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Sanitary Survery 2015 NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 P W S IDA: 1214000 PAGE 2 or 2 MassDEP requires that NWD submit an updated staffing plan to reflect the primary and secondary Certified Operators in charge of water treatment operations before May 31,2015. Questions regarding this document,or other drinking water issues, should be directed to Jim Bumgardner at (413)755 2270. Res,eco Ily tfk r Deird h Doherty, Section Chief Drinking Water Program Bureau of Water Resources Attachments: Sanitary Survey Report cc: Board of Ileallh—Northampton,Boston—DWP,Jim Bumgardner,MassDEP WERO,Greg Nuttleman WERO File W:BRP\WS\CCE-SS NorthamptoM1214000-Northampton Water Dept\Northampton Water Deptjbumgardner- Sanitary Survey-2015.docx Charles D. Baker Governor Karyn E. Polito Lieutenant Governor �G5 ��2q�I5 Commonwealth of Massachusetts Executive Office of Energy & Environmental Affairs Department of Environmental Protection Western Regional Office•436 Dwight Street, Springfield MA 01103.413-784-1100 Mr-Edward Huntley, DPW Director Northampton Water Dept 125 Locust Street Northampton,MA 01060 Dear Mr.Huntley, April 21,2015 Re: Northampton-DWP Northampton Water Dept PWS ID#: 1214000 Sanitary Survey Matthew A. Beaton Secretary Martin Suuberg Commissioner On April 9,2015,Jim Bumgardner of the Massachusetts Department of Environmental Protection (MassDEP),Drinking Water Program(DWP)conducted a Sanitary Survey of the Northampton Water Department(`NWD")public water system. A sanitary survey is an on-site review of the water sources, facilities,equipment,operation and maintenance of a public water system for the purpose of evaluating the system's ability to produce and distribute safe drinking water. The enclosed report includes the system description,findings and compliance plan. During the course of the survey,MassDEP identified areas in which improvements in the administration,and operation and maintenance of the system could be made. MassDEP's evaluation of the water system, and the specific required and recommended actions,were discussed during a debriefing meeting with Greg Nuttleman and David Sparks. This report contains time sensitive requirements,which are summarized in the Compliance Plan Tables. Please review the items noted in the report and Compliance Plan Table B,and return the signature page to MassDEP by May 31,2015. Specifically,MassDEP requires the following actions to remedy items noted in the inspection: An assessment of this public water system's capacity was conducted by MassDEP for the last sanitary survey report, dated May 30,2012. There have been no changes in the management of the system since that survey. No violations of Drinking Water Regulations were noted during this survey. Therefore, MassDEP has determined that this system continues to demonstrate Adequate Capacity. NWD has an infrastructure inventory for all major components of its water system. However, MassDEP has determined that NWD does not have a written list of the useful life expectancy of its assets or a long- term asset replacement plan with a schedule for replacing those assets. MassDEP requires that NWT/ create and submit an Asset Management Plan with written estimates of the useful life of all assets within its infrastructure inventory and a schedule for replacing those assets before May 28,2016. During the survey,NWD indicated that it has employed a new treatment operator,Andrew Dunn(2T- OIT). MassDEP does not have an updated staffing plan indicating the status of the new operator. Electronic File Location:Y:A DWP A¢hiveA WEROA Northampton-1214000-55-2015-0-1-21 The signature on this cover letter indicates formal issuance of the attached document. This information is available In alternate format.Call Michelle Waters-Ekanem,Diversity Director,at 617-292-5751.TTY MassRelay Service 1-800-439-2370 MasSDEP Webslle_waveamass-govfdep Printed on Recycled Paper NORTHAMPTON WATER DEPT PWS ID#: 1214000 INSPECTION DATE:APRIL 9.2015 Page 2 has a plan to appropriate funding to make substantial improvements to the dams and dikes at all three reservoirs subject to City Council approval. The Mountain Street Reservoir is a 330 million gallon reservoir constructed in 1906 at the headwaters of Beaver Brook in Williamsburg with a spillway elevation of 459 feet and an intake elevation of 435 feet. According to the 1995 study, the Mountain Street Reservoir has a safe yield of 0.632 mgd. Mountain Street Reservoir is fed by discharge from the West Whately reservoir and storm water runoff from the adjacent hillsides. A portion of the adjacent drainage area to the north of the reservoir is diverted around the reservoir by a system of dykes and a swamp drain. The swamp drain discharges south of the Mountain Street Reservoir darn via a pipe along the bottom of the reservoir. Discharge over the Mountain Street Reservoir spillway enters Beaver Brook and eventually flows to the Mill River in Northampton. Currently only about 10% of NWD's surface water comes from the Mountain Street Reservoir as the transfer pumps are run about one week per month. Water from the Mountain Street Reservoir cannot feed the WTP by gravity and must be pumped using a pump station located next to the dam. The October 1995 study contains an additional 1.523 mgd yield due to the flexibility offered by cooperative operation of the Ryan, West Whately, and Mountain Street Reservoirs. The approved cumulative safe yield for the Ryan, West Whately,and Mountain Street Reservoirs is 5.043 mgd. Groundwater Supplies N WD operates two groundwater wells to supplement the surface water sources. Both wells were installed in gravel deposits in the 1950s and are equipped with vertical turbine pumps housed in pumping stations. The Clark Street Well #1 is finished at 85 feet in depth and is equipped with a 75 hp motor and is capable of producing 1 MGD (See Photo No. 5). The Spring Street Well #2 is finished at 88 feet in depth and is equipped with a 60 hp motor and is capable of producing about 0.8 MGD. Substantial upgrades were completed at both wells in 2011. The upgrades included well cleaning and redevelopment, installation of a valve control and meter pit, complete electrical panel upgrades, new controls and alarms, and sodium hypochlorite injection equipment. Previously the wells were run off of a timer, but can now be controlled locally or remotely through the SCADA system. The wells will automatically shut down once the discharge pressure reaches 90 psi which equates to 120 psi in the downtown area. Neither well house is equipped with emergency power, but are equipped to run on portable generators. Both well stations are checked daily regardless of whether or not they are being used. Storage: Primary water storage is provided by the WTP cleanvell which was installed as part of the WTP upgrade in 2008. The WTP clearwell is a 4 MG partially buried concrete storage tank with a concrete roof The tank has a central ring and outer ring which are physically separated. The tank is operated as two separate storage tanks with a common intake elevation and discharge elevation. The inner ring and outer rings share a common overflow pipe which is about 10 feet below the top of the tank. The entire City of Northampton is served by gravity from the WTP storage tank, with the exception of a small section in the Audobon Road area. In addition to the 4 MG of storage at the WTP clearwell, a single distribution storage tank serves a small area of higher elevation in the Audubon Road area. The Audubon Road storage tank is an elevated steel tank with a volume of 200,000 gallons that was constructed in 1935 on Audubon Road in Leeds. The tank was last painted in 1999. A thorough inspection of the interior and exterior of the tank was conducted in 2010 and no significant deficiencies were found. During the sanitary survey inspection,the tank coating appeared to be in very good condition. SANITARY SURVEY REPORT Northampton Water Dept April 21, 2015 GENERAL DESCRIPTION The description of the water system is updated from that reported within MassDEP's May 30,2012 sanitary survey report. General: The water supply system for the Northampton Water Department (NWD) includes both groundwater and surface water sources. The surface water supply consists of three reservoirs: Frances P. Ryan (Ryan), West Whately,and Mountain Street. NWD also maintains a fourth reservoir,the Roberts Meadow Reservoir,as an emergency source. The groundwater supply consists of the Clark Street Well(Well#1)and the Spring Street Well (Well #2). NWD is governed by the Public Works Commission and City Council. NWD is financed through an enterprise fund with its water rates approved by the City Council(new in 2015). Water Rates are currently$5.58 per 100 cubic feet. Source: NWD is served by three surface water reservoirs and two groundwater wells. The three reservoirs are Ryan, West Whately,and Mountain Street. The two wells are known as the Clark Street and Spring Street wells. The Ryan Reservoir is a 720 million gallon reservoir constructed in 1971 on Avery Brook north of and adjacent to the West Whately Reservoir. The reservoir was originally designed and operated to provide additional storage for the West Whately/Mountain Street system. In the mid-1990's the water mains were reconfigured to allow Ryan Reservoir operate as an independent water source. Ryan Reservoir is currently the primary source of water for NWD and the WTP draw raw water directly from Ryan. The reservoir is fed by Avery Brook and other unnamed streams. The spillway has an elevation of 675 feet and the overflow discharges to West Whately Reservoir. There are three different intake levels in the gatehouse and normally the middle intake is used. The middle intake elevation is approximately 630 feet. According to a 1995 study, the safe yield of the Ryan Reservoir is 2.616 million gallons per day(mgd). The combined watershed for the Ryan and West Whately reservoirs extends from Whately into the towns