HomeMy WebLinkAboutMisc Correspondence 125 Maxim Road, Hart STATE OF CONNECTICUT
DEPARTMENT OF PUBLIC HEALTH
fir
p' DannelP.Malloy
Jewel Mullen,M.D.,M.P.H.,M.P.A. i Governor
Commissioner ' ,`� ; Nancy Wyman
Lt.Governor
March 28,2013
Ms. Susan Negrelli
The MDC
1420 Farmington Avenue
West Hartford,CT 06107
PUBLIC WATER SYSTEM: Metropolitan District Commission
Hartford,CT
CLASSIFICATION TYPE: Community
PWSID: CT0640011
SUBJECT: SATISFACTORY RESPONSE TO SANITARY SURVEY REPORT
Dear Ms.Negrelli:
Thank you for your recent response to the sanitary survey report issued on December 28,2012 and for
attending a meeting at our office on February 20,2013 regarding your response. This letter serves as an
acknowledgement that your response was received on January 25,2013.
The following regulatory violations have been satisfactorily addressed;however additional information is
needed for some items noted below.
1. Sanitary survey report violations#1,#2,-RCSA Section 19-13-B102(f)(5XA):
• In addition to the proposed upgrades to the access covers,hatches,vents,and monitoring
ports,please verify that the project will also include repairs to leaks,failed repairs of cracks
and expansion joints,and installation of a membrane liner over each 5 million gallon basin as
identified in the tank inspection report.
• Please provide a more definitive timeline for the corrective action plan for proposed repairs to
each 5 million gallon finished water basin.
2. Sanitary survey report violation#4-RCSA Section 19-13-B38a(b):
• Air gaps have been established for the analyzer waste drains. This violation has been
resolved.
3. Sanitary survey report violations#5,46,-RCSA Section 19-13-B 102(f)(5)(A):
a. Please provide a more definitive timeline for the corrective action plan for proposed repairs to
the 6 million gallon(MG)and 9 MG finished water basins. The corrective action plans must
address all sanitary and structural deficiencies identified in the 8/3/12 Underwater
Construction Corporation(UCC)and Acuren tank inspection reports of the 9MG finished
water basin and the 9/25/12 UCC and Acuren tank inspection reports of the 6MG finished
water basin.Please submit a schedule with tentative dates for short and long term
Phone:(860)509-7333 •Fax:(860)509-7359-VP:(860)899-1611
DPH 410 Capitol Avenue,MS#51WAT,P.O.Box 340308
J0 t) Hartford,Connecticut 061.34-0308
www.et.gov/dph
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Ms.Susan Negrelli
Satisfactory Response to Sanitary Survey Report
CT0640011
March 28,2013
Page 2
improvements to each of the finished water basins. Please also propose a water quality
monitoring plan that will establish baseline water quality conditions and potential impacts to
changes in water quality within the finished water basins resulting from water seepage into the
tanks through the 2-inch column holes and/or leaking roof joints. Water quality parameters
included in the monitoring plan can include,but are not limited to chlorine residual,pH,
turbidity and total coliform.
4. Sanitary survey report violation 48-RCSA Section 19-13-B 102(f)(5XA):
• The overflow screen at the Kilkenny tanks has been repaired. This violation has been
resolved.
5. Sanitary survey report violation 49-RCSA Section 19-13-B102(f)(5xA):
• Please provide a more definitive timeline for the corrective action plan for proposed repairs to
the Wickham Hill storage basins.
The following regulatory requirements have been satisfactorily addressed;however additional
information is needed for some items noted below.
2. Sanitary survey requirement#1:MDC has provided DPH with the requested IFE and CFE
turbidity readings for the Reservoir 6 Water Treatment Plant. This requirement has been fulfilled.
3. Sanitary survey requirement#2:During our meeting there was additional discussion on our
position for allowing the physical piping connection between the raw water piping and finished
water piping to remain in place. Our office requests that the MDC provide additional information
on the following;
• The proposal prepared by Wright Pierce on behalf of the MDC indicates a low level water
monitor will be installed in the base of the 54-inch raw water by-pass piping downstream of
the two closed valves. The water level monitor will be tied into the R6WTP SCADA system
and alert the water treatment plant operator of flows above two inches of water in the bypass
pipe which is equivalent to less than 300 gpm. Please provide our office with the water level
and equivalent flow that would warrant additional actions to be taken by the MDC. Please
provide details on what actions would be taken to stop the raw water flow to permanently
prevent it from occurring in the event one or both of the closed valves fail.
4. Sanitary survey requirement#3: Please provide a more definitive timeline for the corrective
action plan for elimination of the cross connection between the 30-inch raw water piping
connection to a 42-inch distribution pipe on Fern Street in West Hartford.
5. Sanitary survey requirement#4: The sanitary survey report response provided details on the
length of piping and difference in elevations between the raw water by-pass drain piping and the
finished water basin overflow piping. Our office acknowledges that the flap valve and screen on
the discharge side of the finished water basin overflow and the bulkhead hatch at the plant bypass
overflow manhole do not have large enough holes to allow vermin to enter. The existing
manhole cover,for the manhole at the junction of the raw water bypass drain and finished water
basin overflow,is designed to allow for a pry bar to get under the cover to remove it;therefore
this presents an access point for vermin to potentially get into the finished water basin overflow
piping. As discussed at the 2/20/13 meeting,please proceed with installing a watertight manhole
cover and notify our office when the installation is complete.
