04_DEP_Corrective_20161230_SOW_Attach_02_NON-CE-14-5D024_Sanitary_Survey.pdf

Commonwealth of Massachusetts Executive Office of Energy & Environmenta l Affa irs

Department of Environmental Protection Central Regional Office • 627 Main Street, Worcester MA 0 1608 • 508-792-7650

DEVAL L PATRICK

Governor

Devens South Post

February 26, 2014

Re: PWS City/Town: Lancaster

RICHARD K SULLNAN JR.

Secretary

KENNETH L KIMMELL

Commissioner

Attn: Raymond A. Prisk, P.E.

30 Quebec St., Bldg. 666, Unit 34 Devens, MA. 01434-4479

PWS arne: U.S. Army Devens (South Post)

PWS ID#: 2147006

Dear Public Water System Official:

Program: Sanitary Surveys

NON-CE-14-5D024

Attached is a Summary of the Sanitary Survey, including a Notice of oncompliance, performed at U.S.

Army Devens (South Post) in Lancaster on December 4, 2013. This summary identifies those items found during the survey that MassDEP has determined need to be corrected and the timeframe for completing them.

Please note that the signature on this cover letter indicates formal issuance of the attached document. If you have any questions regarding this letter, or would like a copy of the Sanitary Survey Evaluation, please contact Kristin Divris at (508) 849-4028 or kristin.divris@State.ma.us.

cc: PWS Sanitary Survey File (stamped "File Copy")

Sincerely, ~d-~ Robert A. Bostwick Acting Section Chief Drinking Water Program

Certified Operator- Robert D. Smith, Small Water System Services Lancaster Board of Health MassDEP-DWP CERO and Boston Correspondence (cover letter only) Cheryl Poirier- BRP Enforcement Coordinator Denise Child- Office of Enforcement DWP Enforcement Book

File Name: Y:\DWP Archive\CERO\Lancaster-2147006-SS-2014-02-26.docx

W:\ WS\DW PROGRAM FILES\SANIT AR Y SUR VEYS\Final\Lancaster-214 7006-SS-20 14-02-26.docx

This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751 . TDD# 1-866-539-7622 or 1-617-574-6868 MassDEP Website: www.mass.gov/dep

Printed on Recycled Paper

Public Water System Summary of Sanitary Survey

U.S. Arm Devens (South Post) 2147006 Lancaster PWSName PWSID# PWS Ci VTown

Survey Date: 12/4/2013 Report Date: 2/26/2014

Surveyor:

Kristin Divris; Barbara

Affiliation: CERO/DWP Kickharn

Person Interviewed: Robert Smith Title: Primary Operator, SWSS

Environmental Scientist, Person Interviewed: Anne Fardy Title: Bluestone Engineering;

Devens DPW

Person Interviewed: Thomas Poole Title: Devens DPW

PUBLIC WATER SUPPLIERS:

A completed Sanitary Survey Evaluation is on-file at the MassDEP CERO office for the above referenced Sanitary Survey Site Visit. A copy of the checklist will be provided upon request.

In addition to the "System Description" and "Statement of Zone I Compliance", this mailing includes a "Summary of Findings" specifying:

Table A - Violations referenced as NON-CE-14-SD024 Table B - Deficiencies Table C- Recommendations Water Supplier Response and Certification Form (To be completed and returned within 30 days of receipt, if Table A and/or Table B items included in Summary of Findings)

During the course of the Sanitary Survey, MassDEP observed conditions in the source, facilities, equipment, operation, or maintenance of the PWS that are violation(s) of a regulation or statute and that jeopardize the delivery of pure and safe water to all consumers (hereafter collectively referred to as "violations"). All violations found at the PWS are listed in the attached Summary of Findings Table A, which is also a Notice of Noncompliance (NON) pursuant to M.G.L. c.21A, § 16 and 310 C.M.R. 5.00.

otwithstanding this NON, MassDEP reserves the right to exercise the full extent of its legal authority in order to obtain full compliance with all applicable requirements. Noncompliance with the terms of the NON may result in further enforcement, including the assessment of administrative penalties of up to $25,000 for each day after the effective date of the NON during which each violation continues or is repeated, and/or the issuance of a unilateral administrative order requiring the necessary corrective action(s) within a reasonable time period. Noncompliance with the terms of such an order may also result in further enforcement, including the imposition of penalties of up to $25 ,000 for each day after the effective date of the Order during which each violation continues or is repeated.

Note: Systems are not relieved of their responsibility for meeting regulatory requirements that may not be covered in the "Summary of Findings".

Public Water System Summary of Sanitary Sur\rey Page 1 of 12

U.S. Army Devens (South Post) 2147006

SYSTEM DESCRIPTION

Lancaster Survey Date: December 4, 2013

U.S. Army Devens (South Post) is currently classified as a Transient, Non-Community (TNC) Public Water System (PWS) located on the 4,900-acre Fort D~vens Military Reservation in the Town of Lancaster. . The PWS has approximately 15 full-time employees on staff and ser.ves an additional population of approximately 200 police officers and military reservists for training and exercise purposes throughout the week and weekends. The property training areas are divided by numbers 1 through 15, and further subdivided by letters (e.g., Section 9A).

The PWS has three, active, gravel packed wells all treated with disinfection, which each serve three, separate distribution systems.

