CITY OF LACEY WATER SYSTEM COMPREHENSIVE PLAN …...The Lacey system is primarily supplied by groundwater, from 19 wells owned and operated by the City. Although chlorine is injected

CITY OF LACEY WATER SYSTEM COMPREHENSIVE PLAN UPDATE

Appendix R INORGANIC ORGANIC MONITORING PLAN

06/14/12

City of Lacey

Inorganic / Organic Contaminant Monitoring Plan

Plan Preparation Information

System Name: Lacey Water Department, PWSID# 43500Y Date Plan Completed: 03/08/2012 Dates Modified: Name of Plan Preparer: Julie Rector, Water Quality Analyst Daytime Phone: (360) 493-2410

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Contents 1. Introduction and Planning Information .................................................................................................... 3

1.1 Contacts for Monitoring and Compliance .......................................................................................... 3 1.2. Source Information ............................................................................................................................ 4

2. Sampling to Determine Compliance with Drinking Water Standards ..................................................... 5

2.1 Source Samples Collected for Compliance with Drinking Water Standards ..................................... 5 2.1.1 Sample Locations ......................................................................................................................... 5 2.1.2 Sample Timing ............................................................................................................................. 5 2.1.3 Waivers ........................................................................................................................................ 7 2.1.4 New Source Monitoring .............................................................................................................. 7 2.1.5 Determining Compliance with Primary and Secondary Standards .............................................. 8

2.2 Distribution System Sampling for Lead and Copper ......................................................................... 8 2.2.1 Sample Number and Frequency ................................................................................................... 8 2.2.2 Sample Sites ................................................................................................................................. 8 2.2.3 Sampling Approach and Methods ................................................................................................ 8 2.2.4 Determining Compliance / No Need for Further Action ............................................................. 9

2.3 Asbestos Monitoring .......................................................................................................................... 9 3. Monitoring Required for Water Treatment Facilities .............................................................................. 9

3.1 Well 7 “ATEC” facility and the Hawks Prairie Water Treatment Plant ........................................... 10 3.2 Disinfection of Well 10 Water .......................................................................................................... 10 3.3 Intertie with the City of Olympia ..................................................................................................... 11

4. Unregulated Contaminants ..................................................................................................................... 11 5. Reporting and Public Notification Requirements .................................................................................. 11

5.1 Tier 1 Notification ............................................................................................................................ 12 5.2 Tier 2 Notification ............................................................................................................................ 12 5.3 Tier 3 Notification ............................................................................................................................ 12 5.4 Lead and Copper Consumer Notification ......................................................................................... 12 5.5 Consumer Confidence Reports ......................................................................................................... 12

Appendix 1 – Inorganic Chemicals regulated by the National Drinking Water Regulations ..................... 15 Appendix 2 -- Organic Chemicals regulated by the National Drinking Water Regulations ....................... 16 Appendix 3 – Radionuclides regulated by the Radionuclides Rule ............................................................ 17 Appendix 4 – Secondary Contaminants that are not Enforced by EPA, but have been adopted as enforceable standards by WA DOH ............................................................................................................ 18 Appendix 5 – DOH Lead and Copper Consumer Notice Template ............................................................ 19 Appendix 6 – Lead and Copper Consumer Notice Certification form ....................................................... 21 Tables Table 1. Sources, Treatment, and Normal Operating Periods …………………………………………….5 Table 2. Source Monitoring Required for the National Primary and Secondary Drinking Water

Regulations………………………………………………………….…………………….….7 Table 3. Source Monitoring Required for New Sources…………………………………………………..8

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1. Introduction and Planning Information Water System compliance monitoring requirements for the City of Lacey Water System are addressed in three planning documents: the City of Lacey Coliform Monitoring Plan, the City of the Lacey Disinfectants and Disinfection Byproducts Monitoring Plan, and this plan, the City of Lacey Inorganic and Organic Monitoring Plan. This plan describes source and distribution system monitoring that is required for compliance with the Safe Drinking Water Act, and includes requirements outlined in the National Primary Drinking Water Regulations, the Arsenic Rule, the Radionuclides Rule, the Lead and Copper Rule, and the Unregulated Contaminant Monitoring Rule (UCMR). Whereas most drinking water regulations originate from EPA’s Office of Ground Water and Drinking Water, EPA has delegated authority for overseeing most drinking water compliance programs to state primacy agencies. In Washington, the Washington State Department of Health (DOH) has primacy authority and implements drinking water programs through the DOH Office of Drinking Water.

