SANITARY SURVEY REPORT For Casas Adobes Water System NM3510209 Este informe contiene información importante acerca de su agua potable. Haga que alguien lo traduzca para usted, o hable con alguien que lo entienda. Prepared by: Ernest Valenzuela New Mexico Environment Department 1170 N. Solano Dr. Suite M Las Cruces NM 88001 575-524-6300 March 20, 2015 State of New Mexico Environment Department Drinking Water Bureau 1170 N. Solano Dr. Suite M Las Cruces NM 88001 RECORD OF INSPECTION This Sanitary Survey Report fulfills the requirements of New Mexico Administrative Code 20.7.10.100 incorporating 40 Code of Federal Regulations 141.21(d) (ii) (2) and 142.16(o)(2) for completing a State approved survey. The information and data was prepared by Ernest Valenzuela. NMED APPROVING AUTHORITY: ______________________________ Date: ________________ Casas Adobes Water System Sanitary Survey Report 2015 Page |3 Introduction A sanitary survey enables the NMED Drinking Water Bureau Water (DWB) to provide a comprehensive and accurate review of the components of a water system, to assess the operating condition and adequacy of the water system, and to determine if past recommendations have been implemented effectively. The purpose of the sanitary survey is to evaluate and document the capabilities of the water system's sources, treatment, storage, distribution network, operation and maintenance, and overall management to ensure the provision of safe water. As part of a sanitary survey the DWB conducted a site inspection of the Casas Adobes water system. The site inspection was conducted by Ernest Valenzuela, and accompanied by NMED Capacity Development Coordinator Mr. Karl Pennock along with the water system operator, Mr. Leonard Sandgren. In addition to the site inspection, DWB reviewed various documents submitted by the water system and conducted a review of DWB compliance files for the water system. System Description The Casas Adobes Water System, is a community system, serves a population of 343, and consists of two production wells, three steel storage tanks with a total storage capacity of 30,000 gallons, a distribution system composed of PVC and consisting of 150 service connections. Water from the wells supplies the two lower storage tanks, where it is boosted to the upper storage tank via a submersible pump. The water then gravity flows from all three storage tanks into distribution. Survey Findings Sanitary surveys serve as a proactive public health measure and can provide important information on a water system’s design and operations, can identify minor and significant deficiencies for correction before they become major problems, and can improve overall system compliance. The following significant and minor deficiencies were identified during the sanitary survey. Significant Deficiencies: A significant deficiency is defined as any deficiency that is causing or has the potential to cause a threat to public health [New Mexico Administrative Code (NMAC) 20.7.10.100 incorporating 40 Code of Federal Regulations (CFR) §141.403(a)(4)]. Water systems must consult with DWB within 30 days and take corrective action for any significant deficiencies found during the sanitary survey no later than 120 days after receiving written notification of such deficiencies, or be in compliance with a DWB-approved schedule and plan for correcting these deficiencies within the same 120 day period [NMAC 20.7.10.100 incorporating 40 CFR §141.403(a)(4) and §141.403(a)(5)(i)-(ii)]. Failure to remedy any significant deficiency will result in a treatment technique violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. A total of eleven (11) significant deficiencies were identified at the Casas Adobes water system during the survey. 1. (SDWIS code006Q), Insufficient number of valves. Regulatory Citation: 40 CFR 141.63(d)(3): Operation/Management; Direct Contamination; Lack of valves in the distribution system creates excessive water outages during repair of leaks or line breaks. Water outages can result in bacteriological contamination or backflow events. Casas Adobes Water System Sanitary Survey Report 2015 Corrective Action: 2. 