we will considered this item to be remedied. When the reservoir was observed during an inspection on November 3 the tank was still leaking. Item #2: The repair of the tank roof has been deemed to be inadequately addressed. Applying a patch to a 30 year old roof and not addressing the issue of water ponding and the associated freezing and thawing is just simply not adequate. A new roof, preferably a poured concrete cap, which provides for RE: Spirit Lake East 'Vater System Improvements January 24, 2005 Page 2 drainage of precipitation is needed. You could not provide certification from a professional engineer that the current roof was adequate and would not leak. Item #3: The installation of a standby generator is for the most part complete. A problem with the relays between the booster pumps and the generator, however, was demonstrated recently when the water system depressurized due to a failure of one phase of the three phase power to the booster pumps. A ,, partial phase failure caused the booster pumps to shut down. Unfortunately, the sensors on the generator ~oYX:: were not of a type that would activate the standby power in the event of a partial power failure. You need to either reconfigure the existing relays or purchase new ones that will address this problem; When the booster pumps shut down due to a power failure they must be reactivated immediately by the generator. Item #4: The installation of an auto dialer is essentially complete. We are unclear, however, if the system worked during the last power failure. The calls that alerted the water system operator to the failure oit- ( apparently came from the customers. Did the auto dialer have the same problem in that it did not \)0 acknowledge the partial power failure? Item #5: The purchase of the replacement pump for the well has been satisfied. Item #6: The initiation of the cross connection control program has not occurred. We are puzzled by your statement that this would be something that a subsequent owner would do. Is it possible that you are confusing this with the initiation of a Well Head Protection program? We agreed that the Well Head Protection Program item was not mandatory at this time. The lack of a Cross Connection Control Program however, cannot be waived. This deficiency was noted over ten years ago. Item #7: The initiation of a Well Head Protection Program has been waived. Item #8: The installation of an external vent for the hypochlorite solution tank has been satisfactorily completed. Item #9: The repair of the flow meter on the well discharge line has been satisfactorily completed. An inspection (survey) of the water system was conducted in early November to determine if the water system had satisfactorily completed the actions necessary for re-approval. Originally this survey was going to check the nine items listed above but in the course of the inspection additional problems were noted. We requested a Plan of Correction for these items within 45 days of the receipt of notification that you had received the, results of that survey. The problems that we noted and our judgment of the corrective actions or Plan of Correction proposals are as follow: Administration1. The operator did not possess a "Distribution 1" certification from the Idaho Bureau of Occupational Licenses. The Plan of Correction for this deficiency was to have Mr. Krueger attain a Distribution System 1 Certification. This is acceptable. RE: Spirit Lake East 'Vater System Improvements January 24, 2005 Page 3 Well A Total Coliform Monitoring Plan was not on file with DEQ. The Plan of Correction for this,/,;!/ deficiency was to develop a Coliform monitoring plan by February 3, 2006. This is acceptable. r;r- A smooth nosed sample tap is required on the discharge to the well. The existing sample tap was a plastic tube clamped to a galvanized pipe. The Plan of Correction for this deficiency was to install a smooth nosed sampling tap. This is acceptable. The well could not be pumped to waste prior to the first service connection. The Plan of Correction for this deficiency was to install a pump to waste by February 3, 2006. This is acceptable. There is no well log on file with DEQ. You provided a well log for the well. This is acceptable. . The vent screen on the well was connected with duct tape. It must be permanently clamped with a steel clamp. The Plan of Correction for this deficiency was to install an adequate screen. This acceptable. The flow meter should be read on at least a weekly basis. The Plan of Correction for this deficiency was to read the flow meter weekly. This is acceptable. Reservoir1. The repairs to the cold joint on the side of the reservoir appeared to extend more than half of the way through the concrete. The impacts of removing this amount of concrete on the strength of the reservoir side walls are unknown. An evaluation performed by a professional engineer must be prepared that will certify that the tank will not fail. The Plan of Correction for this deficiency was to have a Professional Engineer certify the strength of the reservoir wall. This is acceptable. The reservoir cannot be isolated from the water system without depressurization of the distribution system. It appears that the piping that would allow the reservoir to be bypassed has been removed. The Plan of Correction for this deficiency was to have plumbing that would allow the well to be pumped directly to the distribution system installed by February 3 , 2006. This is acceptable. The leaks in the reservoir wall had not been completely repaired at the time of inspection. DEQ will reinspect the reservoir wall as noted in the first part of this letter. There did not appear to be a sill at the reservoir discharge to prevent sediments from flowing into the booster station. Prior surveys have identified a problem with pumping sand from the well. The Plan of Correction for this deficiency was to check the as built plans. They showed a 1 ~-inch sill. The actual existence of a sill at the reservoir discharge can be determined when the reservoir is cleaned. The two overflows from the reservoir were not 24 mesh screens or a weighted flapper valve with expanded metal screens. The overflow was only protected by a screen with Yz-inch openings. This could allow insects and small rodents to access the reservoir. The Plan of Correction for this deficiency was to install adequate screens. This is acceptable. The overflows were not 12 to 24 inches above the ground surface. The Plan of Correction for this deficiency was to clean the brush and overgrowth away from the overflow pipes and create a 12- inch free fall. This is acceptable. The reservoir overflows do not discharge onto a splash plate. The Plan of Correction for this deficiency was to construct a splash plate. This is acceptable. The reservoir did not appear to have a drain. The Plan of Correction for this deficiency was to identify a drain. Although it was not apparent to DEQ at the time of inspection if one does exist , if it does, this deficiency has been satisfied. RE: Spirit Lake East 'Vater System Improvements January 24 2005 Page 4 Pump House1. Three of the bladder tanks appeared to be waterlogged and are in need of replacement:' The Plan of ,.: Correction for this deficiency was to replace the three tanks that had failed by February 3, 2006. This IS acceptable. The well house needs cleaning and organization. All fuels, paints and solvents must be removed from the pump house. The Plan of Correction for this deficiency was to remove the offending items. This is acceptable. All threaded taps in the pump house must have backflow prevention devices. The Plan of Correction for this deficiency was to place atmospheric vacuum breakers on all of the threaded taps. This is acceptable. An electrical fan for fresh air ventilation must be installed in the pump house. The Plan of Correction for this deficiency was to install a fresh air ventilation fan. This is acceptable. Routine maintenance schedules should be established for servicing the pumps. The Plan of Correction for this deficiency was to establish routine maintenance schedules. This is acceptable. 10. Water was impounded on the roof of the reservoir. A registered professional engineer must certify that the current roof is not leaking. No plan of correction was offered for this deficiency. A registered professional engineer refused to certify that the roof was not leaking. The reservoir needs cleaning. The Plan of Correction for this deficiency was to clean the reservoir by February 3, 2006. This is acceptable. Disinfection1. The tap used to fill the hypochlorite tank was not protected by a backflow prevention device. The Plan of Correction for this deficiency was to install an atmospheric vacuum beaker on the tap used to fill the chlorine solution tank. This is acceptable. Rubber gloves and eye protection should be provided to the operator for use during the hypochlorite tank filling. The Plan of Correction for this deficiency was to place eye washing facilities , protective glasses and gloves in the pump house. This is acceptable. The chlorine test kit used by the water system was inadequate for measuring chlorine in the drinking water. It was designed to be used in swimming pool applications. We will check the test kit during the next inspection. A smooth nosed monitoring tap is required after chlorine injection, The Plan of Correction for this c) deficiency was to install a smooth nosed monitoring tap by February 3, 2006. This is acceptable. 