Checklist for Developing a Corrective Action Plan under the NJDEP Ground Water Rule. (DRAFT September 15, 2015 DRAFT)
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1 Checklist for Developing a Corrective Action Plan under the NJDEP Ground Water Rule (DRAFT September 15, 2015 DRAFT) Water System and Well Information Company Name Contact Name Company Mailing Address Phone Location Address of Water System DEP Water System Name and PWSID number Date of NJDEP Safe Drinking Water letter to water system Name of well per Bureau of Safe Drinking Water letter NJDEP Well permit number (request well search if not known) Is there a well record? County: Block: Municipality: Lot: Timeline for Developing and Completing a Corrective Action Plan Date of E. Coli Notification listed on the NJDEP GWR CA letter Stated due date for client to submit Corrective Action Plan due to NJDEP (see 30 day date provided in NJDEP letter) Due Date for Corrective Action Plan to Client Stated Due for completion of Corrective Action Plan (120 date listed in NJDEP letter) Was Time extension filed with NJ DEP? Y or N Submit a well search questionnaire to the Bureau of Water Allocation and Well Permitting at Wellpermitting@dep.nj.gov If yes, new completion date: Date Submitted
2 Checklist for Evaluating a Public Water System under the NJ Ground Water Rule Use this checklist as a guide to insure a comprehensive evaluation of the sources of bacterial contamination in addition to the water well and system. NOTE: Take photos of the well and work done throughout the process including any sampling taps or temporary connections. Also sketch or photo any potential sources of contamination located nearby. Step One: Evaluate the current well and system to determine if the sources of bacterial contamination can be addressed or if a new source is required to provide bacteria free water supply. Well Construction: Age of the well? (estimate if not known) Does the well construction match the well record? Diameter of well? Describe the casing material, length and condition. Well head Inspection: Is the well head buried, raised, flush mounted or in a pit? Note the location and condition of the well head and casing. Describe the type of cap and integrity. Note any damage. Is it prone to flooding or runoff? Debris near wellhead? Nearby storage of materials such as trash, salt, oil, pesticides or hazardous materials? Is there an above ground or underground storage tank nearby? If so, what is in it? Is the well head exposed to weather or is it sheltered? Is the well near a water body or detention basin? Proximity of well to sources of bacterial contamination: (considering drawing on a map or measuring) Sewer or septic system or septic holding tank? Is there a history of problems with the waste disposal system? Nearby sewers or drains? Ditches? Proximity to parking lot or heavily used areas? Is there an abandoned well nearby?
3 Inspection of Pitless Adapter: Type of pitless adapter Is the seal leaking or any breakage noted? Do water lines run directly to the building or connect to other wells? Are voids present or evidence of water leaking down annular space around casing? Pump: Make and model of pump (if pulled or known) Note approximate age and condition of pump Submersible or jet? Recent repair history? Inspection of the well interior: Were any actions taken to clear or prepare the casing for a downhole inspection? Was a video taken? Measured length of casing, if taken Describe condition of casing and screens Static water level? Are the screens clear? Describe depths of fractures/voids encountered Note presence and depth of obstructions Disinfection: Note: Disinfection procedures for community water systems must follow the AWWA procedures in accordance with NJDEP Safe Drinking Water Rules N.J.A.C (d). Noncommunity water systems must be disinfected by following the Safe Drinking Water Rules at N.J.A.C. 7: or by using the AWWA procedures referenced above. Water quality samples are encouraged only after determining there is no chlorine residual. Disinfection procedures may be repeated provided this is completed within the deadline for the corrective action plan. These samples are NOT for compliance with the GWR & should be labeled as special purpose samples by the NJ state certified lab doing the analysis. Was the well and water system disinfected as part of the evaluation? Y or N Method used? Describe the disinfection solution (concentration of chlorine, for example) How long did the disinfectant rest in the well? How long did the disinfectant rest in the water system lines? Date(s) of Disinfection & Method used: Were post disinfection water quality samples analyzed (i.e. special purpose samples)? Outcome?
4 Water System Evaluation: What is the condition of the water supply lines/laterals from the well(s) to the building? Does well connection run directly into the building or treatment facility? Any leakage observed? Describe condition and location of the raw water sample tap(s). Is the raw water tap installed properly and at a safe height? (no tubing should be left attached as a sampling convenience.) Are there protective check valves to protect tap from water storage tank and movement of water? Is there a backflow prevention system (i.e. check valves)? What is it for? Properly installed and effective? What is the condition of the storage tank? Step Two: Summary of Well Evaluation Note the condition of the well(s) and water system when you first inspected the system. It is important to list things you noted that are in good condition as well as what appears to be a problem (refer to the check list in Step One). Your summary can be brief or even just a list of items that were checked and found to be in good working order. Simple corrective actions already taken can be noted. (For example, cracked well cap replaced with list type and make or installed a new raw water tap before the water storage tank.) Essentially, this summary should describe whether or not the well can be put back into service after the appropriate repairs, maintenance, and disinfection. If the recommendation is to install a new well, be sure to describe how the new well would address the unresolvable problems of the current well. For example, the casing is disintegrated or inadequate to protect the well from intercepting water table runoff, etc. In the event that the current well and water system are in good condition, no repairs are needed and thorough disinfection of the well and water system is not sufficient to eliminate the bacterial problem; it may be the ground water source (aquifer) supplying the well is contaminated and no other aquifer is available. In those situations, the installation of disinfection treatment capable of 4 log removal of viruses may be required. Step Three: Development of Corrective Action Plan Describe what actions were taken to evaluate the well and the water system and what remains to be done. (The water system owner will need to provide this to the NJDEP Bureau of Water System Engineering as part of their response within the 30 day deadline.) Repairs or improvements described in Step 2 do not need to be listed again.
5 Provide a list of what actions will be taken to correct the problems or deficiencies noted during the evaluation of the well and water system. You may include statements such as if this is noted, then that will be done It is important that the corrective action plan include any part of the water system that may potentially need to repaired, altered or replaced. In other words, it must be a comprehensive plan which addresses both identified and yet to be encountered problems. Be sure to include a timeframe to accomplish the needed repairs or other actions. Ask for an extension, if you think additional time may be needed in order to resolve complicated issues or to determine the best solution if there are indications that unusual conditions exist at the site, a series of repairs that will require coordination with the owner s business operations or shipment of materials, or purchase of special equipment. Time extension requests are carefully considered by the Bureau of Water System Engineering and not routinely granted unless there is good reason. Remember to communicate with your client regarding what actions will require them to close down their operation and the arrangements to install a temporary potable source of water if necessary. This guide was developed by the well permitting staff and is subject to revision over time. For questions regarding the content or to make suggestions to improve its usefulness, contact the Bureau of Water Allocation and Well Permitting in NJ Department of Environmental Protection. Wellpermitting@dep.nj.gov or call during business hours.
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