of Williamsburg and Conway. The West Whately Reservoir operates as a diversion dam on West Brook with discharge to the Mountain Street Reservoir which is not located in the West Brook drainage basin. West Whately is a 25 million gallon reservoir constructed in 1905 in Whately. West Whately Reservoir has a spillway elevation of 596 feet and an intake elevation of 582 feet. It is fed primarily by an upper tributary of West Brook. Source water originating from the West Whately Reservoir, flows cross-country through a 20" diameter cast iron transmission line that discharges to an open channel. The open channel stream is referred to locally as Borowski Brook and runs for approximately 4,000 feet adjacent to Mountain Street before discharging to the Mountain Street Reservoir. According to the "Final Report To The City Of Northampton Analysis Of Reservoir", Metcalf& Eddy, October 1995, the safe yield of the West Whately Reservoir is 0.272 mgd. Spillway overflow from West Whately enters West Brook and eventually the Mill River in Hatfield. NWD NORTHAMPTON WATER DEPT INSPECTION DATE: APR11.932015 P W S ID#: 1214000 Page 4 and discharge lines along Mountain Street between the WIT and the Mountain Street Reservoir All three reservoirs have been physically separated from the Northampton distribution system by the WTP. The NWT) distribution system consists of approximately 156 miles of water mains ranging in size from 4 to 24 inches in diameter. Water mains are constructed of Cast Iron, Ductile Iron, Asbestos Concrete(AC). All PVC pipe has been replaced. Based on the 2011 Annual Statistical Report,there are a total of 8,667 metered service connections on the distribution system. Treatment: Northampton initially installed disinfection by gaseous chlorine using a chlorination station near the Leeds Pump Station and Audubon Road Tank. In 1993 and 1994, chlorination stations were constructed along the Ryan Road and Mountain Street Reservoir transmission mains(Chlorination Stations#1 and#2 respectively). These two stations were upgraded to improve safety and ease of operation in 1997. These stations no longer provide disinfection and there is no longer any capacity to use gaseous chlorine in any location. The results of the lead and copper monitoring conducted July I and December 31, 1992 in NWD indicated that concentrations in the distribution system were above the action levels requiring treatment for corrosion control. In 1999/2000, the Corrosion Control facility was installed along Route 9 upstream of the Beaver Brook crossing. In 2006, monitoring detected concentrations of chlorination byproducts above regulatory action levels. The new WTP placed on line in January 2008 provides filtration,corrosion control,and disinfection. Distribution System Disinfection The chlorination station located on Water Street in Leeds formerly provided booster chlorination to water conveyed in the 20-inch Mountain Street transmission main. Although daily chlorine residual, pH, temperature, color, and turbidity monitoring continues at the facility, the Leeds Chlorination Station has not been used as a point of chemical application since the WTP was placed on line. The gas chlorine cylinders have been removed. Chlorination Stations #1 and#2 on the Ryan and Mountain Street transmission mains respectively have also not been operated since the completion of the WTP. The Chlorination Station#2 building and injection point are to be maintained for emergency use. In an emergency including loss of the WTP, a temporary connection from the Mountain Street Reservoir to the Mountain Street transmission main can be made upstream of Chlorination Station #2 (by inserting a spool piece) and chemicals can be added for disinfection or other purposes. Corrosion Control Facility The Corrosion Control Facility was constructed in 1999 and placed on line in February 2000. Up until the new WTP went on line, the Corrosion Control Facility was used to inject both sodium hydroxide (p11 adjustment) and liquid zinc orthophosphate (corrosion inhibitor) into the 20-inch and 36-inch water source transmission lines. Sodium hydroxide is now injected up at the new WTP and only zinc orthophosphate continues to be injected at the Corrosion Control Facility. Northampton Water Treatment Plant(WTP) The Northampton WTP is located in Whately on the west side of Mountain Street at the south end of the Mountain Street Reservoir. The WTP receives and treats water from the Ryan and Mountain Street PWS ID#: 1214000 IN SPEC PION DA`WAlexL 9,2 Page 3 INSPECtION DATt1: APRIL 9,2015 A pump station located on Math Street in Leeds(referred to as the Leeds Pumping Station)transfers water to the Audubon Road storage tank, creating a high elevation pressure zone for the Leeds service area. The pump station consists of two centrifugal booster pumps,one controlled by a variable frequency drive(VFD). Booster pump operation is controlled by the water level in the storage tank. The pumps come on at 16 feet, shut off at 18.5 feet and the overflow alarm is set at 20 feet. A 50 KW generator was installed outside the pump station in 2007. The generator is exercised automatically on a weekly basis. After a new subdivision was constructed, controls were put into the pump station so that if the pressure drops below 80 psi, and the tank is full,the variable speed pump will operate to maintain distribution system pressure. The following additional storage tanks located on the system are not in use: The Turkey Hill Road storage tank is a ground level steel tank constructed off of Turkey Hill Road in Florence in 1987. The tank was taken off line in 1995. A 500,000-gallon steel storage tank was constmcted in the 1980s adjacent to the Roberts Meadow Reservoir in Leeds. Water supply system plans involving the use of this tank changed after its installation. The tank has never been connected to the distribution system and has never been used. Distribution: Northampton reports a total of 12.3 miles of transmission water mains. There are two surface water transmission lines in addition to the 20-inch pipe connecting the West Whately and Mountain Street Reservoirs. The Mountain Street Reservoir transmission main is a 20-inch diameter cast iron cement lined pipe extending from Mountain Street Reservoir to the NWD distribution system. The 20-inch main travels approximately 4 miles along Beaver Brook to the chlorination house in Leeds. The Ryan Road Reservoir transmission main is a 24/36-inch diameter ductile iron line constructed in 1994. The 24-inch diameter section is located between the Ryan Road Reservoir and the Ryan Pressure Reducing Chamber. The 36-inch diameter pipe extends along Mountain Street and Route 9 from this junction to the NWD distribution system. Treated water leaving the WTP clearwell passes through pressure reducing valves located in a below grade pit adjacent to the dike of the Mountain Street reservoir. These pressure reducing valves serve to minimize the potential for high pressure transmission line breaks as the main travels cross country through the wet areas along Beaver Brook. Enroute to the Northampton distribution system,the 20-inch and 36-inch transmission mains cross at several locations and run parallel along a 4,000 foot section of Route 9 adjacent to Beaver Brook. The two mains have several interconnections to provide redundancy in transmission from the WTP. The interconnecting valves are normally closed to maintain independent flow within each main. Each main passes through a pressure reducing valve at the Beaver Brook Pressure Reducing Chamber located at the Route 9/Beaver Brook crossing and installed in 1995. The pressure reducing valves in this chamber help equalize flows through the two transmission mains into the City. Twice a year the valves are serviced by an outside contractor. The 2008 addition of the Northampton WIT included reconfiguring the source water transmission mains and changed the operation of the Mountain Street and Ryan Road Reservoir. The transmission main from the West Whately Reservoir to Borowski Brook was not changed. The Mountain Street transmission line was intercepted by a new pumping station (the Mountain Street Pump Station). The pumping station transfers Mountain Street Reservoir water to the WTP (See pump station description in WTP section). The remainder of the Mountain Street transmission main has been connected to the discharge from the WTP and conveys treated water to the Leeds Pump Station. The Ryan transmission line was intercepted by the WTP influent NORTIIA4PTON WATER DEPT INSPECTION DATE: APRIL 9,2015 r Chemical Supply Ty.e Application Point Potassium Dry Raw Water prior to Permanganate WTP at Chemical Manholes Aluminum (Alum) Coagulant Aid Polymer Superfloc C572 Sodium Carbonate Sulfate Concentrated Li.uid Dry or Liquid Raw Water in WTP nior to Static Mixer Raw Water in WTP prior to Static Mixer Dry Sodium Carbonate Dry Raw Water in WIT prior to Static Mixer P W S ID#: 1214000 Page 6 Purpose Oxidizer to aid iron/manganese removal, taste or odor p oblems Coagulant for removal of non-settable solids Status Not currently in use Currently in use Sodium Concentrated Hypochlorite Liquid Sodium Concentrated Hypochlorite Liquid Sodium Concentrated Hypochlorite Liquid Sodium Concentrated Hy °chlorite Liquid Finished Water Troubleshooting and Currently in use correction of Coagulation problems Stabilize alkalinity and Not currently in use facilitate the Precipitation of solids in the adsorption clarifier Increase alkalinity as Currently in use needed for Corrosion Protection Raw Water in WTP prior to Static Mixer Filtered Water prior to Chlorine Contact Tank/Clearwell Pretreatment - special problematic conditions only Primary Disinfection Not currently in use Currently in use Finished Water Filter Backwash Water Table 1: Treatment Chemicals Available for use at NWD Chemical spill containment around the bulk storage and chemical feed tanks is achieved by concrete berms and sumps that can be directed to either the sludge lagoons or to an