0-' Free chlorine residuals should be measure daily. The Plan of Correction for this deficiency was to check the free chlorine residual on a daily basis. This is acceptable. Distribution System1. A cross connection control program must be implemented. This item has not been addressed and remains a deficiency. The valves in the distribution system should be exercised at least two times per year. The Plan of Correction for this deficiency was to exercise the valve in the distribution system two times per year. A leak detection program must be implemented. The flow meter should be read frequently and compared to the meter readings to determine if water loss is less than 15%. The Plan of Correction for this deficiency was to implement a procedure for checking on water loss. This is acceptable. ~.. RE: Spirit Lake East 'Vater System Improvements January 24, 2005 Page 5 The water mains should be flushed annually. The Plan of Correction for this deficiency was to implement a water main flushing programs. This is acceptable. The dead end water mains must be flushed two times per year. The Plan of Correction for this deficiency was to implement a dead end main flushing program. This is acceptable. Hopefully this summary of where the Spirit Lake East water system stands with regard to both Gary Gaffney s disapproval letter and the subsequent survey and related deficiencies will assist ydu understanding what needs to be done to allow the Spirit Lake East Water System attain an approved status. If you would like to request a reinspection after February 3 , 2006 please notify either myself or Mr. Stephen Tanner, the Drinking Water Supervisor for the Coeur d'Alene Regional Office. We will schedule one at the earliest possible time. If you have any questions , comments or suggestions, please do not hesitate to contact us at DEQ at 2110 Ironwood Parkway in Coeur d'Alene; phone (208) 769-1422. Sincerely, Steve Tanner & Gary Gaffney, DEQ, CdA Terry Stulz, Trindera Engineering, 1859 Lakewood Dr, Ste 103, CdA 83814 John Hammond, Jr., Batt & Fisher LLP, PO Box 1308, Boise, 1083701 Harry Hall, IPUC, P.O. Box 83720, Boise, 1083720-0074 John Balbi, 31772 N Kelso Dr, Spirit Lake, 1083869 Survey File 15807EastlndianaAvenue Spokane WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin(g)hansonind.com February 2006 Anthony P. Davis Department of Environmental Quality State ofIdaho 2110 Ironwood Parkway Coeur d' Alene , ID 83814 RE: Spirit Lake East Water Company Dear Mr. Davis: vVe wanted to advise re: our progress based on your last letter dated January 24 2006. Items leading to the Disapproval status: 1. Reservoir wall leak: the leak has been repaired. The tank level will be raised to its full capacity. DEQ can inspect this item during the future inspection. 2. Reservoir Roof: the roof does not leak; as a result, we are reviewing the options to satisfy DEQ. 3. Standby Generator: the relay has been ordered and will be shipped within two weeks from the United Kingdom. Once received, it will be installed, tested and then inspected during DEQ's on-site review. 4. Auto Dialer: the installation is complete , including its operation during a low level power failure (i.e. dropping one leg of a three phase power supply).5. Satisfied. 6. Cross Connection Program: the DEQ mandated and approved Program was mailed to all customers the week of February 13th. A copy of the cover letter and survey postcard are enclosed. 7. Satisfied due to waiver. 8. Satisfied. 9. Satisfied. An on-site inspection will be scheduled with DEQ for items I , 2 , 3 Items from the Sanitary Survey and Plan of Correction: Administration 2. Total Coliform Monitoring Plan: it is enclosed. Anthony Davis February 16 2006 Page Two Well 2. The work is completed for the well to pump to waste prior to the first connection. Reservoir 2. The work is completed for isolation of the reservoir from the water system. Pump House 1. The work is completed re: the installation of new bladder tanks. Disinfection 4. The work is completed re: the installation of smooth nosed monitoring tap. Distribution System 1. The work is completed as the Cross Connection Program has been implemented. We will keep you advised of our progress. We will contact you in the near future to schedule the on-site inspection. Robert 1. Boyle Vice President SPIRIT LAKE EAST WATER COMPANY PWS #1280176 TOTAL COLIFORM MONITORING PLAN Site #1 3600 W. Liberty Dr.lot 17 Site #2 31116 Hayden Dr.lot 64 Site #3 33588 Kelso Dr.lot 111 Site #4 35514 Kelso Dr.lot 233 Site #5 163 Eagle Dr.lot 3- Site #6 13799 Coeur D Alene Dr.lot 184 'j"; Colifonn Monitoring Plan.docI124/20062:02:16 PM . I CROSS CONNECTION CONTROL PROGRAM - '- - Spirit Lake East Water Company . 15807 East Indiana Avenue Spokane Valley, Washington 99216-1864 509-922-5252 July 15 , 2005 ,. . , ~. . INTRODUCTION SLEWC ("Water Company ) is committed to providing you with safe drinking water. A Cross Connection Control Program is designed to prevent the contamination of your public water system from outside sources. We accomplish this goal by implementing a program aimed at identifying health hazards and eliminating potentially hazardous cross connections found in any water using entity which is also connected to your drinking water. Protection safeguards will be required regulating the installation, testing and maintenance of cross connections, which could allow the back flow of non- potable fluids into the public water supply. This program is called your Cross Connection Control Program. - ' WHAT CAUSES A BLACKFLOW HAZARD? Where potential cross connections exist, protection against backflow is needed to eliminate the possibility of contamination. The causes of back flow cannot usually be eliminated completely since backflow is often initiated by accidents or unexpected circumstances. However, some causes of back flow can be partially controlled by good design and informed maintenance. Listed below are the major causes of back flow as outlined under two types of backflow - backsiphonage and backpressure. BACKSIPHONAGE Backsiphonage is caused by reduced or negative pressure being created in the supply piping. A major cause of back siphonage is the interruption of the supply pressure. This will allow negative pressures to be created by water trying to flow to a lower point in the system. Another cause is undersized piping. If water is withdrawn from a pipe at a very high velocity, the pressure in the pipe is reduced and pressure differential created can cause water to flow into the pipe from a contaminated source. The potable water supply can thus become contaminated due to backsiphonage of contaminants creating potential health proble1J1s. - - The principal causes of back siphonage are: 1. Line repair or break, which is lower than a service point. 2. Undersized piping. 3. Lowered pressure in the water main due to a high water withdrawal rate such as fire fighting, water main flushing or water main breaks. 4. Reduced supply main pressure on the suction side of a booster pump. BACKPRESSURE Backpressure may cause backflow to occur where a potable water system is connected to a nonpotable system and the pressure in the nonpQtable system exceeds that in the potable water system. Where high pressures may be created by means of pumps, boilers, etc., there is high risk of nonpotable fluid being forced into the potable water sys~em whenever these types of cross connections are not properly protected. ' .- . CUSTOMER SERVICE Upon application for water service, the Water Company will obtain information in order to screen each new and existing account for potential hazard(s) in accordance with this policy. For new water service or continued existing water service, compliance with requirements pursuant to this policy must be achieved or the agreement for service contract will be tenninated. FREQUENCY Due to changes in models or components of equipment, methods of manufacturing, and additions to plants, buildings, etc., water use requirements undergo continual change. As a result, new cross connections may be installed and existing protection may be bypassed, removed, or otherwise ineffective; therefore, a detailed inspection of all water usage is required periodically. AUTHORITY FOR INSPECTION - ' Authorized employees or agents (such as contractors) of the Water Company shall be pennitted to enter upon all properties for the purpose of sampling and testing of the water, or make inspections and observations of the connections to the public water supply system. Any such person shall provide proper identifying credentials during such inspections. ANNUAL INSPECTIONS Once your backflow prevention assembly is installed, it will be necessary to annually test and maintain the unit to make sure it is functioning properly. The maximum allowable time between your scheduled backflow inspections is one year. It is the property owner s responsibility to make sure an inspection is set up with a State Certified Cross-Connection Technician and that the Water Company receives a copy of the passed backflow device report prior to the one-year maximum. The Water Company will send out a reminder prior to the one-year inspection due date. WHAT ARE THE NEW POLICIES NOW? PURPOSE~ RESTRICTIONS It is the policy of the Water Company that no cross connections are allowed between the Water Company s potable water supply and any other system containing water or any other substance which may be capable of imparting contamination or pollution which would change the quality of water conveyed by the Water Company s system. To enforce this policy and to protect the public water supply system from pollution or contamination, or other quality change due to Cross Connection, the follow,ing restrictions apply: A. No installation of potable water supply piping or part thereof shall be made in such a manner at any premises so as to violate plumbing code whereby a public water supply is connected directly or indirectly with any other water supply system, sewer, drain, conduit, pool, storage reservoir plumbing fixture or other device which contains or may contain contaminated water, sewage or other waste or gas , liquid, or solid which may be capable of imparting contamination to the public water as the result of back flow. B. No person shall make or allow a connection to exist at any premises between pipes or conduits carrying potable water supplied by the Water Company or private water service system and any pipes , conduits or fixtures containing or carrying liquids, gas or other substances from any other source. C. No plumbing fixture, appliance, water using apparatus or device or construction shall be installed or maintained or shall be connected to any public or private potable water supply, when such installation or connection may provide a possibility of polluting such water supply or may provide a cross connection between a distribution 'system potable water used for drinking and other domestic purposes and water which may become contaminated by such plumbing fixture appliance, device or construction. D. No water service piping supplied by any auxiliary water supply source (ie. well, cistern, swimming pool, etc.) or industrial process water piping system owned by any person shall be connected to the public potable water system owned and operated by the Water Company. ,. , valve, or reduced pressure zone (RPZ)) required based on type of hazard and meter size. The Schlumberger T -10 meter/backflow assemblies (combined meter and double check valve backflow preventer) for 5/8" meter size where low potential hazard exists and the SensusIRockwell meter with downstream dual check valve where no potential hazard exists shall be installed in accordance with the Water Company s specifications and manufacturer recommendations. The double check valve assembly for 1" and larger meter size requiring low hazard protection and reduced pressure zone backflow assembly requiring high hazard protection shall be installed by a certified plumber in accordance with the Water Company s specifications and manufacturer recommendations, at the customer s expense. For all backflow