349 DEP Report 4-2-19 MassDEP Commonwealth of Massachusetts
Executive Office of Energy &Environmental Affairs
Department of Environmental Protection
Western Regional Office•436 Dwight Street, Springfield MA 01103.413-784-1100
Charles D.Baker Matthew A.Beaton
Governor Secretary
Karyn E.Polito Martin Suuberg
Lieutenant Governor Commissioner
April 2, 2019
Mr.Mark Ailinger
Linda Manor Nursing Home
349 Haydenville Rd,Leeds,MA 01053
Linda Manor,LLC
C/O Calvin W.Annino,Jr.
Annino,Draper&Moore,P.C.
1500 Main St.,Springfield,MA 01115
Re: Northampton-DWP
Linda Manor Nursing Home
PWS 1D#: 1214001
Sanitary Survey
Dear Mr.Ailinger and Mr.Annino,
On March 7,2019,Hem Pokharel of the Massachusetts Department of Environmental Protection
(MassDEP),Drinking Water Program(DWP)conducted a Sanitary Survey of the Linda Manor Nursing
Home("Linda Manor")public water system. A sanitary survey is an on-site review of the water sources,
facilities,equipment,operation and maintenance of a public water system for the purpose of evaluating the
system's ability to produce and distribute safe drinking water. The enclosed report includes the system
description,findings and compliance plan.
During the course of the survey,MassDEP identified areas in which improvements in the administration,and
operation and maintenance of the system could be made. MassDEP's evaluation of the water system,and the
specific required and recommended actions,were discussed during a debriefing meeting with Jeffrey
Hildreth,Joe Friedrichs and Hem Pokharel. This report contains time sensitive requirements,which are
summarized in the Compliance Plan Tables. Please review the items noted in the report and Compliance
Plan Tables A and B,and return the signature page to MassDEP by May 2,2019. Specifically,MassDEP
• requires the following actions to remedy items noted in the inspection:
An assessment of this public water system's capacity was conducted by MassDEP for the last sanitary
survey report,dated December 19,2016. There have been changes in the administration or management
of the system since that survey. Therefore,MassDEP has determined that this system demonstrates
Conditional Capacity.
Electronic File Location:TADWP Archive\%VERO\Northampton-1214001-SS-2019-O4-r12
The signature on this cover letter Indicates formal issuance of the attached document.
This Information Is available In alternate format.Call the MassDEP Diversity Office at 811.558-1139.TM/MassRelay Service 1-800-439-2370
MassDEP Website:www.massgov/dep
Printed on Recycled Paper
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 PAGE 2 OF 4
Based on the file review,Linda Manor replaces the well pump every 2 years as a maintenance protocol
due to water emergencies experienced in 2008 and 2010. Since MassDEP was not able to review a copy
of the Operation and Maintenance(0&M)plan with the pump change information during the
inspection,MassDEP requires Linda Manor to provide the last pump replacement date if any by
May 2,2019.
During the file review,MassDEP noted a consistent increase in the annual water use based on Annual
Statistical Report(ASR).The water use has increased every year.The water usage has increased 22%in
the years 2014(4.2 MG)to 2017(5.1 MG).Provide an explanation to MassDEP about the consistent
increase in the water usage at Linda Manor by May 2,2019.
During the MassDEP inspection,the new operator who had joined the PWS as a contract operator in 2018
did not seem to have familiarized himself with the Linda Manor PWS very well. He was not able to
present or explain critical operational elements like the Emergency Response Plan(ERP),Operations and
Maintenance(0&NI)plan,0&M logs, location of hydropneumatic tank etc. The inspector left two
copies of the 2016 sanitary survey at Linda Manor for the operator to review and better understand the
Linda Manor PWS.MassDEP requires that the Operator at Linda Manor fully understand the
Linda Manor PWS.Notify MassDEP that the Operator has completed the task and provide
MassDEP with a copy of the ERP,the 0&M plan,and the 0&M logs before May 2,2019.
