A06_McDermitt_Fire_Station_Water_Sampling_Plan_version_2_as_delivered.pdf

DRINKING WATER MONITORING PLAN

BUREAU OF LAND MANAGEMENT

MCDERMITT FIRE STATION

April 23, 2019

Compliance Assistance

Conservation & Planning

Prevention & Sustainability

Prepared for:

Bureau of Land Management

Nevada State Office

1340 Financial Blvd.

Reno, Nevada 89502 and

National Operations Center, OC-670

Denver Federal Center

Building 50, 5th Street

Denver, Colorado 80225-0047

Prepared by:

Aarcher, Inc.

88 Inverness Circle East, Suite I-106

Englewood, Colorado 80112

303.662.1696 www.aarcherinc.com

April 23, 2019

Prepared by Aarcher, Inc. ii

TABLE OF CONTENTS

Table of Contents ........................................................................................................................................ ii

List of Tables .............................................................................................................................................. iv

1 Introduction

2 Water System Information

2.1 Sampling Sites

3 Coliform Sample Collection

3.1 Laboratory Analysis

3.2 Collection Method

4 Routine Coliform Monitoring

4.1 Coliform Monitoring Schedule and Taps from Which Samples are to be Collected

4.2 When Routine Coliform Samples Must be Taken

4.3 What Actions Must be Taken if a Routine Coliform Sample is NOT Taken

4.4 What Actions Must be Taken if a Routine Coliform Sample Tests Positive for Coliform?

5 Repeat Coliform and GRound Water Rule (GWR) Monitoring

5.1 Repeat Coliform Sample Quantity and GWR Sample and Taps from Which Samples are to be Collected

5.2 When Repeat Coliform and GWR Samples Must be Taken

5.3 What Actions Must be Taken if One or More Repeat Sample or GWR Sample Tests Positive for Coliforms?

6 Treatment Technique Triggers and Assessments

6.1 When is Performance of a Level 1 Assessment Triggered?

6.2 How to Perform a Level 1 Assessment

6.3 When is Performance of a Level 2 Assessment Triggered?

6.4 How to Perform a Level 2 Assessment

6.5 What Actions are Required Following a Level 1 or Level 2 Assessment?

6.6 Coliform Treatment Technique Violations

7 Nitrate Monitoring

7.1 Nitrate MCL

7.2 Nitrate Sample Quantity and Taps

7.3 When Nitrate Samples Must be Taken

7.4 What Actions Must be Taken if an Annual Nitrate Result is Less Than the 10.0 mg/L MCL

7.5 What Actions Must be Taken if Annual Nitrate Sample Concentration Exceeds the MCL of

10.0 mg/L

7.6 What Actions Should be Taken if the Average of Initial and Confirmation Sample Nitrate Results are Greater Than or Equal to 50% of the Nitrate MCL of 10 mg/L?

8 Nitrite Monitoring

8.1 Nitrite MCL

Prepared by Aarcher, Inc. iii

8.2 Nitrite Sample Quantity and Taps

8.3 When Nitrite Sample Must be Taken

8.4 What Actions Must be Taken if an Annual Nitrite Result is Less Than 50% of the 1.0 mg/L

MCL 17

8.5 What Actions Must be Taken if an Annual Nitrite Result is Greater Than or Equal to 50% of the

1.0 mg/L MCL, but Less Than 1.0 mg/L

8.6 What Actions Must be Taken if a Nitrite Result Exceeds the MCL of 1.0 mg/L

9 Public Notification Requirements for MCL and Monitoring Violations

9.1 When is a Tier 1 Notification Required?

9.2 What Actions Must be Taken if a Tier 1 Violation has Occurred?

9.3 When is a Tier 2 Notification Required?

9.4 What Actions Must be Taken if a Tier 2 Violation has Occurred?

9.5 When is a Tier 3 Notification Required?

9.6 What Actions Must be Taken if a Tier 3 Violation has Occurred?

10 Water System Disinfection (AWWA Standards C651-92 and C654-87)

10.1 Water Distribution System Disinfection Procedures

10.1.1 Distribution System Disinfection Procedures for a Water System with Pressure Tanks – Well Source

11 Inspection and Troubleshooting Procedures

11.1 Well Inspection

11.2 Pressure Tank Inspection

11.3 Distribution System Inspection

11.4 Backflow Prevention Assembly Inspections

12 System Shut-Down Procedures

13 Recordkeeping

Appendix A. Site Schematic

Appendix B. Sample Preservatives and Hold Times

Appendix C. Chain of Custody Form

Appendix D. Public Notification Forms

Tier 1 E. coli MCL Violation

Tier 2 Treatment Technique Violation – Failure to Perform Level 1 Assessment

Tier 2 Treatment Technique Violation – Failure to Perform Level 2 Assessment

Tier 3 Monitoring Violation

Tier 1 Nitrate MCL Violation

Tier 1 Nitrite MCL Violation

Drinking Water Problem Corrected

Appendix E. Level 1 Assessment Form

Prepared by Aarcher, Inc. iv

LIST OF TABLES

Table 2-1. Water System Information

Table 2-2. Water System – Key Components

Table 2-3. Sample Taps

Table 3-1. Chain of Custody Form Information

Table 4-1. Coliform Sampling Locations

Table 5-1. Repeat Coliform Sample Locations

Table 5-2. Assessment and Public Notification Triggers

Table 6-1. Example Causes of Contamination and Corrective Actions

Table 11-1. Distribution System Inspection

Prepared by Aarcher, Inc. 1

1 INTRODUCTION

This Drinking Water Monitoring Plan was developed by Aarcher, Inc. in accordance with the scope of work for Call #0138 of Blanket Purchase Order L14PA00047, the revised Total Coliform Rule (RTCR), and the Ground Water Rule (GWR).

