HomeMy WebLinkAboutCalifornia Department of Public Health - Local Primacy Agency Annual Evaluation Reportm
~; I'I--~
RON CHAPMAN, MD,MPH
Director & Sfate Health 0/ficer
Butte County Board of Supervisors
202 Mira Loma Dr.
Oroville, CA 95965
Attention: Board of Supervisors
~~
JAN 3 0 2014
~~ January 24, 2014
Subject: LOCAL PRIMACY AGENCY ANNUAL EVALUATION REPORT
EDMUND G. BROWN JR.
Governor
Enclosed is the "Local Primacy Agency Annual Program Evaluation" for Butte County. The
report covers the period from July 1, 2012, through June 30, 2013. This evaluation and report
are required under Section 116330 (d) of the California Health and Safety Code. The purpose
of the evaluation is to review the status of the small water system program that is being
conducted under the Local Primacy Delegation Agreement in effect between the Butte County
Environmental Health Department and the California Department of Public Health.
Based on the evaluation findings, it has been determined that Butte County Environmental
Health Department is in substantial compliance with the California Department of Public
Health's local primacy program requirements at this time. The Local Primacy Agency has met
the goals and objectives established in the Work Plan for Fiscal Year 2012-13.
We look forward to working with Butte County Environmental Health Department during the
current, 2013-14, fiscal year. If you have any questions concerning this matter, please call me
at (530) 224-4861.
z (pry^~~
Reese B. Crenshaw, P.E.
Valley District Engineer
Drinking Water Field
Operations Branch
Enclosures
cc: Richard Hinrichs, P.E., Chief -Northern California Section
Wendy Killou, Chief -Small Water Systems Unit, Sacramento
Elaine McSpadden -Supervisor, Butte County EHD
Division of Drinking Water and Environmental Management
364 Knollcrest Drive, Suite 101, Redding, CA 96002
~`~ (530) 224-4800 (530) 224-4844 Fax
CC VV J / ~}~ Internet Address: www.cdph.ca.gov
State of California-Health antl Human Services Agency
California Department of Public Health
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Local Primacy Agency Annual Program Evaluation
County of Butte
Fiscal Year 2012-2013
INTRODUCTION
On October 23, 2013, the California Department of Public Health (CDPH) conducted the
annual evaluation of the Butte County Small Water System Program (SWSP) for the fiscal
year (FY) 2012-2013. Butte County's Environmental Health Agency has been delegated as a
Local Primacy Agency (LPA) and is the county entity responsible for administering the SWSP
for public water systems (PWS) of less than 200 service connections.
CDPH representatives conducting the evaluation were Dan Cikuth, Associate Sanitary
Engineer from the Valley District and Irene Lee, Environmental Scientist from Small Water
Systems Unit. Representing the LPA was Elaine McSpadden, Registered Environmental
Health Specialist, Butte County Division of Environmental Health. This evaluation and report
is mandated by California Health and Safety Code (CHSC) Section 116330(d). The purpose
of the evaluation is to determine the program status with respect to the objectives set forth in
the Butte County LPA Delegation Work Plan for FY 2012-2013. This report summarizes the
findings, recommendations, and directives of the Valley District, Northern CDPH Drinking
Water Field Operations Branch as it relates to LPA program elements as set forth in
California Code of Regulations (CCR) Title 22, Sections 64253 through 64260.
SUMMARY OF EVALUATION FINDINGS
The Butte County has implemented compliance with all current requirements of the California
Safe Drinking Water Act for the small PWSs located within the county and is working to
secure compliance. In addition, the LPA has substantially met the program objectives that
were outlined in the approved FY 2012-2013 work plan and the LPA Program requirements
set forth in CCR Title 22, Sections 64253 through 64260.
DIRECTIVES AND RECOMMENDATIONS
CDPH finds that the Butte County SWSP is achieving general compliance with the LPA
requirements for small PWSs and meets the goals and objectives established in the FY 2012-
2013 work plan.
Form Revised 8/28/2013 Page 1 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-20t3
CDPH makes the following directives and recommendations regarding the County's program:
1. Continue to prepare and submit a work plan annually to the Valley District office
and the Small Water Systems Unit in Sacramento no later than May 1, 2014 for the
2014-2015 FY.
2. Continue to review water system files to ensure that there is a current emergency
notification plan (ENP) on file. The County should use the State approved format.
This plan should be updated annually and could be required to be updated with the
annual operating permit fees.
3. Continue to incorporate the CDPH Permit Policies and Procedures Manual in the
development and issuance of water supply permits. Reissue a permit whenever the
original permit does not adequately describe the current system or is more than 10
years old using the State formatted permit template: Section 116525 (c) of the
CHSC grants the LPA authority to renew, reissue, revise, or amend any domestic
water supply permit whenever the LPA deems it to be necessary for the protection
of public health whether or not an application has been filed.
The Department recommends the following prioritization scheme when issuing new
permits for water systems:
i. Systems adding new facilities (wells, treatment, etc.)
ii. Surface water systems
iii. Systems treating for a primary MCL violation (Nitrates are of the highest priority of
MCL violations)
iv. Systems that are changing ownership.