MassDEP has not received Linda Manor's Certification of Lead and Copper Consumer Notification, and
90th Percentile Report for its 2018 sampling. The consumer notification was required within 30 days of
your receipt of the analytical results. MassDEP requires Linda Manor to notify the consumers of the
lead and copper results,using the appropriate form,and send a copy of Certification of Lead and
Copper Consumer Notification and 90th Percentile Report for its 2018 sampling to MassDEP.This
is a federal violation and it is addressed in a separate correspondence.
During the MassDEP inspection,the operator was not able to locate the raw water tap due to snow
accumulation. MassDEP requires Linda Manor to locate the raw water tap and send a visual
confirmation of the location to MassDEP by May 2,2019.Also send a copy of the ERP plan and the
0 &M plan that includes how the raw water would be collected in case of emergency,including
emergencies during winter months.
A diagram for the external distribution system outside is shown in figure 1.According to the Operator,this
PWS has since been updated with separate water meters for each source which are not indicated in the
diagram.MassDEP requires Linda Manor to send an updated schematic diagram of Linda Manor
PWS by May 02,2019.
During the MassDEP inspection,the inspector noted the presence of threaded sample taps.With the
threaded sampling tap,the chances of contamination increases during sampling. MassDEP requires that
Linda Manor install smooth nosed raw water sampling taps by May 2,2019.
Maintain the general housekeeping around the pump house.Clutter like empty jars,and unwanted tanks
and buckets in the pump house invite rodents and other disease carrying animals.Keep the pump house
clean; remove unwanted wastes away from the pump house.The operator has provided a verbal
confirmation to the inspector that the pump house has been cleaned after the survey.Provide a
written notice that this task has been accomplished before May 2,2019.
During the MassDEP inspection,the inspector noted that the operator left a portion of the"Certified
Operator Inspection Form and Check List-Contract Operation"blank. MassDEP requires Linda
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 PAGE 3 OF 4
Manor to make sure that the PWS is inspected every month and the"Certified Operator Inspection
Form and Check List-Contract Operation" form is completely filled by May 2,2019.
During the MassDEP inspection,the inspector noticed mixing valves and aerators in the repeat sampling
taps.MassDEP does not permit sampling taps with mixing valves. MassDEP requires Linda Manor to
remove mixing valves from all potential sampling locations before May 2,2019.MassDEP also
reminds Linda Manor that the filters and aerators have to be taken out when sampling for water.
During the MassDEP inspection,the Operator was not able to present the Consumer Confidence Report
(CCR)for a review. MassDEP requires Linda Manor to submit a copy of the 2017 CCR by May 2,
2019.
During the inspection,the flow meter calibration information was not available on site.MassDEP
requires Linda Manor to calibrate the flow meter and notify MassDEP that the calibration is up to
date by May 2,2019.If a new flow meter is recently installed,provide the flow meter installation
date.The flow meter calibration record was one of the 2016 Sanitary Survey requirements,this is a
violation and it is addressed in a separate correspondence.
During the 2016 MassDEP inspection,the Operator was not able to locate the most recent Emergency
Response Plan(ERP).The ERP was one of the 2016 Sanitary Survey requirements,this is a violation.
The operator at Linda Manor submitted a scanned section of ERP via email,after the survey.MassDEP
requires Linda Manor to submit an updated complete ERP by May 2,2019.Since it is likely that
Linda Manor will connect to City water during emergencies as an alternative to trucking in water,
MassDEP recommends that it be included in the Emergency Plan.The updated ERP was one of the
2016 Sanitary Survey requirements,this is a violation and it is addressed in a separate
correspondence.
During the MassDEP inspection,the inspector noted a heating system, ice machines and dishwashers at
Linda Manor.The facility manager at Linda Manor also informed the inspector of the presence of
Laundry services.The manager and the operator were not able to provide information on the backflow
prevention devices.At the time of inspection,Linda Manor was also not able to provide the cross
connection survey report for a review. During the file review,the inspector was able to find a reference to
a cross connection survey report of 2013 in the 2017 sanitary survey report but the inspector was not able
to locate the actual cross connection survey report. Since it has been six years after the referenced
cross connection survey and the water usage has increased by 22% and the operator lacked the
knowledge of cross connection devices.MassDEP requires Linda Manor to conduct a full cross
connection survey and provide a copy of a completed cross connection survey report by August 2,
2019.