6. Sanitary survey requirement#5: The MDC has provided the Department with tank inspection
reports for the tanks listed below. Our office acknowledges the recommendations provided in the
Ms. Susan Negrelli
Satisfactory Response to Sanitary Survey Report
CT0640011
March 28,2013
Page 3
tank inspection reports and recommends the MDC to complete upgrades to the tanks consistent
with the DPH Storage Tank Design and Construction Guidelines. The MDC must submit a
project application to our office for review and approval should any of the tank upgrade projects
include the installation of any painting system or equipment that comes into contact with water
inside the tanks. A corrective action plan to address any additional regulatory violations listed
below that were identified through review of the respective tank inspection must be submitted to
the Department.
a. Kilkenny Rocks Storage Tank 1—no violations identified through review of tank inspection
report.
b. Kilkenny Rocks Storage Tank 2—no violations identified through review of tank inspection
report.
c. Vexation Hill Storage Tank 1-Regulatory violation:RCSA Section 19-13-B102(f)(SXA): The
tank inspection report identified a gap between the air vent cap and screen that could allow the
entrance of insects,birds and other foreign matter into the tank.
d. Vexation Hill Storage Tank 2-Regulatory violation:RCSA Section 19-13-B102(f)(5)(A):
The tank inspection report identified 4 missing threaded rigging plugs where daylight could be
seen from the inside of the tank. The 4 holes through the tank roof can allow for the entrance
of precipitation,insects,birds and other foreign matter into the tank.
e. Vexation Hill Storage Tank 3—Regulatory requirement: RCSA Section 19-13-B 1 02(f)(5)(A):
The tank inspection report states that the air vent is intact and in good condition;however
pictures of the air vent screening were not included in the tank inspection report. The air vent
screening could not be closely inspected due to the lack of adequate OSHA safety equipment
on the tank. The air vent must be constructed to prevent the entrance of insects,birds and
other foreign matter into the tank and should be made accessible for inspection to verify the air
vent screens are intact.
f. Vexation Hill Storage Tank 4—Regulatory requirement: RCSA Section 19-13-B102(f)(5xA):
The tank inspection report states that the air vent is intact and in good condition;however
pictures of the air vent screening were not included in the tank inspection report. The air vent
screening could not be closely inspected due to the lack of adequate OSHA safety equipment
on the tank. The air vent must be constructed to prevent the entrance of insects,birds and
other foreign matter into the tank and should be made accessible for inspection to verify the air
vent screens are intact.
g. Newington Standpipe: On March 21,2013,the MDC began draining the Newington standpipe
to initiate repairs to the tank approved in DPH project 2010-0283.
h. Paxton Way Storage Tank—no violations identified through review of tank inspection report.
i. Eastbury Storage Basin--no violations identified through review of tank inspection report.
j. Reservoir 6 WTP backwash water tank#1 —This is an unfinished water tank therefore RCSA
Section 19-13-B IO2(f)(5)(A)is not applicable;however it is strongly recommended that the
corrosion and holes in the air vent collar and screening be repaired to prevent the entrance of
insects,birds and other foreign matter into the tank.
k. Reservoir 6 WTP backwash water tank#2-This is an unfinished water tank therefore RCSA
Section 19-13-B102(f)(5)(A)is not applicable;however it is strongly recommended that the
gaps between the air vent screening and collar be repaired to prevent the entrance of insects,
birds and other foreign matter into the tank.
1. Reservoir 6 WTP finished water basins 1 &2—The deficiencies and corrective action plan for
these tanks are addressed in the response to sanitary survey violation#1.
in.Day Hill Standpipe—Regulatory violation:RCSA Section 19-13-B 102(f)(5)(A): The tank
inspection report identified a hole in the center of the air vent cap and that the coarse screening
Ms. Susan Negrelli
Satisfactory Response to Sanitary Survey Report -
CT0640011
March 28,2013
Page 4
to the air vent is loose due to deteriorated fastener bolts. Additionally the overflow piping is
not adequately protected.
n. Cedar Mountain North and South Basins—no violations identified through review of tank
inspection report.
o. Wickham Hill Upper and Lower Basins-The deficiencies and corrective action plan for these
tanks are addressed in the response to sanitary survey violation#9.
p. West Hartford WTP 6MG and 9MG Finished Water Basins—The MDC has proposed a
corrective action plan for these tanks in the response to sanitary survey violations#5,#6,&
P.
q. Rocky Hill Standpipe—Repairs were recently completed on this tank through DPH project
2010-0283. The tank inspection report reviewed documents the condition of the tank prior to
completion of this project.
r. Canal Road Tank#1—Repairs to this tank were completed through DPH project 2010-0006.
The tank inspection report reviewed documents the condition of the tank prior to completion
of this project.
7. Sanitary survey requirement#6: The improvements to the Rocky Hill standpipe through DPH
project 2010-0283 have been completed. Work has begun on the improvements to the Newington
standpipe.
8. Sanitary survey requirement#7: The MDC provided our office with a copy of their Valve
Maintenance Procedures for the 49,000 valves in the distribution system. Our office would like
to remind the MDC that the regulatory requirement to maintain essential valves in operating
condition also applies to the essential valves within the water treatment plants.
9. Sanitary survey requirement#8: The MDC has provided documentation that the exposed voids in
the air vents to the Wickham Hill Tank have been sealed.
We appreciate your efforts in working with us to bring your water system into regulatory compliance. If
you have any questions regarding this matter,please contact me at(860)509-7333.
Sincerely,
V
R an Tetreault
Sanitary Engineer 3
.�JDrinking Water Section
`�I'C/rjt
cc: Directors of Health-Towns supplied by the MDC
Mr.Raymond E.Baral,Jr,Certified Operator
Ms.Beth Nesteriak,Certified Operator