The RTCR and the GWR are parallel regulations with separate requirements. The US Environmental Protection Agency (EPA) published the GWR in 2006 and published the RTCR in 2013 (effective April 1, 2016).

The RTCR aims to increase public health protection through the reduction of potential pathways of entry for fecal contamination into the distribution system.

The GWR establishes an approach to identify groundwater systems susceptible to fecal contamination and requires corrective action for significant deficiencies.

Oversight of nonpublic water systems in Nevada is provided by the Nevada State Engineer and the BLM’s Compliance Assessment – Safety, Health, and the Environment (CASHE) Program. The CASHE Program reviews water sampling results’ compliance with Nevada Department of Environmental Protection (NDEP) coliform, nitrate, and nitrite monitoring requirements and cross-connection control regulations. Training on operating, monitoring, and troubleshooting water systems is also provided by the CASHE Program.

A PWS, as defined in Nevada Revised Statute (NRS) 445A.235, "means a system, regardless of ownership, that provides the public with water for human consumption through pipes or other constructed conveyances, if the system has 15 or more service connections, as defined in NRS 445A.843, or regularly serves 25 or more persons …" The McDermitt Fire Station does not meet the definition of a public water system that is regulated by the EPA or the NDEP. Although the water system at this facility does not meet the definition of a PWS, BLM Manual 9184 requires that Bureau-operated drinking water systems be operated and monitored as if they are a PWS.

The RTCR uses total coliform an indicator of the potential risk of microbiological contamination into the distribution system. Total coliform is group of closely related bacteria that, with a few exceptions, are not harmful to humans. A positive total coliform sample result initiates a "find and fix" approach to identify waterborne pathogens that could enter the distribution system. E. coli bacteria are a more accurate indicator of fecal contamination than total coliform, though not a complete measure of waterborne pathogen occurrence.

Waterborne pathogens could include the following:

Bacteria Viruses Parasitic protozoa

In addition to monitoring for total coliform and E. coli, the RTCR requires PWSs and BLM owned non- PWSs if required by their State or District/Field Office Engineer to perform assessments to identify sanitary defects and subsequently act to correct them. Under the RTCR, PWSs and BLM owned non- PWSs must meet a legal limit (called maximum contaminant level [MCL]) for E. coli, demonstrated by routine monitoring. It is BLM policy to comply with the RTCR for its own nonpublic water systems.

Prepared by Aarcher, Inc. 2

2 WATER SYSTEM INFORMATION

Table 2-1 provides details on the water system at this location.

Table 2-1. Water System Information

System Detail Description

Water System Name McDermitt Fire Station

Water System Identification Number Not applicable

Water System Physical Address Highway 95 and North Reservation Road, McDermitt, Nevada

Operation Period Year-round

Water System Classification Not applicable

Is the system a fully regulated PWS or a BLM-owned water system?

BLM-owned

Routine Coliform Sampling Frequency Monthly

Average Daily Population Less than 25 (approximately 20)

Number of Sampling Taps 14

Water Source Well

Operating Pressure (start-up) 35 psi

Treatment Process / Purpose None

Backflow Prevention Assemblies Five known assemblies:

1. Irrigation line along the sidewalk, southwest of the crew quarters

2. Irrigation line near the southeast corner of the shop

3. Stand pipe/hydrant near the northeast corner of the shop

4. Double-check valve between the tank house and the shop

5. Air gap funnel on the tank filling hose stand

System Operator, Address, Phone Number

Johnny Jensen

Winnemucca District Office

5100 E Winnemucca Blvd, Winnemucca, Nevada 89445

Backup System Operator, Address, Phone Number

Terri Suiter

Winnemucca District Office

5100 E Winnemucca Blvd, Winnemucca, Nevada 89445

(775) 623-1509 (desk)

(775) 625-0487 (cell) tsuiter@blm.gov

Donovan Walker

Winnemucca District Office

5100 E Winnemucca Blvd, Winnemucca, Nevada 89445

(775) 623-1526 d1walker@blm.gov

Primacy Agency(s) Not applicable

Drinking water is provided from a well and is untreated. The line from the well runs to a locked enclosure called the tank house, where it is pressurized in three pressure tanks. The distribution line runs from the tank house to a crew quarters building, office building, maintenance shop, engine barn, fire hydrant, several hose bibs and yard hydrants, a tank filling stand pipe, and irrigation system.

The fire station was previously operated seasonally, but since 2017 it has been operated year-round. In

Prepared by Aarcher, Inc. 3 accordance with BLM policy and NDEP regulations a water system in Nevada that is operated year-round could go quarterly coliform sampling, but a seasonally operated water system must sample monthly. The Winnemucca Field Office has decided to do monthly sampling, but the McDermitt Fire Station could revert back to seasonal operation at any time.

NOTE: If McDermitt does revert back to seasonal operation in accordance with BLM policy and NDEP regulations a start-up coliform sample must be taken prior to opening the water system for use by employees. This start-up sample does not count as the monthly sample. Completion of the NDEP start-up procedures would not be required though unless the start-up coliform sample tests positive for total coliforms.

Table 2-2 provides a summary of the distribution system components. A schematic depicting the layout of the water distribution system provided by BLM Nevada is included in Appendix A.

