west virginia capacity development program annual ... · water system – capacity development...

1 of 23

WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL IMPLEMENTATION REPORT

Prepared by:

Bureau for Public Health Environmental Engineering Division

Infrastructure and Capacity Development Section November 2016

of 23

This page intentionally left blank

of 23

WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM

ANNUAL IMPLEMENTATION REPORT Table of Contents

WV Water System Statistics .................................................................................................................... 5 1 Capacity Development Authority (New Systems Program) ....................................................................... 5

1.1 Legal Authority ................................................................................................................................. 5 1.2 New System Control Points ............................................................................................................. 5 1.3 New Systems and Their Compliance Status During FFY 2016 ....................................................... 6 1.4 Future Program Plans for New Water Systems ............................................................................... 7 1.5 Tracking New Water Systems - Program Performance ................................................................... 7

2 Capacity Development Strategy (Existing Systems Program) .................................................................. 8 2.1 Changes to Capacity Development Strategy during FFY 2016 ....................................................... 8 2.2 Providing Technical, Managerial, and Financial (TMF) Assistance to West Virginia’s Existing

Public Water Systems ...................................................................................................................... 8 2.2.1 Capacity Development Assessments ....................................................................................... 8 2.2.2 Financial Planning Assistance .................................................................................................. 9 2.2.3 Sanitary Surveys and Other District Engineer Staff Assistance ............................................. 10 2.2.4 Operator Assistance ................................................................................................................ 10 2.2.5 Area Wide Optimization Program ............................................................................................ 11 2.2.6 Consumer Confidence Report (CCR) Assistance ................................................................... 11 2.2.7 Cross-Connection/Backflow Prevention Assistance ............................................................... 12 2.2.8 Public Education...................................................................................................................... 12 2.2.9 Third Party Activities................................................................................................................ 13 2.3 Identifying and Prioritizing Systems in Need of TMF ..................................................................... 13 2.4 Statewide Concerns Identified ....................................................................................................... 14 2.5 Measuring Improvement - Baseline Ranking of Water Systems ................................................... 15 2.5.1 Baseline Priority Ranking Analysis.......................................................................................... 15 2.5.2 Recent Success Stories .......................................................................................................... 17 2.6 System Compliance Tracking Through ETT .................................................................................. 19 2.7 Future Activities .............................................................................................................................. 19 2.8 Program Progress in FFY 2016 ..................................................................................................... 20

3 Additional Reporting and Other Concerns ............................................................................................... 21 3.1 Report to the Governor .................................................................................................................. 21 3.2 Drinking Water Treatment Revolving Fund (DWTRF) Procedures ................................................ 22 3.2.1 Ensuring DWTRF Applicants Achieve Compliance ................................................................ 22 3.2.2 DWTRF Funding Distribution including small and disadvantaged systems ........................... 22

http://www.wvdhhr.org/oehs/eed/default.asp

of 23

Glossary of Acronyms AM – Asset Management AWOP – Area Wide Optimization Program BPH – Bureau for Public Health C&E - Compliance and Enforcement CCR – Consumer Confidence Report CD – Compact Disc CDA – Capacity Development Assessment CDP – Capacity Development Program CIP – Capital Improvement Plan CUPSS – Check Up Program for Small Systems DWTRF – Drinking Water Treatment Revolving Fund EPA – Environmental Protection Agency ETT – Enforcement Tracking Tool MCET – Maryland Center for Environmental Training MCL – Maximum Contaminant Level NESC - National Environmental Services Center NETCSC – National Environmental Training Center for Small Communities NTNC – Non-transient Non Community Water System O&M – Operations and Maintenance OEHS – Office of Environmental Health Services PPL – Priority Project List PSC – Public Service Commission PSD – Public Service District PWS – Public Water System RCAP - Rural Community Assistance Program SCBG – Small Cities Block Grant SWTR – Surface Water Treatment Rule TMF – Technical, Managerial and Financial (related to water system capabilities) TNC – Transient, Non-community water system WVETC - WV Environmental Training Center WVIJDC – West Virginia Infrastructure and Jobs Development Council WVRWA – West Virginia Rural Water Association WVWARN – West Virginia Water/Wastewater Agency Response Network

of 23

WV Water System Statistics

West Virginia had 917 total public water systems (PWS) in 2016 serving a total population of more than 1.5 million people. With a state population around 1.8 million, public water systems now serve nearly 87% of the state’s population. The Capacity Development Program (CDP) focuses assistance efforts on community water systems (CWS) (51% of WV’s public water systems (PWS)), and will also offer assistance to the non-transient non-community (NTNC), systems. These two types of systems, on which the CDP focuses the assistance efforts, total 60% of all water systems. The impacts of the program potentially affect 98% of the population in West Virginia served by public water systems. Additional information about the size of systems and the population breakdown for the various system sizes can be found in the table below.

Table 1: 2016 Population by size and type of water system

PWS Type Values

Very Small <=500

Small 501-3,300

Medium 3,301-10,000

Large 10,001-100,000

Very Large >100,000

Grand Total

CWS Systems 148 232 63 23 1 467

Population 29,279 368,418 332,093 581,830 200,175 1,511,795

NTNC Systems 68 12 2 82

Population 11,247 15,742 10,124 37,113

TNC Systems 367 1 368

Population 23,443 834 24,277

Total Systems

583 245 65 23 1 917

Total Population

63,969 384,994 342,217 581,830 200,175 1,573,185

1 Capacity Development Authority (New Systems Program)

1.1 Legal Authority

West Virginia initially documented adequate regulatory authority through a WV Attorney General certification dated November 30, 1998. On April 19, 1999, the US Environmental Protection Agency (EPA) determined the West Virginia program met EPA guidance and statutory requirements. The WV Office of Environmental Health Services (OEHS) water system regulatory authority ensuring adequate technical, managerial, and financial capacity is contained in WV Code, §§16-9(a) and 16-13C-3(a). This authority has not changed between October 1, 2015 and September 30, 2016.