4. By April 1, 2014, the LPA is recommended to send a letter notifying all public water
systems within their regulatory jurisdiction of the requirement to complete the
electronic Annual Report (eAR) for calendar year 2013.
5. Continue to ensure that all new systems and all systems undergoing a change in
ownership meet the applicable Technical, Managerial, and Financial (TMF)
Form Revised 8/28/2013 Page 2 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
capacity requirements by evaluating the TMF capacity of those water systems
during the permitting process to ensure that the systems can at all times provide
water that meets drinking water standards to the public. Mail the completed and
signed TMF assessment with a copy of the Staff Evaluation Form each to George
Faggella in Sacramento headquarters and the Valley District Office.
6. Prior to a sanitary survey, the LPA is recommended to request a Water Quality
Monitoring Report from CDPH to ensure that a water system's registered
environmental health lab is successfully transmitting the water quality data
electronically to CDPH as stated in 22 CCR 64469(c).
7. Strive to get 100% of projected inspections/sanitary surveys as stated in the FY
2013-2014 work plan.
8. Continue to retain and update technical reports, bacteriological sample site plans,
and emergency notification plans as necessary when information is developed or
as inspections are conducted.
9. Continue to file and retain bacteriological water quality results for minimum of five
(5) and chemical water quality results for minimum of ten (10) years in each water
system file.
10. Continue to file all correspondences, including enforcement letters, memoranda, or
any other written records for a minimum of three (3) years.
11. The County should utilize the CDPH Lead and Copper Rule database for tracking
compliance with monitoring action level exeedances and monitoring and reporting
of sampling for lead and copper.
12. Continue to submit EDT data files to the SWS Unit monthly.
13. Ensure water systems with a groundwater or surface water source that is adding a
chemical disinfectant to any part of their treatment process or provides water that
contains a chemical disinfectant are monitoring for TTHMs and HAA5s at the
frequency that is stated in the disinfection byproduct rule (DBPR), refer to CCR-
Form Revised 8/28/2013 Page 3 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Title 22 section 64530. Issue an addressing enforcement action if a water system
fails the monitoring and reporting requirements as stated in the DBPR.
14. Follow-up with water systems that exceed the DBPR MCLs as stated in CCR-Title
22 section 64534 and impose increased monitoring requirements, if needed. Issue
an addressing enforcement action if a water system fails a DBPR MCL.
15. The County should utilize the DBPR tracking spreadsheet that is utilized by the
Valley District Office to track water systems that are required to monitor for DBPs
and ensure that they are complying with the DBPR. Contact Valley District Staff for
a copy of the spreadsheet and training.
16. Staff in the Small Water System Program must have detailed knowledge of all
aspects of small water systems as well as the laws and regulations governing
PWSs. Therefore, it is important that Butte County Environmental Health
Department continues to allocate the resources to recruit, develop, retain, promote,
and support staff to assure an able, knowledgeable, and motivated workforce in the
Small Water System Program.
17. Strive to implement addressing enforcement actions as described herein,
particularly for MCL violations, to avoid water systems totaling points towards
EPA's Enforcement Targeting Tool (ETT) when Notice of Violation is utilized.
CDPH looks forward to our continued partnership as we share the oversight of PWSs in Butte
County.
Report Submitted By:
~ +-~L war Date:
Reese Crenshaw, District Engineer
Valley District
CDPH Drinking Water Field Operations
Form Revised 8/28/2013 Page 4 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Report Prepared By:
/~ ...~:~r~ Date: j ~~-F' ~
Irene Lee, En ~~i~r~ nmental Scientist
CDPH Small 4r~ater Systems Unit
Appendices:
Appendix A -LPA Permit Activities
Appendix B -Inventory Maintenance
Appendix C -Routine Inspections/Sanitary Surveys
Appendix D -Water Quality Monitoring Activities
Appendix E - Reporting to CDPH
Appendix F -Enforcement Activities
Appendix G -Program ManagementiWork Plans
Appendix H -LPA Water System Inventory
Appendix I -CDPH Infrastructure Financing Programs
Appendix J -CDPH Small Water Systems Program Plan
Appendix K -LPA File Review
Appendix L-Water Systems Exceeding a Primary MCL(s) and Providing Treatment
Form Revised 8/28/2013 Page 5 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix A: LPA Permit Activities - CCR Title 22, Section 64254
All small PWSs are required to have a Domestic Water Supply Permit that must be
accompanied by a technical report. These reports are submitted and reviewed at the time
new water systems are proposed or an existing system is modified. The LPA issues new or
amended permits following a determination that the technical report is complete and an
inspection of the new or modified water system is performed. In addition, the LPA primacy
regulations require that all permits be re-evaluated at least once every 10 years to confirm
that the permit information is current and that the permits contain conditions appropriate to
ensure the safe operation of the water systems. During FY 2012-2013, the County issued
water supply permits in the CDPH format as summarized in Table 1.