pre venter installations , the Water Company s specifications shall supersede manufacturer s recommendations. B. The Schlumberger T-I0 meter/backflow assembly and the SensusIRockwell meter with downstream dual check valve shall be installed by the Water Company at the customer s expense for new water service. The Schlumberger T -10 meter/backf!9w assembly and the SensuslRockwell meter with down$tream dual check valve shall be installed through the Water Company s meter change-out program for existing water service. The Schlumberger T -10 meter assembly and SensusIRockwell meter with downstream dual check valve shall be owned, tested, maintained, repaired and replaced as needed by the Water Company. C. The RPZ and DCV A backflow preventers installed downstream of meter or meter/backflow assembly shall be owned, tested, maintained repaired and replaced, as needed, at the customer s expense. The backflow preventer installed on fire protection system shall be owned, installed, tested maintained and repaired, as needed, by a certified fire protection system contractor at the customer s expense. The following information shall be forwarded to the Water Company by the customer or the installer and maintained by the Water Company within ten (10) days after the installation of all reduced pressure zone backflow preventers (RPZ), double check valve assemblie~- (~CV A): The inspections and tests on RPZ and DCV A installed downstream of the meter or meter assembly or on fire protection systems shall be at the expense of the customer and be performed by a certified backflow prevention assembly technician, as directed by the Water Company. The inspections and tests on Schlumbeger T -10 meter/backflow assembly and SensuslRockwe11 meter with downstream dual check valve shall be performed by the Water Company. The Water Company, certified backflow tester or certified fire sprinkler contractor will notify the ctm'temer prior to water service being shut-off to perform testing. For those customers responsible for the testing of the backflow prevention assembly installed downstream of meter or meter assembly or on separate fireline systems, the Water Company will notify the customer thirty (30) days in advance of when the test is required and furnish the customer with the necessary test forms(s) and instructions. The test formes) will be completed by a certified backflow tester or certified fire sprinkler contractor (for fire protection systems) and returned to the Water Company no later than theJi1ast month specified on the test form and maintained by the Water Company. ;~; REP AIR OR REPLACEMENT OF BACKFLOW PREVENTIONASSEMBLIES - All repairs to RPZ and DCV A backflow prevention assemblies installed downstream of trre meter or meter assembly shall be conducted by a certified plumber/certified backflow prevention assembly technician, or other persons approved by the Water Company to make such repairs. All repairs backflow prevention assemblies installed on separate fireline systems shall be performed by a certified fire sprinkler contractor at the customer s expense. All repairs to Schlumberger T 10 meter/backflow assembly and SensuslRockwetf'with downstream dual check valve shall be performed by the Water Company. The Water Company shall be notified of any repair which can not be performed immediately. The repair of the malfunctioning backflow preventer shall be made within 10 days of discovery or test. ',"",,_. . The replacement of the dual check, Schlumberger T -10 meter/backflow assembly shall be performed by the Water Company. The RPZ and DCV A installed downstream of the meter or meter assembly shall be replaced, as needed, by a certified plumber at the customer s expense. ENFORCEMENT The Water Company shall endeavor to assure compliance with the requirements of this policy by conference and persuasion. If such efforts over a reasonable period of time, are futile, the Water Company shall take formal action. In any case involving a person who has failed to comply with any provisions of these regulations the procedures shall be as follows: a) The Water Company or authorized representative shall give notices to such person by mail stating the specifics of the failure of compliance and requiring that the person remedy the failure by a specified date. b) If, by the specified date, such person has not remedied the failure the Water Company may cause the water from the public system be discontinued for such person. c) In any case where water service is discontinued for enforcement. purposes, the restoration of such service shall be conditioned on full ~ompliance and payment by such person of any expense incuITed in - - - the enforcement proceeding and in the restoration of service. CROSS CONNFCTION CONTROl MANtlAI StiPP! FMFNT PNWS AWWA t ..". ..........." Date....... ...." ...... t ................. Name ................. t .............,. Address................ 1 t .................. City ................... RE: CROSS CONNECTION CONTROL FOR: The State Board of Health has established rules and regulations pertaining to cross- connection control in public water systems. For the purpose of protecting the health of consumers receiving water from the public water supply system, these rules and regulations have been adopted by this utility in the fonnof a resolution. cross-connection according to the Board of Health means any physical arrangement whereby a public water supply is connected, directly or indirectly, with any plumbing fixture, or other device which contains or may contain contaminated water, sewage, or other waste or liquid of known or unsafe quality which may be capable of imparting contamination to the public water supply as a result of back flow. The tenns backflow means an unwanted flow of non-potable water, used water industrial fluids or other substances from domestic, industrial or institutional piping system into a pure or potable water system. Backflow Prevention AssemblylDevice is a mechanical device to counteract back-pressure or to prevent back siphonage. These mechanical devices will be installed where actual and/or potential cross-connections cannot be eliminated or so designated by the secretary or the water purveyor. These devices will be installed in accordance with State regulations at the customer s expense. These devices must be listed on the "current" list of "Approved Cross- connection Control Assemblies" issued by the State. Insomuch as the State Board of Health holds the water purveyor primarily responsible for preventing contamination of the public water supply, the Board of Directors of this utility may establish requirements for cross-connection control within this utility s service area more stringent than said State regulations, if they detennine that conditions so dictate. After reviewing the mechanical plan of the project in question, we have found some fixtures that are actual or potential cross-connections. Some of these have backflow protection already built into the fixture. If the backflow protection meets State regulations and/or the utility Resolution, no further protection on that particular fixture is needed. Sample Letters and Record F~rn:s (First Edition) CROSS CONNFCTION CONTROl MANUAl StlPPI FME:NT PNWS AWWA Cross-connection Control for: Page: 3 In some cases, an inspection by us will be made when the "roughed in" plumbing is completed. This will be done to locate any internally plumbed cross-connections that may have been missed or added since the mechanical plan was reviewed by us. If any new cross- connections are discovered, we will notify the owner, general contractor, and plumbing contractor as to our fmdings. Inspection of the listed cross-connections and the devices or methods used for preventing or eliminating these cross-connections, along with any other actual or potential cross- connections will be made when construction is completed. The devices that will require annual testing will also be tested at this time. The results of this inspection and testing will be sent to the owner, with copies going to the general contractor, plumbing contractor, and in some cases to a designated representative of the State Health Department. The following list summarizes some of the cross-connections that are generally found this type of project. Some of these mayor may not exist in your proposed project. If you anticipate that any of these cross-connections will exist, you are responsible to see that the following recommended devices or methods are used to prevent or eliminate these cross- connections: Hose Bibs Non-frost free AVB, WATTS#8A WATTS #NF8 , Woodford Series 15 or similar device Frost free Lawn Sprinkler System A VB , PVBA or DCV A AVB, WATTS #8 orMop service or slop sinks with hose fittings similar device Compounded boilers and cooling towers AG or RPBA Pump primers Flushing floor drains AGorAVB Potable water lines directly connected to sewer lines Sample Letters and Record Forr:n~. (First Edition) PNWS-AWWA CROSS CONNFCTION CONTROl MANtIA! StlPPI FMFNT ( .................. Date................... ~ ( ................. Name ................. ( ............... Address................ ( .................. City ................... Re: Cross-Connection Control for Lawn Irrigation Systems.The Water Department is engaged in a program of locating cross-connections between public water supply and possible and possible sources of contamination. The control of cross- connection is accomplished by two basic methods: (1) Inspection and regulation of plumbing or piping systems within the premises; (2) Installation of approved backflow prevention assemblies on water service lines to premises where hazardous cross-connections exist or are likely to occur. The program implements both of these methods. The Rules and Regulations of the State Board of Health require that certain premises install backflow prevention assemblies on the water supply piping as a condition of water service (WAC 246-290-490). Backflow prevention assemblies shall be installed within any premises where in the judgement of the .Water Department the nature of the activities on the premises or the materials used or stored on the premises present a hazard should a cross-connection exist.The Water Department require proper installation of a Washington State-approved backflow prevention assembly (BFP) on water supply piping which meet the following conditions: - - Atmospheric Vacuum Breaker (A VB) may be used on a single zone irrigation system must be installed 6 inches above highest fixture, no shutoff valves allowe~, downstream must pe inspected by the Water Department, but does not require annual testing. Pressure Vacuum Breaker Assembly (PVBA) may be used on multi zone irrigation system, must be installed 12 inches above highest fixture, shutoff valves are allowed downstream, assembly must be tested by the Water Department when initially installed and requires annual testing. Double Check Valve Assembly (DCV A) may be used on multi zone irrigation system, it protects against backpressure and backsiphonage, required on all pumped or elevated piping systems, which may cause backpressure. May be installed in irrigation box, must be tested initially by the Water Department and requires annual testing Reduced Pressure Backflow Assembly (RPBA) required on all systems when fertilizers herbicides, or other materials are injected into the irrigation system. Assembly must be installed a minimum of 12 inches above the ground. Assembly must be tested initially the Water Department and requires annual testing. NOTE: PVBA', DCV A', RPBA', must appear on the most current Washington State- appro~ed list of backflow prevention assemblies. Sample Letters and Record Forms ~First Edition) PNWS-AWWA CROSS CONNFCTION CONTROl MANUAl StlPPI FMENT t ..................Date................... J t .................Name ............"