1.2 New System Control Points

The WV Code noted in the previous section requires a permit to construct a PWS. WV BPH/ OEHS implements this through control points that include a permit application, review and issuance/denial process. During the application process, OEHS permitting section personnel

of 23

identify any potential new PWSs upon receiving a permit application. These potential new PWSs are forwarded to CDP staff. The CDP staff confirms whether the application proposes:

New PWS construction

Existing PWS modification

The permitting staff determines if the system is existing or new and initiates the following actions:

Existing system modification applications are processed

New water systems are provided Form EW-100 Addendum to Permit Application to Install, Extend, or Modify a Community or Non-Community Non-transient Public Water System – Capacity Development Requirements (EW-100 Addendum)

The permitting staff takes no further permit application action until the CDP staff have received, reviewed, and approved or rejected the EW-100 Addendum. When new systems lack adequate budgeting and financial planning, program staff will provide budgeting assistance to the system management. Using the Financial Capacity Guidance Document for Small Systems, CDP provides budgeting assistance that helps the new system develop:

A complete inventory

Total replacement and annualized replacement cost estimates

A capital improvement plan

A yearly budget

A five year budget projection

This review process is outlined in section 2.0 of the Capacity Development Strategy and remains unchanged since EPA approved the Strategy. The PWS review process is not anticipated to change during the next fiscal year.

1.3 New Systems and Their Compliance Status During FFY 2016

West Virginia has implemented the EPA’s enforcement tracking tool (ETT). Utilizing this tool, water system violations are weighted based on the public health significance. The more serious the violation, the higher the points attached to it. All systems scores are monitored. New systems that have come online during the year and the previous 2 years, are scrutinized quarterly for compliance to ensure that their ETT scores are not >11. During FFY 2016, CDP continued communication with the permitting staff to identify new NTNC and CWS. While several systems went offline during the reporting period, no new systems applied for permits requiring capacity development approval. The CDP tracked three (3) systems throughout the FFY 2016. At the end of the reporting period (September 2016) two of those systems moved past their three year tracking mark and will no longer be tracked. Tracking of the ETT score for each of the new systems shows that neither system came close to the ETT action level of > 11 during FFY 2016. This success in operational compliance can be attributed to the diligence of the District Engineers and enforcement staff in working with these new systems to ensure that they understand the reporting and sampling requirements.

of 23

Detailed information about each new system and their operational compliance during FFY 2016 is included in Table 2.

Table 2: New System Compliance (as of September 30, 2016)

PWSID# System Name System

Start Date

End

Tracking

Date

ETT scores 3rd Qtr. 2016

ETT scores 2nd Qtr. 2016

ETT scores 1st Qtr. 2016

ETT scores 4th Qtr. 2015

Population

Served

System

Status

1 WV3304913

– CWS

Hodgesville –

Sauls Run

9/01/2013 9/01/2016 0 0 2 0 307 No Longer

Tracking

2 WV3303033

– CWS

Mingo Co. –

Marrowbone

9/20/2013 9/20/2016 1 0 2 2 241 No Longer

Tracking

3 WV3301819

– CWS

So. Jackson Co

PSD – Rte 33

2/18/2014 2/18/2017 1 8 5 0 125 Tracking

1.4 Future Program Plans for New Water Systems

Through the permitting process, CDP staff will continue to discourage the creation of new, small water systems and encourage these proposed systems to connect or become part of existing, larger, more viable and sustainable water systems. The new systems program is effectively preventing formation of new non-viable (unsustainable) PWSs when they can connect to or partner with existing systems. Typically, new systems have had difficulty understanding and implementing required reporting and monitoring. Hence, the OEHS staff will continue to focus on the initial system start-up assistance and guidance process. This initial monitoring oversight has increased system management’s awareness and initial new system compliance. The permitting program is working well and changes to the control points during the next fiscal year do not appear to be necessary. The process outlined below will continue to be implemented:

Identifying proposed new water systems

Evaluating their managerial, financial, and technical capabilities through construction permit application review

Encouraging new systems to connect or partner with existing viable water systems

Controlling new systems by approving or rejecting the construction permit applications

When a new system does experience violations, the OEHS staff works together to ensure assistance is provided to systems in resolving violations.

1.5 Tracking New Water Systems - Program Performance

Focused support is provided to new water systems by the compliance and enforcement (C&E) staff and district engineering staff to assist new systems in understanding and implementing the requirements of the SDWA. The CDP staff continues to track new water systems during the first

of 23

three years of operation to help ensure that all CWS and NTNC water systems maintain compliance. Compliance with the regulations has a direct correlation to the system’s overall viability and long term TMF capacity. Utilizing the ETT score as a method to track the compliance of new systems, CDP staff watches for systems that show signs of struggling; intervening to determine the system’s need and reasons for potential non-compliance. Having had no systems that are tracked to exceed the ETT action score during FFY 2016 suggests that the efforts of OEHS staff are appropriate and effective.