outside tanker (third party vendor), depending on the severity of the spill. Additional disinfection boost Periodic intense filter cleaning Not currently in use Not currently in use Clarification: Clarification is achieved by flocculating and filtering solids in the raw water supply. After the thorough incorporation of alum and polymer through the static mixer,the chemically treated water flows by gravity to the TriconTM Adsorption Clarifiers. These three prefabricated units are high rate upflow clarifiers that remove flocculated solids by adsorption to the buoyant plastic clarifier media. The units operate on staggered timers and/or pressure sensors that indicate when the media is loaded with solids. Solids are removed by backwashing the clarifier media with compressed air. Backwashing occurs automatically every 6 hours and only one of the three units is backwashed at a time. Once the solids have been separated from the media, influent to the unit resumes. Automatic mechanized valves are used to direct the slurry to the equalization basin and drying lagoons as influent is flushed through the clarifier to waste for a set period of time. The valves then reset to pass influent through the clarification units to the filters. PWS ID#: 1214000 NORTHAMPTON DATE:WATER L 9,2015 Page 5 iNSPECTTONDATE: APRIL 9,2015 Reservoirs. The WIT is designed for a peak delivery of 6.5 mgd that includes 0.6 mgd for filter backwash. The minimum and average design flows are 1.5 mgd and 4.2 mgd respectively. The treatment processes included at the facility include chemical addition and mixing, clarification, filtration, pH adjustment, and disinfection. Finished water flows by gravity from the WTP clearwell to the NWD distribution system. Chemical addition, clarification, filtration, and system control functions take place inside the main building. Combination disinfection retention and finished water storage are provided by the 4-million gallon chlorination contact tank/clearwell installed below ground adjacent to the main building. Wastewater generated by the treatment processes is also managed at the WTP site by means of an equalization basin and parallel settling and freeze drying lagoons. NWD has a"Beneficial Use Determination" or BUD to use the material as cover on the City's landfill,however the Northampton landfill is now closed. Freeze-dried sludge is now sent to the active Chicopee landfill. NWD has a 560 kW propane-fired emergency backup generator that is capable of running all WTP functions in an extended power outage. NWD maintains adequate propane storage to keep the WTP running for at least 4 weeks. Water from Mountain Street Reservoir can be transferred into the WTP via a new pump station and a 20-inch transmission main. The Mountain Street Pump Station consists of three 12-inch 200 HP horizontal double suction pumps. The pumps have manual and automatically controlled variable speed drives with a maximum rating of 3,400 gpm each. The pump station includes provisions for connection a portable emergency generator. Plans are in the works to provide a permanent emergency generator for the station. Flow from Mountain Street Reservoir is measured by a venturi flow meter located at the lift station. Mountain Street flow data is transmitted displayed at the WTP. Water from the Ryan Reservoir flows by gravity through a 24-inch diameter main into either the WTP or Mountain Street Reservoir. Normally, 100 percent of the Ryan Reservoir flow is directed to the WTP. Flow from the Ryan Reservoir is measured by a 20-inch magnetic flow meter located in the basement of the WTP upstream of the junction with the Mountain Street Pump Station discharge. Total flow into the WTP is calculated as the sum of the Ryan Reservoir magnetic meter and Mountain Street Lift Station venturi meter flow rates. Chemical Addition: The NWD WTP has provisions for feeding five different chemicals at a number of locations along the treatment process. These systems provide iron and manganese removal, raw water coagulation, pH stabilization/corrosion control, and disinfection. The type and location of each chemical feed system, the purpose for the chemical,and the current status of use are summarized in the following table: NORTIIAMpI ON WATER DEPI INSPECTION DATE: APRIL 9.2015 PWS ID#: 1214000 Page 8 Additional Treatment Under Consideration: Provisions for future additional chemical addition include piping taps for the addition of fluoride to the filtered water and for the addition of coagulant polymer upstream of the lagoons to aid in solids separation. Connections are also provided for the future addition of ultra-violet disinfection. Northampton is also considering relocating the orthophosphate injection equipment from the Corrosion Control Building on Route 9 to the WTP. WTP ID 1214000-041' WTP Name Corrosion Control Facility 1214000-08T Northampton WIT L_ Table 2: Treatment Plants and Components Class II-T Treatment Description Orthophosphate Inhibitor III-T Coagulation,Clarification,Filtration, Disinfection and pIl Adjustment 1: SCADA Control Scree Photo#3: Process Control Center Photo#4: Sodium Hypochlorite Bulk Storage NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 P W S 1Dtt: 1214000 Page 7 Filtration: Clarified water is polished through four high rate deep bed granular activated carbon filters (five feet deep). The GAC media provides both filtration and adsorption to remove any flocculation carry,reduce turbidity, and correct potential taste/odor problems. Each of the four filters functions independently of the others with pressure automated valves that maintain a constant head over the filter. Backwashing is staggered and is initiated by manual timers (72 hrs), turbidity breakthrough (0.3 NTU), and/or head loss (6 ft) —whichever comes first. Each unit is equipped with a turbidity meter. The normal automated backwash cycle includes a mixed compressed air/low water wash followed by a high water wash. First the unit to be backwashed is isolated and allowed to drain to the chlorine contact tank/clearwell until the water level extends only 2 to 6 inches above the media bed. Compressed air and washwater are then added until the water level approaches the washwater inlets. The air and washwater are then turned off to allow the media to settle. Washwater is then flushed through the filter maintaining the higher water level for approximately 15 minutes. Washwater for this process is pumped from the chlorine contact tank/clearwell. During backwashing, spent washwater flows by gravity to the equalization tank and drying lagoons. Other options for backwash operation include rapid filter draining (direct release to equalization basin/lagoons rather than infiltration through filter media to the contact tank/clearwell), backwashing the filters without the air addition, and/or omitting the filter-to-waste step and placing the filter in service directly after a high rate wash. Corrosion Control: NWD adds a solution of Sodium Carbonate (soda ash)to the filter feed water to adjust the pH for corrosion control purposes. Bulk storage includes 12,000 lbs of powdered soda ash which is approximately a three month supply. Powdered soda ash bags are added to a mixer that has a calibrated auger feed system. The treatment operators simply need to set the water feed rate, and calibrate the auger feed rate so that the mixing happens automatically and maintains an adequate level in the soda ash solution tank. NWD also injects orthophosphate at the Corrosion Control Facility immediately downstream of the WTP. Disinfection: Primary disinfection is provided by the injection of sodium hypochlorite into the filtered water upstream of the clearwell. Bulk sodium hypochlorite is stored in a 5,900 gallon bulk storage tank. Sodium hypochlorite is transferred to a smaller, 500 gallon, feed tank from which the chemical is injected directly into the filtered water effluent line without dilution. The rate of sodium hypochlorite addition is proportional to the flow from the fitters. Primary disinfection takes place in the 4 million gallon chlorine contact tank/clear well prior to the water entering the distribution system. A minimum water level must be maintained in the tank to provide adequate time for the chlorine to neutralize pathogens. Chlorine is consumed in the process. A residual chlorine concentration is needed to carry out disinfection in the distribution system. Residual chlorine concentration is monitored continuously at the discharge from the tank. Additional chlorine can be added at the discharge if needed. Sodium hypochlorite can also be injected upstream of the clarifier or to the backwash water for the filters if needed for periodic maintenance of these treatment units. The target Chlorine concentration is 1.35 mg/L. Chlorine demand drops the chlorine residual to around 1.0 mg/L entering the distribution system. It is necessary to maintain a 1.0 mg/L residual so that a measurable chlorine residual is maintained throughout the distribution system. Chlorine contact time(CT)is calculated on a daily basis. The CT ratio of observed vs.required is generally around 50:1. NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 P W S ID#: 1214000 Page 10 Photo#9: Clarifier(typical Photo#10: GAC Filter(typical) Photo#11: 560 kW Pro'ane Generator Photo#12: Freeze Drying Lagoons Photo#13 TP Chemical injection upstream Photo#14: WTP Hypochlorite Injection downstream NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 P W S TD#: 1214000 Page 9 Photo#5: H ochlorite Da Tank Photo#7: Chemical Containment Sump Pump (typical) Photo#8: RPZ protecting water system in the chemical feed area NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 _- ; jrjiFl!E PWS ID«: 1214000 Page 12 Photo#19: Soda Ash Solution Tank Photo#20: Soda As Feed Porn Photo#21: WTP Clearwell Photo#22: Clearwell Overlla Photo#23: Clearwell Vent Photo#24: Clearwell Vent Screen NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 PWS ID#: 1214000 Page 11 Photo#17: Alum Bulk Storage Tank Photo#1S: Alum