1.1 Contacts for Monitoring and Compliance

City of Lacey— Water System Operators Terry Cargil (360) 413-4395 Peter Brooks, P.E. (360) 438-2675 Sample Collection Bob Burreson (360) 413-4341 Backup samplers Rick McBroom (360) 412-2895 Ed Andrews (360) 413-4356 City contact for monitoring compliance, Julie Rector (360) 493-2410 monitoring plans, and data requests

Laboratory— Water Management Lab, Inc. Christa Holme (253) 531-3121 Thurston Co. Environmental Health Lab Mike Clark (360) 786-5465 (nitrates only) State Department of Health, Southwest Region–

WQ Monitoring Compliance Tracking Sophia Petro (360) 236-3046 Regional Engineer Virpi Salo-Zieman (360) 236-3037

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1.2. Source Information The Lacey system is primarily supplied by groundwater, from 19 wells owned and operated by the City. Although chlorine is injected at each source well or wellfield in order to maintain a chlorine residual within the distribution system, only three of Lacey’s sources receive treatment. The city also purchases water from the City of Olympia, and is supplied through an intertie that conveys treated water from Olympia’s McAllister Springs treatment plant. This source is regulated as surface water with limited alternative for filtration. DOH assigns susceptibility ratings for each source, and these ratings are used in part to determine monitoring frequency and waiver eligibility for various contaminants. Source, treatment, and susceptibility ratings are shown in Table 1. Table 1. Sources, Treatment, and Normal Operating Periods DOH ID Source Name(s) Address Source

Treatment Suscepti-

bility Rating

Normal Operation Periods

S01 Well 1 3300 College St None Moderate Year-round S02 College well 2 8826 Milbanke Dr SE None Moderate* Year-round S03 College well 3 3300 College St None Moderate* Year-round S04 Well 4 6100 W Sarazan SW None High Year-round S06 Well 6C; Judd Hill 2400 Judd St None Low Year-round S07 Well 7 5608 Pacific Ave Pyrolusite filtration

(for Fe, Mn)Low Year-round

S09 Well 9 4830 Yelm Hwy None Low Year-round S10 Well 10 5138 Yelm Hwy Disinfection Low Year-round S15 Beachcrest well 1 8905 48th Ave None Moderate* Year-round S16 Beachcrest well 2 8905 48th Ave None Moderate* Year-round S19 Hawks Prairie 4040 Marvin Rd NE GAC & Greensand

filtration (for Fe, Mn)

Low Year-round

S20 McAllister 2020 Marvin Rd None Moderate Year-round S21 Madrona well 1 8826 Milbanke Dr SE None Low* Year-round S22 Madrona well 2 8826 Milbanke Dr SE None Low* Year-round S24 Nisqually Well 19A 11544 6th Ave None Moderate Year-round S25 Nisqually Well 19C 11544 6th Ave None Moderate Year-round S27 Evergreen Estates 2800 Hibiscus Ct None Low Year-round S28 Madrona WF well 3 8826 Milbanke Dr SE None Low Year-round S29 Betti well 2950 Marvin Rd None Low Year-round S30 Intertie: City of

Olympia Pacific Avenue Disinfected by

supplier Year-round

S17 Wellfield designation for S15 and S16

8905 48th Ave Moderate


8826 Milbanke Dr SE Moderate


8826 Milbanke Dr SE Low

* source within a wellfield – susceptibility is assigned to the wellfield

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2. Sampling to Determine Compliance with Drinking Water Standards Most compliance samples for inorganic and organic contaminants are collected from the sources, but also include samples for lead and copper collected from customer’s taps.

2.1 Source Samples Collected for Compliance with Drinking Water Standards A summary of all compliance samples required for Lacey’s source wells is provided in Table 2. Source water samples are required to verify compliance with primary and secondary drinking water standards. Primary drinking water standards have been established for nitrate, inorganic contaminants (IOCs), organic contaminants (sub-grouped into volatile organic and synthetic organic contaminants), and radionuclides. The individual contaminants that are regulated under the National Drinking Water Regulations are listed in Appendices 1, 2, and 3. The standards for these contaminants are established to protect public health, and are enforceable limits. Secondary contaminants are listed in Appendix 4. EPA has established non-enforceable guidelines for these contaminants. The Washington State Department of Health has also established secondary limits for color, specific conductance, and total dissolved solids. These contaminants are sampled at the same time IOC samples are collected from source wells. When new drinking water standards take effect, compliance samples need to be collected the first year that they are in effect even if a waiver was requested. For example, water systems were required to collect arsenic samples from all sources during the first year the Arsenic Rule was in effect, even if they had purchased inorganics waivers.

2.1.1 Sample Locations

All samples are collected after treatment and/or after chlorine injection, and prior to entry into the distribution system. Most sources have a dedicated sampling station located outside of the wellhouses. Sites that do not have external sampling stations include wellfields S17, S18, and S23, and well 4 – these sites are sampled within their chlorination buildings, at a sample port located near the chlorine analyzers. Sources S07 and S19 are both sampled within their respective treatment plant buildings, at dedicated faucets for final treated water that is leaving the treatment plants.

2.1.2 Sample Timing

The DOH summarizes source monitoring requirements for the Lacey system in an annual Water Quality Monitoring Report. The report lists when samples should be collected within the calendar year, as well as samples that must collected within the 3-year compliance period. Because the report is based on DOH’s database used for compliance tracking, any errors in the report, or changes in the status of a source that may affect compliance monitoring, should be reported to DOH so that they can enter notes or corrections to their database. New sources will be subject to additional sampling that is discussed below in section 2.1.4.

2.1.3 Waivers

DOH has the authority to grant monitoring waivers, and bases eligibility on source susceptibility and the history of monitoring results. Depending on the contaminant and minimum monitoring frequencies required by EPA, waivers can reduce required monitoring frequencies so that no samples, or just fewer samples, must be collected during each 3-year compliance period.