2 Capacity Development Strategy (Existing Systems Program)

2.1 Changes to Capacity Development Strategy during FFY 2016

The Strategy for Capacity Development was submitted to the EPA on August 4, 2000, and was approved on September 27, 2000. During this reporting period, implementation of the approved Strategy continued. Although changes to the Strategy were considered in the past, after consultation with the EPA Regional Capacity Development Coordinator, no changes to the Strategy have been made.

2.2 Providing Technical, Managerial, and Financial (TMF) Assistance to West Virginia’s Existing Public Water Systems

The CDP Strategy outlines a support structure which provides water systems with technical/onsite assistance, tools, resources, and training to enable them to improve their technical, managerial and financial capabilities; ultimately achieving and maintaining operational viability. The support structure includes many activities that are addressed throughout this report including:

Periodic update to a Baseline ranking (see section 2.5 of this report)

Drinking Water Treatment Revolving Fund (DWTRF project) funding (see section 3.2 of this report)

Providing Water Systems with assistance that includes: o Assessments at targeted water systems for improved compliance o Sanitary Surveys and onsite technical assistance from Engineering staff o Other technical assistance (cross connections, consumer confidence reporting,

etc.) o Operator training, third party assistance, etc.

2.2.1 Capacity Development Assessments

The CDP Strategy outlines all assistance provided to water systems. Typically, the CDP’s first assistance step is conducting a detailed technical, managerial, and financial (TMF) water system Capacity Development Assessment (CDA). Assessments are conducted at systems for various reasons which are discussed in Section 2.3 on page 13 of this report. The CDA provides the water system a complete evaluation of their TMF capabilities, identifies TMF needs, and provides recommendations, resources and tools to address their needs. The CDA report is a tool for the water system to use to implement the recommendations resulting in

of 23

long term viability. Throughout the CDA process, CDP staff also provides verbal feedback to water system staff, identifying problems, recommending water system actions, and identifying sources for further assistance. For one year following a CDA, the CDP staff continues to monitor the water system’s progress in implementing the recommendations from the CDA. The CDA procedure and report format are continually reviewed and improved. During FFY 2016, a total of thirteen water systems completed a CDA. A summary of water systems completing a CDA over the past year is provided in Table 3 (page 21). In addition to direct contact by conducting CDAs and follow-up assistance activities, CDP staff provides additional assistance through phone and e-mail contact. The CDP staff also provides water systems with a compact disc (CD) of resources such as generic plans, templates, and guidance documents. All systems, regardless of their size, are eligible for direct water system assistance from CDP staff, water system industry organizations and other state and federal agencies. Assistance includes:

Direct on-site, hands-on assistance

Workshops, seminars and training sessions

Self-help guidance documents The CDP staff provides assistance to help water systems develop:

Budgeting

Asset Management Plans and Capital Improvement Plans (CIPs)

Health and Safety Programs

Consumer Confidence Reports (CCRs)

Cross-Connection and Backflow Prevention Programs

Operation and Preventive Maintenance Programs

Emergency Response Plans

2.2.2 Financial Planning Assistance

During the CDA process, any system that is identified as having inadequate financial capability is encouraged to complete the Financial Capacity Guidance Document for Small Systems. This self-help tool includes an Excel spreadsheet(s) for use by a system with adequate computer resources. However, where necessary or appropriate, this financial planning assistance can be completed using the tables provided in the guidance document and a calculator. The CDP program staff provides copies of this document to water systems upon request, during assessments, and in training sessions. For FFY 2016, the asset management (AM) support to water systems continued to expand. One capacity development staff member with the assistance of a Tetra Tech Staff member, through in-kind funding from EPA, continued to provide support to water systems in the development of their AM plans (including the Check Up Program for Small Systems - CUPSS). Development of an approved asset management plan is required for all systems which receive DWTRF funds. Funding is also being made available to water systems to secure the services of engineering firms to assist with the asset management plan development. The CDP is currently working with 42 systems in asset management plan development/maintenance. For FFY 2016, six (6) systems developed and had approved a comprehensive asset management plan. In

of 23

addition, fourteen (14) systems are currently developing AM plans. There are twenty-two (22) additional plans that are reviewed at the one year mark to ensure the plans are being kept up to date and the system is incorporating the AM process into their daily operations. The CDP staff continues to actively market the importance of establishing an asset management program and provide training on asset management at events attended by water systems personnel.

2.2.3 Sanitary Surveys and Other District Engineer Staff Assistance

The OEHS staff primarily provides direct water system assistance through OEHS field personnel. This assistance includes sanitary surveys, technical guidance, and meetings with water system operators and managers. The district engineering staff conducts sanitary surveys on a schedule that results in each water system receiving a sanitary survey every three years to five years based on the system size, treatment methods, water source, etc. During FFY 2016, a total of 263 sanitary surveys were conducted. Between surveys, the field engineers contact water systems regularly, checking for compliance and providing advice or assistance. This ongoing water system assistance using district engineering staff is highly effective with capable water systems. The district engineering staffs’ assistance focuses primarily on technical issues. While financial or managerial guidance may also be provided by the district engineering staff, systems that have substantial financial or managerial deficiencies are referred to the CDP program for a full assessment. EPA also continues placing increased emphasis on effective water system management. This emphasis has resulted in their sustainable infrastructure initiative, full cost pricing focus, AM, and other financial evaluation tool development. The West Virginia CDP has been actively involved in bringing these EPA initiatives to West Virginia water systems. Often, this is accomplished through training coordinated by the Public Service Commission of West Virginia (PSC) (see section 2.2.8).

