New Mexico Environment Department

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SANITARY SURVEY REPORT
For
Casas Adobes Water System
NM3510209
Este informe contiene información importante acerca de su agua potable.
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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.
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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.
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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
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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
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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.
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