06/14/12

Table 2. Source Monitoring Required for the National Primary and Secondary Drinking Water Regulations Source Nitrate IOC VOC

524.2 SOC 515.2 Herbicides

SOC 531.2 Insecticides

SOC 525.2 Gen. Pest.

SOC 504 EDB and soil fumigants

Gross Alpha & Radium 228

SOC 548.1 Endothall

SOC 1613 Dioxin

SOC 549.2 Diquat

SOC 547.1 Gly-phosate

S01 1 sample each yr (1)

1 sample every 3 yrs


Purchased waiver (2)

Purchased waiver 2

Purchased waiver 2

2 samples every 3 yrs


State waiver State waiver

State waiver

State waiver

S04 1 sample each yr , in May (3)


1 sample every 3 yrs (4)

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

State waiver 2 samples every 3 yrs


State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver

S17 (5) 1 sample each yr (1)



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2




State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2




State waiver

State waiver



Purchased waiver 2

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver



1 sample every 3 yrs (4)(2)

Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver




Purchased waiver 2

Purchased waiver 2

Purchased waiver 2



State waiver

State waiver

1 Nitrate is included with IOCs, and doesn’t need to be collected the same year IOCs are collected 2 DOH will be updating the waiver model; waiver purchases beyond 2010 will depend on new model. 3 Required by DOH. Intent is to sample during month of highest reported concentration to ensure that nitrate remains below 8 mg/L. 4 This is a reduced monitoring schedule granted with a purchased waiver 5 Wellfield Sample

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For each contaminant group, there is a maximum number of compliance periods for which "no sampling required" is allowed, which complicates determining the minimum sampling requirements for organic contaminants. This makes the DOH water quality monitoring report all the more helpful for specifying sample requirements. Waivers must be requested in writing, and DOH simplifies this process considerably by sending forms showing waiver eligibility for each source, and the required number of samples that must be collected with, and without, a waiver. Lacey indicates on the forms which waivers will be requested. DOH does charge for processing waiver requests, but the lower cost of the waivers compared to the lab tests is the primary reason that Lacey requests waivers. State waivers have been issued for Dioxin, Endothall, Diquat, and Glyphosate. In addition, state waivers for EDB and Soil Fumigants apply to all Lacey sources except S01, S18, and S20. As of early 2012, DOH has been working on a new waiver model that is expected to change how waivers are used for compliance monitoring. This section, and Table 2, will be updated after the new waiver model and process take effect.

2.1.4 New Source Monitoring

The Lacey water system is still expanding and is planning for constructing new wells. All new sources have specific monitoring requirements that are summarized in Table 3. New sources are not eligible for waivers until after initial samples are collected. Table 3. Source Monitoring Required for New Sources Parameter/Group Sampling Requirements Nitrate Sample annually (separate sample does not need to be collected same year as IOC) IOC 1 sample each 3-year compliance period for three compliance periods, after which the source may

be eligible for a waiver1. VOC 524.2 Quarterly samples for 1 year; then could be eligible for a waiver. (Without waiver, sample

annually for 3 yrs; then could be eligible to sample every 3 years2) SOCs (includes 515.2 Herbicides, 531.2 Insecticides, and 525.2 Gen. Pesticides

Collect a minimum of 1 sample in initial year, then could be eligible for a waiver. Coordinate sampling expectations with DOH when source is approved. DOH could require quarterly samples in initial year if site is not low risk for SOCs.

SOC 504 EDB Fumigant monitoring is only required if the source is located in the south half of T18N, R01W, or the north half of T18N, R01E or R01W. Sources in these sections will be required to collect quarterly samples for 1 year, and then be required to collect 2 samples every 3 years before being eligible for standard monitoring.

Alpha particles Quarterly for one year, starting within first quarter of initiating use of source. If results of the first two samples are less than the state reporting level, the following two quarters of sampling is waived and standard monitoring can begin.

Beta particles and photon emitters

DOH has not required Lacey to collect beta particle samples from new sources; they have the authority to determine which systems are at low risk

Uranium Gross alpha results can substitute for uranium if gross alpha is < 15 pCi/L Radium 226 Gross alpha results can substitute for Radium 226 if combined results of gross alpha and Radium

228 is < 5 pCi/L Radium 228 Quarterly for one year. If results of the first two samples are less than the state reporting level,

the following two quarters of sampling is waived and standard monitoring can begin. SOC 548.1 Endothall State Waiver granted for all sources SOC 1613 Dioxin State Waiver granted for all sources SOC 549.2 Diquat State Waiver granted for all sources SOC 547.1 Glyphosate State Waiver granted for all sources 1 40 CFR 141.23(c)(1) 2 40 CFR 141.24(f)(4) – (7)

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2.1.5 Determining Compliance with Primary and Secondary Standards

Any time a single sample exceeds a primary standard, a confirmation sample should be collected within 24h of learning of the violation. Failure to collect a confirmation sample for nitrate, in particular, will constitute a monitoring violation that is likely to trigger public notification (see section 5). Compliance with primary and secondary standards is determined by the running annual average at each sampling point. For all analytes with primary MCLs (except nitrate and nitrite), quarterly monitoring is triggered if the MCL is violated. For nitrate and nitrite, quarterly monitoring is triggered when there is a detection that exceeds 5.0 mg/L (50% of the MCL). After completing one year of quarterly sampling, a violation would be confirmed if the running annual average, or one of the quarterly samples, exceeds the MCL. Lacey has one source – source S04, for nitrate – where quarterly monitoring was triggered in recent years. Quarterly monitoring was required by the DOH from August 2006 through July 2008 after nitrate concentrations suddenly increased above 5.0 mg/L in March 2006. Concentrations peaked at 6.7 mg/L, but have been below 6 mg/L since September 2007 and appear to be continuing to decline. The DOH has approved reduced frequency for compliance monitoring to one sample/year now, but has stipulated that the annual sample must be collected in May, to coincide with the month with the highest concentration detected. Even with reduced monitoring approved, Lacey has been collecting monthly engineering samples since August 2006, and will likely continue this practice until nitrate concentrations in well 4 drop and remain below 4 mg/L.