Table 2-2. Water System – Key Components

Component Description Capacity

Well One groundwater well 10-inch diameter well, 600 feet deep

Pressure Tank Three pressure tanks 100 gallons each, total 300 gallons

2.1 Sampling Sites

For the purposes of this plan, the term “sample tap” is used to describe an individual building or an isolated yard hydrant that is not connected to a building. BLM’s CASHE program guidance is that routine and repeat samples should be taken from different sample taps (e.g., different buildings) so that samples represent the entire distribution system. The BLM CASHE program does not recommend that repeat samples are taken from within the same tap (i.e., building), although NDEP may allow it.

Within each sample tap there may be several “sample locations.” For the purposes of this plan, the term “sample location” is used to describe a distinct location within each sample tap where water can be sampled. Sample locations can be a sink faucet, hose bib, or drinking fountain that all receive water from the same tap off the distribution system.

Table 2-3 lists the sample taps identified for the facility. Sampling locations within each tap have been specified. A smooth nose sample tap located in the tank house allows sampling of the “raw water” from the well. This raw water tap is designated as Sample Tap #1. Sample Tap #1 will only be sampled if the monthly routine sample taken from any of the other taps tests total coliform or E. coli positive. When taking a sample, the sample tap number must be noted on the lab form. Sample taps are marked on the facility schematic included in Appendix A.

Table 2-3. Sample Taps

Number Sample Tap Sample Location

#1 Tank house Hose bib

#2 Shop Hose bib, east side

#3 Crew quarters Kitchen sink

#4 Office Sink

#5 Hose filling stand Hose bib

Note: Per conversations with Margie Evans, NDEP, each location within a building and any exterior hose bib is considered a single tap. This is not consistent with BLM CASHE Program guidance. This plan is written to address each building as a sample tap.

Prepared by Aarcher, Inc. 4

3 COLIFORM SAMPLE COLLECTION

Only State-certified laboratories (either State-owned or commercial) may be used for sample analysis. All samples must be collected using a standard sample volume of at least 100 milliliters (mL), regardless of the analytical method used.

3.1 Laboratory Analysis

The certified laboratory currently used for this facility is the Nevada State Public Health Laboratory (NSPHL) located at the University of Nevada Reno. NSPHL accepts samples for coliform, nitrate, and nitrite for analysis Monday through Friday. Samples must be delivered to the laboratory by 4:15 PM on Friday. As the laboratory is not open on weekends, the 30-hour holding time limit for these samples will be exceeded if the samples are delivered by 4:15 on Friday. Samples should be taken at the beginning of the week to ensure holding times are met. Refer to Appendix B for a summary of sample preservation and hold times.

Obtain sample containers from the laboratory and place them in a clean zip lock bag.

Fill out the chain of custody form provided by laboratory (see Appendix C). This completed form must accompany all water samples. This form is used by the laboratory to ensure that the correct analysis is performed and sample holding time is not exceeded. The information provided in Table 3-1 is provided to facilitate completion of the chain of custody form.

Table 3-1. Chain of Custody Form Information

Owner Information

Owner McDermitt Fire Station

Address [Address to receive sample results and/or invoices]

Phone [Contact phone number]

Fax [Contact fax number]

Check box “Not for Compliance”

Source of Water

Public Water System ID Number: Nonpublic Water System

Public Water System ID Name McDermitt Fire Station

Sample Type Check box for SDWA

Reason for Analysis (under “Other”) Nonpublic water system

Use of Water (Nitrate/Nitrite form only) Check box for “Domestic Drinking Water”

Report to Information

Report to BLM, Winnemucca District

Attn Terri Suiter

Address 5100 East Winnemucca Boulevard, Winnemucca, Nevada 86445

Phone (775) 623-1509(desk) (775) 625-0487

Fax (775) 623-1503

Bill to Information

Bill to BLM, Winnemucca District

Address 5100 East Winnemucca Boulevard, Winnemucca, Nevada 86445

Sample Information

Date Collected Date sample was collected

Prepared by Aarcher, Inc. 5

Time Collected Time sample was collected

Source Address Highway 95 & North Reservation Road, McDermitt, Nevada 86445

Sample Taken From Enter the sample tap number as identified in this plan, or other identifier that describes the exact tap where the sample was collected. For example, “Sample Tap #3 Crew Quarters kitchen sink”.

State Nevada

County Humboldt

Sampler Enter name of person that took the sample

Tests

For Coliform: Check box for “Total Coliform SDWA – Qualitative”

For Nitrate/Nitrite: Check box for “Nitrate + Nitrite as N”

Table notes:

*Use the sample location number and also further identify from where in the building (e.g., kitchen sink, bathroom, hose bib) the sample was taken.

3.2 Collection Method

Before taking the sample, label the sample container with the same information (e.g., sample tap number and sample location) as the chain of custody form. Each labeled container should be filled out completely with the date and time that the sample was taken, the client’s name, the sample tap and location, and who took the sample. If bottles are not labeled, this information may be written directly on the bottle. Use water-repellent ink. Put the labeled container back into the zip lock bag.

For coliform samples, it is critical to document the correct sample tap number and sample location (e.g., office sink, crew quarters kitchen sink, etc.) as identified in this plan on the chain of custody form in case a sample tests positive for coliform. The sample locations for three of the four repeat samples that must be collected if a routine sample tests positive for coliforms are dependent on where the initial routine sample was taken. A fourth sample must be taken if a routine sample tests positive for coliforms. This fourth sample required by the Ground Water Rule is commonly referred to as a “triggered monitoring” sample and must be taken from the well, Tap #1.

Complete the following items in the order presented when collecting samples for either routine or repeat sampling:

1. Wash hands using a liquid hand sanitizer before collecting samples.

2. Do not rinse sample bottles before sampling. If the sample bottle contains preservative, do not dump or rinse the preservative from the bottle.

