PREPARING FOR A COMPREHENSIVE COMPLIANCE INVESTIGATION (CCI) h August 15, 2006

Facility Notification ! Courtesy call approximately 1 to 2 weeks prior to investigation, unless... ! TCEQ Region Office advises facility that ALL Required Records must be available for review at the time of the scheduled CCI ! Records List Provided

Presented by: Joy Thurston Cook

What to Expect During the CCI

Required Records Review

! File Review ! Facility Evaluation ! Distribution Evaluation ! Exit Interview

Required Records ! Certified Operators ! CSI Certificates ! Wholesale Water Contracts ! Monthly Operating Reports ! ANSI/NSF Certifications ! Plumbing Ordinance or Service Agreements ! Well Plugging Reports ! Well Logs

Required Records ! Engineering Plans ! Up-to-date Maps of the Distribution System ! Tank Inspection Reports ! Back-Flow Prevention Program ! Sanitary Control Easements ! Variances or Exemptions

Capacities ! ! ! ! ! !

Well Pumping Capacities Storage Tank Capacities Pressure Tank Capacities Service Pump Raw/Transfer Pumping Capacities Flocculation Basin and Sedimentation Basin Dimensions ! Filter Dimensions ! Proprietary Treatment System Capacities

Water Meter

Retail Meters = 1 Retail Connections = 16

Two Year Retention Schedule §290.46(f)(3)(A) ! Volume of water treated each day or each week ! Amount of chemicals used each day or each week

! ! ! !

Dates dead-end-mains are flushed Complaints received by the system (detailed) Dates storage tanks and facilities are cleaned Maintenance records for equipment and facilities

Five Year Retention Schedule §290.46(f)(3)(D) ! Microbiological Analyses ! Annual Inspections for Water Storage and Pressure Tanks ! Inspections for Pressure Filters (SWTP & GUI)

Apartment Building with 16 Units

Three Year Retention Schedule §290.46(f)(3)(B) ! ! ! ! ! !

NOV’s and Corrective Actions Copies of Public Notices issued by the system Disinfectant Residual Monitoring (Distribution) NTU Monitoring/Exceptions/Individual Filters Calibration Records/Laboratory/Meters/Etc. Backflow Prevention Device Programs (intial installs and annual calibrations)

Ten Year Retention Schedule §290.46(f)(3)(E) ! MOR’s and any supporting documentation for Combined Filter Effluent ! Chemical Analyses ! Customer Service Inspections (CSI) ! Written Reports, Summaries, Communications Inspections of the system conducted by the system, private consultants, or the TCEQ

Monitoring Plans and Operations Manual §290.121and §290.42(l) Monitoring Plan ! Identify all sampling locations ! Describe sampling frequency ! procedures and labs used

Surface Water Laboratory Requirements ! ! ! !

Temperature Alkalinity Jar Tester Amperometric Titrator with Platinum-Platinum Electrode for chlorine dioxide.(290.110(d)(5)) ! Sludge judge (SBC) ! Sludge Recirculation Concentrations ! Computer

Operations Manual ! Operator routine maintenance and repair procedures ! Protocols in the event of a natural or manmade catastrophe ! Telephone numbers of personnel and agencies to be contacted in the event of an emergency.

Calibration Requirements §290.46(s)(1) Flow Measuring Devices/Rate-of-Flow Controllers as required by §290.42(d)(5) ! CALIBRATE EVERY 12 MONTHS * Raw Water * Recycled Decant Water * Treated Water used to backwash filters * Treated Water discharged from the SWTP

pH Meters

Turbidimeters

§290.46(s)

§290.46(s) ! Benchtop/ On-Line Calibration - 90 DAYS (primary standards, check secondary) ! Benchtop Calibration Check - EACH series of samples (secondary standards/EACH series of samples) ! On-Line Calibration Check -EACH WEEK (primary, secondary standards OR manufacturers proprietary calibration confirmation device OR by comparing On-Line with properly calibrated Benchtop unit)

! Benchtop and On-Line Calibration -Each Day (according to manufacturers specifications) ! Benchtop Calibration Check - Each Time (check with at least one buffer everytime a series of samples are run)

Disinfectant Residual Analyzers

Sanitary Conditions of PWS Wells

§290.46(s) ! Benchtop Accuracy Verification - 30 DAYS (Known concentrations) ! On-Line Calibration - 90 DAYS (Known concentrations) ! On-Line Calibration Check -MONTHLY (Known concentrations OR comparing with results of an approved benchtop, amperometric, spectrophotometric, or titration method)

! Protection from Flooding ! >50 feet: Livestock, Septic Tanks, Cemeteries, Sewers ! > 150 feet: Septic Tank Drainage Fields, UST, liquid pipeline ! >300 feet: Industrial Waste Drainage Ditch, Lift Stations ! > 500 feet: Sewage Treatment Plant, Landfill, Sewage Irrigated land, BFU Sites, Solid Waste Site

Construction of PWS Wells

Surface Water Treatment Plants

! ! ! ! ! ! ! ! !