2.2.4 Operator Assistance

The CDP continues to provide assistance in training water system operator courses by teaching various parts of the water operator’s courses including:

Distribution and Storage for Class I Drinking Water Operator training

Class II Drinking Water Operator training

Cross-Connections and Backflow Prevention to Class I, II and III operators and to Backflow Testers

Safety to Class I, II, and III operators During FFY 2016, 1266 water operators (of all classes) were certified or had certifications renewed and 178 were certified in backflow prevention. Additionally, 201 people were certified or had certifications renewed as water well drillers/pump installers.

The CDP staff continues to review portions of the training courses and materials for the water operator courses. Materials reviewed include Cross-Connection and Backflow Prevention, Safety, Management, Security, and Emergency Preparedness training modules. OEHS staff also proctors the exams for various water and wastewater classes when needed.

of 23

OEHS participates with other stakeholders in providing input and funding for the Drinking Water and Wastewater Training Calendar prepared by the WV Rural Water Association (WVRWA). The calendar is used to keep system personnel informed of important drinking water education and training opportunities. For FFY 2016 the WVRWA has decided to put its’ calendar online and will no longer be producing a printed training calendar. A hard copy of the calendar can be printed from the electronic calendar.

2.2.5 Area Wide Optimization Program

Since 2004, West Virginia’s Area Wide Optimization Program (AWOP) has maintained a yearly microbial public health risk ranking based on relevant data review. The AWOP data review or “scorecard” incorporates plant optimization goals, past violations, and unresolved sanitary survey deficiencies. The OEHS district engineering staff updates turbidity spreadsheets, generates a master ranking list, and shares it among staff each March. Additional information related to AWOP work with water systems can be found in the 2016 DWSRF annual report. This report is located on the Infrastructure and Capacity Development website at: http://www.wvdhhr.org/oehs/eed/i&cd/dwsrf_annual_reports.asp .

2.2.6 Consumer Confidence Report (CCR) Assistance

West Virginia’s CWSs must submit a copy of their annual CCR and a certification form to the OEHS. CCRs can be submitted for review/critique prior to official submittal, but many water systems do not take advantage of this offer. Consequently, each year a number of these systems’ CCRs have errors or missing information. Each water system’s CCR is reviewed against a required information check-list resulting in follow up which can provide:

A letter and/or a sample CCR, including instructions

The required information check-list

The required certification forms

Individual corrected information enabling non-compliant CWSs to correctly complete their CCR the following year

During this reporting year, 436 out of the 477 required CCRs were received. The staff review found 139 CWS CCRs had errors or lacked necessary information. Staff responded to 120 phone queries concerning CCRs and assisted 11 systems by preparing their CCR for them. Violations for CCR inadequacies are as follows:

33 for not submitting a CCR 24 for submitting the CCR late 88 for not submitting the CCR certification or submitting it late

One system had serious errors and omissions and had already published the CCR without submitting it to this office for review prior to publication. This system was required to re-publish their CCR with the corrections made (at the cost of the system for re-publication).

Correct CCR preparation is facilitated using a generic, fill-in-the-blank CCR CD. It provides the water system a correct CCR format for the next reporting year and future years. The CDP staff provided five (5) systems with an accompanying CD containing the complete CCR package (CCR, certification letters for signature, etc.)

http://www.wvdhhr.org/oehs/eed/i&cd/dwsrf_annual_reports.asp

of 23

2.2.7 Cross-Connection/Backflow Prevention Assistance

The CDP staff has developed a cross-connection and backflow prevention manual and other related training materials. These assistance documents were distributed to students in water operator training classes over the past year, including those who were trained specifically in backflow prevention. The water system can use this manual to develop and implement a cross connection and backflow prevention program. The manual can be used by either public service districts or municipalities. Copies of this manual are available in each of OEHS’s five district engineering offices and are provided to water systems during sanitary surveys. Additional copies are provided to other water systems and private water related businesses upon their request. When distributing the manual, the following EPA publications are included:

Cross-Connection Control Manual (EPA 816-R-03-002)

Consumer Confidence Reports (EPA 816-K-03-003)

Consumer Confidence Reports (EPA 816-H-03-002) During FFY 2016, 20 phone calls were answered from the public with questions regarding Cross-Connection and Backflow Prevention installation/enforcement. Five training classes for Backflow Preventer Testing were taught.

2.2.8 Public Education

During the reporting period OEHS continued implementing public outreach. Some of the education projects were aimed primarily at water systems, their managers, operators and employees. However, other projects (or programs) are intended to educate the general public. Through these educational efforts the objective is to reach as many people as possible with information on the CDP, inform them of what they should expect from their water system and let system personnel and the general public know assistance is available. These programs inform persons served by unsatisfactory or marginally viable water systems of available help and alternatives to improve poor quality water. A West Virginia CDP brochure, ruler and other handouts are distributed to the public at the WV EXPO, WVRWA conference, and Public Health Day at the Legislature. These handouts are available in the central and district offices and are provided to any interested persons including those at speaking engagements and conferences. A capacity development web site providing detailed information about the CDP was maintained during the reporting period. The web site provides links to numerous other web sites with capacity development information. The CDP personnel work with OEHS technical support staff and regularly update and integrate new information into the web site. The CDP staff and other OEHS personnel (enforcement, permitting, field inspection, infrastructure/DWTRF, etc.) developed and made numerous presentations to a variety of audiences. These presentation opportunities enabled us to educate people about CDP’s assistance services and the consequences of inadequate capacity. OEHS staff assists in the delivery of PSC’s Public Service District Board Member Seminar, Municipal Officials Training, and Advanced Utility Topics Seminars. Training topics include a CDP overview, system security, operator certification requirements, sustainable infrastructure and asset management.