Chemical Feed Pumps NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 MS S iD#: 1214000 Page 14 Photo#29: Audubon Road Tank Photo#30: Audubon Road Tank Overdo Photo#31: Spring Street Well Photo#32: Spring Street Well Standby Chlorinator NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 P W S ID#: 1214000 Page 13 Photo#25: Mountain Street Transfer Pumps Photo#26: Corrosion Control Building—Phosphate Feed S stem Photo#27: Corrosion Control Building Circulation Photo#28: Audubon Road Booster Pump Pumps NOR''HAMPTON WATER DEPT PWS ID#: 1214000 INSPECTION DATE:APRIL 9,2015 Page 16 SANITARY SURVEY REPORT Northampton Water Dept April 21, 2015 FINDINGS SECTION I: ADMINISTRATION,MANAGEMENT,AND STAFFING An assessment of this public water system's capacity was conducted by MassDEP for the last sanitary survey report, dated May 30, 2012. There have been no changes in the management of the system since that survey. No violations of Drinking Water Regulations were noted during this survey. Therefore, MassDEP has determined that this system continues to demonstrate adequate capacity. System Classification: NWD is classified as a Community(COM)public water system(PWS)because water system regularly serves at least 25 year-round residents. MassDEP has reviewed the classification status of the NWD distribution system and has determined that the distribution system should be rated as a Class III-D system because it serves a population of 29,342 residents. The NWD overall treatment system rating is Class III-T,based on the treatment system components. NWD revenue for 2014 was$6.6M. Annual expenses were$6.2M. Annual Savings were$0.6M. Annual Debt service was$0.567M. The NWD reserves were approximately$0.761M. NWD has an infrastructure inventory for all major components of its water system. However, MassDEP has determined that NWD does not have a written list of the useful life expectancy of its assets or a long- term asset replacement plan with a schedule for replacing those assets.MassDEP requires that NWf) create and submit an Asset Management Plan with written estimates of the useful life of all assets within its infrastructure inventory and a schedule for replacing those assets before May 28,2016. NWD has a Capital Improvement Plan for large equipment purchased and construction needed in the next 20 years. NWD has an Annual Budget that considers funding for personnel,training,testing,operating, contract services,repairs, capital improvement reserves, emergencies, and debt services. The NWD water rates appear to be sufficient to cover the true cost of producing and delivering safe drinking water. During the survey,NWD indicated that it has employed a new treatment operator,Andrew Dunn(2T- OII). MassDEP does not have an updated staffing plan indicating the status of the new operator. MassDEP requires that NWD submit an updated staffing plan to reflect the primary and secondary Certified Operators in charge of water treatment operations before May 31,2015. NORTHAMPTON WAFER DEPT INSPECTION DATE: APRIL 9,2015 PWS ID#: 1214000 Page 15 Photo#33: S.ring Street Raw Water Ta Photo#34: Sprin. Street Well Screened Ven Photo#35: Clark Street Well Photo#36: Clark Street Well Screened Vent NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 PWS ID#: 1214000 Page 18 Emergency Response Plan During the survey,MassDEP observed that NWD maintains its emergency response plan in a readily available location as required by the regulations at 310 CMR 22.04(13)(a). NWD conducts annual operator training on implementing its Emergency Response Plan. Consumer Confidence Report: All Community Water Systems must prepare an annual Consumer Confidence Report(CCR)as specified in 310 CMR 22.16A. The CCR must be completed and delivered to consumers by July 1 of each year. MassDEP will complete CCR reviews on a selected number of systems each year. If the NWD system is selected for review,NWD will receive a copy of a CCR compliance checklist, along with any enforcement, if applicable, by December 31,2015. MassDEP has prepared Source Water Assessment Reports for all Public Water Systems. Each system must include in the CCR Report, notification to customers of the availability of the report and the means to obtain it. SECTION 2: OPERATIONS AND MAINTENANCE NWD flushes its water distribution system I time per year. MassDEP recommends that samples for coliform bacteria be collected during the periodic flushing events to assure that system disruption does not result in bacteria problems. NWD is in compliance with MassDEP requirement that all Community PWSs have redundant sources, capable of supplying system demand with the highest capacity source off-line, or maintain two days available storage capacity. NWD has a storage capacity of 4.2 million gallons and an average daily demand of 2.78 million gallons per day. SECTION 3: TREATMENT During the survey, MassDEP observed that NWD has amOperations and Maintenance manual available for its treatment process. • NWD maintains adequate logs of its chemical feed, alarm, and control testing activities. • NWD maintains adequate chemical storage, containment, and safety equipment on site. • NWD complies with MassDEP Guidelines for critical chemicals. During the survey, MassDEP observed that there are chemical injection ports available at all wells. Handling Water Treatment Chemical Spills and Liquid in Secondary Containment The hazardous waste nature of most chemicals or chemical mixtures depends in large part on the pH. If the pA is less than or equal to 2, or greater than or equal to 12.5, it is a hazardous waste(1IW). Accordingly, the pH of any spilled material needs to be checked to see if material is hazardous waste. Options for handling the spill material depending on the pH of the material as follows: NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 Table 1 lists the personnel listed in the 2014 ASR by NWD for the operation of its completed the 2014 ASR operator information to reflect the Certified Operators in state of operational staffing). PWS ID#: 1214000 Page 17 PWS (note--NWD 2014, not the current Table 3: Northampton Water Department Certified Operators The NWD distribution operator operates the system for 2, 8 hour shifts per day,five days per week. As a Class III-D system NWD is required to support, at a minimum,the following operational staff: I. One distribution operator serving as the primary operator who holds a Grade D3 license. The primary operator must cover the distribution system 1 work shift per week,which is 7 hours per day, 5 days per week, and must be available to respond to emergencies within one hour at all other times. 2. A secondary distribution operator, holding a minimum of a Grade D2 license must be designated to cover the same hours as the primary operator in his or her absence. (i.e., during vacations, sick leave, etc.) The NWD primary treatment operator operates the treatment system for 5.5, 8 hour shifts per week. As a Class III T treatment system NWD is required to support,at a minimum,the following treatment plant operations staff: 1. One treatment operator serving as the primary treatment operator who holds a GradeT3 license. The primary treatment operator must be present at the treatment facility, a minimum of 7 hours per shift during the days when the treatment facility is in operation(including weekends and holidays) unless otherwise exempted by MassDEP in writing. 2. A secondary treatment operator holding a minimum of a Grade T2 must be designated to cover the same hours as the primary operator in the absence of the primary operator(i.e., during weekends,holidays,vacations, sick leave, etc.). The secondary Certified Operator license status may be"Operator in Training"(Off). NWD therefore will meet MassDEP's Certified Operator requirements once it submits a current staffing plan. Operator Name Grade License# Primary Distribution Primary Treatment Secondary Distribution Secondary Treatment Greg Nuttleman 3T 11444/12079 X [Dean Downer 2T OIT 22715/22730 Rebecca Smith 2T OIT 22426 Scott Ingram 2T OIT 20340 Douglas Duchanne 4T/3T 8102 [Jonathan Bean 3D 12396 X David Sparks 4D/4T 7875/9888 Matthew Wintle 2D OIT 24721 Table 3: Northampton Water Department Certified Operators The NWD distribution operator operates the system for 2, 8 hour shifts per day,five days per week. As a Class III-D system NWD is required to support, at a minimum,the following operational staff: I. One distribution operator serving as the primary operator who holds a Grade D3 license. The primary operator must cover the distribution system 1 work shift per week,which is 7 hours per day, 5 days per week, and must be available to respond to emergencies within one hour at all other times. 2. A secondary distribution operator, holding a minimum of a Grade D2 license must be designated to cover the same hours as the primary operator in his or her absence. (i.e., during vacations, sick leave, etc.) The NWD primary treatment operator operates the treatment system for 5.5, 8 hour shifts per week. As a Class III T treatment system NWD is required to support,at a minimum,the following treatment plant operations staff: 1. One treatment operator serving as the primary treatment operator who holds a GradeT3 license. The primary treatment operator must be present at the treatment facility, a minimum of 7 hours per shift during the days when the treatment facility is in operation(including weekends and holidays) unless otherwise exempted by MassDEP in writing. 