Table 1: Summary of Permits Issued
RWS
Number System Name RWS '
Classification* New Amended Reason
0400138 Strawberry Campground N ® ^ Permit renewal
0400137 Sly Creek Campground N ® ^ Permit renewal
0409188 FEDEX Freight P ® ^ New Permit
0409187 PG&E Table Mountain P ® ^ New Permit
0400081 Feather Ridge Estates C ® ^ New Permit
*C=Community P=Non-transient Non-community N=Transient Non-community
TMF Capacity Evaluation Implementation
The 1996 federal Safe Drinking Water Act amendments specified that new PWSs must have
technical, managerial, and financial (TMF) capacity before they are permitted to operate by
primacy agencies. Anew PWS must demonstrate through its financial resources, technical
resources, organizational structure, and personnel that it has the capability to comply with all
applicable drinking water standards and regulations on an ongoing basis. As a condition of
granting CDPH primacy to conduct the PWS regulatory program in California, the United
States Environmental Protection Agency (EPA) requires that CDPH have a mechanism in
place to prevent the formation of new PWSs that do not have adequate TMF capacity. CDPH
has chosen to incorporate the TMF requirements into its permitting process. In addition,
under CHSC Section 116540(b) all PWSs that undergo a change of ownership after
Form Revised 8/28/2013 Page 6 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
January 1 1998, must demonstrate adequate TMF capacity before being granted a new
permit. CDPH has developed criteria to be used in assessing the TMF capacity of PWSs.
All LPAs are responsible for ensuring that new PWSs, PWSs undergoing a change of
ownership, and funding program applicants have adequate TMF capacity or can acquire it in
a specific time period. As such, permits issued by an LPA in all of these cases must contain
provisions that require compliance with TMF capacity requirements as applicable. The county
has incorporated the TMF capacity requirements into its permit process for new water
systems and systems changing ownership.
THE LPA IS IN COMPLIANCE WITH APPENDIX A REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 7 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix B: Inventory Maintenance - CCR Title 22, Section 64255
The PWS inventory in Butte County consists of 91 water systems including: 36 community,
27 nontransient noncommunity, and 28 transient noncommunity PWSs as summarized in
Table 2. Changes in the inventory during FY 2012-2013 are listed in Table 3. A detailed list of
-Butte County small PWSs are found in Appendix H. The LPA maintains the following
minimum required information for all PWSs in their Decade EnvisionConnect database.
• Water system name
• Water system identification number
• Mailing address
• Type of water system
• Name, address, and phone number of the responsible party
• Type of ownership
• Type of water source
• Type of treatment if any
• Dates of operation for seasonally operated systems
• Number of service connections
• Population served
Table 2: Current Water System Inventory
Water S Stem T e ' FY 2012.2013 FYi2011-201:2
Communi 36 36
Nontransient Noncommuni 27 24
Transient Noncommunit
Total; 28
91 28
88
Form Revised 8/28/2013 Page 8 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Table 3: Water System Inventory Changes
Fiscal Year 2012-2013
PWS
A
ti PWS Classification
Number '8ystem Name c
vity Current Prior Comments
0400065 Spring Valley School P Existing WS that was not
included in invento
0400080 Cohasset School P Existing WS that was not
included in inventor .
0409189 Dauterman Well P Existing WS that was not
included in inventor .
0400144 Cherr Hill Cam round New N New waters stem
0400043 Feather West Trvl trl Inactivated Inac. N Inactivated WS.
THE LPA IS IN COMPLIANCE WITH APPENDIX B REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 9 of 40
Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Appendix C: Routine Inspections/Sanitary Surveys - CCR Title 22, Section
64255
Routine inspections and sanitary surveys frequencies are based on the type of water system,
source type, and any required treatment. The frequencies are as follows, along with the
CDPH performance requirements:
Sanitary surveys consists of a review of the water system permit and files as well as an
onsite inspection of 8 elements in order to evaluate the water system's ability to produce and
distribute safe and reliable drinking water. The components of a sanitary survey are:
1. source(s)
2. treatment
3. distribution system
4. finished water storage
5. pumps, pump facilities, and controls
6. monitoring, reporting, and data verification
7. system management and operation
8. operator compliance with State requirements
The LPA notes water system deficiencies found during a routine inspection or sanitary survey
and outlines a corrective action schedule. Enforcement actions are issued when a water
system fails to correct the noted deficiencies in a timely manner.
Form Revised 8/28/2013 Page 10 of 40
Loral Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
The FY 2012-2013 work plan identified 32 water systems that would receive routine
inspections/sanitary surveys. Staff conducted 37 routine inspections/sanitary surveys which is
116% of the projected routine inspections/sanitary surveys in the FY 2012-2013 work plan
and 41 % of the LPA's PWS inventory. A total of 0 unscheduled inspections/sanitary surveys
were conducted. A summary of the routine inspections/sanitary surveys conducted are
shown in Tables 4 through 11.
Table 4: Community Public Water Systems using Surface Water
None
None
_u ~oNciu um w u ~uuuc au o mcu icma m a sai mai y sw vey.
Table 6: Community Water Systems using Treated Groundwater to Comply with a
Primary Drinking Water Standard(s)
None
nspections include all B elements of a sanitary survey.
