20121221DEQ Report.pdf

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Curt Fransen, Director
TSP&S-11012012
December 13,2012
Jesse Chan, P.E.
1798C Hwy 45
Melba, Idaho 83641
RE: Brian Water Corporation Facility Plan Comments
Dear Mr. chair
IDAPA 58.01.08, idaho ihiles for Public Drinking Water Systems, lists in rule section 502.01 general applicable
issues that must be addressed in Facility Plans. In addition, rule sections 502.042 and 502.04.b thither define
minimum requirements for existing systems such as Bnan Water Corporation that must be addressed in Facility
Plans Subsection 50204 FaCilIty Plan Contents states, in part
The facility plan is intended to address system wide growth, to identify system deficiencies, and to lay out a
plan for system upgrades and expansion.
While the submitted plan addressed the immediate concern involving the nitrate contamination issue it did not
address this overall emphasis of a facility plan; to identify ulLsystem deficiencies and lay out a plan for future
system upgrades and expansion. For example, the eight significant deficiencies listed in the system's last enhanced
sanitary survey (ESS), performed on September 18, 2008, should be identified in the report if they have not been
adequately corrected.
Please note that Subsection 502.04.b also stipulates;
If specific items listed in Subsections 502.04.b.i through 502.04.b.vii or Subsections 502 .04.a.i through
502.042.viii are not applicable to a particular facility plan, then the submitting engineer shall state this in
the facility plan and state the reason why the requirement is not applicable. The facility plan must also
include sufficient detail to support applicable requirements of Sections 501 through 552..
I have summarized the various requirements that must be addressed in facility plans for existing systems below,
with a brief now as to whether or not the submitted plan adequately addresses the issue.
1. 502.01.a -Facility Plans.
i. Hydraulic capacity - Not addressed. At a minimum, an evaluation of the hydraulic capacity
should include a map of the distribution system showing water main sizes, elevation differences,
PriflteU OP Papet
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:Jesse chan, PE
Brian Water Corporation - Facility Plan Counneuts
December 13, 2012
Page 2
dead ends, potential locations for the installation of new mains to improve system efficiencies and
reduce dead ends, etc.
U. Treatment capacity - Adequately addressed. As discussed in the report, point of use (POU) and
central treatment for nitrate removal do not appear to be viable options at this time.
iii.Standby power - Not addressed. Please see referenced ESS related to auxiliary power.
iv.Redundancy— Not adequately discussed in report. While system will eventually be required to
provide redundancy, alternative methods ofpEvidiflg redundancy such as equalization storage:
blending were not folly Investigated.
V. Fire flows— Not addressed. DEQ understands fire flow is not provided (i.e. no fire hydrants) If
so, please note in report.

Vi Project financing - Not addressed. As system is currently pnvately owned, project financing
options are somewhat limited. Report should investigate what options are available under current
ownership and also under potential homeowners' association ownership, to include user charges
and other sources of income.

vu Operation and maintenance considerations - Not adequately discussed in report.
2.502.04.a -New public water system facility plan requirements (to be included in existing public water
system facility plans per 502.041)
L Location - Adequately addreed

ii Population - Adequately addressed
iii. Sources of water - Adequately addressed, however, potential interconnection with local approved
water utility and drilling addRional wells into deeper aquifer should be more thoroughly
investigated For instance, the estimate for connecting to the approved water utility does not
discuss possible easement issues if construction is planned outside of the Warm Springs right-of-
way, and does not discuss other construction coats such as traffic control if construction is planned
inside the right-of-way Similarly, it is unclear whether the new well estimates included all steps
required to construct a new community public water supply well For instance, pitless adapter/unit
costs and connection to a new or existing puinphouse piping costs do not appear to be included in
the well estimates.
iv, Treatment - Adequately addressed
V. Water quantity - Not adequately addressed - As the existing wells ac not metered, it is difficult
to tell exactly how much water is required by the system. Some sort of means to establish
verification with the supplied calculations and actual water usage should be investigated.

vi Storage - Not addressed - The current hydropneumatie tank is not discussed at all, and the
potential for an elevated storage or ground storage at a higher elevation should be evaluated if
reduced well production is planned to be oet with equalization storage

vu Operating pressure - Not addressed. Pressure ranges for all flow conditions must be addressed

Viii Sewage - Not addressed. Please see ride language for requirements (50204 a viii)
3.502.04b - Existing public water system facility plan requirements
i. Hydraulic analysis - Not required by DEQ at this time.

ii Identify and evaluate problems - Adequately addressed

in Financing methods - Not addressed. See above
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Jesse Cban, P.R
Brian Water Corporaticui —Facility Plan Comments
December 13,2012
Page 3
iv. Anticipated charges for users - Not addressed. See above.
V. Organizational and sinifing requirements - Not addressed. Report should discuss operator
certification, potential HOA organization if proposed, etc.
vi.Project recommendation for client consideration - Addressed in report but as discussed above,
potential options should be more thoroughly 'invesdg.
vii.Outline official actions and procedures to iinleinent the project. Not addressed.
When the Facility Plan is approved, a project Mmific Pwbmwary Prelim Engineering Report (PIR) addressing the nitrate
contamination issue may then be submitted to DEQ ftr review. The PER must be submitted prior to submission of
any plans and specifications. Should Brian Water Corporation decide to construct a new well, well construction
plans and specifications may be submitted concurrently with a PER.
Please do not hesitate to contact me at 208-373-0274 or via e-mail at mike.piechowski(ädeqidaho.aov. if you have
questions.
Sincerely,
Mlkc Piechowski, P.E.
Water Quality Pngmcer
MP:sjt
C: Tony Bowar, Brian Water Corporation
PDF: Mike Stanibulis PE., DEQ State Office
Todd Crutcher, P.E., DEQ Boise Regional Office
TRIM Doe ii 2012AGD4033