2.2 Distribution System Sampling for Lead and Copper Lead and Copper sampled from customer’s taps are regulated as national primary standards, though no MCLs have been established. Instead, Action Levels are used to trigger additional actions to protect customer health.

2.2.1 Sample Number and Frequency

Lacey must collect 30 samples very 3 years under an approved reduced monitoring schedule. The most recent set of samples was collected during September 2011.

2.2.2 Sample Sites

The Lead and Copper Rule primarily addresses the effects of corrosive water on older plumbing that was installed after 1982 and prior to1986, when lead solder was banned from use on plumbing fixtures. The Rule was originally written to have water systems survey plumbing materials in the water system, and to collect distribution samples from homes constructed prior to 1978. The Rule also specifies that the same locations must be sampled during successive compliance periods, although homes where the plumbing has been upgraded need to be replaced in the sampling program with another older home. Addresses sampled each compliance period are in w:\jrector\WQ Monitoring Programs and Forms\Lead and Copper\CU_PB_Monitoring.mdb.

2.2.3 Sampling Approach and Methods

The Lead and Copper Rule allows samples to be collected by residents, as long as they are provided with complete instructions for properly collecting samples and they certify that they followed the instructions. For the last few rounds of sampling, sampling kits have been delivered to customer homes that include an introductory letter, sampling instructions, certification form, and a sample bottle with rubber band all in a plastic city of Lacey door hanger bag. The instructions request each customer to collect the sample the next morning, and then leave the sample with the certification form on their front porch. An intern picks up the samples that morning, fills out the laboratory forms, and delivers the samples to the lab. Generally the city delivers about 35 kits in order to get the required sample number, and has had good success with

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this approach. Letters, instructions, and certification forms are in w:\jrector\WQ Monitoring Programs and Forms\Lead and Copper\Lead and Copper Testing Procedures2.doc. Residents who collect samples receive lead and copper results by letter within 2 weeks of the city’s receipt of the lab results. Sharing results with the participants is now a requirement under the latest revisions to the Lead and Copper Rule, but has been part of Lacey’s program for many compliance periods.

2.2.4 Determining Compliance / No Need for Further Action

Compliance is based on the 90th percentile calculated from all distribution system samples collected during the compliance period, including samples collected for studies or to respond to customer complaints. The system is in compliance if the calculated 90th percentiles are less than the Action Levels for lead and copper (meaning, no more than 10% of individual results exceed the Action Levels). The Action Levels are 0.015 mg/L lead, and 1.3 mg/L copper. Exceeding an Action Level could trigger additional requirements, including water quality parameter monitoring, source water monitoring and treatment, corrosion control treatment, and public education. Notification requirements for lead and copper sampling took effect October 2011. These requirements are discussed in more detail in section 5.4. Though Lacey has been in compliance with the Lead and Copper Rule, the city has a history of customer complaints about blue copper staining in the south part of the 337 zone in the vicinity of well 4. Well 4 has the lowest pH of all of Lacey’s source wells, and the city intends to install corrosion control for this well. Project approval was received from DOH, and final facility design has been in progress since 2008.

2.3 Asbestos Monitoring Because more than 10% of Lacey’s waterlines are asbestos concrete, the water system is not eligible for a waiver from asbestos monitoring. Currently the system is required to collect one sample from the distribution system every nine years or as directed by DOH.

The most recent asbestos sample was collected November 9, 2010. The result was less than the detection limit of 0.129 million fibers/liter (MFL). The MCL for asbestos is 7 MFL greater than 10 microns in length.

3. Monitoring Required for Water Treatment Facilities Treated sources have additional monitoring requirements that are for ensuring treatment effectiveness. By ensuring treatment effectiveness, these monitoring requirements also ensure compliance with drinking water standards by showing compliance with MCLs or treatment techniques. Currently the City has four treated sources: well 7 (S07), well 10 (S10), Hawks Prairie well (S19), and wholesale water purchased from the City of Olympia (S30). Additional monitoring requirements for these sources are discussed below. Monitoring requirements for disinfectants are addressed here as well as in Lacey’s Disinfectants and Disinfection Byproducts Monitoring Plan.