Form Revised 8/28/2013 Page 11 of 40
Table 5: Non-community Public Water Systems using Surface Water
Loral Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Form Revised 8/28/2013 Page 12 of 40
Table 7: Non-community Water Systems using Treated Groundwater to Comply with a
Primary Drinking Water Standard(s)
Table 8: Community Water Systems using Untreated Groundwater
Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Table 9: Non-community Water Systems using Untreated Groundwater
Meets GDPH '
PWS 'Date ~ Performance
Ntarx-ber System;Name Inspection/Sanitary Requirement?
Survgy Compieted* ~/N~
Ever 5 ears
Scheduied: Rou#ine Ins actions/Sanity 5urve s '.
0400105 Gra Lod e Check Station 2/6/13 Y
0400164 Cam Okizu 7/18/13 Y
0400062 Richvale Elementar School 3/19/13 Y
0400063 Manzanita Elementar School 4/15/13 Y
0400066 Durham Unified School District 03/15/13 Y
0400137 SI Creek Cam round 10/01/12 Y
0400138 Strawber Cam round 10/01/12 Y
0400141 Llano Seco Rancho 5/28/13 Y
0400150 Sunset Mouldin Chico 12/05/12 Y
0400161 Cohasset Industrial Park 2/5/13 Y
0409178 Sk a House 9/28/12 Y
0409179 L.C. Hunt Club 1/22/13 Y
0409182 Tuscan Ride 9/28/12 Y
0409187 PG&E Table Mountain Substation 8/16/12 N/A news stem
0409188 FEDEX Frei ht 7/12/12 N/A news stem
Unschedule dlns actions/Sani#a Surve s
None
'Inspections include all 8 elements of a sanitary survey
Table 10: Unscheduled Inspection Activities
PWS
Number System Nance ,:Date Reason for Inspection
0400081 Feather Rid a Estates 6/25/13 Troubleshootin
0409184 Chico Gran a 9/27/12 & 7/26/12 Troubleshootin TC+
0400144 Cherr Hill Cam round 8/17/12 Weli Final
Table 11: Scheduled Water Systems That Were Not Inspected
PWS Reason for No Inspection
Number System Name Date
None
THE LPA IS IN COMPLIANCE WITH APPENDIX C REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 13 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix D: Water Quality Monitoring Activities -CCR Title 22, Section
64256
Total Coliform Rule Monitoring
Those water systems identified during this evaluation that failed to monitor and report for the
Total Coliform Rule in accordance with CCR Title 22, Section 64256 are listed below in Table
12, including any enforcement action issued by the LPA#othe water system informing them
of the violation(s). To effectively manage monitoring and reporting requirements, the LPA
tracks the water system monitoring and reporting deficiencies by utilizing their Decade
EnvisionConnect software and takes the appropriate corrective action by issuing the proper
enforcement actions.
Table 12: Total Coliform Rule Monitoring and Reporting Violations
Form Revised 8/28/2013 Page 14 of 40
1-C=Community, P=Non-transient Non-community, or N=Transient Non-community
2-IA=Notice of Violation(s) or FL=Citation or Compliance Order
Local Primacy Agency Annual Evaluation
County of Butte
Chemical/Radiological Monitoring
Fiscal Year 2012-2013
The LPA notifies water systems of the monitoring and reporting requirements by providing a
water quality monitoring schedule to the water system operator annually or by including the
schedule with other correspondence to the water system during the year. Chemical data
submitted by water systems are received and reviewed by the program specialist to ensure
-compliance with the chemical constituents'- monitoring and reporting requirements and -
advises the water system of any follow-up sampling requirements. Hard copies of all
chemical monitoring results are maintained in the water system file.
All transient noncommunity systems have conducted required analyses at least once when
the water sources were initially placed into service. Most community and nontransient-
noncommunity water systems are in compliance with ongoing chemical and radiological
monitoring requirements. Table 13 summarizes the monitoring and reporting violations of
small PWSs for general mineral chemicals (IOC), organic chemicals, radiological constituents
(Rad), lead and copper (LCR), and disinfection byproducts (DBP).
Certified Treatment and Distribution System Operators
CHSC Section 106885 states that any person who operates or supervises the operation of a
water treatment plant or a distribution system of a community or nontransient noncommunity
water system shall possess a valid and current water treatment and/or distribution operator
certificate of the appropriate grade in accordance with the regulations referenced in CHSC
Section 106910.
The determination of the level of operator certification required for a public water system is
defined in CCR Title 22, Sections 63765 for water treatment and 63770 for distribution
systems. The LPA has classified all water systems for the appropriate level of water
treatment and distribution system operator certification. Each water system has been advised
of its system classification for certified treatment or distribution system operator certification.
Table 13 summarizes water systems that are not operating with an operator or with the
appropriate level certified operator.
Consumer Confidence Reporting
Form Revised 8/28/2013 Page 15 of 40
Loral Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
CCR Title 22, Section 64480(a) requires each community and nontransient noncommunity
public water to issue an annual Consumer Confidence Report (CCR) to customers. All water
systems use the standardized reporting format for small public water systems CCRs. The
water system is required to distribute the CCR to its customers and provide a copy to the
county. In addition, the water system is to provide certification that the report has been
-distributed to its customers and-that-the information is correct.. and .consistent with the
compliance monitoring data submitted to the county. Table 13 lists water systems in violation
of the CCR requirements for FY 2012-2013.