... J t ............... Address................ J t .................. City ................... J Dear Customer: ANNUAL TEST REQUIREMENT FOR BACKFLO\V ASSEMBLIES The State Administrative Code and the rules of the t. ..utility... J require the owner of any premises in which a backflow prevention assembly is installed at the utility's service connection to have certified tests made of each such assembly, a minimum of once a year, for its water tightness and reliability. Furthennore, all such assemblies shall be serviced, overhauled, or replaced immediately whenever found to be defective. Certified records of such tests and repairs are required to be submitted by the owner to the t... utility. . . J. More frequent testing may be required if history indicates frequent failures or non-compliance violations. Please arrange to have the assembly, as described on this fonn, tested by at... utility... J authorized tester. The t. ..utility... J restricts this list to certified testers that are familiar with this utility' . procedures. You have the number of days as indicated on the testing fonn to test responsibility signed by the owner or his agent. If these requirements are not met, the t. ..utility... J has the right to tenninate your water service. It is vitally important that you sign the fonn as owner before delivering it to your tester. We will not accept unsigned fonns. Please contact the undersigned for any questions yolJ.-may have about this procedure. III addition the owner has the responsibility to ensure and to provide adequate proof upon demand that his on-site and internal water system complies with the local and state Plumbing and Health Code requirements; to provide test records for all on-site backflow assemblies as required by the Health Code requirements; to provide test records for all on-site backflow services, and/or by t .utility.. J; and to designate a person as Water Supervisor. The Water Supervisor will be the contact person with knowledge of the on-site water system for coordination of questions, request for documentation and on-site surveys. The Owner is further reminded that the Plumbing Code requires that all backflow devices be adequately protected against freezing weather. Thank you for your cooperation. Sample Letters and Record Forms (First Edition) CROSS CONNECTION CONTROl MANUAl SUPPI EMFNT PNWS AWWA t ..................Date................... t .................Name ................. t ...............Address................ t .................. City ................... First Notice Date: Second Notice Date: Dear Property Owner/Occupant: TESTING OF NE\VL Y INSTALLED BACKFLO\V PREVENTION ASSEMBLY SECOND NOTICE Located at: has been installed at the above address. This assembly required testing by a Certified Backflow Prevention Assembly Tester upon installation as a condition to the continued supply of potable water to the premise by the City. To date, your Installer HAS NOT submitted his Test Reportto the Branch for the above assembly. Under Section of the Waterworks Bylaw No. -, you are required to immediately employ a Certified Tester to test the above assembly. A list of companies Testers registered with the City attached for your convenience. The Certified Tester must test the assembly, complete the report and submit it to the Branch within 14 days from the date ofthis letter. . ' Backflow Prevention Assemblies require yearly testing to ensure they are functioning properly. Your co-operation is essential for the protection of your and the City s water supplies from health contaminants. Should you have any questions, please contact at 555-1234. of the Branch Yours truly, Att. Sample Letters and Record For~s. (First Edition) CROSS CONNFCTION CONTROl MANl IAI Sl IPPI FMFNT PNWS AWWA f ..................Date................... f .................Name ................. f............... Address .......".... ... f .................. City................... 1 30 DAY NOTIFICATION OF \V A TER SHUT-OFF TO:OCCUPANTS OF BUILDING Service Address: Account No The backflow prevention assemblies at this address have not been satisfactorily tested, as required annually by the State Department of Health, and by City Ordinance. The person who holds the account at this address has been notified of the delinquency of receipt of satisfactory test reports. The Water Department is required by the State Department of Health to deny or discontinue water service to any customer failing to cooperate in the installation, maintenance testing, or inspection of back flow prevention assemblies. It is the intent of Water Department to give the premise occupants an opportunity to rectify the problem through negotiations with the account holder. This is to serve as notice to the premise occupan~s that, unless the account holder takes actIon to provide satisfactory test reports to this office within the next 30 days, the Water Department will be forced to terminate your service. You will receive a minimum 24 hour notice prior to termination of water service. If you would like more information regarding this issue , please call our Water Quality Control office at 555-1234. MailedIPosted: By:Date: Sample Letters and Record FormS , (First Edition) STATE OF IDAHO OFFICE OF THE ATTORNEY GENERAL LAWRENCE G. WASDEN February 17, 2006 Robert J. Boyle, Vice President Hanson Industries, Inc. Spirit Lake East Water Company 15807 E. Indiana Ave. Spokane, WA 99216-1864 John Hammond, Jr. Batt. & Fisher, LLP PO Box 1308 Boise, ID 83701 Re:Spirit Lake East Water System Improvements Dear Mr. Boyle and Mr. Hammond By letter dated January 24, 2006, the Idaho Department of Environmental Quality(Department) outlined several outstanding items remaining to be addressed prior to the Department granting an approval designation to the Spirit Lake East Water System. Additionally, the Department referenced the November 5, 2005 sanitary survey and deficiencies noted pursuant to that survey. This letter outlines what is required to obtain system approval and achieve compliance with the Idaho Rules for Public Drinking Water Systems (Rules), IDAP 58.01.08, in order to protect public health and the environment. In order for the Department to re-approve the Spirit Lake East public water system and to avoid the Department pursuing an enforcement action to achieve compliance, please complete the following four items by March 1 , 2006: Submit certification to the Department that a relay on the standby generator capable of addres~ing ph~se power failures is installed and operational; c /rv I '" 5-f'\.,J~1 Natural Resources Division, Environmental Quality Section, 1410 N. Hilton, 2nd Floor, Boise, Idaho 83706-1255Telephone: (208) 373-0494, FAX: (208) 373-0481 Robert J. Boyle John Hammond, Jr. February 17, 2006 Page 2 of2 Submit certification to the Department that the auto-dialer is operational under power-failure situations and will automatically notify the operator when problems occur at the water system; Repair the reservoir roof and submit certification to the Department from an engineer that the . roof will not leak. In order to complete item 3 to the satisfaction of the Department, the Department recommends that you place a cap on the reservoir as described in the January 24, 2006 letter from the Department; Submit to the Department, in writing, certification that all items proposed for completion by February 3 , 2006, as outlined in the January 13 2006 letter from Mr. Boyle to the Department, have been completed. (r,r-f er"'.l As to all other remaining deficiencies outlined in the Department's January 24, 2006 letter, please submit a proposed plan and schedule for achieving compliance with the Rules to the Department by March 1 , 2006. Once the deficiencies are corrected, the Department will be available for a reinspection of the water system improvements within 5 days of written notice. Thank you for your attention to this matter. If you have any questions in regards to this letter, please do not hesitate to contact me at 373-0494. Sincerely, Stephanie Ebright Deputy Attorney General STE/bak co:Steve Tanner, Drinking Water Supervisor Gary Gaffney, Senior Environmental Engineer Jem Henry, DW Rule/Enforcement Lead - - " I . \i!