3. Locate the proper sampling tap and remove any attachments such as hoses, screens, and aerators.

Reinstall these items after the sample is taken and the sample container is put back into the clean zip lock bag.

4. Clean the inside and outside of the faucet with alcohol or 10% bleach solution for disinfection. Allow it to evaporate before continuing.

5. Turn on the water and let it run at a steady stream until a temperature change is felt. Do not run the tap for more than 5 minutes. Do not open the tap as far as it will go. A very high flow or sudden changes in water pressure can dislodge sediment and make the sample unusable. Before collecting the sample, turn the water down so that the stream is the width of a pencil.

6. Remove the labeled container from the zip lock bag and unscrew the cap. Hold the cap on its outer edge being careful not to touch the underside of the cap, which may contaminate the sample.

Prepared by Aarcher, Inc. 6

7. Do not use a sample container if the cap was not originally screwed on tightly, as it may have been tampered with or otherwise contaminated.

8. Do not set the sample container or cap on the ground. Coliform bacteria are present in the soil and contact with the floor or ground may contaminate the sample.

9. Place the container under the running water being careful to avoid water splashing onto the sampler’s hands. Splash-back from the sampler’s hands into the container has the potential to contaminate the sample.

10. Hold the sample container below the rim and fill the bottle to the neck or indicated fill line, ensuring the laboratory has enough water to run the test. Do not allow the container to overflow. A 100-mL sample is required for coliform sampling. An air space should be provided in the container.

11. Replace the cap as soon as the sample container is full and removed from the flow of water.

12. Re-sample using an extra sample bottle if the sample container or its cap is dropped on the floor or ground before, during, or after sampling.

13. Place the labeled sample container and completed chain of custody form in a zip lock bag. Place the sealed bag in a clean cooler.

14. All samples should ideally be received by the laboratory between 2°- 6°C. Ice packs or wet ice can be used, but do not allow the samples to freeze. If wet ice is used do not bury the sample in the ice, because as it melts, water might get into the zip lock bag and contaminate the exterior of the sample bottles.

15. Turn off the water and replace any attachments.

16. Drive the samples directly to the laboratory.

When filling out the chain of custody form, it is imperative that the sample tap number shown on the site map (Appendix A) of this plan be written on the form under “Sample Identification.” If a positive coliform result is reported and the sample tap identified on the form is not noted as described in this plan, it will be difficult to determine which tap was sampled. Because the taps of the repeat samples are dependent on the tap where the sample was originally taken, using consistent sampling tap designations is important. If the exact sample tap is not consistently noted, it will also be difficult to use historic results in a trend analysis performed to determine the source of coliform contamination.

Prepared by Aarcher, Inc. 7

4 ROUTINE COLIFORM MONITORING

Routine samples are water samples that are required to take on a regular basis to monitor for the presence of total coliforms. This plan incorporates monitoring requirements from the RTCR (effective April 1, 2016) and the GWR. Total coliform samples must be collected at locations that are representative of water quality throughout the distribution system. A water sample that is positive for total coliforms must be further tested for the presence of E. coli. State-certified laboratories generally test positive total coliform samples for E. coli automatically, but water systems should check to be sure this is completed.

The RTCR uses E. coli as an indicator of fecal contamination, rather than fecal coliforms, because the fecal coliform assay is imprecise and can capture environmental bacteria that do not originate in the human or mammal gut. Generally, coliforms are bacteria that are not harmful, and are naturally present in the environment.

4.1 Coliform Monitoring Schedule and Taps from Which Samples are to be Collected

Coliform sample taps are selected and assigned to represent all areas of the distribution system. There is also a sample tap for raw water from the well (Sample Tap #1). Do NOT use the raw water tap at the source as a sampling site for routine coliform samples. This is a "triggered source water" sampling location under the GWR. Refer to Section 5.1 for additional information on samples required by the GWR.

Collect the monthly samples from the predetermined sample taps identified in Table 4-1 in a sterilized sample container provided by the laboratory following the procedures described in Section 3.1 of this plan. Repeat sampling locations for each of these taps is provided in Table 5-1.

Table 4-1. Coliform Sampling Locations

Sample Period Sample Location

January Sample Tap #2 Shop hose bib, east side

February Sample Tap #3 Crew quarters kitchen sink

March Sample Tap #4 Office sink

April Sample Tap #5 Hose filling stand bib

May Sample Tap #2 Shop hose bib, east side

June Sample Tap #3 Crew quarters kitchen sink

July Sample Tap #4 Office sink

August Sample Tap #5 Hose filling stand bib

September Sample Tap #2 Shop hose bib, east side

October Sample Tap #3 Crew quarters kitchen sink

November Sample Tap #4 Office sink

December Sample Tap #5 Hose filling stand bib

NOTE: If McDermitt does revert back to seasonal operation in accordance with BLM policy and NDEP regulations a start-up coliform sample must be taken prior to opening the water system for use by employees. This start-up sample does not count as the monthly sample. Completion of the NDEP start-up procedures would not be required though unless the start-up coliform sample tests positive for total coliforms.

Start-up sample should be taken from Sample Tap #3, crew quarters kitchen sink. This sample must be labeled “special” and not routine as it does not count was the required monthly sample.

Prepared by Aarcher, Inc. 8

4.2 When Routine Coliform Samples Must be Taken

1. Take samples during the first week of the month. This is necessary to ensure that, if weather or other unanticipated events makes taking a sample difficult, there is sufficient time remaining in the month to collect the sample. This is also necessary to ensure that, if a routine sample tests positive, the required three repeat samples and the GWR-triggered monitoring sample can be taken the same month the positive result occurs.