Form Revised 8/28/2013 Page 16 of 40
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Local Primacy Agency Annual Evaluation
County of Butte
Surface Water Sources
Fiscal Year 2012-2013
PWSs with a surface water source are required to have amulti-barrier treatment process that
includes filtration and disinfection to ensure the removal and/or inactivation of disease-
causing viruses, bacteria, and protozoa. The Surface Water Treatment Rule (SWTR), Interim
Enhanced Surface Water Treatment Rule (IESWTR), Long Term 1 and Long Term 2
------- --Enhanced Surface Water Treatment Rule (LTi-LT2ESWTR) established standards for
approved filtration methods to ensure that these pathogens are reliably removed by the
filtration process. Table 14 lists all surface water systems within the LPA's regulatory
jurisdiction.
The LPA verifies monthly that all surface water and groundwater under direct influence of
surface water (GWUDI) sources are in compliance with the filtration and disinfection
requirements of the SWTR and that the filtration and disinfection compliance data is being
recorded daily when the plant is in operation. Monthly reports of the filtration and disinfection
compliance data are submitted to the LPA. The LPA reviews, tracks, and follows-up on
monthly compliance with filtration and disinfection compliance.
Each water system with filtration technique violations of the LT1 ESWTR are issued a notice
of violation each month that they are out of compliance stating that the water system is in
violation of filtration requirements of the LT1 ESWTR and that the water system needs to
develop a plan of action to bring the water system into back into compliance. Violations are
entered into the LPA's Decade EnvisionConnect software and reported as required to CDPH
via the Electronic Data Transfer process. Table 14 lists surface water systems that are in
violation of the monitoring and reporting requirements of the SWTR or LT1 ESWTR. The
surface water systems are in compliance with the treatment techniques and performance
requirements.
Form Revised 8/28/2013 Page 18 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Table 14: Inventory of Surface Water Systems
0400064 Concow Elementary School P
*C=Community. P=Non-transient Non-community, or N=Transient Nr
Fiscal Year 2012-2013
Membrane No GWUDI
THE LPA IS IN COMPLIANCE WITH APPENDIX D REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 19 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix E: Reporting to CDPH - CCR Title 22, Section 64257
The need for both CDPH and LPAs to develop the capability to transmit PWS program
information via electronic data transfer (EDT) is a requirement of the EPA. The information
that is required to be reported includes:
• Monthly: A list of all small PWSs that failed in the previous month to comply with drinking
water monitoring and reporting regulations. This includes primary drinking water standard
violations as well as monitoring and reporting violations. Information provided should
include the system name and number, the type of violation, and the type of enforcement
action taken if any.
• Quarterly: A list of permits that have been issued, amended, or renewed as well as a list
of small PWSs for which a routine inspection or sanitary survey was conducted.
• Annually: The inventory of small PWSs under the jurisdiction of the LPA.
CDPH has requested that these reports be submitted monthly by the LPA. CDPH reviews
these files as they are received from the LPA and advises the LPA of any reporting
deficiencies associated with transmitting the files. The LPA is expected to review these error
reports and correct any data formatting errors accordingly and then resubmit the data along
with the data for the following reporting period. The LPA uses Decade EnvisionConnect
software to comply with the EDT reporting requirements. The LPA submitted the required
data in a timely manner for FY 2012-2013 except the month of July 2012.
THE LPA IS IN COMPLIANCE WITH APPENDIX E REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 20 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix F: Enforcement Activities - CCR Title 22, Section 64258
The enforcement activities conducted by the LPA are those specified in the primacy
agreement and include conducting site visits to the systems to assist in determining the
cause of bacteriological contamination, directing corrective actions, requiring notification of
the consumer as required, requiring that the water system issue boil water orders or provide
bottled water as necessary until water quality deficiencies have been corrected, and issuing
enforcement actions. Addressing enforcement actions include the issuance of compliance
orders, citations (with or without fines), administrative hearings, or other actions that meet the
definition as outlined in the USEPA Enforcement Response Policy dated December 8, 2009.
All other enforcement actions, such as Notice of Violation, allow points to be accumulated for
the system in EPA's enforcement targeting tool (ETT).
Total Coliform Rule MCL Violations and Enforcement
When a small public water system has been determined to have failed the Total Coliform
Rule (TCR) MCL, county staff may conduct a site inspection of the water system when the
cause of the contamination cannot be easily determined by the system operator. If county
staff is able to determine the cause of the problem, then guidance is provided to the system
operator regarding corrective mitigation measures, follow-up monitoring, and public
notification requirements. The system then is responsible for implementation of the mitigation
measures. Where repeat samples are required, the water system collects 5 routine samples
the following month in accordance with requirements of the TCR. The LPA then issues an
enforcement action to notify the water system that they failed the TCR MCL for the month(s)
specified which includes various directives for the water system to comply with a specified
compliance schedule. These directives may include, but not limited to public notification,
repeat sampling requirements, and/or increased monitoring requirements. Listed in Table 15
are the water systems that violated the TCR MCL in FY 2012-2013.