Well 01G (South Post Well D1) was observed to be an approximately 6-inch diameter, gravel pack well with a concrete slab located within a ladder-accessed, sub-grade vault on the west side of Dixie Road, east of the Echo Range area. The well specifications for this source are unknown. The source has a split cap, screened vent, and an air vacuum valve on the transmission line within the vault prior to being piped into the FAC Building's boiler/mechanical room. The rest of the F AC Building serves as a classroom facility for training with a restroom. The water line enters at the comer of the boiler/mechanical room and is immediately treated with sodium hypochlorite for disinfection before entering the Well-X Trol 125 hydropneumatic tank. There is no raw water sampling tap. After the hydropneumatic tank, water passes through a Hersey meter before serving the boiler and the rest of the building upon demand. The water line to the boiler maintains a pressure regulator and is protected by a Watts 12'' backflow prevention device. Well 01 G does not serve water to any additional buildings beyond the F AC building.

Well 02G (Observed Fire Trainer- OFT Well) is located approximately 22' north of Well 01G and was observed to be an approximately 8-inch diameter, gravel pack well also located within a stair-accessed, sub-grade vault on the west side of Dixie Road, east of the Echo Range area.

Well specifications for this source are unknown. Water from this source is pumped by a Franklin Electric, 1.5 horsepower (HP), submersible pump upon demand. There are two hydropneumatic tanks within the vault; a 2005 Well-X-Trol 350 hydropneumatic and a 1985 steel pressure tank certified by Massachusetts Engineering Co. , Inc. out of A von, MA.; size unknown. Both pressure tanks are connected to the water system; however, the pressure switch for the well pump is connected to the 1985 tank. There is a raw water sample tap present before water is treated with sodium hypochlorite for disinfection. Water then passes through the Hersey meter prior to the pressure tanks. A finished water sample tap is present after the pressure tanks before the transmission line leaves the vault. The vault also contains a sump pump used to pump water out of the vault, which is necessary when running the sample taps prior to sample collection. This source serves water to the OFT only, which is a filling dock with two hydrants located on the east side of Dixie Road.

Well 03G (Range Control Well 3) was observed to be an approximately 12-inch diameter, gravel pack well located about 300' southwest of the Range Control Building and attached Ammunition Warehouse. The transmission line from the well travels under the parking lot and enters the Ammunition Warehouse northwest comer. A raw water sampling tap is present upon entrance to the building. The water line travels up the northwest wall and across the ceiling towards the center of the building into a second story loft area, whic.h is accessed by pull-down stairs within the Range Control Building. Water travels through a Hersey meter, Public Water System Summary of Sanitary Survey Page 2 of 12

Lancaster Survey Date: December 4, 2013 and is injected with sodium hypochlorite for disinfection before entering the Well-X-Trol 251 hydropneumatic tank. Water is served upon demand to a men' s restroom, women' s restroom, hallway bubbler, and closet slop sink all located within the Range Control Building. A separate line travels from the second story loft area after treatment, to an eye wash located at the center of the Ammunition Building. A treated water line also exits the Ammunition Building at the same location the source enters the building, which travels underground to serve the DPW Building located approximately 1200' northwest of the Ammunition Building.

The line enters the DPW Building at the northwest comer in the bathroom, which maintains two bathroom stalls, a urinal and hand sink. There is also a washing machine located in the bathroom that is connected to the water supply. On the opposite side of the bathroom wall, there is one spigot with an attached hose for water use. There is no water use in the rest of the DPW Building. The Quonset Hut next to the DPW Building has no water service.

CAPACITY DETERMINATION

Capacity is the ability of a public water system to plan for, achieve, and maintain financial, managerial and technical compliance with applicable federal and state drinking water standards for the foreseeable future.

Capacity also requires the demonstration of effective controls in all three areas.

This public water system is determined to have conditional capacity. Systems with conditional capacity currently meet MassDEP drinking water regulations but have issues that need to be improved.

STATEMENT OF ZONE I COMPLIANCE

p- You are hereby notified that Wells OlG, 02G and 03G are in non-compliance with MassDEP's requirement, 310 CMR 22.21(3)(b), that Zone I activities be limited to those directly related to the provision of public water or will have no significant adverse impact on water quality. Wells OlG. 02G and 03G will remain in non-compliance status until the non-conforming activities identified below have either ceased or are no longer within the Zone I. Pursuant to 310 CMR 22.04(1) and 310 CMR 22.21(1)(a), you or your designated representatives must notify MassDEP prior to a change in facility ownership or a change in land use within the Zone I, or any change that can impact the quality or quantity of the drinking water supply. You or your designated representative must obtain MassDEP approval prior to modifying or expanding the facility, or replacing any well or source. MassDEP will not approve any proposed modifications or expansions resulting in water quality withdrawals that exceed the designated MassDEP approved pumping rate.

Refer to MassDEP BRP Policy #94-03A Implementation of Zone I Requirements http: //www.mass.gov/dep/water/laws/9403a.pdf.

Non-conforming activities documented within the Zone I:

Well 01G: Roadway, Parking Area

Well 02G: Roadway, Parking Area, Portion of Building

Well 03G: Parking Area

Public Water System Summary of Sanitary Survey Page 3 of 12

Lancaster Survey Date: December 4, 2013

GENERAL SYSTEM COMMENTS

SYSTEM MANAGEMENT

As a TNC, Master Plans and Capital Improvement Plans are typically unnecessary provided comprehensive preventative maintenance plans and/or asset management plans exist that account for scheduling tasks, recording necessary and spare parts, and documenting financial capacity. It is unknown if a reserve account exists that is specific to this PWS for unexpected drinking water issues or unbudgeted expenses, and the PWS lacks the aforementioned plans. In addition, the PWS developed water service in an site known as Area 9A without prior MassDEP approval, and is considering expansion in another area known as the FBI Building in coordination with MassDEP. MassDEP recommends the PWS develop a Master Plan for the entire property for current and future planning purposes.

