Document Em8RwEV3VZrNY4eODnzLaRj3j

March 28, 2024 CERTIFIED MAIL-RETURN RECEIPT REQUESTED Mr. Joseph Bob Utility Manager Nooksack Indian Tribe P.O. Box 157 Deming, WA 98244 Re: Sanitary Survey Notice of Deficiencies at Nooksack Indian Tribe, Rutsatz Road, PWS ID# 105300088 Dear Mr. Joseph Bob: Thank you for having your sanitary survey conducted on October 11, 2023, by Indian Health Service's (IHS) tribal utility consultant Sandy Redsteer. A Sanitary Survey is a comprehensive evaluation of the source, pumps and pumping facilities, treatment, storage, distribution, laboratory facilities, management, and operator qualifications at a public water system, required under the National Primary Drinking Water Regulations (40 CFR Part 141). This letter is to inform you that significant deficiencies were identified at Rutsatz Road water system during the sanitary survey. These significant deficiencies have the potential to impair your water quality and jeopardize public health. Significant deficiencies require immediate attention and must be corrected within 120 days from receipt of this letter. If you are not able to address significant deficiencies by this deadline, you must be on an approved corrective action plan (CAP). Failure to do so will result in a violation of the National Primary Drinking Water Regulations (40 CFR 141.403). Significant Deficiencies: The following items must be corrected, or on an EPA approved schedule to be corrected, within 120 days of receipt of this letter for ground water systems (40 CFR 141.403(a)(5)). Treatment: The reagents used for free chlorine analysis were not available for review at the time of the survey. Please submit a picture of the reagents that shows the expiration date.  Finished Water Storage: Parts of Tank #1 (ST-01), were not inspected at the time of the sanitary survey. Please provide documentation as soon as possible for the following: o The hatch must be raised 4 inches above the tank roof and tightly sealed with a gasket. Please submit pictures of the hatch and installed gasket. o The storage tank hatch must be secured against unauthorized access. Please submit pictures of the hatch lock. Operator Compliance: Operator certification documents were not presented at the time of the sanitary survey. Therefore, it is unknown if the system has a certified operator. Please submit a copy of the operator's certification. The following significant deficiencies identified during sanitary surveys conducted on 9/11/2014 or 10/11/2023 are scheduled to be addressed by Indian Health Service Project #PO-20-N02. Source: Well #1 (WL-01) cannot be pumped to waste. The shared discharge piping also needs proper support. Please submit photos of the piping to EPA once installed. Source: Well #2 (WL-02) cannot be pumped to waste. The shared discharge piping also needs proper support. Please submit photos of the piping to EPA once installed. Source: The casing height for Well #1 (WL-01) is not 18 inches above the ground surface. This significant deficiency was first identified from the sanitary survey conducted on 9/11/2014. Please submit photos of the new casing height to EPA once corrected. Source: The casing height for Well #2 (WL-02) is not 18 inches above the ground surface. This significant deficiency was first identified from the sanitary survey conducted on 9/11/2014. Please submit photos of the new casing height to EPA once corrected. Source: Well #1 (WL-01) is located less than 100 feet away from a septic tank. This significant deficiency was first identified on 9/11/2014. Bollards will be added to protect the well and the septic tank is serviced regularly to mitigate the contamination concern. Recommendations: The following items are best management practices to improve drinking water systems; addressing these is voluntary. Treatment: Chlorine residuals should be checked daily at the finished water tap. Treatment: There is no spill containment for the chlorine solution tank located in the TP-01 Rutsatz Road Pump House. Consider installing spill containment for the chlorine solution tank to minimize danger to personnel and damage to equipment in the event of a spill. Treatment: Remove empty chemical bottles from the TP-01 Rutsatz Road. Distribution: Consider exercising valves routinely and no less than annually to ensure proper operation. Distribution: Consider routinely reading service line meters. Finished Water Storage: Vegetation should be kept clear from around the overflow drainpipe outlet to ensure proper operation. 