2. Take sample on a day coordinated with the laboratory. Samples must be delivered to the laboratory by 4:15 PM on Friday.

4.3 What Actions Must be Taken if a Routine Coliform Sample is NOT Taken

If monthly samples are not taken, a Tier 3 public notification must be prepared and posted. See Section 9 for details on public notification requirements and Appendix D for public notification forms.

4.4 What Actions Must be Taken if a Routine Coliform Sample Tests Positive for

Coliform?

Each total coliform-positive routine sample must be tested for the presence of E. coli. If any routine sample is total coliform-positive, repeat samples and a Ground Water Rule sample from the well are required. If any sample is also E. coli-positive, then the sample result must be reported to the Field Office/District Engineer, the State Engineer, and the Station Manager by the end of the day that the water system is notified.

1. Ensure that the laboratory tests the sample for E. coli. State-certified laboratories should test positive total coliform samples for E. coli automatically, however, the water system operator should verify that this has been completed. Because the system is not a PWS, NDEP should not be contacted following a positive E. coli result. The State Engineer, District/Field Office Engineer, and the Station Manager must be notified immediately.

2. If the sample is positive for E. coli, consult with local management, the Station Manager, the Field Office/District Engineer, and the State Engineer on whether the water system should be shut down until it tests absent of coliforms.

3. Attempt to find the cause or source of the positive result.

4. If a routine sample tests positive for coliform, repeat sampling, including a GWR sample, must be conducted. Repeat sampling and the GWR sample locations and procedures are described in Section 5.

Prepared by Aarcher, Inc. 9

5 REPEAT COLIFORM AND GROUND WATER RULE (GWR) MONITORING

Repeat samples are follow-up samples that are required each time a routine sample is positive for total coliforms. A repeat sample is only taken if a routine sample tests positive for coliforms.

Repeat samples, like routine samples, must be tested for the presence of total coliforms, and if positive, for the presence of E. coli. State-certified laboratories generally do this automatically, but water systems should check to be sure it is completed. The primary reasons for taking repeat samples are to verify the initial positive result and to determine if the bacteriological contamination is limited to a single tap or is widespread in the distribution system.

The presence of coliform bacteria suggests that there could be a problem with existing equipment or treatment systems, contamination of the source water, or a breach in the distribution system that could introduce E. coli contamination.

To comply with the GWR, after a positive coliform result, in addition to the three repeat samples, a sample must be taken from the well or sample tap closest to the well prior to treatment. The GWR refers to this sampling as triggered monitoring. In the case of the McDermitt Fire Station water system, the sample tap closest to the well prior to treatment is designated as Sample Tap #1.

5.1 Repeat Coliform Sample Quantity and GWR Sample and Taps from Which Samples are to be Collected

Do not disinfect the system prior to taking repeat samples. Disinfecting the distribution system after a positive routine coliform sample defeats the purpose of determining if the initial positive result was due to sampling error, or if the contamination is widespread or isolated.

1. Collect three repeat coliform samples AND one GWR-triggered monitoring sample from the predetermined sample taps indicated in Table 5-1 within 24 hours of being notified of the positive result by the laboratory.

2. The taps at which the three repeat samples must be taken is specified in the regulations as follows: 1) sample tap that initially tested positive; 2) sample tap within five taps upstream from the initial sample tap that tested positive; 3) within five sample taps downstream from the initial tap that tested positive;

and 4) one ground water source sample.

3. The one GWR-triggered sample must be taken from a location that represents the raw water source and should be as close to the well as possible (Sample Tap #1).

Table 5-1. Repeat Coliform Sample Locations

Location of Positive Sample

GWR Sample Location Repeat Sample Locations

Shop hose bib, east side (Sample Tap #2)

Tank house (Sample Tap #1)

Shop hose bib, east side (Sample Tap #2)

Crew quarters kitchen sink (Sample Tap #3)

Office sink (Sample Tap #4)

Crew quarters kitchen sink (Sample Tap #3)

Office sink (Sample Tap #4)

Hose filling stand bib (Tap #5)

Office sink (Sample Tap #4)

Office sink (Sample Tap #4)

Prepared by Aarcher, Inc. 10

Location of Positive Sample

GWR Sample Location Repeat Sample Locations

Hose filling stand bib (Sample Tap #5)

Hose filling stand bib (Sample Tap #5)

4. Collect each repeat and GWR sample in a sterilized sample container provided by the laboratory and following the procedures described in Section 3.1 of this plan.

5. If any or all of the three repeat samples are not taken or if the GWR-triggered monitoring sample is not taken complete the following:

a. Consult with Field Office/District Engineer and the State Engineer on whether a Level 1

Assessment should be performed, who will perform it, and if the repeat and GWR sample should be taken now. Document their guidance and file with the drinking water monitoring results.

b. Implement the guidance from the Field Office/District Engineer or State Engineer.

c. Notify the Station Manager the samples were not taken and what actions are being taken now.

d. Prepare a Tier 3 public notification and post a copy of it in the office and crew quarters. See

Section 9 for details on public notification requirements and Appendix D for public notification forms. Because the system is not a PWS, NDEP should not receive a copy of the certified public notification.

e. File a copy of the public notification with the monitoring results.

5.2 When Repeat Coliform and GWR Samples Must be Taken

1. Take all three repeat samples and the GWR-triggered monitoring sample within 24 hours of being notified of the positive routine result by the laboratory.

2. Inform local management, the Field Office/District Engineer, and the State Engineer if the repeat samples cannot be taken within 24 hours of being notified. Examples of reasons the repeat samples cannot be taken within the 24-hour period may include the laboratory being closed or doing so poses a work conflict (e.g., notification was received too late on Friday and sampling on Saturday would require overtime). Take repeat samples as directed by management, but no longer than 3 days after being notified by the laboratory.