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3.1 Well 7 “ATEC” facility and the Hawks Prairie Water Treatment Plant An ATEC water treatment system was constructed in 2001 to remove iron and manganese from well 7 water. Treatment consists of oxidizing raw water first with potassium permanganate and then chlorine, and then filtering through pyrolusite (manganese dioxide) media. Treated water consistently meets the treatment goals of <0.15 mg/L iron, and <0.025 mg/L manganese. Hawks Prairie Well #1 also exceeds the secondary MCL for manganese. In addition, the well has been known to have objectionable taste and odor due to the presence of hydrogen sulfide. Initially when the well was brought on-line in 1996 the city diluted water from this source in the 4 MG Hawks Prairie reservoir that is located at the well site. However, dilution limited the city’s ability to maximize use of this well and its water right so the city built a treatment facility on the same site in 2008. The treatment process involves aerating raw water, filtering it through GAC filters to remove hydrogen sulfide, injecting chlorine, filtering through green sand filters to remove iron and manganese, flowing through a chlorine contact chamber to ensure breakpoint chlorination, and boosting the chlorine concentration as needed to achieve the target residual. Applicable monitoring requirements for chemical contaminant treatment systems are in WAC 246-290-455. The minimum requirement for monitoring is to collect finished drinking water samples at a point directly downstream of the treatment plant prior to the first consumer on a monthly basis. There are no requirements for routinely submitting monitoring data to the Department of Health, although records can be requested at any time. Under WAC 246-290-480, data records for monitoring the treatment system are required to be maintained for a minimum of 3 years. For the purposes of tracking the performance of the treatment systems, water system operators collect and analyze samples each weekday that the treatment plants are in operation. Raw and finished water are tested for iron and manganese. Total chlorine is measured by analyzers in finished water. Hardcopy results will be retained for a minimum of 3 years, but all data will also be maintained in electronic files that will be retained for the life of the facility. Filters at both treatment plants are backwashed to remove accumulated material. At this time there are no specific requirements associated with residuals management for treatment plants that remove secondary contaminants. However, the city is aware that EPA is considering new regulations that address residuals management.

3.2 Disinfection of Well 10 Water Well 10 is Lacey’s only source that is disinfected. Disinfection was provided in 2007 after the well was offline for a period for rehabilitation and other work, and a number of follow-up bacteria samples tested positive for total coliforms. However, samples of raw well 10 water collected since disinfection was constructed show have been absent of coliforms. Coliform bacteria is regulated under the national primary standards, and applicable monitoring requirements for source disinfection are listed in WAC 246-290-451(6). There is no requirement to sample treated well 10 water prior to entry to the distribution system. Instead, compliance with disinfection of the source is based on meeting the required contact time, and by showing that a detectable chlorine residual is maintained in all active parts of the distribution system. The WAC requires chlorine residuals to be sampled at representative points in the distribution on a daily basis, unless reduced monitoring is approved. In November 2007 Lacey received approval from DOH to reduce disinfection residual monitoring to weekdays only. Monitoring requirements related to the use of chlorine are discussed more detail in the City of Lacey Disinfectants and Disinfection Byproducts Monitoring Plan.

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3.3 Intertie with the City of Olympia This intertie is located on Pacific Avenue and supplies treated surface water that is regulated as having a “limited alternative to filtration.” Olympia must ensure that water entering the distribution system contains a chlorine residual of at least 0.2 mg/L at all times. Monitoring requirements associated with disinfected surface water sources are in WAC 246-290-692(5) and WAC 246-290-694(8) and are discussed in the City of Lacey Coliform Monitoring Plan and City of Lacey Disinfectants and Disinfection Byproducts Monitoring Plan. Olympia is planning to replace its surface water source, McAllister Springs, with a wellfield. For Lacey, Olympia’s future change from a surface water to groundwater source of supply will mainly affect Triggered Source monitoring required under the Groundwater Rule, as well as disinfection byproduct monitoring.

4. Unregulated Contaminants EPA uses data collected from the unregulated contaminants programs to determine whether or not to regulate these contaminants in the future for the protection of human health. Under the Unregulated Contaminants Monitoring Rule (UCMR), community water systems are responsible for collecting samples, having them analyzed for specific contaminants by certified labs, ensuring that data are reported to EPA’s central data exchange (CDX) database, and notifying the public of the results.

For UCMR1, Lacey collected List 1 samples in July 2002, and January 2003. Because several of the analytes could be analyzed using VOC or SOC methods, Lacey did not purchase waivers for that compliance period and arranged with the laboratory to have the samples analyzed for UCMR1 as well as contaminants regulated under the National Primary Standards. This saved the city a significant amount of money, although UCMR1 did cost the city approximately $9,500 for analytes not covered by other tests. For UCMR2, Lacey was required to sample for both List 1 and List 2 contaminants. Because it was not possible to combine sampling with other compliance sampling as with UCMR 1, UCMR 2 sampling cost Lacey approximately $44,000. Lacey collected List 1 samples in 2008 and List 2 samples in October 2009 and April 2010.

EPA is required to publish a new contaminant monitoring list every five years, and as data become available, List 2 contaminants may move up to List 1, and List 3 contaminants may move up to List 2. Because of this, Lacey will probably have to monitor modified List 1 contaminants every 5 years.

5. Reporting and Public Notification Requirements The following description is not meant to be an all-encompassing description of reporting and public notice requirements for the Lacey Water System. Instead, this is intended to identify when compliance monitoring results will trigger public notification requirements, and the timing of notification required for those situations. Generally, the Department of Health should be notified as soon as possible whenever monitoring data indicate a violation of a drinking quality standard. For most constituents, the violation will also trigger public notification, investigating the source of the problem, and taking corrective action as directed by DOH. However, this should all be done under consultation with the Department.