OPERA TOR COMPLIANCE

Robert D. Smith, of Small Water System Services (SWSS), maintains a Licensed Grade 2D and 2T Full Operator with license numbers 23627 and 23767 respectively. The 2012 eASR listed Robert D. Smith as the primary operator; however, the PWS certified operator compliance notice on file dated 611 /2005, lists Deborah A. Bray as the primary operator. Since Robert D. Smith is currently the primary operator for this PWS, an updated certified operator compliance notice, COD-5 form, and Small PWS Staffing and Comprehensive Operations Plan are required. The correct forms are attached to this report for completion and submission to MassDEP.

SOURCES

Well 01G (South Post Well #D1) was incorrectly located in MassGIS . A locational change request was submitted to MassGIS on 1124/2014.

Well 01 G is the only source that maintains a screened vent; however, the split well cap on Well 01G constituted a Groundwater Rule Significant Deficiency (GWR-SD), and a notice for such was issued on 12/20/2013. Wells 02G and 03G are not vented and must be retrofit with properly screened vents.

During the sanitary survey inspection, Well 02G maintained flexible tubing directly into the wellhead that was not protected, which also constitutes a GWR-SD and was included in the 12/20/2013 notice.

Non-compliant land uses within the Zone I are described in the Statement of Zone I compliance.

PUMPING STATIONS

The sump pump present within the vault of Well 02G discharges just outside the north comer of the vault at above-ground level. There is little evidence that the amount of water discharged from the sump would have an impact on the well itself or the surrounding Zone I due to the intermittent use, and therefore should not be considered process and instrumentation waste recommended to be discharged at least 1 00 ' from the wellhead.

Emergency power is available for Well 03G and the Range Control Building/Ammunition Warehouse only, but the frequency of testing was unknown. The Department recommends that testing the emergency power under full load be performed on an every six month to annual basis and recorded as appropriate. In addition, portable generators may be considered for operating

Public Water System Summary of Sanitary Survey Page 4 of 12

2147006

Lancaster Survey Date: December 4, 2013

Wells 01 G and 02G if necessary during any power loss, and should also be periodically tested under load.

Although all three wells are metered, the meter age of each is unknown. MassDEP recommends that all source meters be replaced or calibrated either every ten years or according to flow based upon the manufacturer' s specifications.

An Operations and Maintenance (O&M) manual for the LMI Chemical Feed Metering Pump at Well 03G was on-site; however, it alone does not provide the information necessary for operating and maintaining the entire PWS. During the survey, it was found that there was confusion regarding the operation of Well 03G; specifically, which lines were carrying treated water. Subsequently, this led to the discovery that the sample tap used by operators for the raw water is a fmished water sample tap on the line going to the DPW Building. Therefore, historical data for the raw water at this source must be further reviewed by MassDEP and reconciled as necessary. All raw water transmission and finished water distribution lines must be clearly identified for Wells 01G and 03G. Due to the limited pipe used for Well 02G, raw and finished pipe identification is not required.

To ensure proper PWS operations, MassDEP also requires the PWS develop a written and complete O&M manual specific to the source, treatment and distribution system of each of the three systems, along with the operations at Area 9A. In addition, MassDEP recommends the PWS develop a written Preventative Maintenance (PM) and asset management plan that provides a reference for scheduling tasks, recording assets and expense accounting for the overall system.

A guide for PM and asset management plans is attached to this report and can also be found on the MassDEP website at: http://www.mass.gov/eea/agencies/massdep/water/drinking/

TREATMENT

Wells 01G and 02G maintain LMI chemical feed metering pumps for sodium hypochlorite (disinfection), which are interlocked with their respective well pumps. Historical records indicate that the PWS installed unpermitted disinfection at Well 01 G in January 2003 and at Well 02G in April 2004. A treatment permit for both sources must be submitted to MassDEP for review.

Well 03G disinfection was approved through a WS34 permit application in December 2009.

This source maintains an LMI chemical feed metering pump, which is paced on flow by a 3-50 gallon per minute (gpm) transmitting flow meter that adjusts the chemical feed rate so that it is proportional to the water flow. A programmed controller receives the flow signal, confirms flow and energizes the chemical feed pump outlet to provide power. This ensures that the chemical feed pump operates only when water is flowing.

A raw water sample tap is not available at Well OlG, which is a GWR-SD that was included in the 12/20/2013 notice. Per 310 CMR 22.05(l)(a), a raw water source sample shall be collected if the water at the entry point to the distribution system is not representative of the source. The PWS has been submitting monthly bacteria results since 2006 indicating raw water sampling was conducted at Well OlG; however, since no raw water sampling tap exists, the data is false and must be invalidated. The PWS must install a smooth nose-sampling tap prior to any treatment, and begin monitoring the raw water monthly.

Public Water System Summary of Sanitary Survey Page 5 of 12

Lancaster Survey Date: December 4, 2013

The chlorine day tanks for Wells 01G and 02G do not have proper secondary containment per the Chapter 6 Guidelines, which note that unless otherwise approved by MassDEP in writing, all liquid chemical tanks shall be provided with containment of not less than 11 0 percent of the total volume of the tanks. Considering the location of the chemical day tanks; within the boiler room of Well 01G, and immediately next to Well 02G within the vault, secondary containment is necessary to avoid further complications that would arise in the event of a spill.

No personal protective equipment for sodium hypochlorite was observed during the inspection at any of the sources. Minimum protection for the eyes, hands and skin should include goggles, disposable latex/rubber apron, PVC or rubber gloves and rubber boots.

GWR Form A (Log Credit) was completed and submitted for Wells 01G and 02G; however, it was not submitted for Well 03G as MassDEP recommends.