~I: HANSON HANSON INDUSTRIES, INC.15807 East Indiana Avenue. Spokane. WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail; admin(gJhansonind,com February 23 , 2006 Anthony P. Davis Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d' Alene , ID 83814 Re: Spirit Lake East Water Company Dear Mr. Davis: 16th I did not have this information in my progress report dated Febnlary We have retained Liquid Engineering to perform the work to clean the bottom of the reservoir. This item was listed in our Plan of Correction from the Sanitary Survey. Liquid Engineering sets its appointments by region as it is based in Billings , Montana. We were advised that its crew will arrive sometime within 6-8 weeks from February 6th to perform the work. Sincerely, Vice President i.j CPf'j ~~~~~ February 9 2006 Mr. Jim Kruger Hanson Industries (East Spirit Lake) 9112 West Liberty Spirit Lake East, ID 83869 RE: Job Confirmation Information Dear Mr. Kruger: First ofall! would like to thank you for choosing Liquid Engineering (LEC) for your water system work. We truly appreciate the opportunity to work with you and your staff In order to assist LEC in completing yourjob . I would like to provide you with the following scheduling and coordination information. Our scheduling department will be contacting you to begin preparations for the crew arrival. To eliminate additional mobilization charges LEC crews travel nationwide, year-round and will be completing your work in one of our scheduled routes (unless other arrangements are made). As we continue to refine a specific arrival date, our schedulers will remain in contact with you until thejob is complete. Please keep in mind, that our operations personnel often discover problems which were unexpected by other clients, and schedule slippage does occur; your understanding is appreciated. The following information is provided to ensure proper completion of your system work: . \Veekend Access: With contilllled access ri'om our clients, LEe tries to schedule: its crews 7 days a week. Therefore. please inform our schedulers if your utility has difficulty with weekend availability. In most cases it is not necessary for you to dedicate onsite support personnel to assist us in our \Vork. Please let our schedulers know ifalTangements can be made in advance to keep our crews productive. . Water Level: Please infonn all personnel involved with this project that LEC is a diving contractor and unless otherwise discussed, it will be necessary to have your tanks filii and in nonnal operation. Cleanings and Inspections are more efficient with the tank full. Be aware, cel1ain LEC operations may present a problem with the water level 15-18 feet below the top access hatch. Please keep us productive by confirming a full tank prior to arrival- and avoid potential standby charges for events beyond Liquid Engineering s control. ~ Rcmeved '.Vater . :.::. Materia!s: Irl the e','er:t INe are c!ea!li"g your ta!lk. ::-!ease identif':.' ?!1 area ,-\'here the ereVi may discharge the vacuumed water and materials. Depending on the type of accumulated sediment, in IllOSt cases the discharge resembles "dirty water" and there is typically no heavy residual sludge left to dispose of. Liquid Engineering is aware of most state & local discharge requirements. please let us know in advance if there are any specific discharge concems for your particular utility. We look forward to arrival and completion of your project. Should you have any additional questions please feel free to give me a call at 800-438-2187. In the meantime, I would like to thank you again for the oppol1unity to work with you. Si ncere! \'. /l/d t !-:Ii- lIL, 1,y - op",1'o", Cooed;,..",. 7" Eo" .'\Irpon Rood .1'0 Box HI)2.'P 1':dl'Ilg'. 1\ IT 5') I ()H -P2") . HI )()..HH-2 I H7" . -I()(,."" I -P I PS . lox. -II 'I.-oSI .() 12() kUllOill" I'QI",kllg",ccrlllg ,0111 . """",liQ"idl'l1""'l'l'ril1~ 11)111 \LI'\Ll:I", """""","'""'"""""""."."".'"". """",'l""""""I."""'c,""'-;""." "",. I". ",,,g'"'."",.""".""""". \L."..".I ""'.""" ",,', ".",.- .. 'd",g """"-"""""""""""'""""""'".\"" '""'" ,, ' I :,. ",., ("""."""" "."" ",. ,1"",. " "- "c' . \", ,""""" STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY ----- 2110 IRONWOOD PARKWAY. COEUR D ALENE, IDAHO 83814 . (208) 769-1422 JAMES E. RISCH , GOVERNOR To~1I H;RDESTY, DIRECTOR April 25, 2006 Robert J. Boyle Hanson Industries, Inc, Vice President Spirit Lake East Water Company 15807 E Indiana Ave Spokane, WA 99216-1864 Re:Spirit lake East Water System Improvements Dear Mr. Boyle: Thank you for your letter to Steve Tanner of August 28, 2006. We are puzzled by your request for approval a repair methodology that we have repeatedly denied. In both of our meeting with Mr. Raymond Hanson and Jim Krueger we have indicated that using a hot torch down type fabric material is unacceptable. We have observed the failure of this type of roofing system in the past during inspections of this reservoir. We asked for a. sealing technology that would satisfy the long term needs of the water system. At our last meeting this appeared to be a hot tar coating applied after the existing roofing material had been removed. Instead we received essentially the same proposal that we have repeatedly rejected. It appears that there is a certain amount of information that is lost in not dealing with you directly. If you would like to meet with DEQ we would be happy to accommodate you. It may also be to your advantage to contact a civil engineering firm that has exDeriencein water system desian to address the problems presented by the existing roofing system. We have previously reviewed a report from Welch Comer and Associates of Coeur Alene, your former consultant, that indicates that a new roof is necessary. Documents that have been presented to DEQ recently have been from a roofing company that may not have experience in drinking water reservoir systems. You may need professional design services from a qualified engineering firm. If you have any further questions on this matter, please contact DEQ at 2110 Ironwood Parkway in Coeur Alene. Our phone number is (208) 769-1422. Anthony Analyst John Hammond Jr, Batt & Fisher, LLP , PO Box 1308, Boise, 1083701 Stephen Tanner, 10EQ/CdA Stephanie Ebright, 10EQlSO Jerri Henry, 10EQlSO Gary Gaffney, 10EQlCdA STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 2110 Ironwood Parkway. Coeur d'Alene, Idaho 83814-2648. (208) 769-1422 Dirk Kempthorne, Governor Toni Hardesty. Director April 28, 2006 Robert J. Boyle Hanson Industries , Inc, Vice President Spirit lake East Water Company 15807 E Indiana Ave Spokane, WA 99216-1864 John Hammond , Jr Batt & Fisher, LLP PO Box 1308 Boise, 1083701 Re:Spirit lake East Water System Improvements Dear Mr. Boyle and Mr. Hammond: On April 11 , 2006, Steve Tanner, Stephanie Ebright, and I , representing the Idaho Department of Environmental Quality (DEQ), inspected the water system to determine compliance with DEQ's letter of January 24 , 2006 that outlined remaining water system deficiencies. These deficiencies were as follows: 1. Repair of leaks in the wall of the reservoir. 2. Repair of reservoir roof.3. Installation of a standby generator to provide power to the water system pumps during power failures.4. Installation of an auto-dialer to notify the operator when problems occurred at the water system facilities. 5. Purchase of a replacement pump for the well to minimize the length of time that the water system would be out of water should equipment fail.6. Initiating a cross-connection control program.7. Installation of an exterior vent from the chlorine solution tank. 8. Repair of the water trow meter on the well discharge line. The DEQ has found that , with the exception of item number 2 above , the water system has adequately addressed all other listed system deficiencies. In regards to item number 2, repair of reservoir roof, by letter on October 6 , 2005 , the DEQ recommended that the system instigate a sampling plan in order to ensure that the water in the reservoir was not subject to contamination. If the water system agreed with this sampling proposal , the DEQ asked that the system so indicate in writing by October 2005. As of this date , the DEO has not received a written response from the system agreeing to the sampling proposal. Spirit lake East Water System Improvements April 28, 2006 Page 2 On November 1 , 2005 , representatives of the DEQ inspected the water system and noted ponding on the reservoir roof. At the time of the April 11 , 2006 inspection , the DEQ representatives again observed ponding on the reservoir roof. Water ponding on the roof can result in the joint seals failing due to freeze effects and water in the reservoir becoming contaminated. The Idaho Rules for Public Drinking Water Systems currently applicable to the reservoir, require that "storage reservoirs have adequately drained watertight roofs or covers." Title 1 , Chapter 8, Section 1-8307.03 (1977). Additionally, the applicable rules require that "reservoirs shall be constructed and maintained in such a manner that stored water is protected from all possible sources of contamination." Section 1-8307.01. In order for the system to regain an approval designation and to ensure that water in the reservoir is protective of public health, the DEQ requests that the system conduct a sampling effort that includes relocating the chlorination system to inject into the discharge side of the booster pumps and sampling the water pumped from the well and of water stored in the reservoir weekly for total coliform during a six-month period. If the system does not wish to conduct a sampling effort as proposed , the DEQ requests the system provide an alternative proposal , to the agency. detailing actions the system will take to ensure that the roof is draining adequately and that stored water in the reservoir is protected from all possible sources of contamination along with a time line for completing such actions. The system shall provide , in writing, its preferred option to the DEQ by May 12 , 2006. Once the system and the DEQ have agreed to a sampling plan or alternative proposal, along with timelines for completion, the agency will reassign an approval designation to the system. If you have any further questions on this matter, please contact DEQ at 2110 Ironwood Parkway in Coeur d'Alene. Our phone number is (208) 769-1422. Anthony P. avis Analyst Stephen Tanner , IDEQCdA Stephanie Ebright IDEQSO Jerri Henry IDEQSO - .~ "\! . HANSON 15807 East Indiana Avenue, Spokane, WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin(!j)hansonind.com May 26, 2006 Anthony P. Davis Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Davis: We received your April 28th letter. We are again requesting DEQ to reinstate us Approved Status" without further delay. We spent more time and effort researching DEQ's request to re-pipe the system test it for 6 months and/or put a new roof onto the tank. DEQ raised nine issues in the Disapproval" notice. Eight of the issues have been resolved/completed as noted in your correspondence. The last one is the roof which does not leak or have a ponding situation. We previously water tested the roof as per our engineer s direction and advised DEQ. We have monitored the water quality as required by DEQ and provided the reports showing us to be in compliance. The amount of water on the roof as demonstrated at the April 11 th walk through was barely enough to cover about one-half of a quarter placed onto a small section of the roof. The re-piping is impracticable due to the variable flows and does not solve anything since we do not have a water quality problem due to a leaking roof. We also completed all issues raised in DEQ's sanitary survey (independent of the above referenced nine items) which were numerous and extensive but done as soon as practical in full compliance and accepted by DEQ. I am available to meet and discuss these matters if DEQ needs further information re: our position to place us back into Approved status. Please contact me at your earliest convenience to schedule a meeting the week of May 29th in your office. We are hopeful that we can resolve this last issue and I hope to hear from you next week re: our reinstatement or to meet and confer. Thank you. ~: 11 Raymond A. Hanson 15807 East Indiana