Linda Manor is hereby notified that the well(s)with nonconforming activities noted in Table 03 are in
nonconformance with the MassDEP's requirement(310 CMR 22.21(1)(b)(5))that Zone I activities be
limited to those directly related to the provision of public water or will have no significant adverse impact
on water quality(as specified in Policy 94-03A). To the extent possible, efforts should be made to reduce
or eliminate the impacts of non-conforming uses within the Zone I. Pursuant to 310 CMR 22.04(1) and
22.21(a),Linda Manor must notify MassDEP if it plans to modify,increase water use,or expand its
source or to replace any wells. At the time of such notification of a proposed modification,
expansion,or replacement,MassDEP may require Linda Manor to comply with the Zone I
requirement that all Zone I activities be limited to those directly related to water supply or will
have no significant impact on water quality.
LINDA MANOR NURSING HOME PWS 1Dt#: 1214001
INSPECTION DATE:MARCH 7,2019 PAGE 4 OP 4
Questions regarding this document,or other drinking water issues,should be directed to Hem Pokharel at
413-755-2271.
Respectfully,
Deirdre Doherty, C ief
Drinking Water Program
Bureau of Water Resources
Attachments: Sanitary Survey Report,Coliform Sampling Plan
cc: Board of Health—Northampton,Boston—DWP,Hem Pokharel(eCopy),MassDEP WERO,&Jeffrey Hildreth
WERO File W:\BWR\WS\CCE-SS\Northampton\1214001 -Linda Manor Nursing Home\LMNH-HP-SS-2019.docx
SANITARY SURVEY REPORT
Linda Manor Nursing Home
April 2, 2019
GENERAL DESCRIPTION
The description of the water system is updated from that reported within MassDEP's December 19,2016
sanitary survey report.
General:
Constructed in 1989,Linda Manor Extended Care Facility is a 123 bed skilled nursing facility located on
State Route 9(Haydenville Road)in Leeds,MA. The facility is owned by Linda Manor LLC and leased to
Berkshire Health Care Systems Inc.of Pittsfield,MA who is the responsible party for the upkeep and
maintenance.
Linda Manor provides skilled nursing for short term rehabilitation,long term care hospice care and respite
care. Although the facility operates its own PWS,it is connected to the Northampton Sewer System.
Berkshire Health Care Systems Inc.also leases and operates the adjacent Assisted Living Facility the adjacent
lot to the southwest. Completed in 2015,the Assisted Living Facility provides 88 beds in studio,one
bedroom and two bedroom apartments. This facility is connected to the City of Northampton PWS as well as
the Northampton Sewer System.
Both facilities are connected to the Fire Suppression System which is located between the two buildings
Source:
Linda Manor Extended Care Facility is supplied by two(2)six inch diameter bedrock wells located in a field,
situated approximately 200 feet southeast of the facility.
Well l:
The southernmost source,construction on Well OIG was completed on July 21, 1988 by the Kirk R Henshaw
Well Drilling Company of Chesterfield MA. The 6-inch well is 300-feet deep with 164-feet of casing set 10-
feet into competant bedrock(noted at 155 feet). Water bearing features were noted by the driller from 190 to
195 feet and 275 to 278 feet. The top 6-feet of the casing is provided a sanitary seal of cement grout. The
depth of the seal was determined based on the fact that the surrounding geology consists of hardpacked dry
glacial till.
A 48-hour pump test was completed on the source from July 27 to July 29, 1988 at a rate of 15-gallons per
minute.Withdrawal rate was established at 10.4 gallons per minute.
The source is equipped with a 1-horsepower pump set at 270-feet. Due to water emergencies experienced in
2008 and 2010,Lind Manor replaces the well pump every 2 years as a maintenance protocol.
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 2
MassDEP approved the source based on the referenced pump test for 10.4 gallons per minute(14,976 gallons
per day)in a December 22, 1988 letter.