2  Operations and Management: There is no emergency power or alternate water supply for Rutsatz Road Pump House (TP-01), Well #1 and Well #2 (WL-01 and WL-02). Consider installing emergency power to ensure reliable operations of drinking water treatment and supply in the event of a power loss. Operations and Management: All records related to the water system should be maintained and be easily accessible for water system staff. The Ground Water Rule requires systems to consult within 30 days of receiving a notice of a significant deficiency. Significant deficiencies require immediate attention and must be corrected within 120 days from receipt of this letter. If you are not able to address significant deficiencies by this deadline, you must be on an EPA approved CAP. EPA recognizes that the Nooksack Indian Tribe is working with the Enforcement and Compliance Assurance Division (ECAD) to address existing violations at Rutsatz Road water system, including some of the significant deficiencies identified above. We encourage the Nooksack Indian Tribe to continue coordination with ECAD to remedy these significant deficiencies within the required timeline. Please submit documentation of significant deficiency corrections made, and/or a proposed schedule of the dates and actions of future corrections to R10TribalDW@EPA.GOV and copy miller.jessica.l@epa.gov, enforcement case officer. If you have any questions or would like to address the findings of the sanitary survey, please contact me at R10TribalDW@EPA.GOV or 503-326-2653. Thank you and your staff for their cooperation and time on the survey as well as assistance in addressing these findings. Sincerely, CAITLIN BATES Digitally signed by CAITLIN BATES Date: 2024.03.28 11:17:50 -07'00' Caitlin Bates, PE Environmental Engineer Enclosures: Sanitary Survey, Photos cc: Ms. Sandy Redsteer, Tribal Utility Consultant, Indian Health Service Jessica Miller, ECAD Case Officer, EPA 3 DEPARTMENT OF HEALTH & HUMAN SERVICES PUBLIC HEALTH SERVICE _________________________________________________________________________________ Indian Health Service Office of Environmental Health and Engineering Olympic District Office 500 Pacific Ave., Suite 400 Bremerton, WA 98337 360-792-1235 February 8, 2024 Mr. Joe Bob, Utility Manager 4975 E. Deming Rd. Deming, WA 98244 RE: Sanitary Survey - Nooksack - Rutsatz Road Community Water System (CWS) PWSID# 1053000088 Mr. Bob: Thank you for your time and assistance in completing the sanitary survey of the Rutsatz Road Community Water System (PWSID# 105300088), conducted on October 11, 2023 by the Indian Health Service (IHS). The assessment of the water system is a tool for identifying areas requiring improvement and maintenance, and must be conducted every three years in accordance with the Safe Drinking Water Act (SDWA). A sanitary survey is a comprehensive evaluation of the water source, treatment facilities, operation and maintenance, and management of public water systems. It is intended to improve system safety and operation and safeguard public health. EPA Region 10 will utilize the results of the Sanitary Survey Report to identify significant and minor deficiencies and notify you of them in a separate letter. The following potential deficiencies were noted during the sanitary survey: 1. The well casings are not 18-inches above grade. 2. The wells cannot be pumped to waste. 3. There is not a written cross-connection control plan. 4. The operator is not certified. 5. The system in violation of required public notifications. If you have any questions or need additional information please contact me at (360) 792-6483 or Sandy.Redsteer@ihs.gov . Sincerely, ________________________________ Sandy Redsteer Indian Health Service, Tribal Utility Consultant cc: Tribal Drinking Water Coordinator, EPA Region 10 Ryan Estabaya, Environmental Engineer, IHS EPA REGION 10 DIRECT IMPLEMENTATION SANITARY SURVEY COLLECTION FORMS Note: Bolded questions and answers lead to or may lead to significant deficiencies. PUBLIC WATER SYSTEM (PWS) INVENTORY PWS Name: Rutsatz Rd PWS ID: 105300088 Tribe/Government: Nooksack Tribe Date of Survey: 10/11/2023 System Classification: C NTNC TNC Primary Source: SW GW SWP GWP GUDI Secondary Source: SW GW SWP GWP GUDI Seasonal: Yes No Seasonal Begin Date: N/A Seasonal End Date: N/A Surveyor(s) Name(s): Sandy Redsteer, IHS TUC Persons Present: Joe Bob, Utility Manager Water System Staff Owner or Primary Administrative Contact Utility Manager Financial Contact (if different than above) Designated/Lead Operator Operator Name Nooksack Indian Tribe Joe Bob Kevin Roberts Russell Roberts Address 5016 Deming Rd Deming, WA 98244 Phone Email (360) 592-5176 (360) 389-1597 JBob@nooksack-nsn.gov KRoberts@nooksack.nsn.gov Service Connections Population Residential: 45 Residential: 150 Non-residential: 0 Non-Transient (at least 6 months): 0 Average Daily Demand 11,500 (GPD or MGD): GPD Transient: Peak Daily Demand (GPD or MGD): 18,000 20,000 GPD 0 Total Production Capacity (GPD or MGD): 86,400 GPD Have any customers been without water in the last year? Yes No Is there an emergency backup source? Yes No Have there been any reports of a waterborne disease? Have there been any changes since the last survey (sources, treatment, connections, etc.)