3. If a routine sample tests positive for E. coli the water system must be shut down and tap secured immediately or the repeat samples MUST be taken within 24 hours regardless of the circumstances.

5.3 What Actions Must be Taken if One or More Repeat Sample or GWR Sample Tests

Positive for Coliforms?

1. Inform local management, the Fire Station manager, the Field Office/District Engineer, and the State Engineer of the positive repeat sample, clarify whether any results were positive for E. coli, and ask for further guidance. Specifically ask the District and State Engineer whether a Level 1 or Level 2 assessment must be performed.

2. Document guidance received from the Field Office/District Engineer or the State Engineer noting the actual guidance received, whether a Level 1 or Level 2 Assessment should be performed and who will do the Assessment (i.e., qualified BLM personnel or contractor), date, and time of the call.

Prepared by Aarcher, Inc. 11

Document the same information even if it is provided in a voice mail.

3. Implement guidance received from the Field Office/District Engineer or the State Engineer and document the efforts made to find the source of the positive coliform results

4. If the initial routine sample tests positive for only total coliforms and one or more of the repeat samples and/or the GWR sample tests positive for only total coliforms attempt to find the cause or source of the positive result. If required by the Field Office/District Engineer or the State Engineer document the efforts made to find the source using the NDEP Level 1 assessment form. Note: If a second Level 1 Assessment is triggered within a 12-month rolling period a Level 2 Assessment must be performed. Contact the Field Office/District Engineer or the State Engineer for guidance on getting a contractor or qualified BLM personnel to do the Level 2 Assessment.

5. If the initial routine sample tests positive for E. coli and if any of the repeat samples and/or GWR sample also tests positive for total coliforms or E. coli, prepare and post a Tier 1 public notification.

See Section 9 for details on public notification requirements, and Appendix D for public notification forms. Also contact the Field Office/District Engineer or the State Engineer for guidance on getting a contractor or qualified BLM personnel to do the Level 2 Assessment.

6. If the initial routine sample tests positive for only total coliforms and if any of the repeat samples and/or the GWR sample tests positive for E. coli, prepare and post a Tier 1 public notification. See Section 9 for details on public notification requirements, and Appendix D for public notification forms.

Also contact the Field Office/District Engineer or the State Engineer for guidance on getting a contractor or qualified BLM personnel to do the Level 2 Assessment.

7. If the GWR sample tests E. coli positive five additional samples must be taken from Sample Tap #1 as required by the GWR to verify the well is contaminated with E. coli. If any of those five samples tests E. coli positive the water system must be shut down until a 4-log disinfection system installed as required by the GWR. Contact the Field Office/District Engineer or State Engineer for a decision on whether the water system will be shutdown permanently or a 4-log disinfection will be installed.

Consult Table 5-2 to determine whether a Level 1 or Level 2 Assessment is triggered and if a public notification must be prepared and posted. See Section 6 for detailed guidance on performing Level 1 or 2 Assessments. See Section 9 for details on public notification requirements, and Appendix D for public notification forms.

Table 5-2. Assessment and Public Notification Triggers

Routine

Total Coliform

Routine

E. coli

Repeat

Total Coliform

Repeat

E. coli

Level 1 Assessment

Level 2 Assessment

Public Notification absent N/A N/A N/A No No No positive absent absent absent No No No positive absent positive absent Yes* No No positive positive absent absent No No No positive positive positive absent No Yes Yes positive positive positive positive No Yes Yes positive absent positive positive No Yes Yes

*If directed by the Field Office/District Engineer or State Engineer. NOTE: if a second Level 1 Assessment is triggered in a rolling 12-month period a Level 2 Assessment must be performed by a contractor or qualified BLM personnel.

Prepared by Aarcher, Inc. 12

6 TREATMENT TECHNIQUE TRIGGERS AND ASSESSMENTS

The Pony Springs Fire Station water system is not classified as a fully regulated PWS because it does not provide water to an average of 25 people any 60 days of the year. Therefore, compliance with NDEP regulations on the performance and documentation of assessments to identify the cause of positive coliform results is not technically required.

PWSs are required to perform and document assessments to identify and correct defects that could provide a pathway of entry for microbial contamination into the distribution system or that are indicative of a failure or imminent failure in a barrier that is already in place. Although the water system at this facility does not meet the definition of a PWS, BLM policy is sample its water systems as if they are PWSs and to operate them in accordance with guidance from the Field Office/District Engineer or the State Engineer.

The BLM’s Engineering Advisory Team has determined that BLM non-PWSs will attempt to find the cause of positive total coliform results using in-house personnel, but that formal documentation and use of the Level 1 Assessment form is not a requirement, but a suggestion. Formal documented in-depth assessments of BLM non-PWSs will only be done when a non-PWS tests positive for E. coli or a second Level 1 Assessment is triggered in a rolling 12-month period. Level 2 Assessments will be performed by qualified contractor or BLM personnel in accordance with state regulations and guidance for a Level 2 Assessment. The remainder of this section describes the procedures that will be followed if a Level 1 or Level 2 Assessment is recommended by the Field Office/District Engineer and the State Engineer.

Table 6-1 is an excerpt from the NDEP website “Level 1 & Level 2 Assessments and Corrective Actions” and is provided here to show example causes of contamination that can lead to positive coliform sample results.