Well 2:
Well 02G is located approximately 25-feet north of Well 01 G. It was installed as a mechanical back up to
Well OIG and to supplement Well OIG to meet the water system design rate of 13.8 gallons per minute.
Construction on Well 02G was completed on January 18, 1989 by the Kirk R Henshaw Well Drilling
Company of Chesterfield MA. The 6-inch well is 280-feet deep with 164-feet of well casing set 8-feet into
competant bedrock(observed at 156-feet). Water bearing features were noted by the driller from I56-feet to
206-feet. Similar to Well 01G,Well 020 is also equipped with a 6-foot deep sanitary seal.
After construction,a 48-hour pump test was completed on the source from August 14 to August 16, 1989.
The well was pump tested at 12 gallons per minute. The source is equipped with a 1 horsepower pump set at
250-feet. After completion of the pump test,MassDEP approved the source for 9.0 gallons per minute
(12,960 gallons per day)in a May 2, 1990 letter. Due to water emergencies experienced in 2008 and 2010,
Lind Manor replaces the well pump every 2 years as a maintenance protocol.
Although Well#2 was originally designed to be a backup source of Well#1,both wells currently operate in
lead/lag mode. There is a single 3-inch meter located in the boiler room of the facility that records facility
demand out of the storage tanks on the discharge line from the booster pumps. The meter is owned and
maintained by the City of Northampton Water Department and is used to bill Linda Manor for wastewater
(the facility is connected to the Northampton wastewater collection system).
A non-potable well is located on the south side of the driveway and is used as a fire protection well. Initially
this source was to be used as the primary well but could not meet MassDEP's new source approval criteria.
When Linda Manor was informed of this action,it was relegated to fire protection status. The 6-inch bedrock
well was constructed by Cummings Well Drilling of West Boylston,MA on April 1, 1988. The source is
470-feet deep with 175-feet of casing set 19-feet into competant bedrock(observed at 156-feet). There is no
connection between the the system and the potable system.
Storage:
Potable Water Storage:
Storage for the Linda Manor Extended Care Facility consists of two underground fiberglass storage tanks
located east of the math building,approximately 80 feet from both Well OIG and 02G. Installed in 1988 with
the construction of the facility each tank has a capacity of 8,000 gallons.Tanks at Linda Manor do not have
tank alarms.Both tanks have overflow,and they are fitted with a screen.
There is also a single Well-X-Trol WX350 120-gallon hydropneumatic storage tank in the boiler room off the
northern wing of the building that pressurizes the distribution system.
Fire Storage Tanks:
The fire storage tanks are located at the south end of the building adjacent to the fire protection building.
Each of the three tanks has a capacity of 40,000 gallons. The fire system,which is separate from the potable
system,is charged by a diesel driven pump located in the Fire protection building.
LINDA MANOR NURSING HOME PWS IDR: 1214001
INSPECTION DATE:MARCH 7,2019 Page 3
Distribution:
A diagram for the external distribution system outside is shown in figure 1. This figure has since been
updated with separate water meters for each source which are not indicated in the diagram.
Wells OIG and 02G currently operate in a lead/lag sequence and flow to the two underground 8,000 gallon
storage tanks. After water emergencies in 2008 and 2010,in 2011 individual motor starters were installed on
both wells pumps and an alarm system was installed on the atmospheric tanks to notify staff if the water
levels in the tanks dropped to 1/2-capacity.
Each well has a separate I-IDPE 1 1/2-inch discharge line which flows first to a sample pit which contains the
raw water sample taps. The taps are raised to just below the manhole cover and a wrench is used when
operating the valves for the taps. From the Sample tap manholes,the water lines from well O1G and 02G
form a single 2-inch HDPE line and flow to a three way valve chamber for the atmospheric storage tanks.
The valve pit allows the atmospheric tanks to be isolated for maintenance and repair. From the three way
valve chamber water enters one of the two 8,000 gallon storage tanks. Both outlets from the atmospheric
tanks join a single 4-inch water line that supplies the booster pump skid in the boiler room.