3. Page |4 Casas Adobes water system shall install valve to isolate water line breaks eliminate water outages throughout the whole distribution system. Casas Adobes water system must consult with the DWB within 30 days. Deficiency: (SDWIS code 006P), Pressures in the distribution system are too high (100psi) or too low (20 psi). Regulatory Citation: 40 CFR 141.403(a)(4): Operation/Management; Extreme high pressures could cause an increase in water line breaks. Breaks in the distribution lines could introduce contaminants and/or microbes into the system. Extremely low pressure could lead to backflow occurrences. Corrective Action: Casas Adobes shall maintain high and low pressures by installing (PRV) pressure reducing valves on the main line down from the storage tanks to insure proper pressure thru out the distribution. Deficiency: (SDWIS code 001W-004B), Inadequate or lack of an emergency operations plan. Regulatory Citation: 20.7.10.400.E NMAC 40 CFR 141.403(a)(4): Operation/Management; Lack of an adequate Emergency Plan could lead to extended delays in supplying safe potable drinking water during minor or major emergencies. Public Water Systems that assess their vulnerabilities and adopt thorough emergency response plans are minimizing the likelihood of major delays in supplying safe potable drinking water to their customers. Corrective Action: Casas Adobes shall start an Emergency Response Plan. An ERP guide is enclosed with this Sanitary Survey. (SDWIS code001V), Inadequate or lack of an operations and maintenance plan or necessary operational policies. Concern/Description: Corrective Action: 20.7.10.400.E NMAC: An Operation and Maintenance Plan is an essential part of any water supply system. The manual should summarize the actions necessary to identify those steps required for cost effective, efficient, safe, and reliable project start-up and continued successful operation. A proper plan should result in a flawless transition from one operator to the next. Lack of a proper O&M plan could result in insufficient operation of the water system as well prolonged water outages during emergency situations. Lack of an adequate O&M plan can result in poor treatment decisions, failure to monitor; equipment failures; inability to obtain needed services or parts, and improper operation of facilities. Casas Adobes water system shall maintain an O&M plan. An O&M plan guide is enclosed in the Sanitary Survey. Casas Adobes Water System Sanitary Survey Report 2015 4. 5. 6. 7. Page |5 Deficiency: (SDWIS code 003Q) Required records not kept on site. Regulatory Citation: 40 CFR 141.33: Confirmation/Monitoring. Failure to maintain records on site will affect the operator’s ability to make process control decisions for treatment, operational decisions for system maintenance and system monitoring requirements. Corrective Action: Casas Adobes water system shall keep all files in an organized manor of all correspondence, sanitary surveys, analytical reports form lab, (i.e.) IOC, SOC, VOC and financial documentation. Deficiency: (SDWIS code 001K) Inadequate surface construction or missing appurtenances at well or spring box (e.g. vent, check valve, flow meter, isolation valves, pressure gauge, air/vacuum valve, etc). Regulatory Citation: 20.7.10.400.C NMAC: Direct Contamination, Delivery, Treatment. Improper surface construction or lack of appurtenances may allow contamination of the source, failure of pumps, damage to casings, damage to discharge lines, inability to provide adequate treatment or process control decisions, or determine water loss. Corrective Action: The Casas Adobe water system shall clean the turbine pump which is full of dirt and oil, the vent screen needs cleaning to prevent over heating of the pump. The concrete slab is broken and detreating which may contaminate the well. The flow meter is not operating properly when the pump is in production, the meter fluctuates from 50 to 100gpm which is unreliable. The discharge valve leaks, the valve gasket shall be replaced to prevent contamination of the drinking water supply. Deficiency: (SDWIS code 002D) Materials in contact with potable water are not approved for use in PWS. Regulatory Citation: 20.7010.400.K NMAC: Direct Contamination, Delivery. Materials which are not approved for use in drinking water may fail prematurely or introduce contaminates into the drinking water supply. Corrective Action: During the course of the survey it was noted that JB Wells stop leak and other materials were used to seal holes on north storage tank. Also WD40 lubrication was use at the upper storage tank target cable. These materials are not standard ANSI/NSF certified for potable drinking water and are not to be used as such. Deficiency: (SDWIS code 004T) No road /access to the storage tank facility. Regulatory Citation: 40 CFR 141.403(a)(4): Casas Adobes Water System Sanitary Survey Report 2015 Page |6 Operation/Management. Improper or no access to water system facility such as a storage facility could lead to the inability to maintain these facilities during emergency situations. It is unable to operate or maintain facility. Corrective Action: The Casas Adobes water system shall construct a road for access to the upper storage tank for proper operation and maintenance. (SDWIS code 006J): Inadequate number of flush hydrants and or inadequate flushing program. Regulatory Citation: 40 CFR 141.63(d)(3): Direct contamination; lack of proper flushing and low water use can result in water having a long residence time in the which can result in production of disinfection by-products or a reduction in chlorine residuals. Corrective Action: The Casas Adobes water system shall install fire hydrants for fire protection and flushing program. Regulatory Citation: (SDWIS code 005I): System revenue is inadequate to maintain facilities and operations. Regulatory Citation: 40 CFR 141.403(a)(4): Condition indicates a failure to properly operate, maintain, manage, or financially support the system, such that it is unable to provide a reliable, adequate supply of safe drinking water. Corrective Action: 8. The Casas Adobes water system shall submit these documents, If the owner of the system charges independently for water service current water system budget and most recent budget comparison, If the owner of the system charges independently for water service - Water rate and fee schedule Deficiency: (SDWIS code001N): Storage tank facility has leaks Regulatory Citation: 20.7.10.400.D NMAC: Leaks are located in a portion of the facility which does not always maintain pressure and are large enough to potentially result in structural failure of the facility. Leaks in an area with no water pressure can result in the introduction of foreign materials into the facility. Corrective Action: It is advised that Casas Adobes water system remove and or replace the north storage tank before structural failure accrues. Casas Adobes Water System Sanitary Survey Report 2015 Page |7 Minor Deficiencies: The following are minor deficiencies which DWB recommends be corrected before the next sanitary survey to ensure the deficiencies do not become significant. 9. Deficiency: (SDWIS code 004M): Inadequate storage facility foundation Regulatory Citation: 40 CFR 141.403(a)(4): Storage facility’s foundation appears unleveled or maybe settling. Inadequate or unmaintained storage facility foundations could lead to extensive costly damage to the storage tank as well as interruptions in adequate storage capacity. Corrective Action: It is advised that Casas Adobes water system follow these recommendations. AWWA recommends that a thorough structural and coating inspection be carried out approximately every five years. This inspection should be performed by National Association of Corrosion Engineers (NACE) certified inspectors and according to AWWA D101-53, “AWWA Standard for Inspecting and Repairing steel water tanks, standpipes, reservoirs, and elevated tanks for water storage”. Conclusion The sanitary survey for the Casas Adobes water system was completed on March 5, 2015. Based upon the onsite inspection and review of various operational and managerial documents and of DWB compliance files, (11) eleven significant deficiencies were identified and (1) one minor deficiencies was identified. The Casas Adobes water system must comply with the following bullets in the correction of these deficiencies. Upon receipt of this report, the Casas Adobes water system must consult with the DWB within 30 days for all significant deficiencies (i.e., provide written documentation to DWB within 30 days of receipt of this report stating how and when each significant deficiency will be addressed). Failure to consult with DWB within 30 days on all significant deficiencies will result in a monitoring and reporting violation of NMAC 20.7.10.100 incorporating 40 CFR Par 141 Subpart S. The water system must take corrective action on all significant deficiencies no later than 120 days after receiving written notification of such deficiencies, or be in compliance with a DWB approved schedule and plan for correcting these deficiencies within 120 days. Failure to correct any significant deficiency in accordance with the previous bullet will result in a treatment technique violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. In addition, the Casas Adobes must provide written documentation to the DWB within 30 days of completing corrective action for each significant deficiency. Failure to submit documentation within 30 days will result in a monitoring and reporting violation of NMAC 20.7.10.100 incorporating 40 CFR Part 141 Subpart S. If you have any questions or need additional clarification concerning this report please call Ernest Valenzuela at 575.524.6300 or e-mail ernest.valenzuela@state.nm.us.