FINISHED WATER STORAGE

The three sources and their respective distribution systems do not maintain any atmospheric storage tanks. However, there are six, 3,000-gallon atmospheric storage tanks that serve Area 9A, which are filled with potable water from a bulk delivery service (off-site tanker). Area 9A consists of two buildings; the water tank building and the showers building. This area was not observed during the sanitary survey due to time constraints; however, due to continuous bacteriological issues at these tanks throughout 2013, Area 9A has been added to the Total Coliform Rule (TCR ) Sampling Plan, and the PWS must begin maintaining a log of monthly tank inspections for this area immediately. A monthly tank inspection form is also attached to this report. Further bacteriological issues during 2014 may necessitate a specific site visit to determine the cause of the contamination.

DISTRIBUTION SYSTEM

The distribution map provided shows well locations, and serves as a good overhead view of the entire property, but it does not depict water lines, sampling locations, treatment, or storage. A revised map for each distribution system showing water lines, valves, buildings served, treatment location, tanks and sampling locations is required.

Lack of a raw water sample tap at Well 01G, which is a GWR-SD noted under the "Treatment" section should have been identified and documented with a revision to the TCR Sampling Plan.

In addition, water service through the installation of atmospheric storage tanks within Area 9A also requires revision to the TCR Sampling Plan.

The PWS does not maintain a routine flushing program, but due to the intermittent use of the sources, a written protocol should be developed to ensure that valves are routinely exercised and water does not remain stagnant within the lines. Leak detection should be included as part of the routine flushing program.

The 611 /2005 Cross Connection Program Plan Questionnaire identified that reduced pressure backflow prevention (RPBP) devices were utilized; however, the number(s) and location(s) were not identified. There has also been inconsistent reporting of cross connection devices within the annual statistical reports (ASR) since 2007, while no report of devices or required testing were documented in the 2012 ASR. In addition, the boiler feed at Well 01G is protected by a Watts 'l'2" dual check valve that was not reported in an ASR, and does appear to have been installed to

Public Water System Summary of Sanitary Survey Page 6 of 12

Lancaster Survey Date: December 4, 2013 allow for required testing. There were also cross connection issues within the DPW Building at both the hose and potentially the washing machine connection, which were not protected by atmospheric vacuum breakers. The PWS must have a full cross connection inspection performed to identify all potential cross connections and devices present, including Area 9A.

WATER QUALITY

There are slightly elevated iron levels present at all three sources with results ranging from 0.51 to 1.4 mg/L. Iron has a secondary maximum contaminant level (SMCL) of 0.3 mg/L, therefore results at these levels will contribute to discolored, metallic tasting water, and staining to the plumbing.

During the survey, GWR SD-2 was identified for Wells 01G and 02G; "There are unprotected openings in the sanitary well casing or cap." GWR SD-5 was identified for Well 01 G; "There are no raw water sample taps available for the collection of source samples for all wells." GWR SD-

. 18 was also identified as, "The TCR Plan has not been updated to reflect current modifications of the distribution system. The PWS contacted MassDEP on 111 7/2004 and submitted the GWR NSD Response Form on 1/24/2014, indicating the PWS is unable to correct all GWR significant deficiencies within 30 days of SD issuance. PWS must submit a corrective action plan identifying a schedule to correct all significant deficiencies within 120 days of the GWR-NSD, which was issued 12/20/2013.

Due to issues outlined in previo.us sections of this report, the TCR Plan does require revision. A revised version of the plan is attached to this report for completion, signature and submission to MassDEP for approval.

OTHER ISSUES OBSERVED

The US Army Corps of Engineers is evaluating the impacts of multiple locations of wastewater disposal on the 5,000 acre facility in relation to both existing and proposed potable water supplies and nearest surface water sensitive receptor. The Army is planning to extend services to a proposed FBI training facility as well as an expansion of Area 9A, for which a new source approval permit is required. The wastewater design flow of the FBI training facility is 600 gallons per day (gpd) and Area 9A will be expanded from a total of2,000 gpd septic systems (two 1,000 gpd septic systems each) to 9,800 gpd septic systems (two 4,900 gpd septic systems each). Potable water supply wells will be needed for both locations. The US Army submitted a Hydrogeologic Evaluation Permit (BRP WP83) in November 2012 and received a Technical Deficiency from MassDEP in August 2013 . After the additional information is received and a fmal Hydrogeologic Permit is issued, the US Army must submit a Groundwater Discharge Permit for review and approval.

In addition to the above, the Range Control and DPW Buildings, served by Well 03G, both have Title 5 septic systems for 350 gpd. The Observed Fire Training site (OFT) served by Well 01G, and the FAC Building served by Well 02G, both have Title 5 systems of700 gpd. At the time of this report, there are no proposed changes at any of these locations.

OUTSTANDING ACTIONS

ENFORCEMENT ACTIONS

None.

INSPECTION ACTIONS

None.

Public Water System Summary of Sanitary Survey Page 7 of 12

Lancaster Survey Date: December 4, 2013

SUMMARY OF FINDINGS

NOTICE OF NONCOMPLIANCE NON-CE-14-5D024

Table A - Violations Please note that this document is also a Notice of Noncompliance (NO ) pursuant to M.O.L. c.21A, § 16 and 310 C.M.R. 5.00.

Within 30 days of receipt of the NON and Summary of Sanitary Survey, you must fill-in the corrected date(s) and submit this form to MassDEP and the attached WATER SUPPLIER RESPONSE AND CERTIFICATION FORM, including all applicable attachments.

GWR Action Date Citation TABLE A- CORRECTIVE ACTION Significant Due Complete

Deficiency! Date* byPWS PWS does not maintain a raw water source sampling tap at Well OlG and has been falsely reporting raw water bacteria samples for Well

1.