2. A secondary treatment operator holding a minimum of a Grade T2 must be designated to cover the same hours as the primary operator in the absence of the primary operator(i.e., during weekends,holidays,vacations, sick leave, etc.). The secondary Certified Operator license status may be"Operator in Training"(Off). NWD therefore will meet MassDEP's Certified Operator requirements once it submits a current staffing plan. NORTHAMPTON WAFER OLD INSPECTION DATE: APRIL 9,2015 P W S ID1l:1214000 Page 20 SECTION 4: DISTRIBUTION, STORAGE AND PUMPING FACILITIES Distribution system pressure is generally in the range of 35-120 psi. All systems may be subject to a cross connection audit by MassDEP,to ascertain whether the water system is in compliance with the cross connection regulations as outlined in Section 22.22(16)(e)of the Massachusetts Drinking Water Regulations. A cross connection program review was completed during the inspection. NWD completed resurveying its facilities for cross connections in 2014. Follow up distribution system checks are conducted on a regular basis. NWD is in regular contact with the plumbing inspector whenever a plumbing permit requires assessment for cross connections and water meters. The following elements of the NWD Cross Connection program were reviewed and determined to be functioning to MassDEP's satisfaction: o NWD conducts regular annual cross connection device testing. o NWD issues written enforcement notices for cross connection violations. o NWD conducts prompt and appropriate cross connection program enforcement actions. SECTION 5: WATER QUANTITY No water quantity issues were identified during the Sanitary Survey inspection. The average daily demand for NWD was 2,780,165 gallons per day based on the 2014 Annual Statistical Report. The average daily withdrawal for NWD exceeds the Water Management Act(WMA)permitting threshold and therefore requires MassDEP approval for its withdrawal. MassDEP issues two types of approvals,for water withdrawals in excess of 100,000 gallons per day, WMA registrations and permits. Water Management Act withdrawal registrations are based on a system's water withdrawal from 1981 to 1985 and are reviewed for renewal every 10 years. The NWD WMA registration was last reviewed and renewed in 2008. MassDEP reviews WMA permits every five years. WMA registration and permit volumes are additive. The permit volume is authorized for withdrawals above any withdrawal volume registered to the PWS. The NWD authorized WMA registration and pennit volumes are as follows: Registered Withdrawal Volume: 3.96 mgd Permitted Withdrawal Volume: 0.81 mgd Total Approved Withdrawal Volume: 4.77 mgd Actual System Withdrawal based on the 2014Annual Statistics Report: 2.78 mgd NWD is therefore in compliance with the WMA water withdrawal volume requirements. WMA conservation standards have been created to insure water withdrawn from the State's water resources goes to supply the water system demand,not to waste or uses that are unaccounted for. Water Management Act residential water conservation goals are 65 gallons per person per day. Based on the 2014 Annual Statistical Report,NWD residential use is 45 gallons per person per day. The 2014 unaccounted for water(`UAW")is reported at 8.7%. The WMA UAW water conservation goal is 10%. NORTHAMPTON WATER DEPT PWS 1D$: 1214000 INSPECTION DATE: APRIL 9,2015 Page 19 1. If the pH is Q and?12.5,the spill material needs to managed in accordance with 310 CMR 30.000, as corrosive Hazardous Waste (Waste Code D002). PWS's have the option of neutralizing the material (Elementary Neutralization)as long as the primary material is HW for"corrosivity only". Once the PWS neutralizes the material, it can be handled as Industrial Wastewater(BMW). For example, if sodium hypochlorite or sodium hydroxide is spilled into containment has a pH of 1.00,the public water system can neutralize this particular spill material and dispose as Industrial Wastewater(IWW). Dispose liquid IWW at a local municipal wastewater treatment plant(POTW) able to accept IWW. 2. If the pH is within the 2-12.5 range,then it is considered industrial wastewater. PWS's need to manage/handle it in accordance with 314 CMR 18.00 (tanks and container management for IWW). PWS's may find someone who can use the material as product or can take it to a POTW. PWS's cannot discharge it to the ground, surface water or into a septic system. For most water treatment chemicals, the"corrosivity only" standards apply and only pH is considered when determining whether the material is hazardous waste or not,using the criteria above. Neutralization of these chemicals is the preferred option to change the pH(and hazardous waste status) so that the material is not considered hazardous waste and may be disposed of as Industrial Waste Water. The water treatment chemicals covered by the"corrosivity only" standards are as follows: • Sodium Hydroxide • Potassium Hydroxide • Sodium Hypochlorite • Sodium Silicate • Alum • Sodium Alginate • Orthophosphate and Polyphosphate solutions • Fluorosalisylic acid • Sodium fluoride • Sodium Carbonate(Soda Ash) • Potassium Carbonate(Potash) • Sodium Bicarbonate(baking soda) Care should be taken when neutralizing any corrosive chemical. Consult the MSDS sheet for preferred neutralization methods. Neutralization of sodium hypochlorite can be safely accomplished using sodium bisulfite, sodium metabisulfite, or sodium thiosulfate to safely neutralize sodium hypochlorite. The secondary containment structures protecting spills of reactive chemicals must be segregated so that the reactive chemicals will not mix. The secondary containment structures for any materials that would create a Hazardous Waste when mixed should be separate so that a Hazardous Waste mixture is not created. The regulatory conditions of a corrosive material are included in 310 CMR 30.123. The regulatory conditions of a reactive material are included in 310 CMR 30.124. The characteristics of any water treatment material not listed above should be checked to determine whether it is corrosive or reactive. Reactive chemicals may not use neutralization or dilution remediation strategies and must be handled as hazardous waste(IlW). If a public water supplier has any compliance questions regarding these materials and wastes,please call Saadi Motamedi (413) 755-2131. NORTHAMPTON WATER DEPT PWS IDk: 1214000 INSPECTION DATE: APRIL 9,2015 Page 22 MassDEP reviewed the most recent NWD Water Quality Sampling Schedule(WQSS)dated June 2, 2014. NWD is required to collect water quality samples according to that schedule. A spreadsheet' is available from the MassDEP website(www.mass.gov/eea/agencies/massdep/)that contains the monitoring requirements for every PWS in the Commonwealth. NWD has installed raw water sampling taps at its source(s) and should be able to sample for bacteria at its groundwater source(s)within 24 hours of a bacteria detection as required in the regulations at 310 CMR 22.05(1). A review of MassDEP records indicates that NWD has been approved for reduced Lead and Copper monitoring to 30 samples every three years. NWD is required to collect the next round of 30 samples during the period between June and September of 2015. The following tips may be useful in complying with the Lead and Copper regulations in the future: • All samples must be collected within the required time frame. Late sample data submitted will not be accepted. • Once a sample bottle has been accepted by the water system and delivered to the laboratory, the results cannot be invalidated due to sampling practices. • NWD must collect 2 samples(kitchen and bubbler) from two schools served by the water system during each sampling round. School results are not included in the 90th percentile calculation. Samples from schools are to be 250 milliliters in volume, not 1 liter. MassDEP has recently released a web-based water quality data submission feature in its electronic submissio website(eDEP). eDEP now allows certified labs to submit water quality data electronically. PWS users have the ability to view their data on-line. To start using eDEP or to learn more about electronic submission of water quality data, please visit: https://edep.dep.mass,gov/DEPHome.aspv on the world-wide web. SECTION 7: SOURCE AND SOURCE PROTECTION The protection of a groundwater recharge area is critical to maintaining a safe and ample supply of water to the NWD customers. Protection zones become more critical to water quality, and the activities within the zone more restrictive, as the wellhead is approached. Zone I is the most vulnerable and restrictive protection zone around a well. Depending upon pumping volume,a Zone I ranges from a radius of 100 to 400 feet around the wellhead. The Regulations at 310 CMR 22.21 (3)specify that only activities that are directly related to the water system and/or non-threatening to water quality occur within this zone. Zone I should be owned or controlled by the water supplier. The Zone H or Interim Wellhead Protection Area (1 WPA) encompasses a larger area around a wellhead. Zone Its are established using pumping test observations and groundwater modeling to estimate the contributing area to a groundwater source. Table 4 lists the sources and the dimensions of their wellhead protection zones. The name of the spreadsheet is`locidxls". NORTHAMPTON WATER DEPT PWS ID#: 1214000 INSPECTION DATE:APRIL 9,2015 Page 21 SECTION 6: WATER QUALITY MONITORING AND REPORTING MassDEP reviewed the most recent NWD Water Quality Sampling Schedule(WQSS)dated June 2, 2014. NWD is required to collect water quality samples according to that schedule. Bacteriological Monitoring The required number of total coliform samples is based primarily on population and system characteristics. If the NWD population changes such that it exceeds or falls below a threshold listed in Table I of 310 CMR 22.05 NWD must contact the MassDEP regional office to update its Coliform Monitoring Plan. System characteristics such as storage,treatment facilities, source water quality and the number of sources also affect the total number of required coliform sampling locations. For those systems that treat the source water, the Coliform Monitoring Plan must include an additional sample collected from the raw water source(s)under 310 CMR 22.05(1)(a). MassDEP reviewed the current Coliform Bacteria Sample Plan dated January 26, 2011. The schedule was determined to satisfy the following criteria from the regulations at 310 CMR 22.05 (1): o Sites representative of the water throughout the distribution system: Chartpak,Look Park, Florence Fire Station, Cooley Dickenson, 18 West Farms Road,Northampton State Hospital, City Hall,Clarke School, Water Dept., Clarion Hotel,Ryan Road School, State Police King Street,Burger King, Roland's Motor Works, 355 Bridge Street,Minute Maid,Hampshire County Jail, Audubon Road Tank o Sites representative of raw water prior to treatment: Ryan Reservoir, Well#1,Well#2 o Sites representative of treated water: Point of Entry o Sites representative of storage: Audubon Road Tank See Section R for Revised Total Coliform Rule(RTCR)highlights. Chemical Monitoring The current monitoring period for 2014-2016 represents the second period of a 9-year monitoring cycle. All monitoring waiver decisions have been made. Your Water Quality Sample Schedule (WQSS) for 2014-2016 has been issued and reflects those decisions. The new schedules reflect changes to Disinfection Byproduct monitoring that include sampling in specific months and particular weeks of those specific months. See the NWD WQSS for details on DBPR monitoring. Some Community and Non-transient Non-community systems that monitor disinfection by-products, e.g., Trihalomethanes (THMs) and Haloacetic Acids (HAAS5), during the "month of warmest water temperature" must take these samples in August. The schedule will show"ATJG" for those systems. Other systems will have specific months specified in a given quarter (e.g., June, September, December, etc.). The particular week of the month in which sampling must occur is included on the schedule if required. Radiological Monitoring Monitoring waivers are not considered for radiological monitoring. Monitoring frequencies for radionuclides are pre-determined by the Standardized Monitoring Framework and have been incorporated into the WQSS by MassDEP/DWP/WERO. These frequencies are based on either the grandfathered results of samples collected before December 8, 2003 or from results collected since that date. NOR CHAMPION WATER DEPT INSPECTION DATE: APRIL 9,2015 PWS IDR: 1214000 Page 24 When the RTCR is adopted by Massachusetts the regulations may reflect the following: Routine sampling no longer creates a non-compliance situation. Routine sampling where>1 TC+or>5% TC+instead creates a triggered assessment situation. Compliance is based on repeat sampling,required when the routine or repeat sample is TC+. Routine samples are the monthly distribution system samples listed on the Colifonn Monitoring Plan. Special samples(e.g., after tank cleaning, disinfection,flushing) are not normally used in compliance calculations, but may be, at the discretion of MassDEP. Repeat Sampling: Systems serving<33,001 population and therefore collecting<40 samples per month must collect 3 repeat samples for every routine sample TC+. If one or more of those repeat samples is TC+or EC+ then a Level I assessment is triggered. Once the assessment is triggered, additional repeat samples are not required unless specified by MassDEP. Systems serving>33,001 population and therefore collecting>40 samples per month that have a total of 5% TC+of all routine plus repeat samples must complete a Level I assessment. • Systems that fail to collect all required repeat samples following a TC+must conduct a Level assessment. • Assuming that repeat samples are TC-,those three repeats complete the compliance monitoring for that month, i.e., systems collecting only one routine sample per month no longer need to collect five samples for the month, as well as the month following the TC+. Assessments Systems must conduct assessments to identify sanitary defect(s). The system must correct any identified sanitary defect(s). • A Level I Assessment must be performed by the owner or operator each time a Level 1 Assessment is triggered. The Assessment is submitted to MassDEP within 30 days of the triggering event (collection date of the initial TC+), • A Level 2 Assessment must be performed by the state or state-approved entity each time a Level 2 Assessment is triggered. The Assessment is submitted to MassDEP within 30 days of the triggering event(collection date of the initial TC+). Level 2 Assessments are triggered by: 1. Incuring an E. colt MCL violation, 2. Triggering a second Level 1 Assessment within a rolling 12-month period Seasonal Systems Seasonal systems must demonstrate completion of a MassDEP-approved startup procedure before serving water to the public. Startup procedures will include the collection of a TC-sample prior to serving water to the public, the only exception to this would be for systems that do not drain the water from the distribution system and remain pressurized. Seasonal systems may collect special samples to diagnose effectiveness of flushing and disinfection,but they must be designated as such on the Chain of Custody and followed by the above-mentioned TC-sample for compliance purposes. Major Violations E. coli MCL Violations occur when there is any combination of EC+for routine or repeat sample results and a TC+or EC+from the other set of samples for that month: NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 PWS ID4: 1214000 Page 23 Suffix Source Name Wellhead Protection Rate Units Zone I(ft.) Method IWPA(ft.) 01G GP WELL 1 730 gpm 400 g.m tI m Mt Street Reservoir 02G GP WELL 2 575 gpm 400 1214000- Table 4 ellhead Protection Zones The NWD system is currently in compliance with Zone I requirements. Any modifications to the Zone I or activities within are subject to MassDEP approval. PWSID Source Name Non-Conforming Activities in Zone I-Zone A Activities in IWPA-Zone II 1214000- Gp Well# 1 Residential buildings,property Residential buildings, property OIG owned by others owned by others, mining, industrial areas, mining,recreation 1214000- Mt Street Reservoir None None O1S 1214000- Gp Well#2 Residential buildings,property Residential buildings,property 02G owned by others owned by others, mining, industrial areas,minin_,recreation 1214000 Ryan Reservoir None None 03S 1214000- West Whately None None 04S Reservoir Table 5: Nonconforming Activities within the NWD source water protection areas NWD maintains 4 surface water sources. Much of the source watershed is located in the Towns of Conway, Whately,and Williamsburg. The protection of a surface water recharge area(watershed)is critical to maintaining a safe and ample supply of water to the NWD. Activities throughout the watershed should be assessed and evaluated for the potential to impact water quality. Protection zones become more critical to water quality, and the allowable activities within the zones more restrictive, closer to the source water. Zone A is the most vulnerable and restrictive protection zone around a reservoir and tributary streams(source water). The Zone A is the area 400 feet from the edge of the reservoir and 200 feet from the edge of all tributaries draining into it. Zone B is the area V2 mile from the edge of the reservoirs but does not extend beyond the outer edge of the watershed. Zone C is the remaining area in the watershed not designated as Zone A or B. MassDEP conducted an assessment of the system for the Source Water Assessment and Protection Program(SWAP) and a report was sent on January 22,2003. SECTION 8: CURRENT AND FUTURE REGULATORY REQUIREMENTS Revised Total Coliform Rule(RTCR)Highlights—includes only the changes from the present requirements. NORTHAMPTON WATER DEPT INSPECTION DATE:APRIL 9,2015 PWS Ill#: 1214000 Page 26 Every public water supplier was required to submit an Emergency Response(ERP) Compliance Checklist to MassDEP by December 31, 2009. Lead & Copper Rule—Short Term Revisions MassDEP incorporated EPA's recent revisions to the Lead and Copper Rule into the State's Drinking Water Regulations on December 25,2009. Key components of the revisions include the following: 1. The results from any samples collected during the compliance period, even if they are collected at unapproved sites, must be incorporated into the 90''n percentile compliance calculation. 2. All community systems must include specific required informational language in their CCR regardless of whether the system detected lead in any of its samples. The required language can be found at: http://www.mass.gov/dep/water/drinking/systems.htm#ccr. 3. For systems that have exceeded the lead action level,the language in the required public education materials has been revised and can be found at http.//www.mass.gov/dep/water/drinking/leadlang.doe 4. Al] homeowners that participated in the sampling must be sent their sample results within 30 days of when the system recieves the results. The homeowner notification must contain certain required language which can be found at: http://www.mass.govidep/water/approvals/dwsforms.htm#lead. 5. Once a year all community water systems must submit a certification form to MassDEP to document that items No.3 &4 above have been completed. A complete description of the revisions can be found at: http://www.massigovklep/service/regulations/nrewregs.htm4gwrIcr UIC Issues The Underground Injection Control(U1C)Program regulates discharges to the ground via Class V wells such as dry wells, septic systems tied to industrial processes, leaching catch basins and other subsurface leaching systems. The UIC Regulations list authorized activities in 310 CMR 27.05, including heat exchanger return water, non-contact cooling water, storm water drainage,waste fluids other than sanitary waste,aquifer recharge wells, and salt water barrier intrusion wells. Prohibited activities are listed in 310 CMR 27.04, and generally, include the introduction of fluid containing any pollutant that would likely cause a violation of the Massachusetts Drinking Water Regulations,the groundwater discharge standards listed in 314 CMR 5.10 or adversely affect the health of persons. One common unpermitted UIC application is for floor drains in a boiler room piped to a drywell or septic systems in facilities that are unsewered. Contact Richard Larson at(413)755-2207 if the PWS source area has any unregistered UICs. Radionuclides Rule This rule applies