18 inch casing Sealing Block Sealed Well Head Vents Sampling Tap Flow Meter Fenced or Housed All Weather Road Screened Air Release

Source Water Restrictions ! Liquid and Solid Waste Controlled on Watershed ! Type and Depth of Raw Water Intake Structure ! Screens or Grates on Intake ! 200 foot Restricted Zone ! Boat Ramps, etc. > 1000 feet

Storage Tanks

Storage Tanks

Ground and Elevated ! ! ! ! ! ! ! !

General Condition Inlet and Outlet Water Level Indicators Vents Hatches Overflows Ladders Fencing

! ! ! ! !

Pressure General Condition Air-To-Water Volume Indicators Pressure Release Devices Pressure gauges Air Filters

Disinfection ! General Condition of Facilities, Equipment and Housing ! Vents, Fans if necessary ! Injection Points ! NH3 bottle ! SCBA

Surface Water Disinfection ! ! ! !

Surface Water Treatment Plants ! ! ! ! !

Chemical Storage Adequate Supply (Bulk - 15 day supply) Standby Chemical Feeders Leak Prevention, Backflow Prevention and Containment Tanks Labeled Day Tanks

Surface Water Treatment Plants Chemical Storage ! ! ! !

Check your chlorine residual Pressure Leaks Exposed lines

Measurement and Dosage Control Clog Prevention on Feed Lines Continuous Coagulant Feed Separate Dry Feed with Dust Control

Exit Interview

Distribution ! ! ! !

Type, Feed Points, & Monitoring Pre & Post Disinfection Chlorine & Ammonia Separated Continuous Monitoring & Reporting

! ! ! ! !

Previous CCI issues Current Deficiencies 14-Day Area of Concern Notification Additional Issues Exit Interview Form

After Receiving the Letter ! ! ! ! !

GUIDANCE MANUALS Download these manuals from the TCEQ Website at http://www.tceq.state.tx.us Just insert the document number in the subject search box ! RG-195: 30 TAC Chapter 290 Subchapter D ! RG-346: 30 TAC Chapter 290 Subchapter F ! RG-384: How to Develop a Monitoring Plan ! RG-407: Disinfectant Residual Reporting ! RG-211: Monthly Testing and Reporting at SW Treatment Plants Using the new Automated Forms

Joy Thurston-Cook TCEQ San Antonio Region 13 14250 Judson Rd. San Antonio, Texas 78233-4880 Office: 201.490.3096 Direct Line: 210.403.4018 E-mail: jthursto[at]tceq.state.tx.us

If Violations are Noted Respond in writing by the compliance due date Option to Contest Violations (contact on ltr.) Call us with questions Call us for technical assistance Call us for time extensions

Questions?

Operations and Maintenance Manual Checklist Please include this checklist with your operations and maintenance manual.

Information Included: Facility description Explanation of startup and normal operating procedures

Routine maintenance program Records and reporting system Sampling and analyses program Staffing and training requirements Identification of pollution sources at the water supply Safety program Unaccounted-for water tracking plan Emergency plan and operating procedures Emergency personnel contact information Manufacturer’s manuals