Chemical and Radiological Violations and Enforcement
Chemical data submitted by the water systems is reviewed by the program specialist to
ensure compliance with the MCL requirements. If necessary, the LPA advises the water
system of any follow-up sampling requirements. Hard copies of all chemical monitoring
Form Revised 8/28/2013 Page 21 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
results which are submitted are retained as hard copies in the water system file. Listed in
Table 16 are the water systems in FY 2012-2013 that exceeded a chemical or radiological
MCL along with the associated enforcement action issued.
Form Revised 8/28/2013 Page 22 of 40
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Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
Appendix G: Program Management/Work Plans - CCR Title 22, Section
64259 though 64260
The LPA is under the Butte County Division of Environmental Health is responsible for the
management of the County's small public water system regulatory program. The SWSP is
administered by the Brad Banner, Director-o# Environmental Health,-and-Elaine McSpadden,
Supervisor of Environmental .Health. The county's SWSP is funded by the SWSP Fees.
Table 17 lists the various fees that Butte County Environmental Health charges to the PWSs.
Table 17: Butte County SWSP Fees for FY 2012-2013
File Maintenance
CCR Title 22, Section 64259 states that each LPA shall establish and maintain an
individual file for each small PWS which includes the following information:
• Current water supply permit and technical report.
• Permit applications, permit technical reports, and all technical reports supporting
the water supply permits for a minimum of 10 years.
• Current plans and specifications pertaining to source information, treatment
information, storage facilities, distribution plans, water quality plans, total coliform
sample siting plans, and emergency plans.
• Copies of bacteriological water quality analyses for a minimum of 5 years.
• Copies of water quality monitoring data for a minimum of 10 years.
Form Revised 8/28/2013 Page 24 of 40
Lc?cal Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
• Correspondence, memoranda, and other written records pertaining to the water
system issued or written within the past 3 years.
• Copies of all compliance orders, citations, court actions, and other enforcement
documentation issued.
- Butte County maintains their files by hard-copy and electronically.
Work Plans
CCR Title 22, Section 64260 requires LPAs to submit proposed annual work plans to CDPH
no later than May 1 of each year for the fiscal year commencing July 1 of that year. The work
plan outlines the proposed activities that include the following:
• Listing goals and objectives
• Maintaining water system inventory and tiles
• Issuing water supply permits
• Conducting inspections/sanitary surveys
Monitoring water quality data
• Submitting various reports to CDPH
• Issuing enforcement actions
• Maintaining and submitting data to CDPH
The LPA submitted a work plan for FY 2013-2014, dated 6/10/13.
THE LPA IS IN COMPLIANCE WITH APPENDIX G REQUIREMENTS:
® YES ^ NO
Form Revised 8/28/2013 Page 25 of 40
Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Appendix H: LPA Water System Inventory
0400001 Youth With AMission-S rin s Of Livin 150 49
0400003 Northwoods Mutual Water S stem 31 16
0400004 Forest Ranch Mutual Water S stem 92 42
0400007 Butte Creek Estates Mutual Water Co 399 133
0400008 Gran Mutual Water Co 200 59
0400012 Farm LaborHousin 500 144
0400013 Merr Mountain Mutual 100 77
0400014 Lake Madrone Water District 297 115
0400016 Berr Creek Communit Service Dist 99 36
0400019 Pacific Hei hts MHP 74 35
0400020 Pleasant Grove MHP 327 88
0400021 Robinson S Corner MHP 20 22
0400023 Golden Oaks Mobile Estates 86 52
0400026 Meadowbrook Oaks 50 25
0400027 Foothill Mobile Home Park 180 127
0400028 Bi Bend Mobilehome Park 85 35
0400030 Golden Feather MHP 275 100
0400036 Mountain View Mobile Acres MHP LLC 230 129
0400040 Almond Grove Mobile Park 250 163
0400041 Forest Ranch Mobile Park 25 16
0400042 Forest Villa e LLC 34 21
0400045 Cohasset Mobile Estates 20 17
0400046 Ponderosa Mobile Estates 70 62
0400049 Butte Creek MHP 100 33
0400051 Din erville Usa Park 50 76
0400058 Rancho Villa Mobile Acres 32 21
0400078 Forest Knolls Mutual Water Co 41 16
0400081 Feather Rid a Estates 32 12
0400090 Mountain Villa a Homeowner S Assoc 40 17
0400091 Buzztail Communit Service District 25 31
0400123 Humboldt Hi hlands Mutual 50 21
0400149 Humboldt Woodlands Mutual 50 32
0400151 Keefer Creek Estates Mutual 95 56
0400155 Bi ers Glen Mutual Water Co 10 29
0409181 Blue Oak Terrace Mutual 1 51
0409183 Sierra Moon Subdivision 12 118
Total Number of Community Water Systems 36
Form Revised 8/28/2013 Page 26 of 40
Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Nontrans ient~Noncpmmund WaieYS s#ems '
~,~~ ~ ~ ~ Pppulation Number of
~ Wa#er System Name Service
NurrltSer ~.. ~ .;
Connections
0400060 Honcut Elementar School 36 3
0400062 Richvale Elementa School 63 3
0400063 Manzanita Elementar School 225 3
0400064 Concow Elementa School 115 1
0400065 S rin Valle School 185 1
0400066 Durham Unified School District 1400 18
0400067 Feather River School 50 2
0400068 Berr Creek School 180 6
0400070 Butte-Glenn Communit Colle a Dist 9900 35
0400073 Nord Countr School 66 6
0400079 Forest Ranch Charter School 146 4
0400080 CUSD -Cohasset Elementar School 79 2
0400107 Feather Falls School 50 2