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Most public notice and reporting requirements discussed below are in WAC 246-290-71001, Public notification. Public notice requirements have been divided into three tiers which are based on the seriousness of the violation or situation, and the potential risks to public health. Public notice for Tier 1 and Tier 2 violations should be done in consultation with the Department.

5.1 Tier 1 Notification Tier 1 notification must be provided to customers as soon as possible, but no later than 24 hours after learning of the violation. The Department of Health must also be notified immediately. Violations that would trigger Tier 1 notification could include:

an acute violation for total coliforms in the distribution system (i.e., a confirmed presence of total coliforms with the presence of fecal coliform or E. coli in any of the samples)

a violation of the MCL for nitrate from a source, or a failure to take a confirmation sample within 24h of receipt of a sample showing a violation of the nitrate MCL

an outbreak of waterborne disease that is likely to result from the water system

5.2 Tier 2 Notification Tier 2 Notification must be provided to customers as soon as practical, but no later than 30 days after learning of the violation. The notice must be repeated every 3 months as long as the violation persists, unless the Department determines that prolonged notice is not required. Violations that would trigger Tier 2 notification could include:

a nonacute violation for total coliforms in the distribution system any violation of an MCL, MRDL, and treatment technique requirement that does not require

Tier 1 notification

5.3 Tier 3 Notification Tier 3 Notification must be provided to customers no later than one year after the violation occurs. Typically Tier 3 notification can be provided via the annual Consumer Confidence Report. Violations that would trigger Tier 3 notification could include:

monitoring violations that do not require Tier 1 notification availability of unregulated contaminant monitoring results exceedance of the fluoride secondary MCL

5.4 Lead and Copper Consumer Notification Effective October 2011, water systems must provide notification of sample results to water users where lead and copper samples are collected. This notification must provide specific language regarding health effects of lead and copper. Certification of public notice must also be provided to the Department after sampling is completed. Templates for public notification and certification of public notice are provided in Appendices 5 and 6.

5.5 Consumer Confidence Reports CCRs must be delivered to customers by July 1 of each year. The reports are required to contain information on the quality of the water delivered by the systems and characterize the risks (if

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any) from exposure to contaminants detected in the drinking water in an accurate and understandable manner. The CCR must report detected results for all contaminants for which monitoring is required. For reporting purposes, an analyte is "detected" when results are at or above the levels prescribed in 40 CFR 141.23 (inorganic contaminants), 40 CFR 141.24 (for organic contaminants), or 40 CFR 141.25(c) (radioactive contaminants). The data must be derived from the most recent data collected to comply with EPA and state monitoring requirements, and results for detected analytes must be reported in the CCR every year until a subsequent sample from that source provides more updated information. . If regulated contaminants are sampled less than once a year, the table(s) must include the date and results of the most recent sampling and the report must include a brief statement indicating that the data presented in the report are from the most recent testing done in accordance with the regulations. No data older than five years need be included. For most contaminants that are sampled annually or less frequently, report the highest detected level at any sampling point and the range of detected levels. For contaminants evaluated on a system-wide basis by calculating a running annual average of all samples at all sampling points (e.g., disinfection byproducts under Stage 1), report the running annual average and the range of individual results expressed in the same units as the MCL. For lead and copper, report the 90th percentile value of the most recent round of sampling and the number of sampling sites exceeding the action level. For total coliform, report the highest monthly percentage of positive samples. The table(s) must clearly identify any data indicating violations of MCLs, MRDLs, or treatment techniques. Explanations of violations must be clear and understandable, and must include the length of the violation, the potential adverse health effects, and actions taken by the system to address the violation. To describe the potential health effects, the system must use the relevant language of WAC 246-290-72012. When nitrate is detected at levels above 5 mg/l, but below the MCL of 10 mg/L, the CCR must include the following language unless alternative language is approved by the Department:

Nitrate in drinking water at levels above 10 ppm is a health risk for infants of less than six months of age. High nitrate levels in drinking water can cause blue-baby syndrome. Nitrate levels may rise quickly for short periods of time because of rainfall or agricultural activity. If you are caring for an infant, you should ask for advice from your health care provider.

EPA also amended required notification language for all CCRs regarding lead, effective Ocotober 2011. The following is EPA’s language:

If present, elevated levels of lead can cause serious health problems, especially for pregnant women and young children. Lead in drinking water is primarily from materials and components associated with service lines and home plumbing. The Lacey Water System is responsible for providing high quality drinking water, but cannot control the variety of materials used in plumbing components. When your water has been sitting for several hours, you can minimize the potential for lead exposure by flushing your tap for thirty seconds to two minutes before using water for drinking or cooking. If you are

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concerned about lead in your water, you may wish to have your water tested. Information on lead in drinking water, testing methods, and steps you can take to minimize exposure is available from the Safe Drinking Water Hotline or at http://www.epa.gov/safewater/lead

For detected unregulated contaminants for which monitoring is required, the table(s) must contain the average and range at which the contaminant was detected. The report may include a brief explanation of the reasons for monitoring for unregulated contaminants. By April 1 of each year, CCR data need to be provided to water systems that purchase water. Lacey currently supplies CCR data to Claudia’s water system, and receives data from the city of Olympia.