of 23

2.2.9 Third Party Activities

Third party assistance has been provided through existing contractual agreements or by other state, federal, or non-profit entities. The primary third party assistance providers available to West Virginia water systems include:

Public Service Commission of West Virginia (PSC)

West Virginia Rural Water Association (WVRWA)

National Environmental Services Center (NESC)

Rural Community Assistance Program (RCAP)

West Virginia Environmental Training Center (WVETC)

Maryland Center for Environmental Training (MCET)

National Environmental Training Center for Small Communities (NETCSC)

Regional Planning and Development Councils

Peer assistance from other WV water systems

West Virginia Water/Wastewater Agency Response Network (WVWARN) Many of these organizations have actively provided water system assistance throughout the reporting period. In addition to OEHS’s direct assistance, water systems are regularly referred to these third party organizations. These organizations routinely provide:

Technical (hands on) assistance and information

Trouble shooting problems in operation and distribution

Support, resources and tools for managerial and financial stability and infrastructure resilience

Training and education opportunities

Coordination of borrowing of equipment and operators

2.3 Identifying and Prioritizing Systems in Need of TMF

CDA’s are conducted for multiple reasons, including:

Baseline score indicates the system is struggling to develop or maintain their TMF

DWTRF funding applicants

Receptive systems with an elevated ETT score

Systems identified by engineering field staff as needing special assistance

At the request of the system This year, we continued to work with enforcement staff, and district engineering staff to identify CWS’s that had an ETT score > 11(not including orphaned systems) and those CWS’s that were on the threshold of 11 (score of 9-10) and therefore were possible candidates for a CDA. More information on this process can be found in section 2.6 on page 19 of this report. The majority of the CDA’s conducted this year were systems that had been identified through this process. Thirteen assessments were conducted in FFY 2016. A majority of those, nine (69%) were conducted for an elevated ETT score. Three (23%) were conducted with a system that applied for the DWTRF funding to ensure that they are sustainable and had adequate capacity to complete the project and repay the loan funding. One (8%) was conducted at the request of the system.

of 23

2.4 Statewide Concerns Identified

As part of the CDA process, the CDP staff reviews baseline data/scores, a TMF capability questionnaire, EPA’s ETT, PSC annual report submissions, sanitary surveys, etc. The study identifies short comings and gaps that are indicative of the system’s inability to be sustainable. These deficiencies can be categorized as site-specific or global, as described below.

As systems have made progress to become more viable over the years, many of the deficiencies have moved from global to system-specific as more and more of the systems have addressed issues. Site-specific TMF capability deficiencies: These deficiencies are unique to a specific water system. In addition, site-specific deficiencies often require on-site, hands on assistance. Site-specific deficiency examples are:

Treatment and distribution system leaks and breakdowns

Lack of knowledge of critical system components and their condition

Inadequate spare parts inventory

Failure to follow the sampling schedule

Failure to enact adequate rates to sustain system operations

Failure to create and enact both long term and short term budgets

Failure to create/implement standard operating procedures, operations and maintenance tasks, and long range asset replacement plans

OEHS staff can assist water systems in addressing site-specific deficiencies through:

District engineering staff assistance

CDP staff assistance

Educational resources such as draft plans/templates and free software, written material and training seminars

Referral to third party resources Global TMF capability deficiencies: The following deficiencies are common to numerous water systems. Many of these deficiencies can be addressed through guidance documents or workshops. Examples of global deficiencies are:

Failure to update/maintain system maps

Failure to ensure that system management/board members are adequately trained

Failure of operators to obtain proper, adequate training to keep up to date with changing regulations

Use of reserve funds for everyday expenses due to inadequate rates to meet operational expenses

Failure to monitor the system’s financial health (i.e., expenses vs income)

Failure to include the public in long-term planning

Need to explore energy efficiencies/conduct an energy audit

of 23

Global deficiencies are addressed using tools such as:

Workshops

Group training sessions or seminars

Guidance documents While there are a number of short-comings found when systems are reviewed, there are several deficiencies that are noted more often and are seen as key indicators in system viability. Those deficiencies are:

No long-term repair/replacement planning such as asset management

Little or no long-term (and sometimes short-term) financial planning

No preventive maintenance procedures or policies

No budgeting or poor financial planning and tracking

No health and safety procedures or policies

No emergency/contingency plans

System management staff not understanding their ultimate responsibility for ensuring the water system’s technical capability to provide reliable, safe drinking water and an adequate budget and rates supporting long-term water system viability

2.5 Measuring Improvement - Baseline Ranking of Water Systems

Section 1420(c)(2)(D) of the Safe Drinking Water Act, requires all states to develop a baseline priority ranking of their water systems. The initial 2002 baseline ranked the 737 West Virginia CWS and NTNC water systems that were in operation in 2002. Compiling the initial 2002 baseline and the updates of 2005, 2008, 2011, and 2014 involved gathering information from the water systems and the OEHS District Engineers (district offices are located in Beckley, St. Albans, Kearneysville, Wheeling, and Fairmont). CDP staff evaluated the information collected and developed a score for each water system. Once evaluated, every water system was assigned a score between 0% and 100%. The updated baseline data are being used (in conjunction with other measures) to help evaluate the overall status of West Virginia water systems and the effectiveness of the CDP. In 2014, the updated baseline was compiled for the CWS and NTNC water systems in a manner similar to the initial baseline; yielding a current score for every water system (0% - 100%). The most current baseline ranking of water systems is available at the Capacity Development website: http://www.wvdhhr.org/oehs/eed/i&cd/baseline_assessment.asp.