Table 6-1. Example Causes of Contamination and Corrective Actions

Examples of Common Causes of

Contamination Example Common Corrective Action(s)

Loss of system pressure

Maintenance of adequate pressure

Valve maintenance

Addition or upgrade of on-line monitoring and control

Cross connections Maintenance of adequate pressure

Installation of backflow prevention assembly/device

Implementation/upgrade of cross connection control program

Cracks in well seal, casing, etc. Replacement/repair of well components

There are two levels of triggered assessments, Level 1 and Level 2. The assessment level depends on the trigger’s potential impact to public health. For example, a Level 2 Assessment is required when E. coli is present in the sample. E. coli is a greater threat to public health; therefore, requires a more in-depth and comprehensive review of the water system as compared to a Level 1 Assessment.

There are five basic elements to investigate during an assessment:

1. Atypical events that may affect water quality or indicate that water quality in the distribution system was impaired;

2. Changes in distribution system maintenance and operation, including water storage;

3. Water source and treatment methods that affect distributed water quality;

4. Inadequacies in sample sites, sampling protocol and sample handling; and

5. Existing water quality monitoring data.

Prepared by Aarcher, Inc. 13

6.1 When is Performance of a Level 1 Assessment Triggered?

A Level 1 Assessment is a basic examination of the source water, treatment, distribution system (including storage facilities), and relevant operational practices. It is intended as a self-assessment and is typically performed by a person or persons responsible for the system provided they have knowledge of how the water system is designed to operate.

A Level 1 Assessment is triggered if one of the following occurs:

Two or more total coliform-positive samples in one month. Use routine, repeat, and GWR triggered source water monitoring results in your determination of the number of positive total coliform results in one month.

All required repeat samples are not collected following a positive coliform sample.

6.2 How to Perform a Level 1 Assessment

As a non-PWS, this facility is not required to notify NDEP of the need for a Level 1 Assessment or to submit the assessment to NDEP.

1. If a Level 1 Assessment is triggered, notify Field Office/District Engineer and/or the State Engineer via email, and request their determination as to whether a Level 1 Assessment will be performed and who will perform it.

2. The Field Office/District Engineer and the State Engineer may choose to conduct a Level 1 Assessment to identify and correct defects that could provide a pathway for microbial contamination into the distribution system or that are indicative of a failure or imminent failure in a barrier that is already in place. The water system may perform the assessment using BLM personnel who are knowledgeable of the water system or hire a third-party consultant. This person(s) is not required to have an operator’s license.

3. Document guidance received from the Field Office/District Engineer and/or the State Engineer regarding performance of a Level 1 Assessment and file with the coliform monitoring results. File the documented guidance with the coliform monitoring results.

4. The Level 1 Assessment is to be performed (if performed at all) within 30 days of it being triggered.

File the completed Level 1 Assessment with the coliform monitoring results.

6.3 When is Performance of a Level 2 Assessment Triggered?

A Level 2 Assessment is a more comprehensive and in-depth examination compared to a Level 1 Assessment because the trigger for a Level 2 Assessment is multiple positive coliform results with one or more positive for E. coli or the system routinely has total coliform results the source of which has not been identified by performance of a Level 1 Assessment. Performance of Level 2 Assessments is mandatory for BLM non-PWSs when triggered because E. coli poses a serious threat to human health.

A Level 2 Assessment is triggered if one of the following occurs:

A second Level 1 Assessment is required within a rolling 12-month period. Instead of performing a second Level 1 Assessment, a Level 2 Assessment is required because the water system likely has a pathway allowing coliforms to enter it on a recurring basis.

Any of the three repeat samples or the GWR triggered-source water sample tests positive for E. coli;

A routine sample tests positive for E. coli and any of the repeat sample tests positive for total coliform or E. coli. A Level 2 Assessment must be completed even if all the repeat sample tests negative for E.

coli;

Prepared by Aarcher, Inc. 14

Failure to take all required repeat samples following a routine sample that tests positive for E. coli; or

Failure to test for E. coli following any repeat samples that test positive for coliform.

6.4 How to Perform a Level 2 Assessment

As a non-PWS, this facility is not required to notify NDEP of the need for a Level 2 Assessment.

1. If a Level 2 Assessment is triggered, notify the Field Office/District Engineer and/or the State Engineer.

2. If the Field Office/District Engineer and/or the State Engineer agrees a Level 2 Assessment has been triggered, a qualified engineering consultant or qualified BLM engineering personnel must perform the assessment.

3. File the completed Level 2 Assessment with the sampling results.

6.5 What Actions are Required Following a Level 1 or Level 2 Assessment?

1. Correct sanitary defects found through either a Level 1 or Level 2 Assessment within 30 days. A sanitary defect is defined as “a defect that could provide a pathway of entry for microbial contamination into the distribution system or that is indicative of a failure or imminent failure in a barrier that is already in place.”

2. If the sanitary defect cannot be corrected within 30 days, contact the Field Office/District Engineer and the State Engineer for guidance on whether the water system should be closed until the sanitary defects are corrected. Implement and document this guidance and file with the sampling records.

6.6 Coliform Treatment Technique Violations

If a Level 1 or Level 2 Assessment is not performed within 30 days after being triggered, or if any sanitary defects identified during the Level 1 or Level 2 Assessment are not corrected within 30 days (or in accordance with a schedule acceptable to the Field Office/District Engineer and the State Engineer), complete the following:

1. Inform the Fire Station Manager, the Field Office/District Engineer, and the State Engineer that the assessment was not performed, or the corrective action was not completed, and ask for further guidance.

2. Prepare and post a Tier 2 public notification, informing visitors and BLM personnel of the delay in the performance of the assessment. Follow the procedures in Section 9.3 for Tier 2 Public Notice.