to community water systems of all sizes and is currently in effect. This rule retains the existing MCLs for combined radium-226 and radium-228, and gross alpha particle radioactivity, and specifies an MCL of 30 ug/L for uranium. Please refer to the NWD Water Quality Sampling Schedule for specific testing requirements. NORTHAMPTON WATER DEPT P W S ID#: 1214000 INSPECTION DATE: APRIL 9,2015 Page 25 Routine Set Repeat Set EC+ TC+ EC+ Any missing sample EC+ EC+ 7C+ EC+ Treatment Technique Violations occur when a system fails to conduct either a Level 1 or Level 2 Assessment within 30 days of the trigger,fails to correct all sanitary defects from a Level 1 or Level 2 Assessment within 30 days of a trigger or in accordance with a state-approved time frame, or the failure of a seasonal system to complete state-approved start-up procedures prior to serving water to the public. Emergency Plans,Response and Reporting Requirements: On May 2,2008,MassDEP issued revised regulations regarding emergency plans, response and reporting requirements. As of that date, Public Water Systems were required to have prepared an Emergency Response Plan, which includes appropriate response actions to potential or actual emergencies, including but not limited to: 1. Loss of water supply from a source; 2. Loss of water supply due to major component failure; 3. Damage to power supply equipment or loss of power; 4. Contamination of water in the distribution system from backflow or other causes; 5. Collapse of a reservoir,reservoir roof, or pump house structure; 6. Break in a transmission or distribution line that could result in a loss of service to customers for more than four hours; 7. Potential or imminent threat of chemical or microbiological contamination of the water supply over limits specified by MassDEP's Office of Research and Standards' as set forth in the Standards and Guidelines for Contaminants in Massachusetts Drinking Waters. (available on- line at http://www.mass.gov/dep/water/laws/regulati.htm#chems); 8. Potential or imminent threat of an overfeed of an approved drinking water treatment chemical into the system; 9. An act of vandalism or sabotage that has the potential to impact or impacts water quality or the quantity of water available to the system. 10. A shortage or lack of resources that could affect the operations of the system, such as: a. Staffing shortages: b. Receipt of notice from a power utility of lengthy power outages; or c. Imminent depletion of treatment chemical inventory;and 11. Any other failure of part or all of the water supply system due to equipment failure,human acts(deliberate or accidental) or natural or human made disasters. These requirements are described in sections 310 CMR 22.04(13) of the Regulations. Section 310 CMR 22.15(9)of the regulations incorporates 2-hour and 24-hour emergency notification requirements to both MassDEP and the Board of Health,for specified emergency. Within 30-days of a reportable emergency,the water supplier must complete an Emergency Response Report and submit a copy of that Report to MassDEP for Level III, Level IV or Level V emergencies,Cross Connection incidents, and any of the emergency incidents listed in Items#1 through#11 above. NORTHAMPTON WATER DEPT INSPECI ION DATE: APRIL 9,2015 PWS IDf: 1214000 Page 28 • Any individual filter with a turbidity level greater than 1.0 NTU must be reported to MassDEP. • Any individual filter with a turbidity level greater than 0.5 NTU at the end of the first four hours of filter operation (following backwash or when off-line filters are put on-He) must be reported to MassDEP. 'turbidity limits and monitoring requirements for slow sand systems will not change under this rule. Filter Backwash Recycling Rule This rule is currently in effect and applies to all public water systems that use surface water or ground water under the direct influence of surface water, practice conventional or direct filtration, and recycle spent filter backwash,thickener supernatant, or liquids from dewatering processes. The rule stipulates that all recycle flows must return through all processes of the system's treatment system (i.e.,the headworks). Systems must apply to MassDEP if they want to recycle at an alternate location. Arsenic Rule On January 23, 2001,The Environmental Protection Agency(EPA) issued a Final Rule to reduce the public health risk from arsenic in drinking water by changing the Maximum Contaminant Level (MCL)for arsenic from the current 50 parts per billion(ppb)to 10 ppb. EPA's Rule is in response to the requirements of the 1996 amendments to the Safe Drinking Water Act. This rule will affect community and non-transient,non-community water systems and was effective January 23,2006. Groundwater Rule EPA finalized this rule on October 12, 2006 and MassDEP adopted the Rule into regulation on December 25, 2009. The rule applies to all public water systems that rely on groundwater sources. PWS compliance with this rule is now mandatory. Major components of the rule include: 1. MassDEP must conduct regular,comprehensive sanitary surveys on Ground Water Systems (GW S-PWSs with groundwater sources that do not disinfect)and identify significant deficiencies. Beginning in 2009, all community GWSs must be surveyed every three years unless they are classified as exceptional by the State. All non-community GWSs must be surveyed every five years. 2. All GWSs are required to sample and test their groundwater sources for fecal contamination (fecal indicator)within 24 hours of any detection of Total Coliform in any routine distribution system bacteria monitoring sample. The triggered monitoring sample must be taken at a location representative of the source,prior to storage. MassDEP requires that all GWSs have the ability to get this source sample on short notice and requires that sampling ports be installed on all groundwater sources if not available. 3. The fecal indicator for Community systems serving greater than 3,300 persons is enterococci. The fecal indicator for all other GWSs is ecoli. Furthermore, if ecoli is detected in any groundwater source, regardless of population, the fecal indicator is ecoli. If a source sample is collected on the same day as a distribution system sample, and the distribution system sample is total coliform positive, then the source sample can be used to satisfy the triggered monitoring component of the GWR, and consequently the fecal indicator is ecoli. 4. Any GWS with significant deficiencies or source sampling indicating fecal contamination must take corrective action including using alternative sources of water,correcting and removing the source of contamination, or providing 4-log removal of viruses. NORTHAMPTON WATER DEPT INSPECTION DATE: APRIL 9,2015 PWS ID#: 1214000 Page 27 Disinfectant Byproduct Rules(Stage 1 &2 DBPR) Both of these rules apply to all sizes of community water systems and non-transient,non-community PWSs that add a disinfectant(other than ultraviolet light)to the water. The rules are intended to reduce potential cancer and reproductive and developmental health risks from disinfection byproducts in drinking water that form when disinfectants are used to control microbial pathogens. The Stage 1 rule has been in effect since 2000 and establishes MCLs for TTHMs,five haloacetic acids (HAA5s), bromate,and chlorite. The MCLs for TFIlMs and IIAA5s are 0.080 mg/L and 0.060 mg/L respectively. The rule also establishes a maximum residual disinfectant level(MRDL) for chlorine of 4.0 mg/L. The more recent Stage 2 rule(published January 4,2006) does not change any of the MCLs,but does require that most water systems evaluate their distribution system(Interim Distribution System Evaluation-"IDSE")to determine if there are other locations with elevated disinfection byproduct concentrations that were not sampled under the Stage 1 Rule. These locations will then be used by the system as the sampling sites for Stage 2 DBPR compliance monitoring. Some systems,with historically low levels of TTHMs and I-IAA5s (below 0.040 mg/L and 0.030 mg/L respectively), were granted a waiver from having to do any additional samples/studies. MassDEP is in the process of evaluating all Stage 1 and IDSE data for all water systems that must comply with the Disinfection Byproduct Rules. A determination has been made regarding the location and frequency of all required Stage 2 Rule sampling. The sampling locations and frequencies were included in current sampling schedules that were to sent to all Public Water Systems. Monitoring for Stage 2 has begun. Compliance under the Stage 2 rule is determined by using the miming annual average at each sampling location instead of averaging the results from all sampling sites as one done under the Stage I rule. For systems that only sample once per year, or once every three years, compliance will be based upon that single sample result. Long Term 1 Enhanced Surface Water Treatment Rule(LT1ESWTR) This rule applies to all public water systems that use surface water or ground water under the direct influence of surface water and serve less than 10,000 people and was made effective on January 14,2005. This rule adds requirements for control of Cryptosporidium and sets a MCLG of zero for this pathogen. Systems must achieve at least a 2-log removal of Cryptosporidium,which is demonstrated by meeting new effluent turbidity limits specified below. Systems are still required to meet a 3-log removal/inactivation of Giardia and a 4-log removal/inactivation of viruses. The new turbidity requirements are stipulated as follows: • Combined effluent performance requirements for plants using conventional filtration treatment or direct filtration: • Combined filtered water effluent turbidity must be less than or equal to 0.3 NTU in at least 95% of the measurements taken each month,with measurements taken every four hours of operation. • Combined filtered water effluent turbidity must not exceed 1.0 NTU at any time with measurements taken in four-hour intervals. • Individual filter performance