? Yes No Yes No Are there any planned capital improvements? Is the source capacity adequate? Comments: Yes No Yes No 1 Rev. 12-09-2022 GROUNDWATER SOURCES WELL INFORMATION Well Name: Well 1 Local Well Name (if different): Facility ID (SDWIS): WL-01 Well Tag ID: GPS Coordinates: Well Location (well house, vault, pitless adapter, etc.): Pitless Adapter Activity: Active Inactive Availability: Permanent Seasonal Emergency Is the well log available (it must be shown to surveyor)? Does EPA have a copy of well log? Yes No Yes No Total Well Depth: 80.5833 ft Depth of Screen(s) or Intake(s): 67.5-80.5 ft Date Constructed: 8/6/1990 Date of Rehabilitation: Confined or Unconfined Aquifer: Static Water Level: 40 ft Casing Type and Diameter: Welded steel, 8-inch Casing Depth: 68 ft Pump Horsepower: 3 Yield (gpm): 100 Is source capacity adequate to meet demand? Yes No Was a source water assessment conducted? Yes No Unknown Is there a source of emergency power available to produce average daily demand? Yes No Well 2 WL-02 Pitless Adapter Active Inactive Permanent Seasonal Emergency Yes No Yes No 80 ft 68-78 ft 4/8/1993 40 ft Welded steel. 8-inch 68 ft 3 120 Yes No Yes No Unknown Yes No WELL CONSTRUCTION Well Name: Is site security adequate (including protection from vehicle damage)? Is well house sealed and free from animal droppings? Is well in a pit or vault? If yes: Is well terminus above grade? Is flood protection adequate (concrete floor and drainage to daylight or pump with alarm?) Will runoff drain away from well head (or is there a concrete well pad)? Is well subject to flooding? Well 1 Yes No Yes No N/A Yes No Yes No N/A Yes No N/A Yes No Yes No Well 2 Yes No Yes No N/A Yes No Yes No N/A Yes No N/A Yes No Yes No 2 Rev. 12-09-2022 If yes, how often? Is further evaluation for GUDI needed? What is the proximity to surface water? Are there water quality changes following precipitation? Yes No Yes No Yes No Yes No Is the sanitary seal (gasket) on well cap intact? Yes No Yes No Are there holes or openings in well head or its appurtenances (e.g., electrical conduit)? Yes No Yes No Is there a raw water sample tap (or way to sample source prior to treatment)? Yes No Yes No Is well casing 18" above grade (or 12" above concrete slab)? Yes No Yes No Is well vented? Yes No Yes No Terminating at or above top of casing (or pitless unit)? Yes No Yes No Downturned? Yes No Yes No Properly screened (16 to 24-mesh, depending on climate)? Yes No Yes No Is there an air/vacuum relief valve? Yes No Yes No At least 18" above grade? Yes No N/A Yes No N/A Downturned? Yes No N/A Yes No N/A Upstream of check valve? Yes No N/A Yes No N/A Properly screened (16 to 24-mesh, depending on climate)? Yes No N/A Yes No N/A Can well be pumped to waste at its designed capacity (blow-off, hydrant, tap, etc.)? If no dedicated blow-off, describe how this is done: Yes No Yes No Is the source metered? Yes No Yes No Routinely read? Yes No Yes No Is flow/production recorded? Yes No Yes No Does the well have a: Check valve? Yes No Yes No Isolation valve? Yes No Yes No Pressure gauge? Yes No Yes No Are there potential sources of contamination near well? Yes No Yes No Livestock or animal droppings <100' Yes No Yes No Sewage lines (pressure, gravity, etc.) <50' Yes No Yes No Individual home sewage holding tank (septic) <100' Yes No Yes No Sewage drain, leach or disposal field <100' Yes No Yes No Are chemicals, oil or heavy machinery stored in well house or near well head? Yes No Yes No Other? If yes, list here: Yes No Yes No If well is permanently inactive, is it properly abandoned/ decommissioned? Was paperwork sent to EPA? Yes No N/A Yes No N/A Yes No N/A Yes No N/A IHS Project PO-20-N02 plans to extend both well casings to meet 18-inch minimum height Comments: requirement and update pump house plumbing to include pump to waste capability. 3 Rev. 12-09-2022 GROUNDWATER & CONSECUTIVE SYSTEMS: DISINFECTION Type of Disinfectant: Sodium Hypochlorite Is the system required to disinfect? If yes, is 4-log required? Yes No Yes No Have there been any interruptions in disinfection? (Significant if yes and disinfection required) Why? Yes No What is the disinfectant usage rate (e.g., gal or L/day for liquid)? Unknown, operator was not available to answer. Is chemical feed adjusted or shut off when water production varies or stops? (Significant if no and disinfection required) Yes No What is the residual goal at the entry point (EP) to ensure a 0.2 mg/L minimum residual in DS? Unknown How often is residual checked downstream of each injection point? Unknown Where is it measured? How is it measured (free or total; continuous or grab)? Are daily operating records maintained (e.g., volume of chemical used, residuals, etc.)