0400133 Lundber Rice Products 100 6
0400140 Durham Da on Industrial Partners 80 3
0400141 Llano Seco Rancho 40 17
0400150 Sunset Mouldin Chico 130 5
0400152 C ress Acres 282 7
0400154 Smucker Natural Foods 130 2
0400158 Francis Pro ert Mana ement 51 18
0400161 Cohasset Industrial Park 47 22
0400162 Pleasant Valle Ba tist Church 500 1
0409175 Norfield Industries 40 3
0409177 G & J Pro erties 30 1
0409187 PG&E -Table Mountain 25 5
0409188 Fedex Frei ht 37 1
0409189 Dauterman Well 100 3
Total Number of Nontransient Noncommunit Water S stems 27
Form Revised 8/28/2013 Page 27 of 40
Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013
County of Butte
Form Revised 8/28/2013 Page 28 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Appendix I: CDPH Infrastructure Financing Programs
Fiscal Year 2012-2013
CDPH has several funding programs to assist small PWSs with improvements to bring the
systems into compliance with State and federal regulations. The LPA forwards information
relating to State funding programs to all water systems that have significant deficiencies. The
information includes apre-application for funding and the deadline for its submittal to the
State. The LPA assists CDPH in evaluating proposed projects for the systems requesting
funding under the various programs.
Table 18 lists water systems under the Butte County LPA regulatory jurisdiction that
submitted apre-application and subsequently were placed on a priority project list and invited
to apply for funding in one of CDPH's 3 funding programs: Proposition 50, Proposition 84,
and the State Revolving Fund (SRF) in FY 2012-2013. Also included are PWSs that are in
the process of receiving a funding agreement in one of these 3 funding programs.
The California Rural Water Association (CRWA) is continuing to provide technical assistance
to the small PWSs in Butte County to complete the Drinking Water SRF applications and the
mandatory elements of TMF. CRWA also provides technical assistance for completion of
TMF capacity criteria for water systems changing ownership or those needing help or training
on specific operational issues.
Table 18: Water Systems Currently Seeking CDPH Funding
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0400058 Rancho Villa ^SRF 0400058-002C Arsenic Completed, except for some
Mobile Acres ^ Prop50 final paving which is waiting
® Prop84 for warm weather.
0400081 Feather Ridge ®SRF No project E. Coli New application is in.
Estates ^ Prop50 number yet. remediation
^ Prop84
Form Revised 8/28/2013 Page 29 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Appendix J: CDPH Small Water System Program Plan
Fiscal Year 2012-2013
CDPH has developed a Small Water System Goal targeted to bring small community
systems into sustainable compliance with primary drinking water standards. CDPH has
developed an implementation plan that defines specific tasks to achieve the goal as well as
measureable results of progress. The implementation plan includes the use of CDPH staff
and coordination with LPA drinking water programs, technical assistance providers, and
stakeholders to accomplish its goal. This comprehensive approach will address the specific
violations and reduce the number of primary drinking water standard violations in California.
The Small Water System Program Plan Goal consists of a bringing approximately 63 of these
systems back into compliance. Achieving this goal will bring the compliance rate of small
water systems in the state from the present 92% to 95%, matching that of large community
water systems. CDPH will focus internal efforts and third party provider services toward these
listed systems in order to bring them into compliance. The intent is to direct attention and
resources to these systems to help them secure funding that will solve their problems and to
develop their TMF capacity to a level that will that will ensure sustainability into the future.
The Program Plan tracks the progress of 183 community water systems that have between
15 and 999 service connections that are on the list. You can find information below related to
the implementation and progress of the Small Water Systems Program Plan.
Table 19 lists water systems under the Butte County LPA regulatory jurisdiction that are on
the Program Plan list and what their status is to meet their milestones in returning to
compliance with the primary drinking water standards.
Table 19: Water Systems Listed on the Small Water System Program Plan
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0400027 Foothill MHP ^SRF Arsenic Solved. Returned to
^ Prop50 compliance since Jan
^ Prop84 2010.
0400058 Rancho Villa Mobile Estate ®SRF Arsenic Returned to
^ Prop50 compliance.
^ Prop84
Form Revised 8/28/2013 Page 30 of 40
Local Primacy Agency Annual Evaluation
County of Butte
Appendix K: LPA FILE REVIEW
Fiscal Year 2012-2013
<ATTACHED REVIEW FORMS - Norfield Industries & Forest Ranch, total 8 pages >
Form Revised 8/28/2013 Page 31 of 40
California Department of Public Health
Small Water System Unit
LPA File Review
Page X32
Last Updated:8/5/2013
California Department of Public Health
Small Water System Unit
LPA File Review
Date of Last Sanitary Conducted:l/25/12 State Formatted Report?:XYes ^ No(D)
Do the Sanitary Survey Reports Include all 8 Elements(see below)?:XYes^ No(D)
Sanitary Survey Elements: Source, Treatment, Distribution, Storage, Pump Facilities, Monitoring/Reporting/Data Verification, Management/Operation, and
Operator Certification.