Yes

No

Page Number

RECORDS REQUIRED TO BE AVAILABLE DURING INVESTIGATIONS OF “NON-COMMUNITY” PUBLIC WATER SYSTEMS A. ALL SOURCE WATER SYSTEMS 1. Population served 2. Number of motel rooms and/or RV/camping spaces (if applicable) 3. Purchased water systems only - purchase contract with maximum purchase rate shown 4. Monitoring Plan including a copy of Bacteriological Sample Site Plan 5. Twelve (12) latest months of bacteriological sample results. Includes raw water samples, if applicable. 6. Past 12 months of “Monthly Reports of Water Works Operation” including: a. average daily water usage for past 12 months b. maximum day water usage for past 12 months (date and amount) c. amount of chemicals used (290.46(f)(3)(A)(i) d. Chlorine residual monitoring records 7. Public notices issued for bacteriological or chemical violations 8. Distribution system map 9. Equipment capacities a. Well pumps - rated capacity (GPM). Actual capacity will be checked during investigation. b. Service / filter / transfer pumps (GPM) c. Ground storage (Gal) d. Elevated storage (Gal) and height of tank overflow e. Pressure tanks (actual measured size in gallons) 10. Annual tank inspection forms 11. Well completion data, including: a. Driller’s well log (State of Texas Water Well Report) b. Cementing certificate c. Sanitary control easement (or city ordinance with similar restrictions) 12. Verification of ANSI/NSF Standard 60 for chemical additives (including bleach) and Standard 61 for vertical turbine lubricating oil (“NSF” symbol on label satisfactory) 13. TCEQ Plan Review final approval of well completion data for new wells 14. TCEQ Plan Review construction approval for new treatment facilities and storage/pressure tanks 15. Operator certification for non-transient systems (schools, offices, factories, etc) 16. Results of last investigation and system response 17. Operations Manual 290.42(k) 18. Monitoring Plan 290.121(a). B. SURFACE WATER SYSTEMS (All of the applicable ones above plus:) 1. Raw water pumping capacities 2. Sedimentation / clarification basin and filter dimensions 3. Gas chlorine / ammonia evacuation plan 4. Copies of CT Study & 1.0 NTU waiver 5. All Calibration records for turbidity and chlorine monitors, flow meters, pH...make sure your standards are not expired.

NOTE: You do not need to make copies of any of the above records for us unless we specifically request it, we just need to be able to review your file copies during the inspection.

RECORDS REQUIRED TO BE AVAILABLE DURING INVESTIGATIONS OF “COMMUNITY” PUBLIC WATER SYSTEMS A. ALL SOURCE WATER SYSTEMS 1. Total number of retail meters and/or population served (For cities - know official 2000 US Census) 2. Number of master meters serving apartments complexes and mobile home parks 3. Equivalent Living Units (ELU) - number of individual apartments and mobile home spaces. 1. TOTAL METERS

2. MASTER METERS

3. ELU

4. Wholesale contracts with maximum purchase rate indicated in GPM 5. “Monthly Reports of Water Works Operation” including: a. average daily water usage for past 12 months b. maximum day water usage for past 12 months (date and amount) c. amount of chemicals used (290.46(f)(3)(A)(i) d. water usage e. Chlorine residual monitoring records 6. Copy of Monitoring Plan including the Bacteriological Sample Site Plan 7. Twelve latest months of bacteriological sample results - includes raw water samples, if applicable. 8. Public notices issued for bacteriological or chemical violations 9. Distribution system map 10. Equipment capacities -Actual capacity of each well will be checked during investigation. 11. Annual tank inspection forms (for all Ground Storage and Pressure Tanks) 12. Well completion data, including: a. Driller’s well log (State of Texas Water Well Report) b. Cementing certificate c. Sanitary control easements (or city ordinance with similar restrictions) 13. Verification of Plumbing Code Ordinance or Service Agreement 14. “Customer Service Inspection” and “Backflow Prevention Assembly Test Report” forms 15. Verification of ANSI/NSF Standard 60 for chemical additives (including bleach) and Standard 61 for vertical turbine lubricating oil (“NSF” symbol on label is satisfactory) 16. TNRCC Plan Review final approval of well completion data for new wells 17. TNRCC Plan Review construction approval for new treatment facilities and storage/pressure tanks 18. Operator certification (including Customer Service Inspection endorsement, if appropriate) 19. Results of last investigation and system response 20. Consumer Confidence Report 21. Drought Contingency Plan 22. Operations Manual (290.42(k)) 23. Complaint Tracking 24. *** Calibrations (chlorine residual analyzers and well meters) Well Meters must be calibrated once every three years. B. SURFACE WATER SYSTEMS (All of the applicable ones above plus:) 1. Raw water pumping capacities 2. Sedimentation / clarification basin and filter dimensions 3. Gas chlorine / ammonia evacuation plan 4. Copies of CT Study & 1.0 NTU waiver 5. All Calibration records for turbidity and chlorine monitors, flow meters, pH...make sure your standards are not expired.