Avenue, Spokane,WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin~hansonind.com June 8 , 2006 Anthony P. Davis Department of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Davis: Enclosed is the Bureau of Occupational Licenses letter dated June 2nd re: Mr. Kruger s license. His license was an item in our Plan of Correction but we did not have a date certain due to the Bureau s processing of his request which was submitted in 2005. His test date is scheduled for July 19th with location and time to be determined by the Bureau. Sincerely, ~JA ~.c ;;. - B Vice President STATE OF IDAHO BUREAU OF OCCUPATIONAL LICENSES Owyhee Plaza 1109 Main St., Suite 220 Boise. Idaho 83702-5642 (208) 334-3233 FAJ( (208) 334-3945 Mail ibol(q)iboLidaho.!!oy Website www.iboLidaho.!!oY June 2, 2006 JAMES R KRUGER 2 2 7 E GARLAND SPOKANE WA 99207 ---- RE:Board of Drinking Water and Wastewater Professionals Application Dear Applicant: Please be advised that your application for DRINKING WATER OPERATOR DISTRIBUTION - CLASS 1 was reviewed for examination by the Board of Drinking Water and Wastewater Professionals at their meeting that was held on May 24 2006. The Board recommended you for examination on July 19, 2006. You will receive the location and time of the exam at a later date. If you have any questions, please call me at the above number. Sincerely, Mary Miles Secretary/Drinking Water and Wastewater Professionals /mm . . Memorandum Date:June 14 2006 To:Anthony Davis; Idaho Department of Environmental Quality CC: From:Bob Boyle at Hanson Industries 15807 E. Indiana Avenue, Spokane Valley, 'VA 99216 USA RE: (509) 922-5252 (Office) 922-5757 (fax); email: bboyle~hansonind.com Spirit Lake East Water Company Enclosed is the Bureau of Occupational Licenses letter dated June 8 , 2006 to Jim Kruger advising him that his Class 1 license test is scheduled for July 19 2006. We will provide notice of the results once received from the Bureau. Thank you. 01/07/94 _- ~ ... ST ATE OF IDAHO .. BUREAU OF OCCUPATIONAL LICENSES Owyhee Plaza 1109 Main St, Suite 220 Boise. Idaho 83702-5642 (208) 334-3233 FAX (208) 334-3945 Mail ibotcQJibo1.statc:.id. Wc:bsitc: www.ibol.idaho.!!oYJune 8. 2006 Dear James R Kruger: The Idaho Board of Drinking Water and Wastewater Professionals has reviewed your application for licensure. You meet the appropriate qualifications and have been approved to take the following . . "."\I\~'",,exammatlOn: Exam Type: DRINKING WATER OPERATOR Exam Class: DRINKING WATER OPERATOR DISTRIBUTION - CLASS 1 **Ifthe exam Type or Class is incorrect, please notify the Bureau immediately Your examination is scheduled on \Vednesday, July 19, 2006 at 09:00 AM at NORTH IDAHO COLLEGE, WORKFORCE TRAINING CENTER- 525 W CLEARWATER LOOP, POST FALLS, ID 83854. In order to be admitted to the examination you must bring this letter and a state or government issued picture D. You must be on time. Examination candidates will not be admitted after the completion of roll call. You must notify this office in writing and prior to the exam date if you cannot attend this exam. Failure to appear without prior written notice will result in a forfeiture of your fees and the termination of your application. Please bring a calculator with you. No programmable calculators are allowed in the exam.Scratch paper and pencils will be available to you at the exam site. The results of your examination will be ina-iled to you as soon as they are processed. This process may take up to three (3) weeks. DO NOT CALL THE BUREAU FOR YOUR EXAl\'1 RESULTS. We will not provide results over the phone. . --- ---- - --.- u - --- --.--- --. -- -- (ANI) ID ATE NA. "IE DATE Of BIRTH: James R Kruger 5/27/1953 - - 15807 East Indiana Avenue. Spokane. WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail: admin(gJhansonind.com August 28, 2006 Steven Tanner Department of Environmental Quality State of Idaho 2110 Ironwood Parkway Coeur d' Alene , ID 83814-2648 RE: Spirit Lake East Water Company Dear Mr. Tanner: The last item in our Plan of Correction was to correct the ponding ' on the roof of the reservoir. We have explained our position on this issue in previous correspondence. We are enclosing a proposal from United Roofing Company dated July 20, 2006 to perfonn the work necessary to eliminate the ponding. We request your written acceptance of the procedure whereupon the work will be completed shortly thereafter. Upon completion and acceptance of the work, we request re-instatement to Approved status. This letter is a follow up to the two meetings held with you and your staff with Raymond Hanson and Jim Kruger. This is the same proposal forwarded to you by Mr. Kruger the week of August 14 2006. Mr. Hanson and Mr. Kruger understood from these meetings this work was acceptable to DEQ to resolve the issue; however, Mr. Kruger advises that DEQ wants a new procedure (i.e. a new hot tar roof) to resolve the issue. As a result, we are requesting DEQ's acceptance of the United Roofing Company procedure and confinnation ofre-instatement status upon DEQ's acceptance of the work. Sincerely, ~~~ Vice President .. . ,~~ "~ u~,- - - United Roanna . :. ~-----. . -------------.".!'. !!~!:l21!! !"i!:~W~9!i!J.:!!1~!2!!~~-!!t!!2!!~~!!!!!!-3!j~~~.z~~!!io..:~tj!!2 ;.msr: :!:!:'1 DDnnfiC' AT .!: ft '!oJ':: '!.J' :.::." ~""'JU DATE: 7/27/06 TO: Jim Kruger ,-,,~-u. "LU co"')o " ......~.'..,., ~'tT'-:I .,7/"-/ WE HEREBY SUBMIT SPECIFICATIONS AND ESTIMATES FOR ROOF AT: ....'" ~nl..n . ."KP .......T "" ,.TP.. l..nK ...-- -. ----- --- - - -.-- - ---- Appiy an additional layer of smooth surface tonh down membrane at the area of PQiiding Then apply aluminum coat the existing roof. F~!'" ih~ I'D!:!: ~f$2367_C.u Over the existing roofmg apply an additional layer of mineral surface torch down membrane. For the price of $5485. Ov~!'" in!: ~:!.i~i..n g !- I)(.rLi!g !!pply !! fully !!d.h~~J TPO b!"!!!!~~ iii~,:ii.;: ;0 iii:W iiiiO~fd: d ffigc aDd seal to the roofrneml:mme. For the price of $6993. 'O'O"", .....................",.,. "TT'"'T'Iorn..'......... T'I Tn',,-"'"T" Jr. "T"T'"T'lT' T . ...Tn." . ror-n r"r-J. HU T'.T'r. n.1""~ r~vrv",,~: !l!::.!\..!:..D! !'J rU~..l'!!~n lyU"'-!r..!'-..!..,",-I.., 1-\""1 L_~D' '.!'-_ '!V r'.1 r', "'I ACCORDANCE Willi ABOVE SPECIFICATIONS. FOR THE SUM OF: AS STATED ABOVE PAYMENT TO BE MADE AS FOLLOWS: DUE UPON COMPLETION AT 1 J.~ A 'T'I:;'DJ A J '" A 010" rei' A D A ...,.'" tOn .r.. DC A'" ';'ui-J","'-i':':f, "i ",r,,Jjv , i:la:i ,,..ilDi ;::;'TT..n iN MoLL 1"'.. L LL'U.-J-c'-' M.L~ '-"-'M."""~'" '-'.LJ"'" .. 'J ""'AJ ....." ..... .L."-."" LLJ'-', -' " -" .. '""~ . ~ L"J ~~.... ~~. ~~ ~. . . WORKMAN LIKE MANNER ACCORDING TO STANDARD PRACTICES. ANY AL TERA nONS OR DEVIA nON FROM ABOVE SPECIFICATIONS INVOLVING EXTRA COSTS WILL BE EXECUTED ONL Y UPON WRlTTEN ORDERS, AN!) w1LL BECOIvi.::E AN EXTRA. CH.~GE O'V"ER A_ND ABOVE T'..n:f:. ESTIMATE. ALL AGREEMENTS CONTINGENT UPON STRIKES, ACCIDENTS, WEATHER OR DELAYS BEYOND OUR CONTROL. OWNER TO CARRY FIRE, TORNADO AND OTHER NECESSARY l1'~SUP,..Al',JCE. OUR '.'RE fULLY COVERED BY WOlU(l'.1..",N'S COIvlPENS.! I INSURANCE. ,;. .T'I'IT.~u.7","" ;;;i.-::;r.;- ,;. TiTDii'.nv.. ""-"""""L./-"'~ ",..'V.,no... ~z.~. ACCEPTANCE OF PROPOSAL: THE ABOVE PRICE. SPECIFICA TrONS AND CONDITIONS .A..FE SATISFACTORY 81.m ARE h~RE.BY ACCEPTED, YOU ARE AUTHORIZED TO DO THE WORK AS SPECIFIED. PAYMENT WILL BE MADE AS OUTLINED ABOVE. NOTE: nus PROPOSAL MAY BE WITHDRAWN BY US IF NOT ACCEPTED WITHIN 30 DAYS. DATE OF ACCEPTANCE:SIGNATURE: - - 15807 East Indiana Avenue, Spokane, WA 99216 (509) 922-5252' Fax (509) 922-5757 E-mail; admincgJhansonind.com September 8, 2006 Anthony Davis Departmental of Environmental Quality 2110 Ironwood Parkway Coeur d' Alene , ID 83814 RE: Spirit Lake East Water Company Dear Mr. Davis: I reviewed your April 25th letter to Bob Boyle and take this opportunity to clear up any miscommunication since I attended both meetings with DEQ. In the first meeting, we discussed DEQ's desire to have the Company install a new metal reservoir. We explained the large expense to the ratepayers which we did not want to do. As an alternative, we submitted three alternative roof repairs to eliminate the ponding. I thought we all agreed that DEQ would accept a repair that would guarantee the elimination of the roofponding and so we left to research that solution. In the second meeting, we discussed a quote from a licensed roofing contractor and how to complete the repairs. This led to a firm quote from the licensed contractor to repair the ponding with a guarantee. This quote was delivered to Mr. Tanner by Jim Kruger and was followed up with Bob Boyle s August 28th letter. Ponding is defined as "the excessive accumulation of water at low-lying areas on a roof that remains after the 48 hours after the end rainfall under conditions conducive to drying" as per the National Roofing Contractors Association, NRCA Roofing & Waterproofing Manual, Fifth Edition (copy enclosed) Our condition is not ponding but we will nonetheless conduct the repair. We are prepared to repair the roof as per the quote with the August 28th letter. I am in Alaska the week of September 11 th. I will contact you upon my return. Thank you. a. 1.f Raymond A. Hanson 'Technical database search I NRCA, National Roofing Contractors Association I NRCA, N... Page 1 of 1 Find a Contractor Consumer Information About NRCA Professional Roofing Technical The Industry Related Organizations Shop NRCA Education IV/embership Directory JOIN NRCA I Heme I Contact I Search I Print Technical I Search I Search results I Term definition Glossary of roofing terms search Enter a term:I Search: --- Browse by letter:I Search i Ponding: the excessive accumulation of water at low-lying areas on a roof that remains after the 48 hours after the end rainfall under conditions conducive to drying. NRCA Roofin & Water roofin Manual Fifth Edition !9 CoQYm ht 2006 National Roofina Contractors Association http://www .nrca.net/ consumer/technical! search! glossarydetails.aspx?ID Number-- 541 ",. "".,,..., Mer User na Passwol Neec ,~,~-~'"~.,._"""-"' Select .. '~";o,,:;c-; Ind PLQ(essiQ 8!!g!Jsti~ online ~J3.C:::Ap.n apQi.Jtjts efforts ( t19t:e .11, ..:='-", C;..,. Whati starting roofing ' $5 - $9 ' . ' $10- $J ' $13 - $ ' $16 - $ .' more tt View res ----- Regist 9/5/2006 '0 ' p. 1 Ru~ 22 06 11:40p ; . .; .:~;, _u.o_, .".'---'---" . -' ,--' ...., "-'" .