? (Significant if no and disinfection required) Yes No Are chemicals and feed lines clearly labeled? Yes No Is there a sample tap post-treatment? Yes No Is the treatment building safe and secure? Yes No Is there redundant disinfection equipment? (Significant if no and disinfection required) Yes No Is emergency power available? Yes No Will the first customer receive disinfected water with adequate contact time to inactivate 99.99% of viruses? Yes No Comments: SURFACE OR GROUNDWATER SYSTEMS: LIQUID DISINFECTANT Is ventilation adequate? If not, is there significant corrosion? There is corrosion, but not significant Are there spill containment provisions? Is liquid solution tank covered? Are pumps in good condition? (Significant if imminent risk of failure and disinfection required) Is there a functioning 4-in-1 or vertical foot valve at least 2" above floor? If no, describe: 4 Rev. 12-09-2022 Yes No Yes No Yes No Yes No Yes No Yes No Can chemical feed pumps operate within the necessary range? Are disinfectant reagents expired? Operator keeps testing kit in vehicle, could not inspect. If yes, which ones? Yes No Yes No Unk STORAGE FACILITIES Storage Tank Name: Tank 1 Facility ID: ST-01 Type of Tank: Ground Storage Below Grade Standpipe Elevated Floating Flow Thru Hydropneumatic (proceed to section below) Material: Glass-Fused Bolted Steel Date Constructed: 3/31/1994 Storage Volume (gallons): 100,000 Is storage capacity adequate? Yes No Average detention time: 7 days Can the tank be isolated from the system? Yes No Is the site subject to flooding? Yes No Is the tank structurally sound? Yes No Is tank base subject to erosion? Yes No Is tank secure from unauthorized access? Yes No Is tank leaking? Yes No If yes, explain (and include photos when possible): How are tank levels controlled? Transducer If manually, is water level indicator operational? Yes No Are there holes or openings in tank side or roof (near level indicator or electrical conduit)? Yes No If there is an altitude valve, is it properly maintained and in working condition? Yes No N/A Has tank been inspected and/or cleaned in the last seven years? Yes No Date of last inspection/cleaning: August 10, 2020 Is tank base overgrown with vegetation? Yes No Does tank meet OSHA requirements for climbing? Yes No Does tank interior appear to be in good condition? Yes No DRAIN - If drain and overflow are combined, proceed to overflow section Does drainpipe terminate with mesh screen, a sealed duckbill valve or metal flapper? Yes No N/A Does drainpipe terminate 12-24 inches above grade? Does drainpipe terminate above a splash pad or riprap? If drain terminates into a sewer or vault, is there an air gap? OVERFLOW Does overflow terminate with proper mesh screen OR a sealed duckbill valve? (Metal flapper must have 16 to 24-mesh screen inside, depending on climate) Does overflow terminate twice the pipe diameter above grade (and no less than 12 inches)? Yes No N/A Yes No N/A Yes No N/A Yes No Yes No Does overflow terminate above a splash pad or riprap? If no, could overflow compromise tank base (or other facility)? If overflow terminates into a sewer or vault, is there an air gap? Yes No Yes No Yes No N/A 5 Rev. 12-09-2022 AIR VENT Is vent properly screened (16 to 24-mesh, depending on climate)? Does vent turn downward and terminate 24" or three pipe diameters above roof surface? For elevated tanks: Is vent screen at least 8" above roof surface? HATCH Is hatch locked? Is hatch tightly sealed with shoebox lid/gasket? Is hatch raised 4" above roof OR 24" above grade (for tanks below grade)? Did not climb the water storage tank. Comments: Yes No Yes No Yes No Yes No Yes No Pipe Material and Diameters: 6-inch PVC DISTRIBUTION SYSTEM Is there asbestos/cement piping? Yes No System pressure range: Number of pressure zones: Number of dead ends: 3 Number of booster stations: Are there adequate hydrants to flush all sections of distribution? Are service lines metered? Routinely read? Have there been any line breaks? Is there a procedure for disinfecting after repairs? Has pressure anywhere in distribution gone below 20 psi? Is there a flushing program? Are there issues with PRVs? If yes, describe: Are air relief valves turned downward (18" above ground) and properly screened (16 to 24-mesh, depending on climate)? Are valves exercised routinely (and not less than annually)? Are there leaks? What % of water is unaccounted for? Are distribution system maps available? (Collect a copy via photo, PDF or hard copy) FOR SYSTEMS THAT DISINFECT Is disinfectant residual measured regularly in distribution? (N/A for UV) Where? What is residual goal in distribution? 