requirements for these systems. • Individual filter effluent must be monitored continuously for turbidity. NORTHAMPTON WATER DEPT P W S TDN: 1214000 INSPECTION DATE: APRIL 9,2015 Page 30 Beaver Conflict Resolution In July 2000, the Massachusetts Legislature enacted a new law that provides any parties who are experiencing public health threats as a result of beaver or muskrat flooding may apply to the local municipal Board of Health(BOH)to abate those threats. The Division of Fisheries & Wildlife regulations that oversee this process(321 CMR 2.08)further state that the MassDEP's Drinking Water Program would make the determination of a threat in all cases involving Public Water Systems. This determination is to be used to obtain an Emergency Permit from the local BOH. Depending upon the situation,the local Conservation Commission may also become involved. MassDEP's policy applies to surface water reservoirs, ground water wells and pump stations. MassDEP may determine a threat o human health and safety exists if beaver or muskrats or dams or active lodges are observed within designated areas. In some cases,documented water quality degradation is required before a threat to human health and safety is determined. The MassDEP contact for beaver conflict resolution issues in western Massachusetts is James Gibbs (413- 755-2299). NORTHAMPTON WATER DEFT INSPECTION DATE: APRIL 9,2015 5. The rule specifies that nanofiltration, certain types of microfiltration,chemical disinfection using chlorine or ozone will provide 4-log removal of viruses when used in stand-alone applications. 6. The rule does not specify that ultraviolet(UV)disinfection can be used in a stand-alone application to achieve 4-log removal of viruses. 7. GWSs that install a treatment technique to comply with the GWR are required to conduct" compliance monitoring"that verifies the effectiveness of their virus removal. GWSs that employ a treatment technique and serve greater than 3,300 persons must install continuous chlorine monitoring at or before the first customer. GWSs that employ a treatment technique and serve 3,300 persons or less are required to monitor their process once per day at or before the first customer. P WS ID;i: 1214000 Page 29 The text of the regulations is available on-line at http://www.epa.gov/safewater/disinfection/gwr/. Long Term 2 Enhanced Surface Water Treatment Rule(LT2ESWTR) EPA published the LT2ESWTR on January 5,2006,which will reduce illness linked with the contaminant Cryptosporidium and other pathogenic microorganisms in drinking water. Under this rule,systems will monitor their water sources to determine treatment requirements. This monitoring includes an initial two years ofmonthly sampling for Cryptosporidium. To reduce monitoring costs,small filtered water systems (those serving under 10,000)will fist monitor for E.coli,which is less expensive to analyze than Cryptosporidium,and will monitor for Cryptosporidium only if their E. coli results exceed specified concentration levels. Monitoring starting dates are staggered by system size, with smaller systems beginning monitoring after larger systems. Systems must conduct a second round of monitoring six years after completing the initial round to determine if source water conditions have changed significantly. Systems may use (grandfather) previously collected data in lieu of conducting new monitoring, and systems are not required to monitor if they provide the maximum level of treatment required under this rule. NWD must report the sampling schedule and sampling location description for initial source water monitoring for Cryptosporidium,E. colt,and turbidity no later than October 1,2007. Initial source water monitoring for these parameters must begin one year after the monitoring plan deadline. Filtered water systems have been classified in one of four treatment categories(bins)based on their monitoring results. The majority of systems were classified in the lowest treatment bin,which carries no additional treatment requirements. Systems classified in higher treatment bins must provide 1.0 to 2.5-log additional treatment for Cryptosporidium. Systems will select from a wide range of treatment and management strategies in the"microbial toolbox"to meet their additional treatment requirements. All unfiltered water systems must provide 2 or 3-log inactivation of Cryptosporidium,depending on the results of their monitoring. In addition, systems must review their current level of microbial treatment before making a significant change in their disinfection practice. This review will assist systems in maintaining protection against microbial pathogens as they take steps to reduce the formation of disinfection byproducts under the Stage 2 DBPR. MassDEP has obtained primacy for this rule,submittals are required to be made to MassDEP,Micael McGrath,Western Regional Office,436 Dwight Street,Springfield,MA 01103. Mike may be contacted at (413) 755-2202. NORTHAMPTON WATER DEP F INSPECTION DATE:APRIL 9,2015 P W S ID#: 1214000 Page 32 NORTHAMPTON WATER DEPT PWS ID#: 1214000 INSPECTION DATE:APRIL 9,2015 Page 31 SANITARY SURVEY COMPLIANCE PLAN RESPONSE FORM for TABLE A or B Within 30 days of receipt of this inspection report,you must complete and submit this response form if your ystem has TABLE A —Violations and/or TABLE B-Deficiencies (see attached Compliance Tables). Attach a :opy of the completed tables listing the date that the corrective action was or will be taken by your system and dl other applicable documentation. (310 CMR 22.04(12)) Please note that violations listed in TABLE A of the Compliance Plan are also a Notice of Noncompliance (NON) pursuant to M.G.L. c.21A, §16 and 310 C.M.R. 5.00 and may require the submission of quarterly written progress reports on the identified violations. fhe following corrective actions listed in the Sanitary Survey Compliance Plan(s)TABLE A and/or B has been aken by the public water system.(Please check all that apply). ❑ My system has taken ALL of the corrective actions listed within the timeframes specified in the Sanitary Survey Compliance Plan(s). • For each item,I have listed the completion date of the corrective action within each table. • I have attached copies of supporting documentation as required. ❑ My system has taken SOME BUT NOT ALL of the corrective actions listed within the timeframes specified in the Sanitary Survey Compliance Plan(s). My system HAS NOT complied with ALL of the requirements set forth in the Sanitary Survey Compliance Plan(s). • For each item,I have listed the actual or anticipated completion date of the corrective action within each table. • I have attached copies of supporting documentation as required. • I have attached a revised corrective action schedule establishing timelines for my system to address outstanding items and I will submit a written progress report each quarter(every 3 months)until all items have been addressed. I understand that my system may be subject to further enforcement action. ❑ My system is UNABLE to comply with some or all of the corrective actions within the timeframes specified in the Sanitary Survey Compliance Plan(s). I understand that my system may be subject to further enforcement action. • An explanation is attached. hereby acknowledge receipt of the inspection findings and compliance plan table(s)of the sanitary survey conducted ry the Deparuuent of Environmental Protection's Drinking Water Program. I certify that under penalty of law I am he person authorized to fill out this form and the information contained herein is true, accurate and complete to the lest of my knowledge and belief Water Commissioner,Owner,Owner Representative or Other Responsible Party: Signature: Date: Print Name: Title: Return this form,a copy of each Compliance Plan Table and all attachments to: DEP-BRP Drinking Water Program,436 Dwight Street, Springfield,MA 01103 Attention: Jim Bumgardner NORTHAMPTON WATER DEPT INSPECTION DA FE: April 9,2015 PWS ID#: 1214000 INSPECTIONDATE:Apt 9, ZUIe SANITARY SURVEY COMPLIANCE PLAN- SECTION B - REQUIREMENTS Sanitary survey items that are required to be corrected to improve the protection of drinking water and public health pursuant to M.G.L. 111§ 160. MassDEP/DWP will •rovide technical assistance to systems res•ondin to these deficiencies. Please call our re ional DWP office for referral to the a •ro eriate staff Berson. Section Deficiencies Corrective Actions Deadline Sig. Completed • for Del? Date • Taking Corrective Actions Administration During the survey,NWD indicated that it has MAssDEP requires that NWD submit an updated May 31, No employed a new treatment operator, Andrew Dunn staffing plan to reflect the primary and secondary 2015 (2T-OIT). MassDEP does not have an updated Certified Operators in charge of water treatment staffing plan indicating the status of the new operations. • operator. Administration NWD has an infrastructure inventory for all major MassDEP requires that NWD create and submit an May 28, No components of its water system. However, Asset Management Plan with written estimates of 2016 MassDEP has determined that NWD does not have a the useful life of all assets within its infrastructure written list of the useful life expectancy of its assets inventory and a schedule for replacing those assets. or a long-term asset replacement plan with a schedule for re.lacin_those assets. _. _ . . * MassDEP reserves the right to exercise its Order authority under M.G.L. Chapter I 1 I, Section 160,or to take other appropriate action as permitted by law, in order to prevent the pollution and to secure the sanitary protection of the water supply and to ensure the delivery of a fa and pure water supply to all consumers, including without limitation if sufficient progress to meeting a recommended deadline is not achieved. MassDEP requests that periodic progress reports be submitted,e.g.,quarterly(each January 1s,April Is',August 1",December 1st,etc.,for as long as necessary)or otherwise. G WR SD=Ground Water Rule Significant Deficiency