2.5.1 Baseline Priority Ranking Analysis

The systems were ranked (0% – 100%) and categorized as viable, marginal and failing based on score. A high baseline score indicates a viable water system with adequate TMF capability. Similarly, a low score indicates a failing water system with inadequate TMF capability. Systems whose score was 70% or greater are considered viable, those with a score between 40% and 70% are considered marginal and those 40% or below are considered failing. The 2014 baseline ranking data showed that 470 (82%) of the 572 CWS and NTNC water systems in West Virginia are viable systems having adequate TMF capacity; 83 (14%) are marginal and 19 (3%) are failing. 1.47 million people (96.4% of the population served by CWS and NTNC systems) are served by viable systems while failing and marginal systems serve

http://www.wvdhhr.org/oehs/eed/i&cd/baseline_assessment.asp

of 23

54,650 people (or 3.6% of the population). There has been an elimination of more than 125 of the smallest (<300 population) water systems, many of which were failing systems, since 2002 and a population shift away from failing systems to viable systems.

The failing and marginal systems pose a constant threat of disrupting their customers’ drinking water supply. Such disruptions threaten the customers’ health and welfare and also are an impediment to economic development in areas served by these systems. While West Virginia still has 102 water systems that are marginal or failing, the 2014 baseline data shows steady improvements in the water systems’ capacities. Since 2002, the number of viable systems has increased from 399 to 470 (15.2%) while the number of failing systems is down from 94 to 19 (80%), and the number of marginal systems is down from 244 to 83 (66%) (Figure 1).

Figure 1: West Virginia Water System Viability Trends

Figure 2 indicates that there are only two failing systems and very few marginal systems that have more than 1000 customers; reinforcing the need for an adequate customer base to achieve and maintain water system viability. Those systems with a population below 300 are most at risk of failure. Figure 2: 2014 West Virginia Water System Viability Designation by Population Served

0

100

200

300

400

500

2002 2005 2008 2011 2014

399 411442 435 470

244187

130118 8394

67 65 3919

Water System Viability Trends in West Virginia

Viable

Marginal

Failing

130

94

149

97

4130

9 317

1 1 00

50

100

150

200

<300 systempopulation

300-999 systempopulation

1000-2999 systempopulation

>2999 systempopulation

West Virginia Water System Viability Designation by Population Served, 2014

Viable

Marginal

Failing

54% 33% 69%

of 23

2.5.2 Recent Success Stories Following are 2 (two) examples of success stories for West Virginia’s Infrastructure and Capacity Development Program: Lubeck PSD - Belleville Extension Project Design Loan

Project Purpose and Public Health Need: The Lubeck Public Service District (PSD) is located in Wood County, West Virginia and serves approximately 4,365 customers. The Lubeck PSD currently has no existing water distribution system providing water to the rural Belleville service area. Most residents in this area depend on water wells that are unreliable in quantity and unsuitable as potable water. Some groups in this area have shared wells among multiple residences, which could leave several people susceptible to a lack of suitable water should the wells become contaminated or begin performing poorly. Many residents purchase water from a local bulk water station and haul it to their residences to fulfill their clean water needs. It is the desire of the Lubeck PSD to be able to provide the residents of the Belleville area with a clean, reliable source of drinking water so the vulnerabilities listed above can be eliminated in this area. Project Benefits Included the Following:

This project will result in benefitting the residents in the Belleville area by providing them with a public drinking water supply that will eliminate private water supplies such as wells which produce insufficient quantity and/or quality of water resulting in a public health risk. Project Scope: The Lubeck Public Service District (PSD) has recognized the need to supply a source of drinking water to the residents within and surrounding the rural area of Belleville, Wood County, West Virginia. Currently, residents in this area have limited access to reliable sources of clean, potable water. To provide service to the Belleville area, it is necessary to construct extensions to the existing Lubeck PSD water system. The scope of the proposed project consists of the following:

Extension of approximately 19 miles of waterline to serve approximately 180 customers in the Belleville area

Project Financing: The total project cost is $3,922,600. The DWTRF provided a $242,633 principle forgiveness design loan. The remaining balance of the project will be comprised of a $3,272,600 DWTRF base loan (0.5% for 30 years), and a $407,367 DWTRF principle forgiveness loan.

of 23

Bluewell PSD (Town of Pocahontas) Water System Improvements Project

Project Purpose and Public Health Need:

