HomeMy WebLinkAboutWashington State Department of Health
BILATERAL COMPLIANCE AGREEMENT
' Water System Name: City of Auburn Water System
Subject: Compliance with the Lead and Copper Rule, Chapter 246-290-WAC
i
The following compliance agreement is hereby established between the Department
of Health (herea.fter, Department), and City of Aubum Water System (hereafter,
City).
The Department and the City agree on the following corrosion control issues,
' approaches and schedules:
1. Auburn has slightly exceeded the copper action level at the 90th percentile
I
per the Lead and Copper Rule (1.5 and 1.57 mg/L copper at 90t11 percentile
compared to standard of 1.3 mg/L copper for medium size systems).
I
2. The best utility system approach is to adjust the pH of the water in the
distribution system to reduce corrosiveness towards copper and may include
other appropriate measures such as replacement of susceptible materials,
changes to electrical grounding practices, etc.
3. Corrosion control optimization is realized when the elevated pH levels will
have caused the following:
■ Copper levels are reduced and maintained below the action level of 1.3
mg/L at the 90th percentile (see items 4 and 5 for clarifications);
■ No significant adverse impacts of the treatment on bacteriological
quality in the distribution system;
■ No significant adverse impacts of the treatment on domestic customer
satisfaction (e.g., red water due to disturbances in unlined cast irons);
and
■ No significant adverse impact on commercial and industrial customers,
health care facilities, and wastewater facilities.
Any significant adverse impacts occurring as a result of corrosion control will
be investigated and documented along with possible mitigation measures m a
report prepared by the City and submitted to DOH. - r- = `
SG'..
.i
i
r
4. The 90th percentile copper level will be calculated using the original 60
monitoring sites per the Lead and Copper Rule plus an estimated 30
additional monitoring sites in the vicinity of untreated sources. The limits of
the zones surrounding untreated sources are depicted on Exhibit 1.
5. Untreated sources of supply will be sampled within the limits of the zones of
influence using the number of connections and the population of the zone and
a factor of 2.5 people per connection as a conversion factor as follows:
Population Number of Sample Sites
<100 5
101-500 10 ,
501-3,300 20
3.301-10,000 40
Sample sites will be selected per the Lead and Copper Rule. Any previous
monitoring sites in the untreated zones of influence will be retained and can
be used in lieu of a new site.
6. Treatment is anticipated in 4 stages at this time.
Source Stage
Coal Creek Springs. plus blending of well (#4) 1
1
Well #2
Well #1 2, if needed
Well #4 3, if seeded
West Hill-Springs 4, if needed
Wells 5 and 5A (Lakeland Hills) No treatment. Monitoring indicates
supply is not corrosive.
Wells 3A and 3B No treatment. Emergency source only.
Future Sources To be determined.
7. Monitoring will be conducted after each stage to determine if optimization is
achieved. If optimization is achieved, no further treatment stages are
needed. If optimization is not achieved, the City plans to proceed to nett
stage with Department approval.
2
9. Schedule for Stage 1.
I
Time Frame
Stage I .Action. U/Nonth.s Ending Date.
Submit Lead'and Copper Compliance Report-700H July 1. 1995 June 19, 1.995
Schedule lrlet (submitted)
Finalize BCA (assumed stars) 0 October 1, 1996
Select Sites and Technology-Fredesign Engineering Report - 5 March L -1997
May 1, 1997
2
DOH Approval
-
anuaz3' 11998
' • Design, Environmental; and Permitting Submitted 8 J ,
(Plans and Specifications)
DOH ?Approval 3 Aril 1, 1998
Bidding/Award 4 August L 1998
Construction Completion 12 August 1. 1999
Star. L 2 October 1, 1999
r
System Equilibrium 3 January 1. 2000
Monitoring R4 port (2 rounds) 12 Januar/ 1. 2001
Submit Report to. Determine if System Optimized 3 April 1.2001.
9: If the Lead and Copper Rule is amended or changed, the Department and
City-will revie~v~the changes.-aad their effects on the City, and-if needed, will
jointly renegotiate this agreement.
e City of kuburn agrees Rerform t e following:
Submit a project report and construction documents. In accordance with
- WA-C 248-290-110 and 120 submit for review. and approval a project report
(Predesign Engineering. ' Report) and construction documents (plans ' and
specifications) for' the installation of -the corrosion -control treatment equipment
approved by the Department.
Construct 'corrosion control -treatment facilities. Complete the installation of
Stage 1 - corrosion control treatment. facilities in accordance with Department
approved construction documents prior.to August 1, 1999:
ty parameters in
Monitor water quality parameters. Monitor water quali
accordance with Title 40 CFRChapter 1 Part 141.87(c), (d), and (e) beginning on
January 1, 2000.