--,- "-'--'-' ,-,,' .. - ,_u .. ::,;;;::;' IlSa1c7S""ZidWA,9ga2! ;,::lro9)l!ri5,6QO\", 1S!)9)'I!iS.JIIJ9':' ;': :, mil:1aeSJlliV1n5QBi!;;msl\:t:m ' U' , -' " u ,' ,,' "" ' " '--"., u,' , '" , ..' U 'Qrin~d~ ij 9ft fig PROPOSAL DATE: 7-20-06 TO: James Kruger PHONE: 868-5929 WE HEREBY SUBMIT SPECIFICATIONS AND ESTIMATES FOR ROOF AT: Spirit Lake Water Tank Using APP modified Torch-Down Membrane to match the eristing roofmg install a piece slightly smaller than the low spi)t of the roof deck, apply additional layers to build up the surface until are satisfied that it will no longer pond water, to make it flat, if not even slightIyraised. Once we are satisfied with the results, apply aluminum eoating to the existing roof surface. For the prite of $2 987. WE PROPOSE: HEREBY TO FURNISH MA TERrAL AND LABOR-COMPLETE IN ACCORDANCE WITH ABOVE SPECrFICA TIONS. FOR THE SUM OF: AS STATED ABOVE PAYMENT TO BE MADE AS FOLLOWS: DUE UPON CO~LETION ALL MATERIALS ARE GUARANTEED TO BE AS SPECIFIED. ALL WORK TO BE COMPLETED IN A WORKMAN LIKE MANNER ACCORDING TO STANDARD PRACTICES. ANY AL TERA nONS OR DEVIA nON FROM ABOVE SPECIFICA nONS INVOLVING EXTRA COSTS Wll...L BE EXECUTED ONLY UPON WRITTEN ORDERS, AND WILL BECOME AN EXTRA CHARGE OVER AND ABOVE THE ESTIMATE. ALL AGREEMENTS CONTINGENT UPON STRIKES, ACCIDENTS , WEA TIlER OR DELAYS BEYOND OUR CONTROL OWNER TO CARRY FIRE, TORNADO AND OTHER NECESSARY INSURANCE. OUR WORKERS ARE FULLY COVERED BY woRKMAN'S COMPENSATION INSURANCE. AUTHORIZED SIGNATURE: ACCEPTANCE OF PROPOSAL: THE ABOVE PRICE. SPECIFICATIONS AND CONDITIONS ARE SATISFACTORY AND ARE HEREBY ACCEPTED. YOU ARE AUTHORIZED TO DO THE WORK AS SPECIFIED. PAYMENT WILL BE 1v1ADE AS OUTLINED ABOVE. NOTE: TillS PROPOSAL MAYBE WITHDRAWN BY us IF NOT ACCEPTED WITHIN 30 DAYS. DATE OF ACCEPTANCE:SIGNATURE: RESPONSE NO. Bob Boyle From: Sent: To: Bob Boyle (bboyle~hansonind_com) Friday, July 01 , 20053:25 PM j oh n b ~ ladybug prod ucts. com Mr. Balbi: I asked our engineers to research your inquiry re: adding a fire suppression device/system onto the existing water supply system , most likely at the tank. Their response is that there would not be sufficient fire flow at peak use demand. This of course assumes all customers are using lots of water during an emergency requiring fire flow; this mayor may not occur given the emergency. If the customers would agree on implementing a water rationing program (DEQ has been asking for water rationing for irrigation purposes the last couple of years) perhaps an alternative use days type program would lessen the peak demands. I don I t know the answer to this technical question so I will raise it with our engineers next week and advise you as well as my schedule. Right now , the best time to meet is the week of July 18 or 25th after my trip. Thank you foryour interest. No virus found in this outgoing message. Checked by AVG Anti-Virus.Version: 7.323 / Virus Database: 267.8/37 - Release Date: 7/1/05 Bob Boyle ~.. From: Sent: To: Subject: Bob Boyle (bboyle~hansonind.com) Wednesday, June 01 200510:42 AM mike schmidt RE: sle water Mr. Schmidt: we are working on the comments received from DEQ dated April 22 , 2005. DEQ did not approve some of our proposed remedies in my 3/14/05 letter. The biggest issue is that DEQ wants us to take down the tank for 30 days we are looking at how to provide water to our customers during this period. I am working with our engineers to comply with this mandate but I am about to ask DEQ that we do the work requiring the tank outage after summer (post Labor Day), not during the summer. However, this is not under my control. I can advise what specific work we are going to do after DEQ responds to our latest inquiry/clarification. Thanks for the interest. - - - - - Original Message - - - -- From: mike schmidt (mailto:ceasar~icehouse.netJ Sent: Monday, May 30, 2005 3: 01 To: bboyle~hansonind. com Subject: sle water Mr. Boyle, received a copy of your 3/14/05 letter to DEQ witha list of proposed project improvements agreed to involving the current water situation. To date, I have seen no activity at all at the water plant area. As the letter indicates a completion date of July 15th, can you indicate when work will commence and whether we will be without water during the reservoir repairs? We have our monthly meeting coming up on June 7th and I could passany messages you need to let us know....... Mike Schmidt No virus found in this incoming message. Checked by AVG Anti-Virus.Version: 7.322 / Virus Database: 267.0 - Release Date: 5/30/05 No virus found in this outgoing message. Checked by AVG Anti-Virus. Version: 7.322 / Virus Database: 267.2 - Release Date: 5/31/05 . , Page 1 of - ,. Bob Boyle To: John B Subject: RE: Spirit Lake East Mr. Balbi: I am now settled back in Spokane after several weeks abroad and with new partners in the West. I am a veteran of several of the types of meetings you propose and , as such, I recommend an agenda detailing the Committee s and Board's points of interest. In this way we will be able to address many, if not all, of the issues in a conference call. This is the most expeditious way to coordinate schedules and get at the issues. Our plans and goals have been communicated openly with Bob Lloyd and Mike Schmidt for the last 2 years. What we don resolve or need to follow up with can be done later at an "all hands" meeting. The possibility of homeowners association ownership of the water system/company has been discussed for years with several Boards and members without any result/success. The last attempt was with the North Kootenai Water District. Do the Committee, Board and homeowners now all agree on this possibility? I am open to suggestions. Thank you. From: John B (mailto:johnb(Q)ladybugproducts.com) Sent: Tuesday, August 16, 2005 3:07 To: Robert Boyle Cc: Mike Scmidt; ANTHONY DAVIS; writeoffsite(Q)icehouse.net Subject: Spirit Lake East Hello Robert attached is a Memo for you John Balbi R/17/?OO'i Spirit Lake East Water Committee August 16 , 2005 Spirit Lake Water Co / Hanson Ind. Robert Boyle / Owner. 15807 E Indiana Ave Spokane Valley, WA Dear Mr. Boyle, Have you forgotten about us? As Stated in our letter to you on 6/20/05 would like to make arrangements to meet and discus several points of interest to the homeowners of Spirit Lake East. This meeting would include Members of the board of Spirit lake East and the Water committee. We would like to meet about the possibility of transfer of ownership of the water Co. to the homeowners. John Balbi 208 623 2587 joh n b~ladybug products.com Joyce & Wayne Nowacki 666- 2056 Cell 687 5177 writeoffsite(Q).icehouse .net Page 1 of Bob Boyle From: Bob Boyle (bboyle(IDhansonind.com) Sent: Tuesday, August 23 200510:16 AMTo: 'John B' Subject: RE: Spirit lake East Very good. Feel free to call me before if you want to "sound out" some ideas before your joint meeting and/or conference call. Thank you. From: John B (mailto:johnb(9jladybugproducts.com) Sent: Tuesday, August 23, 2005 9:23 AM To: Robert Boyle Cc: writeoffsite(9jicehouse.net; Mike Scmidt Subject: Spirit lake East Spirit Lake East Water Committee August 22 2005 Dear Mr. Boyle, The Spirit Lake Association board, The Treeport Association Board and the Spirit Lake Water Committee will be meeting this week. We would like to speak with one voice before our Conference call as you pointed out. I n that way we can communicate as one. I should be able to set up a meeting after you arrive back in Spokane when you return. John Balbi ... 8/23/2005 Page 1 of - ,~.. Bob Boyle ------------------.---------------------- From: John B (johnb(gjladybugproducts.com1 Sent: Tuesday, September 06, 2005 6:20 PM To: Robert Boyle Cc: writeoffsite(gjicehouse.net; Mike Scmidt Subject: Spirit Lake East Water Spirit Lake East Water Committee September 6, 2005 Dear Mr. Boyle As the Scheduled meeting between joint homeowner associations was held and a meeting of the water committee with a SLEHA board member present this agenda has come to surface. We would also like to meet with you as there is not any facility that is available to us that has a conference call capability. The Spirit Lake East agenda is as follows Will if any agreed on repairs be completed? Restoration of the Reservoir Spare Well pump on hand Installation and implementation of the auto dialer Installation and set up Generator capable of powering the water system and any others issues outlined in your agreement with D. Transfer of ownership to the association could possible take place with the understanding that most if not all cost could be deferred to a tax credit given by the Homeowners associations as you suggested in the past. A time frame is needed to deploy the proper documents to the people Spirit Lake East and other authorities. The Fire Suppression device at the well site is a necessary addition to the people of Spirit lake east and should be installed as soon as possible to avoid The Freezing whether approaching. Thank you Spirit Lake Water Committee 10/1012005 Page 1 of 2 Bob Boyle From: Gary.Gaffney~deq.idaho.gov Sent: Wednesday, September 07 200510:10 AM To: admin~hansonind.com Subject: FW: Spirit lake East Water From: John B (mailto:johnb(Qjladybugproducts.com) Sent: Tuesday, September 06,20057:20 PM To: Anthony Davis; Gary Gaffney; Stephen Tanner Cc: O.Cooper(fppuc.idaho.gov; Gary Gaffney Subject: Spirit lake East Water Memo September 6, 2005 Greetings: As we are all aware the September 1 deadline has past. Has Hanson/Spirit lake Water Co submitted the reservoir planes as thy have promised. We have been by the site through out the past month and no evidence of any sort of preparation has been noted. Is D.E.a. still taking the stance of sit back and see? Has there been any communication with Hanson/Spirit lake Water Co? If so could you send it to our committee either though this E-mail Address or my postal address. Winter is coming upon us if Hanson/Spirit Lake Water Co does not start soon we will be delayed to next year this would be a great loss to the people of Spirit Lake East. If in fact there has been no communication between D.Q. and Hanson/Spirit lake Water Co would you open a channel and ask them to conform to their agreement with D.Q. ? Thank You for your interest in Spirit lake East The Spirit Lake East Water Committee John Balbi 2086232587 john b(illladybugproducts. com Joyce & Wayne Nowacki 666- 2056 Cell 687 5177 wri t .Qffs i t~(fYi ceh 9 US~J1~J; 9/812005 Page 1 of . ,~.. Bob Boyle From: John B Dohnb~ladybugproducts.comJ Sent: Sunday, July 03 , 2005 7:34 AMTo: Robert BoyleCc: Mike Scmidt Subject: Spirit lake East Spirit Lake East Water Committee July 3 , 2005 Dear Mr. Boyle, in response to your letter sent 7/1/05 I would like to clarify our intentions. The fire suppression device.would not be used as a live connection to fight a fire. Our purpose would only to fill Fire Department water trucks used to bring water to the event. As currently Spirit Lake East has a 192 000 gallon tank running at approximately one half capacity (ill 100 000 that would mean that after the tank is repaired in September we would have 92 000 Gallons in excess of theamount that is available to us now. Taken into account that the well would be recharging as the trucks cycle though the event. I believe