Prepared by Aarcher, Inc. 15

7 NITRATE MONITORING

Coliform and nitrate/nitrite monitoring is required because they are acute contaminants. Individuals consuming drinking water contaminated with coliforms and/or nitrate/nitrite can become sick in a couple of days.

7.1 Nitrate MCL

The MCL for nitrate is 10.0 mg/L measured as nitrogen.

7.2 Nitrate Sample Quantity and Taps

Collect one sample as close as possible to the source prior to any treatment (Tap #1) following the sampling procedures detailed in Section 3.

7.3 When Nitrate Samples Must be Taken

Collect the annual sample in January. If a nitrate sample is not taken, follow the public notification procedures in Section 9 for a Tier 2 violation.

7.4 What Actions Must be Taken if an Annual Nitrate Result is Less Than the 10.0 mg/L MCL

If the sample result is less than 10.0 mg/L, no further action is required for the year.

7.5 What Actions Must be Taken if Annual Nitrate Sample Concentration Exceeds the

MCL of 10.0 mg/L

1. Take a confirmation sample within 24 hours of receiving notification from the laboratory that the initial sample result exceeded the MCL. The confirmation sample must be taken within 24 hours of receiving the initial sample result that exceeds the MCL.

2. If a confirmation sample within 24 hours, prepare and post a Tier 1 public notification. Follow the public notification procedures in Section 9 for a Tier 1 violation and take a confirmation sample within two weeks. The notification must state that the nitrate MCL has been violated and the notification must be posted on site within 24 hours.

3. If the average of the initial and confirmation sample is below 10.0 mg/L no further action is necessary.

4. If the average of the quarterly and confirmation sample results exceeds the 10.0 mg/L MCL, inform the Fire Station Manager, the Field Office/District Engineer, and the State Engineer of the nitrate MCL violation and ask for further guidance. Treatment may be required to correct the nitrate contamination.

Follow the public notification procedures in Section 9 for a Tier 1 violation. The notification must state that the nitrate MCL has been violated and the notification must be posted on site within 24 hours.

7.6 What Actions Should be Taken if the Average of Initial and Confirmation Sample

Nitrate Results are Greater Than or Equal to 50% of the Nitrate MCL of 10 mg/L?

The NDEP requires additional monitoring when a community or non-transient, non-community water system has a nitrate sample result that is greater than or equal to 50% of the nitrate MCL (i.e., 5.0 mg/L).

While the facility is not a PWS and is a transient non-community water system, the additional monitoring is highly recommended to ensure the nitrate concentration is stable and not increasing over time:

Prepared by Aarcher, Inc. 16

1. Take a quarterly sample for at least 1 year following any nitrate result where the concentration was greater than or equal to 5.0 mg/L, but less than or equal to 10.0 mg/L.

2. After 1 year of quarterly sampling results less than 10.0 mg/L nitrate, consult with the Field Office/District Engineer and the State Engineer regarding resuming annual nitrate monitoring.

3. Quarterly nitrate monitoring may be discontinued, with the concurrence of the Field Office/District Engineer and the State Engineer, after 1 year if the nitrate results are consistently below 10.0 mg/L.

Future nitrate monitoring should be performed during the quarter in which the highest nitrate concentrate was reported.

Prepared by Aarcher, Inc. 17

8 NITRITE MONITORING

The NDEP requires that transient, non-community water systems be monitored for nitrite every 3 years.

Therefore, so as not to overlook the 3-year cycle, take the nitrite samples every year at the same time as the nitrate sample.

8.1 Nitrite MCL

The MCL for nitrite is 1.0 mg/L measured as nitrogen.

8.2 Nitrite Sample Quantity and Taps

Collect one sample as close as possible to the source prior to any treatment (Tap #1) following the sampling procedures detailed in Section 3.2.

8.3 When Nitrite Sample Must be Taken

Collect the sample in January.

8.4 What Actions Must be Taken if an Annual Nitrite Result is Less Than 50% of the

1.0 mg/L MCL

If the sample result is less than 0.5 mg/L, no further action is required for the year.

8.5 What Actions Must be Taken if an Annual Nitrite Result is Greater Than or Equal to 50% of the 1.0 mg/L MCL, but Less Than 1.0 mg/L

1. Take a quarterly sample for at least 1 year following any nitrite result where the concentration was greater than or equal to 0.50 mg/L, but less than 1.0 mg/L.

2. After 1 year of quarterly sampling results less than 1.0 mg/L nitrite, consult with the Field Office/District Engineer and the State Engineer regarding resuming annual nitrite monitoring.

3. If a nitrite sample is not taken, follow the procedures in Section 9 for a Tier 2 violation.

8.6 What Actions Must be Taken if a Nitrite Result Exceeds the MCL of 1.0 mg/L

1. Take a confirmation sample within 24 hours of receiving the initial sample results. Compliance with the MCL is determined based on the average of the initial and confirmation samples.

2. If a confirmation sample cannot be taken within 24 hours, prepare and post a Tier 1 public notification. Follow the procedures in Section 9 for a Tier 1 Public Notice and take a confirmation sample within 2 weeks.

3. If the average of the annual and confirmation sample exceeds the MCL, it is a Tier 1 violation. Follow the procedures in Section 9 for a Tier 1 public notification and take a confirmation sample within 2 weeks.

4. Inform the Fire Station Manager, the Field Office/District Engineer, and the State Engineer of the nitrite MCL violation and ask for further guidance.

5. Document guidance received from local management, the Field Office/District Engineer, and the State Engineer noting the actual guidance received, date, and time of the calls. Document the same information even if it is provided in a voice mail.

6. File a copy of the public notification with the monitoring results.

7. Implement guidance…