Monitor- tap-water- quality. Monitor tap water quality in accordance with Title
40 CFR Chapter 1 Part 141.86 (d) and complete, two six-month monitoring
compliance periods prior to=January 1, 2001.
3
Well #4. Discharge Well #4 into Reservoir #1 for blending under normal operating
)rocedures. • Monthly production records will be kept to document where the water
4 is directed and made available to the Department upon request.
Optimization Report. Prepare and submit an optimization report that addresses
copper monitoring results, any significant adverse effects that may reasonably be
associated with corrosion control, any copper staining incidents that occur in the
untreated zones of influence, and any copper staining or corrosion incidents in new
construction. The report will document what action the City plans to take to
address these occurrences. Further, the optimization report will recommend a pH
operating range for optimization and will recommend if Stage 2 treatment needs to
be implemented.
i
The DgDartment of He lath g Pe to:
i
Concur with Optimization. The. Department agrees that optimization is
achieved, that Auburn will be considered in compliance with the LCR, and that no
further stages of implementation will be required when the following conditions are
met.
■ Copper levels are reduced and maintained below the action level of 1.3 mglL
at the 90th percentile (see items 4 and 5 for clarifications);
■ No significant adverse impacts of the treatment on batteriological quality in '
the distribution system;
■ No significant adverse impacts of the treatment on domestic customer
satisfaction; and
■ No significant adverse impact on commercial and industrial customers,
health care facilities, and wastewater facilities.
The Department will also consider the Optimization Report in . determining
compliance with the LCR.
Well No. 4. The Department will allow Well No. 4 to be discharged directly into
the distribution system should distribution system pressure drop below 35 psi
during an emergency (fire, main break, etc.).
Defer enforcement. The Department shall not initiate any enforcement actions
for violations of the Lead and Copper Rule as long as the conditions of this
agreement are being met.
4
i
Renegotiate agreement. The 'Department will negotiate the level of activity or
-the schedules 'in this agreement if requested by the City.
Terminate agreement. The Department.- agrees to terminate this agreement
within 30 days upon request by the City.
All_ documents or reports required by this agreement, questions about compliance
and ~ request to .modify. this .'agreement shall be directed to DOH Northwest
Drinking Water Operations, :1511 3rd Avenue, Suite 719, Seattle, Washington
98101.
WASHINGTON STATE DEPARTMENT HEALTH WATER SYSTEM REPRESE~1i TA
(Sig re) ( nature)
(Title) U (Te)
C'~ bor7 ytiy-7G7/ ~ 8a ~ 6-z-
(Date) (P)ane) (Date) (Plane)
, 5 -
i
STATE
,~0~' tttt i
0 6 . 'f y
STATE OF WASHINGTON '
DEPARTMENT OF HEALTH 20435 72nd Ave. S., Suite 200, K17-12 • Kent, Was 98032-2358
July 10, 2002 1 QUU~ C~
, OFF
PETER B LEwIS, MAYOR MA'VOr~ °
CITY OF AUBURN I
25 W MArN ST
AUBURN WA 98001
E
Subject: Auburn Water System (ID# 03350)
King County
Bilateral Compliance Agreement Amendment No. 2 - Revision of Schedule Only
i
Honorable Mayor Lewis:
We have discussed schedule modifications to our Bilateral Compliance Agreement (BCA) with
Duane Huskey of your staff. The Department is in agreement with the proposed modifications.
The BCA was last revised on March 6, 2000 with Amendment No. 1. With your permission and by
way of this letter, the BCA is hereby modified with Amendment No. 2 as noted below:
8. Schedule for Stage 1.
Complete Construction of Facilities September 18, 2002
Monitoring Report - 2 Rounds September 17, 2003
Submit Report to Determine if System is Optimized December 23, 2003
The City of Auburn agrees to perform the following:
Construct corrosion control treatment facilities. Complete the installation of
Stage 1 corrosion control treatment facilities in accordance with Department
approved construction documents prior to September 18, 2002.
i
Monitor water quality parameters. Monitor water quality parameters in
accordance with Title 40 CFR Chapter 1 Part 141.87 (c), (d), and (e) beginning on
September 19, 2002.
Monitor tap water quality for lead and copper. Monitor tap water quality in
accordance with Title 40 CFR Chapter 1 Part 141.86 (d) and complete two six-
month monitoring compliance periods prior to September 19, 2003.
Auburn Water System
July 10, 2002
Page 2
If you have any questions or comments, please call me at (253) 395-6764.
Sincerely,
James Nilson PE
Regional Engineer
NW Drinking Water Operations
cc: Public Health - Seattle & King County
Karen Heneghan - DOH
Ingrid Salmon - DOH
i
i
I