310 CMR 010. PWS must install a smooth nose sample

Yes: SD-5 3/26/2014 22.05(1)(a) l. tap prior to disinfection and immediately begin monthly bacteria monitoring of raw source water. Provide photo documentation to MassDEP of completed work.

PWS has been erroneously reporting raw water bacteria sample results for Well 030 due to confusion of system operations. PWS must

2.

310 CMR develop a written Operations & Maintenance

No 3/26/2014 22.05(1)(a) (O&M) Manual specific to each source, treatment and distribution system for all three sources, and immediately begin sampling from the proper raw water sample tap.

PWS is obtaining bulk water delivery for Area 9A that includes a series of six, 3,000 gallon

310 CMR atmospheric storage tanks, which must be

22.04(4) & 310 included in the Total Coliform Rule (TCR) Yes: SD-18 3/26/2014 .) .

CMR 22.05(1) Sampling Plan. A revised TCR Plan is attached to this report for completion and submission to MassDEP.

PWS has not been reporting cross connection information properly within the Annual

310 CMR

Statistical Report (ASR). Perform full cross

4.

22.22(3)(J) connection inspection of entire system, No 5/26/2014 including Area 9A and submit fmdings to MassDEP. Properly report all cross connection devices within the 2013 ASR.

310 CMR

PWS must submit a BRP-WS37 permit

5.

22.04(1)(a) application to MassDEP for approval of a new No 4/26/2014 transient, non-community source at Area 9A.

Public Water System Summary of Sanitary Survey Page 8 of 12

Table B -Deficiencies**

Lancaster Survey Date: December 4, 2013

MassDEP has made note of several items that do not reflect good water system practice; and, if left unresolved, could lead to problems that are more serious and may be elevated to violations in subsequent surveys. Due to the item' s importance an action due date has been established.

GWR Action Date Citation TABLE B- CORRECTIVE ACTION Significant Due Complete

Deficiency! Date* byPWS Submit well specifications for all sources to l.

310 CMR MassDEP, including year installed, well depth, No 5/26/2014 22.04(3) casing depth and diameter, pump setting and manufacturer, and screen len!rths.

310 CMR

Submit to MassDEP a complete and updated

2.

22 .11B(3)

Certified Operator Compliance Notice and No 3/26/2014 Form COD-5

310 CMR

The well cap of Well OlG had an unprotected

22.04(7) & opening and must be replaced with a properly

" vented sanitary well cap . Submit photo Yes: SD-2 4/20/2014 .) .

Guidelines Chapter 4 documentation of completed work to MassDEP.

310 CMR

The well cap of Well 02G had unprotected

22.04(7) & flexible tubing fed directly into the wellhead

4.

Guidelines that must be either properly capped, or removed Yes: SD-2 4/20/2014

Chapter 4 and sealed. Submit photo documentation of completed work to MassDEP.

310 CMR Both Wells 02G and 03G were not properly

22.04(7) & vented with screen. Both wellhead caps must

5.

Guidelines be replaced or retrofitted to include a properly No 4/26/2014

Chapter 4 screened vent. Submit photo documentation of completed work to MassDEP.

310 CMR

To facilitate identification of raw water and

6.

22.04(7) & finished water lines at Wells 01G and 03G, No 4/26/2014 Guidelines Chapter 2.12 PWS must color code and label piping.

310 CMR

Disinfection installed at Wells 0 1 G and 02G is

7.

22.04(1) unpermitted. Submit to MassDEP a BRP- No 5/26/2014 WS34 permit application for both sources.

Day tanks for sodium hypochlorite at Wells

310 CMR 01G and 02G do not have secondary

8.

22.04(7) & containment. Install secondary containment of

No 4/26/2014 Guidelines not less than 110% of the total tank volume and Chapter 6.1.11 submit documentation of completed work to

MassDEP.

310 CMR

There was no personal protective equipment

22.04(7) & (PPE) at any of the sources where sodium

9.

Guidelines hypochlorite (NaOCl) is in use. Provide PPE in No 3/26/2014

Chapter 6.3.4 accordance with the Material Safety Data Sheet (MSDS) for NaOCI.

Public Water System Summary of Sanitary Survey Page 9 of 12

Lancaster Survey Date: December 4, 2013

GWR Action Date Citation TABLE B- CORRECTIVE ACTION Significant Due Complete

Deficiencyt Date* byPWS Area 9A maintains six atmospheric storage tanks that have been experiencing continuous bacteriological issues. PWS must begin

310 CMR22.05 monthly exterior inspections of the tanks and

10. & Guidelines maintain a written dated log of the inspections. No 3/26/2014

Chapter 8.1.22 A copy of the monthly fmished water storage tank inspection log. is attached to this report.

Submit a copy of the first completed monthly inspection log to MassDEP.

Submit an updated map of each distribution

II.

310 CMR system that identifies the source, transmission

No 3/26/2014 22.19(6) lines, distribution lines, treatment, tank and sampling locations.

A Ground Water Rule Notice of Significant Deficiency (GWR-NSD) was issued on

12.

310 CMR 12/20/2013. PWS must submit a corrective

No 3/26/2014 22.26( 4)(a)5 action plan identifying the timeline to correct all deficiencies within 120 days of the GWR-

NSD.

** MassDEP reserves the right to exercise its Order authority under M.G.L. Chapter Ill , 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 fit and pure water supply to all consumers, including without limitation if sufficient progress to meeting a recommended deadline is not achieved.

Table C- Recommendations MassDEP has included a list of recommendations you are encouraged to evaluate and follow in order to improve your system's ability to provide safe and pure drinking water. Failure to act on these recommendations may be elevated to deficiencies in subsequent surveys.

Citation TABLE C- RECOMMENDATIONS

I.

310 CMR MassDEP recommends PWS develop an overall Master Plan to identify and coordinate 22.04(1) current and future water supply needs.