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Appendix 1 – Inorganic Chemicals regulated by the National Drinking Water Regulations Primary Standards -- Inorganic Chemicals

Contaminant MCLG (mg/L)

MCL or TT (mg/L)

Antimony 0.006 0.006 Arsenic 0 0.01

Asbestos 7 million fibers per

liter

7 MFL

Barium 2 2 Berlyllium 0.004 0.004 Cadmium 0.005 0.005 Chormium (total) 0.1 0.1 Copper 1.3 TT Action Level = 1.3

Cyanide (as free) 0.2 0.2

Fluoride 4 4

Lead zero TT Action Level = 15

Mercury (inorganic) 0.002 0.002 Nitrate (as N) 10 10

Nitrite (as N) 1 1 Selenium 0.05 0.05 Thallium 0.0005 0.002

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Appendix 2 -- Organic Chemicals regulated by the National Drinking Water Regulations Primary Drinking Water Regulations -- Organic Chemicals


MCL or TT

(mg/L)

Acrylamide zero TT Alachlor zero 0.002 Atrazine 0.003 0.003 Benzene zero 0.005 Benzo(a)pyrene (PAHs) zero 0.0002

Carbofuran 0.04 0.04 Carbon tetrachloride zero 0.005

Chlordane zero 0.002 Chlorobenzene 0.1 0.1 2,4-D 0.07 0.07 Dalapon 0.2 0.2 1,2-Dibromo-3-chloropropane (DBCP) zero 0.0002

o-Dichlorobenzene 0.6 0.6 p-Dichlorobenzene 0.075 0.075 1,2-Dichloroethane zero 0.005 1,1-Dichloroethylene 0.007 0.007 cis-1,2-Dichloroethylene 0.07 0.07

trans-1,2-Dichloroethylene 0.1 0.1

Dichloromethane zero 0.005 1,2-Dichloropropane zero 0.005 Di(2-ethylhexyl) adipate 0.4 0.4

Di(2-ethylhexyl) phthalate zero 0.006

Dinoseb 0.007 0.007 Dioxin (2,3,7,8-TCDD) zero 3E-08

Diquat 0.02 0.02 Endothall 0.1 0.1 Endrin 0.002 0.002 Epichlorohydrin zero TT Ethylbenzene 0.7 0.7 Ethylene dibromide zero 0.00005 Glyphosate 0.7 0.7 Heptachlor zero 0.0004 Heptachlorepoxide zero 0.0002 Hexachlorobenzene zero 0.001 Hexachlorocyclepentadiene 0.05 0.05

Lindane 0.0002 0.0002 Methoxychlor 0.04 0.04 Oxamyl (Vydate) 0.2 0.2 Polychlorinated biphenyls (PCBs) zero 0.0005

Pentachlorophenol zero 0.001 Picloram 0.5 0.5 Simazine 0.004 0.004 Styrene 0.1 0.1 Tetrachloroethlene zero 0.005 Toluene 1 1 Toxaphene zero 0.003 2,4,5-TP (Silvex) 0.05 0.05 1,2,4-Trichlorobenzene 0.07 0.07

1,1,1-Trichloroethane 0.2 0.2 1,1,2-Trichloroethane 0.003 0.005 Trichloroethylene zero 0.005 Vinyl chloride zero 0.002 Xylenes (total) 10 10

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Appendix 3 – Radionuclides regulated by the Radionuclides Rule Primary Drinking Water Regulations -- Radionuclides


MCL or TT (mg/L)

Alpha particles none ----------

zero

15 picocuries per Liter (pCi/L)

Beta particles and photon emitters

none ----------

zero

4 millirems per year

Radium 226 and Radium 228 (combined)

none ----------

zero

5 pCi/L

Uranium zero

30 ug/L

as of 12/08/03

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Appendix 4 – Secondary Contaminants that are not Enforced by EPA, but have been adopted as enforceable standards by WA DOH Secondary Standards -- Inorganic Chemicals

Contaminant Secondary Standard

Aluminum 0.05 to 0.2 mg/L

Chloride 250 mg/L

Color 15 (color units)

Copper 1.0 mg/L

Corrosivity noncorrosive

Fluoride 2.0 mg/L

Foaming Agents 0.5 mg/L

Iron 0.3 mg/L

Manganese 0.05 mg/L

Odor 3 threshold odor number

pH 6.5-8.5

Silver 0.10 mg/L

Sulfate 250 mg/L Total Dissolved Solids 500 mg/L

Zinc 5 mg/L

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Appendix 5 – DOH Lead and Copper Consumer Notice Template

CONSUMER NOTICE Lead and Copper Water Sample Results

The ____________________________________________________ Water System, I.D. ___________________ , is providing you with the lead and copper test results on the water sample collected at your location. Please share this notice with everyone who uses or drinks the water. The results at _________________________________________________________________________________

are: lead ____________________ mg/L and copper _______________ mg/L. The maximum contaminant level goal (MCLG) is the level of a contaminant in drinking water below which there are no known or expected risks to health. MCLGs allow for a margin of safety. The action level is the concentration of a contaminant that, if exceeded, triggers treatment requirements or actions a water system must follow.