Is a Sanitary Survey Past Due Based on the 3 or 5 year Frequency: ^ Yes(D) X No
Notes: Previous sanitary survey was 6/24/09.
Bacteriological Sample Siting Plan: Date of Last BSSP:6/6/07 BacT Monitoring Frequency:
X Yes ^ No D # 1 er X Mon. ^ Qtr.
BSSP is > 10 Years Old?: ^ Yes(D) X No BSSP Needs Revisions? ^ Yes(D) X No
Emergency Ops Plan: X Yes ^ No(D) Date of Last Emergency Ops PIan:9/4/01
Water System Ops Plan?:XYes ^ No(D) Date of Last Water System Ops Plan: 9/4/09
Notes:
ENP is generally updated during inspection if needed. During the last inspection, it was noted that the ENP will
need to be updated for new operator by Feb 2012 and new ENP was not available at the time of evaluation.
Bacteriological Issues:
^ TCR MCLs
^ TCR M&R
Is the LPA Requiring Water System to Sample Source(s) for TC+ (GWR)?: XYes ^ No(D)
Is the LPA Using WOI Last Sample/Next Due Reports?: ^Yes X No(D)
Last Sample Date(s) of Req. Inorganic Chemicals (IOC): In Compliance?:XYes ^ No(D)
^ N/A Arsenic- 4/15/2011; IOC- 12/15/2004; Perchlorate- 10/14/2013
Last Sample Date(s) of Req. Volatile Organic Chemicals (VOC): In Compliance?:XYes ^ No(D)
^ N/A VOC- 10/24/2013
Last Sample Date(s) of Req. Synthetic Organic Chemicals (SOC): In Compliance?:XYes ^ No(D)
X N/A
Last Sample Date(s) of Required Radiological Chemicals: In Compliance?:XYes ^ No(D)
^ N/A Gross alpha - 9/21 /2011
Page X33
Last Updated:8/5/2013
California Department of Public Health
Small Water System Unit
LPA File Review
Page X34
Lasi Updated:8/5/2013
California Department of Public Health
Small Water System Unit
LPA File Review
Is the Water System Submitting Monthly SWTR Monitoring Reports, including CT reports?: U Yes
If Yes, Are they the State Formatted Reports? ^ Yes ^ No(D)
Is the Water System Submitting Quarterly TOC Monitoring Reports?: ^ Yes ^ No(D)
If Yes, Are they the State Formatted Reports? ^ Yes ^ No(D)
Is the Water System Monitoring for DBP?: ^ Yes ^ No(D) XN/A System does not disinfect.
Does the Water System have a DBP Monitoring Plan on File?: ^ Yes ^ No(D) X N/A
Notes:
N/A -the system does not disinfect.
Needs to follow up with the water system to have an updated ENP as noted in the last sanitary survey report and
has not received it yet.
Need to reconcile the WS number. The water system # for the laboratory results is 0400175 and the actual
water system # is 0409175. All records need to be changed to be consistent in both PICME & EnvisionConnect.
**The reconciliation of water system number is complete after the evaluation.
Reviewer: Irene Lee Date: 10/23/13
Page X35
Last Updated:6/5/2013
California Department of Public Health
:Small Water System Unit
LPA File Review
Page X36
Last Updated:8/5/2073
California Department of Public Health
`Small Water System Unit
LPA File Review
California Department of Public Health
Small Water System Unit
1PA File Review
Page X38
Last Updated;8/5/2013
California Department of Public Health
Small Water System Unit
LPA File Review
Is the Water System Submitting Monthly SWTR Monitoring Reports, including CT
If Yes, Are they the State Formatted Reports? ^ Yes ^ No(D)
Is the Water System Submitting Quarterly TOC Monitoring Reports?: ^ Yes ^ No(D)
If Yes, Are they the State Formatted Reports? ^ Yes ^ No(D)
Is the Water System Monitoring for DBP?: ^ Yes ^ No(D) X N/A
Yes
Does the Water System have a DBP Monitoring Plan on File?: ^ Yes ^ No(D) X N/A
Notes:
Ground water system, one well, not chlorinated.
Reviewer: Dan Cikuth Date: 10/23/13
Page X39
Last Updated:8/5/2013
Local Primacy Agency Annual Evaluation
County of Butte
Fiscal Year 2012-2013
APPENDIX L: WATER SYSTEMS EXCEEDING A PRIMARY MCL(S) AND
PROVIDING TREATMENT (SURFACE WATER OR GWUDI
NOT INCLUDED)
PYILS ~
Number ~
SYStem Name PVIIS
*;
Classification `
MCL(s) Exceeding Treatment `Type
Provided
0400060 Honcut Elementary P Nitrate POU / RO
School
*C=Community, P=Non-transient Non-community, or N=Transient Non-community
Form Revised 8/28/2013 Page 40 of 40