MassDEP recommends PWS develop a written Preventative Maintenance and Asset

2. 310 CMR Management Plan that identifies and records water supply assets, schedules tasks and 22.04(1) accounts for the system's financial capacity to respond to unexpected needs and expenditures.

310 CMR 22.21

MassDEP recommends the PWS post water supply protection signage within the area of all three wells .

4.

310 CMR MassDEP recommends PWS identify back-up power capabilities and perform 22.04(13) generator testing, under full load, on an annual or semi-annual basis.

5. 310 CMR 22.26

MassDEP recommends PWS complete and submit GWR Form A - Log Credit Determination Form to calculate potential CT at Well 03G.

310 CMR22:19 MassDEP recommends PWS develop a written, annual, system-wide flushing and

6. & Guidelines valve exercise program that incorporates leak detection to avoid stagnant water issues

Chapter 9 due to intermittent use.

*If the time required to complete the action is greater than 3 months, submit quarterly progress reports and anticipated completion date.

Public Water System Summary of Sanitary Survey Page 10 of 12

Lancaster Survey Date: December 4, 2013 t GWR Significant Deficiencies: The EPA, as part of the Groundwater Rule, required states to identify specific Significant Deficiencies that are related to the potential for fecal contamination of the water system. Significant deficiencies, when identified at a PWS that is subject to the Groundwater Rule, are regulated under the treatment technique requirements of the GWR. A PWS has 120 days to correct any significant deficiencies after notification from the state of their existence. If the deficiencies cannot be corrected within 90 days, then the PWS must enter into a MassDEP-approved correction action plan, with intermediate timelines for compliance. Failure to have an approved corrective action plan in place within 120 days or to comply with the timelines contained within the corrective action plan, constitutes a treatment technique violation, as detailed in 310 CMR 22.26(4). If a system fails to correct any identified significant deficiencies, then the PWS will be required to provide an alternate source of water, eliminate the source of contamination, or provide treatment that reliably achieves at least 4-log inactivation of viruses.

Public Water System Summary of Sanitary Survey Page 11 of 12

Lancaster Survey Date: December 4, 2013

WATER SUPPLIER RESPONSE AND CERTIFICATION FORM

Within 30 days of receipt of this inspection report, you must complete and submit this form if your system has Table A - Violations and/or Table B - Deficiencies. Attach a copy of the completed table(s) listing the date that the corrective action was/or will be taken and all other applicable documentation. (31 0

CMR 22.04(12)).

The following corrective actions listed in the Summary of Findings Table A and/or Table B have been taken by the Public Water System. (Please check all that apply).

0 My system has taken ALL of the corrective actions listed within the timeframes specified in the Summary of Findings.

• I have listed the completion date for each item within the table(s).

• I have attached copies of supporting documentation as required .

0 My system has taken SOME BUT NOT ALL of the corrective actions listed within the timeframes specified in the Summary of Findings.

• I have listed the actual or anticipated compliance date for each item within the table(s).

• 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.

0 My system is UNABLE to comply with some or all of the corrective actions within the timeframes specified in the Summary of Findings. I understand that my system may be subject to further enforcement.

• An explanation is attached.

I hereby acknowledge receipt of the Summary of Sanitary Survey including the Summary of Findings for the sanitary survey conducted by Department of Environmental Protection's Drinking Water Program. I certify that under penalty of law I am the person authorized to fill out this form and the information contained herein is true, accurate and complete to the best of my knowledge and belief.

Water Commissioner, Owner, Owner Representative or Other Responsible Party:

Signature: ________________________ __ Date: ------------------------------

PrintName: ______________________ __ Title: ------------------------------

Return this form, a copy the Summary of Findings and all attachments to:

MassDEP

BRP Drinking Water Program 627 Main Street

Worcester, MA 01608 Attention: Kristin L. Divris

Public Water System Summary of Sanitary Survey Page 12 of 12

Lancaster Survey Date: December 4, 2013

SURVEY CHECKLIST

CITY/TOWN: Lancaster SURVEY DATE:

PWSNAME:

U.S. Army Devens (South

SURVEYOR:

Post)

PWS ID#: 2147006

PERSON

INTERVIEWED:

Prior to Survey:

F Prepare survey form by download information from WQTS F Review treatment records and prepare treatment forms F Review Coliform sampling plan F Review sample schedule/book for outstanding monitoring F Review current statistical report F Operator/owner/contact changes F Cross-Connection reporting F Source withdrawal info (last 3-5 years) F Review SWAP file and Zone I method assignment info F Review GIS maps 17 Verify well locations and Zone I, IWP A radii 17 Review potential land use threats.

17 Check for completed GWUDI evaluation or exemption forms

Comments:

12/4/2013

K. Divris

Robert Smith, Anne Fardy, Thomas Poole

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 1 of 16

Lancaster Survey Date: December 4, 2013

SYSTEM MANAGEMENT

Who is the legally responsible party for the PWS?

United States Army

(Who would sign the Consent Order with MassDEP?)

Raymond A. Prisk, P.E. , Fort

Who is responsible for the day-to-day management ofPWS? Devens Director of Public Works

Are operational records available?

Yes

(Operator Inspection, Maintenance, X-Conn & Complaints)

Are the records being kept correctly? Yes

Is there a Master Plan?

No- Chp

11.4

If yes, what is the date of the Master Plan NA

Is there a Capital Improvement Plan?

No - Chp

11.4.3

If yes, what is the date of the Capital Improvement Plan? NA

Is there a Reserve Account in case of unbudgeted expenses? Unknown

Is Emergency Response Plan readily available? G\VR-!