The MCLG for lead is “0” and the action level is 15 ppb (or .015 mg/L).

The MCLG and action level for copper is 1,300 ppb (or 1.3 mg/L). The water system’s compliance with the Lead and Copper Rule (LCR) is calculated by using sample results collected from sites in our sampling pool. Your location’s lead or copper results may be higher or lower than the compliance calculation for the overall water system and does not reflect our water system’s compliance with the LCR. We will notify all water users if the lead or copper results from our water system exceed the action level. For more information, please contact: ______________________________________________________________ (owner or operator) at ( ) - or _______________________________________________________________________ (phone number) (address) This notice is sent to you by ___________________________ Water System on ___/___/_____

How Lead Gets Into Water Lead in drinking water most often comes from water distribution lines or household plumbing rather than from the water system source. Plumbing sources can include lead pipes, lead solder, faucets, valves, and other components made of brass. Lead from other sources (such as lead-based paint and contaminated dust or soil) can increase a person’s overall exposure, which adds to the effects of lead in water. Potential Health Effects of Lead

The greatest risk of lead exposure is to infants, young children, and pregnant women. Lead can cause serious health problems if too much enters the body. Lead is stored in the bones and can be released later in life. Lead can cause damage to the brain and kidneys, interfere with production of red blood cells that carry oxygen, and may result in lowered IQ in children. During pregnancy, the child receives lead from the mother’s bones, which may affect brain development. Low levels of lead can affect adults with high blood pressure or kidney problems.

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How Copper Gets Into Water

Copper is a mineral and natural component in soils. In the correct amounts, it is an essential nutrient for humans and plants. In Washington State, most copper in drinking water comes from corrosion of household plumbing. Plumbing sources can include copper pipe and brass fixtures. Copper from plumbing corrosion can accumulate overnight. Potential Health Effects of Copper Although copper is an essential mineral in the diet, too much copper can cause health problems. Copper is widely distributed within the tissues of the body, but accumulates primarily in the liver and kidneys. A single dose of 15 mg of copper can cause nausea, vomiting, diarrhea, and intestinal cramps. Severe cases of copper poisoning have led to anemia and to disruption of liver and kidney functions. Individuals with Wilson’s or Menke’s diseases are at higher risk from copper exposure. How you can reduce exposure:

When your water has been sitting for several hours, flush the pipe by running the cold-water tap until the water is noticeably colder before using the water for drinking or cooking. (The longer water has been sitting in the pipes, the more dissolved metals it may contain).

Use only cold water for drinking, cooking, and making baby formula. Hot water may contain higher levels of lead or copper.

Frequently clean the filter screens and aerators in faucets to remove captured particles.

If building or remodeling, only use “lead free” or low lead piping and materials. Avoid using copper piping or brass fixtures for locations where water will be consumed or used in food preparation (such as kitchen or bathroom sinks).

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Appendix 6 – Lead and Copper Consumer Notice Certification form

Lead and copper consumer notice and certification form All Group A water systems that conduct lead and copper monitoring must provide individual sampling results to the persons at each sample location. You must also submit the form below to the Washington State Department of Health (DOH) to verify that you completed the notification. You should select all sites for lead and copper sampling from your current lead and copper sampling pool.

Notification of Results: The water system must provide the consumer notice as soon as possible, but no later than 30 days after learning the results.

Community water systems: You must provide individual sampling results to all residences where you collected lead and copper samples. In multi-unit structures, notify only each unit tested.

Nontransient noncommunity water systems (NTNCs): You must notify all consumers who use water from the sample tap, even if they do not receive a water bill. With prior approval from DOH, NTNC water systems can post the notice in public areas.

Certification to the state: DOH must receive a sample copy of one consumer notice and a signed certification form (below) within 90 days after the monitoring period ends.

To meet this reporting requirement, you may:

Use the DOH Consumer Notice Template.

Use the applicable EPA Consumer Notice template.

Prepare your own Consumer Notice in conjunction with the state.

If you choose to produce your own Consumer Notice, it must include all of the following:

1. The sample results of the tap tested.

2. An explanation of the health effects of lead.

3. Steps consumers can take to reduce exposure to lead in drinking water.

4. The water system’s contact information.

5. The maximum contaminant level goal (MCLG) and action level for lead, and the definitions of these two terms.

Lead and Copper Results: Consumer Notification Certification Form The water system must complete this section. The signature below certifies that the notice contains all required elements.

Complete the following items (check all that apply): Results received from lab on ____ / ____/____. Notice mailed to water users at each sample site location on ____ / ____/____. Notice hand delivered to water users at each sample site location on ___ / ___ /___. Notice posted at ____________________________ on ___ / ___ / ____.

(By Department Approval Only)

_______ ___________________________ ______________________ _______________ PWS ID Signature of owner or operator Position Date

Within 90 days after the monitoring period ends, send a copy of the completed notice and this certification form to: Washington State Department of Health, Office of Drinking Water, Water Quality Section, PO Box 47822, Olympia WA 98504-7822 or fax to (360) 236-2252.

Documents

CITY OF LACEY WATER SYSTEM COMPREHENSIVE PLAN …...The Lacey system is primarily supplied by groundwater, from 19 wells owned and operated by the City. Although chlorine is injected