The Bluewell PSD (PSD) has provided a public health contribution in aid to WV residents along the Mercer County, WV and the Tazewell County, VA state line. Those residents are the customers of the Town of Pocahontas (town), VA which serves about 500 people in WV and an equal amount in VA. The town has a deteriorated water treatment facility that has been determined to have reached the end of its useful life and likely could result in catastrophic failure. The town has been under orders from DEP regarding the discharge of waste from the facility. The town has had problems maintaining adequate operator coverage and relies on contract operators from adjacent water systems to operate the water system. The town’s council and mayor do not have the managerial capacity to continue operation of a water system and expressed a desire to get out of the water business. The WV and VA SRF programs collaborated to assist with the development of a project to allow the shutdown of the town’s water plant by obtaining water from the Tazewell County Public Service Authority (TCPSA). The TCPSA will implement a project to reliably provide water to the town and the WV customers the town currently serves. An intergovernmental agreement has been implemented between the PSD and TCPSA to allow the WV SRF program to provide funds for the project with the PSD acting as a conduit for the contribution in aid. TCPSA will eventually take over operation and maintenance of the entire town’s water system.

Project Benefits Included the Following:

This project will eliminate an incapable water system through consolidation with a very capable water system. The town’s water treatment plant has been unreliable and has deteriorated significantly that it needs major repairs. The town is under environmental orders to make improvements regarding the plant’s waste streams. The town will no longer have to rely on contract operators to maintain treatment plant coverage for compliance. Water loss resulting from leaking distribution lines has increased over the years and the town is not capable of adequate repairs. The TCPSA will provide operation and maintenance of the water system to provide a reliable source of water for the customers. Project Scope: The TCPSA is a very capable water system and will be the project sponsor. The overall project will be completed in three phases. The connection to the town is in the second phase. The major scope of the second phase project consists of the following:

Installing 3,200 LF of 10-inch water line for constructing two (2) system loops with the Town of Tazewell

Upgrade of the Divides #1 and #2 pump stations Project Financing: The total project cost is $2,070,106. The DWTRF provided a principal forgiveness loan for $420,000 and the VA SRF program provided a $750,106 low interest loan along with a $900,000 principal forgiveness loan to make the project affordable.

of 23

2.6 System Compliance Tracking Through ETT

System compliance tracking has always been a task assigned to the OEHS C&E staff. The C&E staff utilizes the ETT tool to target penalties and/or compliance assistance to those systems with an elevated ETT score. The EPA requires OEHS to take action on systems with an ETT score >11. The ETT report with the quarterly compliance status for all systems is sent to EPA. The enforcement action taken is a decision from the consensus of the C&E staff, the CDP staff, the district engineering staff, and the EPA. Utilizing the ETT tool, the C&E staff also targets those systems that have not yet reached the actionable score assigned by EPA. The C&E staff is pushing systems that are on the cusp of reaching the action level (those with an ETT score >8) to begin proactive measures that will remedy violations and lower their ETT score. The CDP staff and the C&E staff have teamed up in the selection of systems that will be targeted for a CDA. The very low scoring, failing systems (those considered to be orphaned systems) are not to be the target of the CDA process as most of these systems have no one designated as a responsible party for the system and therefore, no ability nor desire to improve. It is hoped that shifting CDP’s attention from “hopeless” systems to “struggling” systems will enable the CDP to focus our efforts on systems that have the capability to achieve and improve their compliance. With input from the district engineering staff, the C&E staff works hand in hand with CDP staff to identify by both the ETT score (>11)and the baseline score (marginal or upper failing scores) those systems that will be targeted for an assessment. These non-compliant systems will remain the focus of the CDP staff that is tasked with identifying these system’s TMF deficiencies along with defining a reason for their inability to remain in compliance. Once the analysis has been completed, staff is responsible for assisting that system to attain and maintain compliance, build TMF, and improve overall system sustainability.

2.7 Future Activities

The CDP will continue to use a proactive, hands-on approach in supporting water systems. The need for a CDA will be determined through funding applications, the recommendations of field staff, request of a system, request of OEHS’s compliance/enforcement staff, and by CDP staff review of baseline scores. All initial assessments are onsite and include resources, tools and guidance needed to improve water systems’ TMF.

The CDP monitors the ETT list and continues to work with the OEHS C&E Section and other water utility related organizations (e.g., Public Service Commission, Rural Community Assistance Program, Regional Planning and Development Councils, adjacent Public Service Districts, etc.) to aid water systems having long-term compliance problems.

The CDP will follow-up with systems for a full year following an assessment to monitor their progress in implementing the CDP recommendations to improve their TMF.

The CDP also monitors newly formed water system’s ETT scores for violations related to failure to follow the monitoring and compliance schedules.

of 23

The CDP will continue to provide a CDA to all PWS requesting DWTRF funds for projects. This will be an opportunity to:

Identify systems that need a CDA

Obtain improvement in TMF for facilities requesting funding

Suggest additions to the projects that can address identified shortcomings in the system

CDP staff will continue to provide training opportunities to water systems including:

Teaching portions of the water system operators courses

Teaching PSD and Municipality Courses on Capacity Development, TMF, and AM through the West Virginia PSC

The CDP will further programmatic improvements by:

Simplify the AM plan development process, tools, and resources to be more sustainable by systems, 3rd party assistance providers and CDP staff. Build CDP staffing and skills

Continue CDP staff secession planning including the development of standard operating procedures for review of CCR’s which are submitted by water systems as an annual water quality report for their customers

Incorporating recently developed databases for CDA, baselines, CCR’s, and AM into the daily practices of the Engineering Division staff more broadly than just CDP

Exploring the need to include, in the CDA process, questions/discussions regarding the understanding of and compliance with source water protection planning requirements