6 Rev. 12-09-2022 1 0 Yes No Yes No Yes No N/A Yes No Yes No Yes No Yes No Yes No N/A Yes No N/A Yes No Unk Yes No Unk Yes No Yes No N/A Unknown Is there a trace residual at the farthest point in distribution? (Significant if SW, SWP or GUDI) Yes No Comments: CROSS CONNECTION CONTROL Is there a written cross-connection control plan? (Significant for CWSs or if there are unmanaged cross connections or back flow prevention devices requiring routine maintenance) Are backflow prevention (BFP) devices installed at appropriate locations? Do severe hazard connections (radioactive materials, pesticide application, sewage, laboratories, hospitals, fuel storage, etc.) have an appropriate RPZ or air gap? Are RPZs inspected annually by a certified tester? Is backflow prevention adequate for raw make-up water? Is there a water supply line plumbed directly into chemical tank without a reduced pressure backflow device on the supply line? Are BFP devices inspected routinely (at least annually)? Do trailers or mobile homes connected to hydrants have a double check valve? Do stock tanks have an appropriate air gap or atmospheric vacuum breaker? Do all threaded taps and yard hydrants have appropriate pressure, atmospheric vacuum breaker or double check valves? Are there any obvious cross connections (such as hoses submerged in a pool, watering trough or other non-potable body of water)? Are there other leaks in the water system? (Significant depending on severity) Describe: Yes No Yes No Yes No N/A Yes No N/A Yes No Yes No Yes No N/A Yes No N/A Yes No N/A Yes No Yes No Yes No Unk Comments: OPERATIONS & MANAGEMENT Does PWS have a certified operator? Yes No PWS Required Certification Level: Is operator certified at the appropriate level? Yes No Treatment: Distribution: Operator Name Certification/Agency Level Date Issued Date Expires Kevin Roberts 7 Rev. 12-09-2022 OPERATIONS & MANAGEMENT Does the PWS have a governing body or board of directors? Is there a clear plan of organization among responsible staff? Is management or Tribal Leadership aware of any issues at the water system? Is there a current master plan? Is there a written operations & maintenance manual? Are there written SOPs for equipment, treatment, sampling procedures, etc.? Is there emergency power for the WTP or an alternate water supply? (Significant for SW) PLANNING Is there a written emergency response plan (including contacts, responding to pressure loss, water outages, contamination, etc.)? Is there a source water protection plan and/or well head protection plan? Has a capacity assessment been done? Does the system have a drought management plan, including impacts from extreme weather events? Is there a water conservation plan? Is there a preventative maintenance plan? Is there an asset inventory or asset management plan? Has repair or replacement of critical assets been prioritized? Are as-builts available? FINANCIAL Does system bill for water? What is the fee schedule? Collection rate? Does revenue cover operating expenses? Are there enough funds for repairs or emergencies? For staff training? Does system have an annual operating budget? MONITORING & RECORDING Are records kept according to requirements? MORs - 3 years Coliform bacteria - 5 years Chemicals - 10 years Documentation of corrective actions - 3 years Sanitary survey reports - 10 years Does system issue required public notifications? Are sampling plans for coliform, DBPs, lead & copper, etc. kept on file and readily available? Is required monitoring for the current calendar year complete (specified in EPA-provided schedule)? Does the operator know the location of each entry point to the distribution system? And how to properly label EP samples? Does the operator know what to do in the event of a total coliform positive result? Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Unk Yes No Unk Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No 8 Rev. 12-09-2022 Comments: I was told the operator is certified, but I have not received a photo of the certification. Many questions were not answer and survey was short due to Utility Manager recently having a virus and we were both masked. Utility Manager took survey form to fill out, but it was not filled out by return visit on 1/31/2024. SYSTEM SCHEMATIC 9 Rev. 12-09-2022 Pump House Control Panel Daily Operating Record New Pressure Sensor PH Piping PH Piping - ARV w/ Screen PH Piping - ARV PH Piping - Need an appropriate support PH Piping PH Piping - Soda Ash Tank Not in Use PH Piping - Chlorine Tank PH - Eye Wash device was not working correctly Well 2 Well 1 - Not in use Well 1 - Not in Use Water Storage Tank Overflow/Drain Outlet w/ Screen