9 Yes

Does the Emergency Response Plan reconcile with the ERP Compliance Yes

Checklist?

Has a PWS Affidavit been recorded at Registry of Deeds? (Non-Municipal

A Only)

Is there a "system" to monitor and operate the PWS remotely? No

Does the system meet redundancy requirements? (COM Only) A

Does the system have the ability to receive bulk deliveries ofwater?(Small COM

NA

only) Can the system provide a general schematic of full PWS? Yes

Is system keeping a log of customer complaints? List context of complaints in No comments.

Comments:

SYSTEM MANAGEMENT

As a TNC, Master Plans and Capital Improvement Plans are typically unnecessary provided comprehensive preventative maintenance plans and/or asset management plans exist that account for scheduling tasks, recording necessary and spare parts, and documenting financial capacity. It is unknown if a reserve account exists that is specific to this PWS for unexpected drinking water issues or unbudgeted expenses, and the PWS lacks the aforementioned plans.

In addition, the PWS developed water service in an site known as Area 9A without prior MassDEP approval, and is considering expansion in another area known as the FBI Building in coordination with MassDEP. MassDEP recommends the PWS develop a Master Plan for the entire property for current and future planning purposes.

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 2 of 16

Lancaster Survey Date: December 4, 2013

OPERATOR COMPLIANCE

D h .fi d ? G'NlPI oes system ave a certl 1e operator. - Yes Ar d . fl . dJ ? GWR-2? e operator gra es appropnate or system s1ze an or treatment type. - Yes

Do the listed operators have current licenses? Yes

Are Licensed Operator Services in-house? No

Does the PWS Staffing Plan on file need to be updated?

Yes-

22.11 B(3)

Are Licensed Operator Services contracted out? Yes

If Contract Operator, is an approved Certified Operator Compliance Notice on No-file? 22.11B(6)

Is there a backup operator available for emergencies? Yes

Who covers for contract operator? I Additional SWSS operators

Comments:

OPERATOR COMPLIANCE

Robert D. Smith, of Small Water System Services (SWSS), maintains a Licensed Grade 2D and 2T Full Operator with license numbers 23627 and 23767 respectively. The 2012 eASR listed Robert D. Smith as the primary operator; however, the PWS certified operator compliance notice on file dated 6/1/2005 , lists Deborah A. Bray as the primary operator.

Since Robert D. Smith is currently the primary operator for this PWS, an updated certified operator compliance notice, COD-5 form, and Small PWS Staffing and Comprehensive Operations Plan are required. The correct forms are attached to this report for completion and submission to MassDEP.

SOURCES

WELL INSPECTION

l Source ID Year Casing height In Pit WeU Vent

Seasonal? Condition?

Installed (ft) (YIN)? House? Screened?

i 2147006-01G Unknown 1 Yes No Yes No Poor .. -- . - -- -i 2147006-02G Unknown 2 Yes No NA No Fair I2147006-03G 1996-1998 2 No No NA No Good - .. .. -- -- ..

Are there any unapproved groundwater sources being used? GWR- 4 No

No- Are the sources correctly located in MassGIS? Submit

Change

Do all wells have a tight well cap with a screened vent?

No- Chp

4.20 Are there any unprotected openings in the sanitary well seal (e.g. vent for the Yes- Chp well casing not screened and/or turned downward, unsealed conduit opening)? 4.20

I

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 3 of 16

Lancaster Survey Date: December 4, 2013 lJWK--

Is surface water runoff directed away from the source? Yes

Is the wellhead, cap, and/or vent subject to flooding (this includes buried well casing)? GWR-3 No

Is there evidence of flooding or standing water in the ~it or pump house that could result in the entrance of fecal contaminants? GWR-!

6 No

Does the wellhead appear damaged in a manner that would make the source susceptible to contamination? GWR- I

No

Has there been any maintenance work done on the well, if so what and when_ No

SOURCE PROTECTION

Does the PWS own or control its ' Zone I(s)? Yes

Are all current land uses within the Zone I limited to those directly related to the provision of the public water system or to other land uses which the public water

0-system has demonstrated have no significant impact on water quality? (For

22.21(3)(b) example banning the use of fertilizers/pesticides or non-water supply chemicals in Zone I?)

Are there any open floor drains within the Zone I? No Is UIC assistance needed?

No Contact Euaene.Brunelle@,state.ma.us 508-767-2710 for assistance.

Are there any potential sources of pollution observed in the Zone I or IWP A other than those listed in the Statement of Zone I Compliance? Refer to GIS No maps and MassDEP searchable online hazardous waste site list.

Are source water protection measures adequate? Yes

List any waste water system components within the Zone I. None

Is PWS protection area posted? (Table C only) No-C

Have conditions changed since the last survey within the Zone I, IWP A or Zone No

II that may require a re-evaluation of waiver? If yes, list in comments.

Comments:

SOURCES

Well 01G (South Post Well #D1) was incorrectly located in MassGIS. A locational change request was submitted to MassGIS on 1/24/2014.

Well 01 G is the only source that maintains a screened vent; however, the split well cap on Well 01G constituted a Groundwater Rule Significant Deficiency (GWR-SD), and a notice for such was issued on 12/20/2013. Wells 02G and 03G are not vented and must be retrofit with properly screened vents.

During the sanitary survey inspection, Well 02G maintained flexible tubing directly into the wellhead that was not protected, which also constitutes a GWR-SD and was included in the 12/20/2013 notice.

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 4 of 16

Lancaster Survey Date: December 4, 2013

Non-compliant land uses within the Zone I are described m the Statement of Zone I compliance.

r

ZONE I PICTURE FROM GIS ATTACHED

r

SURFACE WATER SEPARATE CHECKLIST ATTACHED

PUMPING STATIONS

(NOT SUBMERSIBLE PUMPS)

Does system only have submersible pumps?