Exploring options for additional onsite, hands-on support to systems for implementation of CDA recommendations for identified shortcomings

Modify the CDA questionnaire to incorporate O&M specific questions, remove questions that can be answered with information already available in other reports (such as sanitary surveys), and explore addition of questions related to source water planning

2.8 Program Progress in FFY 2016

Overall CDP performance as well as individual system progress is measured every three years through the Baseline survey. A report of the baseline survey results is available online to show progress from 2002 to 2014 (see http://www.wvdhhr.org/oehs/eed/i&cd/baseline_assessment.asp). Individual system progress is also measured through the follow-up process to each assessment and will be measured again as part of the 2017 baseline. See Table 3 for assessments conducted in FFY 2016.

http://www.wvdhhr.org/oehs/eed/i&cd/baseline_assessment.asp

of 23

Table 3: Summary of Water System CDA’s in FFY 2016 and Reasons for Assessment

3 Additional Reporting and Other Concerns

3.1 Report to the Governor

SDWA § 1420(c)(3) requires a report to the governor every three years. This report was completed and forwarded to Governor Earl Ray Tomblin on September 23, 2014. Report availability to the public was advertised in the State Register on September 26, 2014. A letter providing a copy of the report and documentation of transmittal and public notice was sent to Victoria P. Binetti, EPA Associate Director for Drinking Water and Source Water Protection, September 26, 2014. The report can be accessed online at the following link: http://www.wvdhhr.org/oehs/eed/i&cd/Governors_Report_Page.asp . The next report will be submitted on or before September 30, 2017.

System Name Date of Assessment

FFY DWTRF Water Sys

Request

OEHS Staff

Request

ETT Outside Request

Baseline

LINCOLN PSD August 2016 2016 X

PLEASANT HILL P S D RT 16 DISTRICT

July 2016 2016 X

CRUMPLER COMMUNITY WATER

June 2016 2016 X

MINISTERS RUN WATER ASSOC

May 2016 2016 X

GREENBRIER COUNTY PSD 2

April 2016 2016 X

FOX GLEN UTILITIES March 2016 2016 X

PRESTON COUNTY PSD 4

February 2016

2016 X

SHINNSTON - SALTWELL ROAD

February 2016

2016 X

RICHWOOD WATER DEPT

December 2015

2016 X

ARTHURDALE WATER ASSOC.

December 2015

2016 X

SUGAR LANE WATER ASSOCIATION

November 2015

2016 X

SUNNY VIEW ACRES WATER PROJECT

November 2015

2016 X

CENTRAL HAMPSHIRE PSD GREEN SPRING

October 2015

2016 X

http://www.wvdhhr.org/oehs/eed/i&cd/Governors_Report_Page.asp

of 23

3.2 Drinking Water Treatment Revolving Fund (DWTRF) Procedures

3.2.1 Ensuring DWTRF Applicants Achieve Compliance

The Capacity Development Strategy specifies systems seeking DWTRF loans will be assessed and to determine if the system has sufficient capacity and is sustainable. The CDP staff assesses the capacity of water systems most likely to receive DWTRF loan monies; evaluating their TMF capabilities to ensure that the system will be able to repay the loan. While assessing the water system, direct assistance and advice is provided. The CDA report recommends actions addressing the system’s capacity needs and provides a list of assistance providers. Systems not having sufficient capacity must address their capacity deficiencies before receiving a DWTRF loan or as part of the construction project. Deficiencies noted during assessments are technical, managerial, and/or financial in nature. In such instances the technical deficiencies (e.g., fencing, water loss, tank replacement, etc.) must be addressed in the proposed project while the managerial/financial deficiencies (e.g., cross connection program, asset management plans, capital improvement plans, budget, five-year budget projection, etc.) must be developed and/or implemented before the completion of the project. The DWTRF Project Priority Ranking System awards the highest points possible in several categories for projects correcting problems causing public health and non-compliance issues, increasing the overall project ranking. The project must address the causes for non-compliance to receive these points. In keeping with EPA regulations, DWTRF funds are not loaned to systems with an ETT score elevated to 11 or greater and those systems without adequate TMF unless the funding will build the system’s TMF and address the reasons for chronic non-compliance.

3.2.2 DWTRF Funding Distribution including small and disadvantaged systems

Since the DWTRF program began in 1998, 122 loans totaling in excess of $216 million dollars have been committed in loans for water system upgrades in West Virginia. In SFY 2016, these funds were distributed to small system sizes; systems ranging from 612 customers to 15,358 with the total population affected, for projects funded, of 49,526. It should be noted that the EPA defines a small system as any system <10,000 customers and more than 90% of systems in West Virginia meet this definition. Figure 3 illustrates the funding distribution to various system sizes over the past 3 years.

of 23

Figure 3: Distribution of Loan Dollars by System Population Size

Figure 4 illustrates the percentage of SFY 2016 funds disbursed to various size systems with 0% funds going to systems with more than 100,000 population. Figure 4: SFY 2016 Funding Distribution by System Population Size

0123456789

$ D

isb

urs

ed

in

Millio

ns

Distribution of Loan Dollars by System Population Size

2014

2015

2016

30%

43%

27%

SFY 2016 Funding Distribution by System Population Size

<500

501 to 3,300

3,301 to 10,000

10,001 to 100,000

>100,000

west virginia capacity development program annual ... · water system – capacity development...

Documents