that if more water than this is necessary that equipment from other locations will be brought in that quell the event in progress. Other options would include using the existing low water device that is in operation now to warn operators that they should switch water resources. In a informal meeting with Spirit Lake Fire Department personnel it was determined that a fire hydrant at the closest location possible at the tank and the street would be a much better location than at the tank in the event of inaccessibility to the tank due to snow or other obstacles. This would be a standard fire freeze proof connection per fire code. Looking forward as recommended by welch & comer report if the second well is located at the same site which would utilize the entire infrastructure and reduce duplication of equipment. We would be able in ultra high demands turn on the backup pump and essentially doubling our pumping capacity and greatly reduce the possibility of running out of water in any situation. As for the water rationing I think that this premature .we know that north Idaho has been in a drought situation for several years. Thankfully we are at normal water level after a short snow season due to extended rainfall. I would like to ask ifDEQ's directives were made directly at Spirit Lake East or as a general recommendation to all water users. Would you mind forwarding the information to our board for review? Thank You John Balbi John Balbi 208 623 2587 john b(fY lad ybugproducts. com 9/13/2005 Page 1 of 2, ,~.. Bob Boyle From: John B (johnb~ladybugproducts.com) Sent: Tuesday, June 21 , 2005 1 :36 PMTo: Robert BoyleCc: Mike Scmidt; writeoffsite~icehouse.net Subject: Spirit Lake East Spirit Lake I Water Comm June 21 , 2005 Dear Mr. Boyle Let me introduce our committee my name is John Balbi and co committee members Joyce ar Association board to explore options for the betterment of our water system. At this time we would like to make arrangements to meet and discus several points of intere: of the board of Spirit Lake East and the Water committee. May I take this opportunity to bring a portion of background sentiment of a growing number In the beginning most people did not want to take over a water system that had so many de attitude about how we would operate such a system. We now have a better understanding and that major part of the renovation of the system wi , We would like also to discus the installation of a fire connection to the water reservoir durin~ responsibility of Spirit lake East, Speaking with the Spirit Lake Fire Dept. In the event of a e minutes. This would lead to a huge advantage to the residents here at Spirit Lake East. Please contact me at your earliest convenience. John Balbi John Balbi 208 623 2587 j ohnb(q?ladybugproducts.com ,;~" Joyce & Wane N owaki 666- 2056 Cell 6875177 W wri tea ffsi te(fYi ceho ll~e. net 9/13/2005 Page 1 of ~.. Bob Boyle From: John B. (johnb(Q2ladybugproducts.coml Sent: Wednesday, September 14, 200512:10 PMTo: John Hammond; Robert Boyle Subject: Spirit Lake East Spirit Lake East Water Committee - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - -- - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 9/14/2005 Robert Boyel Spirit Lake East Water Co. 15807 E Indiana Ave Spokane Valley, WA. - John Hammond esq. Batt & Fisher, LLP U, S. Bank Plaza, 5th Floor 101 S. Capitol Boulevard O. Box 1308 Boise, 83701 Re: Water Users address list Per our conversation with Mr. Hammond on 9/13/05. The Spirit Lake East Water committee is requesting a copy of the water user s on the system. This will be used for the purpose of distributing information on the water system. This information will be shared with the Spirit Lake Homeowners Association. At this time we would like to make clear that a meeting must take place with Mr. Boyel for further fact finding such as costs to run this system to be presented to the general population. This would be to answer questions intelligently when asked by our constituents. Thank you for your Interest in Spirit Lake East John Balbi 208 623 2587 j ohnb(fYladybugproducts. com Joyce & Wayne Nowacki 666- 2056 Cell 6875177 W '!YriJ~.9if~ it~(fY ic:~hoJJ~e. n~t 9/15/2005 -- , Page 1 of 2 ~.. Bob Boyle --'--- u_....__._u_m___u_-.. -n--- -- ..--- ----- - - - - ------.-----_____--n_n----..--_--.---... --- ---------.._- From: John B. Uohnb~ladybugproducts.com) Sent: Monday, September 19, 2005 1 :38 PMTo: Robert Boyle; John Hammond Cc: writeoffsite~icehouse.net; Mike Schmidt Subject: Scheduled Meeting Spirit Lake East Water Committee 9/19/2005 Robert Boyel Spirit Lake East Water Co. 15807 E Indiana Ave Spokane Valley, W A. John Hammond esq. Batt & Fisher, LLP U, S. Bank Plaza, 5th Floor 101 S. Capitol Boulevard O. Box 1308 Boise, 83701 Re: Scheduled Meeting Gentlemen I am late getting back to you due to problems beyond my control. I have discussed our phone conversation with fellow water board members and Mike Schmidt President of the Homeowners Association. We are in agreement to meet at Sprit Lake East the week of 9/26/05 In addition to the agenda we have provided on 9/6/5 we would like to see costs of day to day operations. This would include labor, power, materials, chemicals, reports and any other costs that you have incurred in the running of Spirit Lake East Water Co. Also Dates will be discussed to have informational meetings for our association members and when to send out questioners. Thank you for your interest in Spirit Lake East John Balbi 208623 2587 j 0 hnb~ladybugproducts. com Joyce & Wayne Nowacki 666- 2056 Cell 6875177 W 10/10/2005 Page 1 of Bob Boyle From: Bob Boyle (bboyle~hansonind.com) Sent: Wednesday, November 23, 2005 11 :00 AMTo: 'John B.' Subject: RE: Spirit lake East - Treeport Mr. Balbi: our expert, John Hammond with Batt & Fisher 208.331.1000, will be contacting you directly re: the interest of the two Associations. Please work with him. Thank you. From: John B. (mailto:johnb(Q)ladybugproducts.com) Sent: Friday, November 18, 2005 5: 18 PM To: Robert Boyle Subject: Spirit Lake East - Treeport Spirit Lake East ~ Treeport Water Committee November 18 2005 Dear Mr. Boyle We Would like to infonn you that a 76% approval rate to investigate the transfer of ownership was achieved at the quarterly Spirit Lake East Homeowners meeting .This meeting was held jointly with the community of Treeport although there was no separation in counting the votes for the most part the united community were in favor of a transfer. At this time we wish to understand your position on the availability of the system. This will be our first step. On your reply we could set up a meeting complying with your requirements. Thank you for your interest in Spirit Lake East - Treeport communities John Balbi 11/23/2005 ..-.... Bob Boyle 0 , ~.. From: Sent: To: Bob Boyle (bboyle~hansonind.com) Tuesday, October 19 , 2004 11 :48 AM ceasar~icehouse.net Mike: Steve Cordes of welch Comer advises the draft of the water system study will be available this Friday Oct. 22nd. I plan to pick my copy up at the WC Liberty Lake office. Once we get it then I will call Dick Fairhurst to get his schedule ideas etc. prior to the Oct. 28th Board meeting. Thank you. Outgoing mail is certified Virus Free. Checked by AVG anti-virus system (http://www.grisoft.com). Version: 6.775 / Virus Database: 522 - Release Date: 10/8/04 Page 1 of2. ,~.. Bob Boyle From: Bob Boyle (bboyle~hansonind.comJ Sent: Thursday, October 14, 2004 5:52 PMTo: Mike & Celia Subject: RE: water study-long range options Mike: I thought the plan was to (1) get the WC study and see what improvements it thought was needed ASAP; (2) see what the Water District review and response was to the study; (3) the District Board on October 28th would then advise us what it wanted to do; (4) if the District wanted to go forward then; (5) the District would make a deal with us then present its improvements (with some kind of $$ identified) to the customers for a vote on annexation; (6) if voted in and approved, the District would be the water purveyor. I believe we should follow the plan since we don t have the study, we don t know what the District wHI do and the system is newer now than before. What do you think? I am assuming the District decision will meet the Nov 9th deadline. Has that changed? Thanks. ----- Original Message----- From: Mike & Celia (mailto:ceasar(Q)icehouse.net) Sent: Thursday, October 14, 2004 5:28 To: bboyle(Q)hansonind.com Subject: water study-long range options Bob As the customers , SLEHA is extremely interested in what is going to take place up here. The original offer of a $50 000 tax shelter is certainly out of the question after the $75 000 +- Hanson Industries just had to endure due to the pump catastrophe. Options 1. Does Hanson have interest in making WK suggestions , still turning over water system and get a $250 00 +- tax shelter? 2. Would Hanson rather keep water system and seek pue approval for water increase to cover needed improvements? 3. Is there any other alternatives or options not discussed to date? I have already discussed with Welch-Comer that we ALL (those who paid for study) want hard copies of what they intend to submit to NKWD at their October 28th meeting so we can be represented. You may well have some ideas of your own. We have our own membership meeting coming up on November 9th. I would really appreciate some information , appearance at that meeting to explain your position or whatever possible so we , the customers can begin to discuss whatever option appears most feasable. We have a sub-committee formed who are presently looking at NKWD costs , etc. Mike Schmidt 10/14/04 Bob Boyle . ,~.. From: Sent: To: Subject: mike schmidt (ceasar~icehouse.net) Thursday, October 28 20043:17 PM bboyle~hansonind.com water meeting Bob First I want too thank you for your attendance and your patience. One of the common complaints in SLEHA has been ; "What has Hanson done with monthlywater receipts ?" On my way home from the meeting I had a thought: As a PRIVATE FOR PROFIT BUSINESS Hanson spent XXXX dollars to build the water system including well , pumps,reservoir , distribution system, etc. It was mentioned at the meeting of the profit ratio alllowed after expenses. At first, 1977/8 - 1980 there wereonly customers paying a water bill to amortize that expenditure. From 1980 to 1990, the number rose to number. From 1990 to 2000 users rose toconnections. A graph/spread sheet to show how long it took to amortize the original existing system before applying for more money by rate increases might calm many customers down who seem to believe all this system came from the toothfairy. . Mike Schmidt Incoming mail is certified Virus Free. Checked by AVG anti-virus system (http://www.grisoft.com).Version: 6.775 / Virus Database: 522 - Release Date: 10/8/04