Does pump station appear to be adequately maintained?

Is pump station subject to flooding? (Either inside or outside infiltrating into the building) GWR-!6

Electrical controls designed to avoid being subject to flooding?

Is pump station secured against unauthorized persons or animals?

Is wastewater from pump station operations (analyzers, floor drains, sump pumps, water cooling systems etc.) properly discharged to a sewer or dry well/outfall located outside ofthe Zone I? If the public water system (PWS) does not own land outside the Zone I, discharge may occur within the Zone I at least 1 00 ft. from the wellhead.

Is emergency back-up power available to operate the pump station?

How frequently are emergency power generators tested under load?

Does the system maintain a contract to provide an emergency back-up generator?

If yes, is there a prepared electrical connection for generator?

Does the air/water relief valve discharge have an air gap? (Not hard piped to floor drain) GWR- I?

For remote pumping stations, does system have ability to add disinfectant?

METERS

Does system have master meter(s)?

Meter( s) read in? [I Cu ft

Does master meter(s) account for all water withdrawn?

Where is the meter(s) located? I See Comments

Frequency of master meter(s) readings?

Is each source independently metered, or represent a totalized flow for more P' than one source? r

Yes

Yes

No

Yes

Yes

No - Chp 5.10.4

See Comments

Unknown

No

No-C

NA

Yes

Yes

P' Gallons

Yes

Weekly

Individual Totalized

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 5 of 16

What is the date oflast master meter calibration or installation?

more recent - enter year if only information available)

Are there individual service meters?

If yes, what is the frequency of service meter reading?

Is there a service meter replacement program?

OPERATION AND MAINTENANCE

Lancaster Survey Date: December 4, 2013

(Whichever is Unknown

NA

Choose an item.

A

Is all critical infrastructure locked or sufficiently secured (e.g. pump house, well Yes 1 h . 1 b ·1d· )? GWR-?O vau t, c em1ca treatment m mg . -

Is there an Operations & Maintenance (O&M) manual on-site? Yes

Is there a Preventative Maintenance (PM) Program?

No- Chp

Is a current Emergency Contact List available? Yes

Is there a plan/procedure for emergency repairs and spare parts? Yes

Who performs emergency repairs? I SWSS or Devens DPW

Comments:

PUMPING STATIONS

The sump pump present within the vault of Well 02G discharges just outside the north comer of the vault at above-ground level. There is little evidence that the amount of water discharged from the sump would have an impact on the well itself or the surrounding Zone I due to the intermittent use, and therefore should not be considered process and instrumentation waste recommended to be discharged at least 1 00 ' from the wellhead.

Emergency power is available for Well 03G and the Range Control Building/Ammunition Warehouse only, but the frequency of testing was unknown. The Department recommends that testing the emergency power under full load be performed on an every six month to annual basis and recorded as appropriate. In addition, portable generators may be considered for operating Wells 01G and 02G if necessary during any power loss, and should also be periodically tested under load.

Although all three wells are metered, the meter age of each is unknown. MassDEP recommends that all source meters be replaced or calibrated either every ten years or according to flow based upon the manufacturer's specifications.

An Operations and Maintenance (O&M) manual for the LMI Chemical Feed Metering Pump at Well 03G was on-site; however, it alone does not provide the information necessary for operating and maintaining the entire PWS. During the survey, it was found that there was confusion regarding the operation of Well 03G; specifically, which lines were carrying treated water. Subsequently, this led to the discovery that the sample tap used by operators for the raw water is a finished water sample tap on the line going to the DPW Building. Therefore, historical data for the raw water at this source must be further reviewed by MassDEP and

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 6 of 16

Lancaster Survey Date: December 4, 2013 reconciled as necessary. All raw water transmission and finished water distribution lines must be clearly identified for Wells OlG and 03G. Due to the limited pipe used for Well 02G, raw and finished pipe identification is not required.

To ensure proper PWS operations, MassDEP also requires the PWS develop a written and complete O&M manual specific to the source, treatment and distribution system of each of the three systems, along with the operations at Area 9A. In addition, MassDEP recommends the PWS develop a written Preventative Maintenance (PM) and asset management plan that provides a reference for scheduling tasks, recording assets and expense accounting for the overall system. A guide for PM and asset management plans is attached to this report and can also be found on the MassDEP ·website at:

http://www.mass .Q:ov/eea/agencies/massdep/water/drinking:/

TREATMENT

Additional Treatment Checklists Added

No Treatment r Treatment in QTS is correct 17 Unapproved Treatment P

Hypo chlorination P Chemical Feed r Aeration r Water Softening r Surface Water Treatment·r Other - See Comment r

GENERAL TREATMENT QUESTIONS (ROLL-UP)

Is the treatment effectively removing/treating targeted contaminants? Yes

Are raw water sample taps available for the collection of source samples for all No-ll ? G\VR-5 22.05(1)(a) l. we s.

Does system have emergency chemical injection port(s)? GWR- 6 Yes

Does the system utilize a sediment filter? No

If yes, how often is the filter and/or filter media replaced? NA

Iftreatment backwashed, where is it discharged (dry well, municipal sewer, NA ground surface, lagoon, septic, tight tank)

Is there a treatment O&M manual available? Yes

If yes, is it current? Yes

Is chemical storage adequate? No-V

Is safety adequate?

N -Chp

6.3.4

Is treatment equipment properly maintained? Yes

Are there any unprotected by-passes at any point in the treatment process that No could result in fecal contamination (i.e. filter backwash, membrane cleaning

2011 Ver 1-03 Public Water System Sanitary Survey Evaluation Page 7 of 16

Lancaster Survey…