The Booster pump skid contains three pumps which pressurize the hydropnuematic tank and the distribution
system. A pressure sensor at the hydropnuematic tank controls the pumps(lead/lag and standby). The
pumps are all VFD controlled and ramp up and down as pressure in the system dictates. A single 3-inch
copper water line supplies the distribution system taps. A 3-inch water meter installed on the water line is
owned and maintained by the Northampton Water Department. It is used to bill the facility for wastewater
disposal.
Treatment:
Currently neither Well O1G nor 02G have treatment.
LINDA MANOR NURSING HOME PWS111/4: 1214001
INSPECTION DATE:MARCH 7,2019 Page 4
.11 t ,
•
It
---\I
1 .
O
1
1 ut14-1 __•
I I
I \ , , .. eld
J
4zusilkfoh --viral A WE.Rex
�,7.
. xmER 4,,
/ veerw"3 W+y M,,6r Sr 5flekiC&" 14(2)
•
`i
vcp?t5tnetelip
//z
Figure]: Sketch of Linda Manor PWS from the past survey
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page yS
I
•iaistv. 444i11
G 4-0
411
ANSE
•
Hydropneumatic tank Pump controller Booster pumps
1
Water Flow meter Wells
M /
/
P
•
41
vJ
.,, 1:
Well flow meter Tanks
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 6
SANITARY SURVEY REPORT
Linda Manor Nursing Home
April 2, 2019
FINDINGS
SECTION 1: ADMINISTRATION,MANAGEMENT,AND STAFFING
An assessment of this public water system's capacity was conducted by MassDEP for the last sanitary
survey report, dated December 19,2016. There have been changes in the administration or management
of the system since that survey. Therefore, MassDEP has determined that this system demonstrates
Conditional Capacity.
System Classification:
Linda Manor is classified as a Community(COM)public water system(PWS)because the facility
regularly serves at least 25 year-round residents.
MassDEP has reviewed the classification status of the Linda Manor distribution system and has
determined that the distribution system should be rated as a Class VSS system because it serves a
population of 120 residents.
Maintain the general housekeeping around the pump house. Clutter like empty jars,and unwanted tanks
and buckets in the pump house invite rodents and other disease carrying animals.Keep the pump house
clean; remove unwanted wastes away from the pump house.The operator has provided a verbal
confirmation to the inspector that the pump house has been cleaned after the survey.Provide a
written notice that this task has been accomplished before May 2,2019.
During the inspection,the flow meter calibration information was not available on site. MassDEP
requires Linda Manor to calibrate the flow meter and notify MassDEP that the calibration is up to
date by May 2,2019.If a new flow meter is recently installed,provide the flow meter installation
date.The flow meter calibration record was one of the 2016 Sanitary Survey requirements,this is a
violation and it is addressed in a separate correspondence.
Table 01 lists the personnel employed by Linda Manor for the operation of its PWS.
Operator Name Grade License Primary
Distribution
Jeffery Hildreth 1T/2D 11601/11466/ X
4936 _
Table 01: Linda Manor Nursing Home Operators
Linda Manor can meet MassDEP's Certified Operator requirements.MassDEP will address the
need for a follow-up sanitary survey to demonstrate operator knowledge.
LINDA MANOR NURSING HOME PWS 1D#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 7
The Linda Manor distribution operator operates the system for 1, 1 hour shift per month. As a Class VSS
system Linda Manor is required to support, at a minimum,the following operational staff:
310. One distribution operator serving as the primary operator who holds a Grade D2 license.
The primary operator must cover the distribution system 1 work shift per month(1 hour
per day)and must be available to respond to emergencies within one hour at all other
times.
2. Designation of a secondary distribution operator is not required for any VSS PWS,
However,MassDEP does require that Linda Manor designate a secondary distribution operator to
cover the same hours as the primary operator in his or her absence of greater than 30 days(i.e.,
during vacations,sick leave,etc.). Linda Manor must notifyMassDEP in the event that a
secondary operator is designated and operating the PWS.
Emergency Response Plan
During the 2016 MassDEP inspection,the Operator was not able to locate the most recent Emergency
Response Plan(ERP).The ERP was one of the 2016 Sanitary Survey requirements,this is a violation.
The operator at Linda Manor submitted a scanned section of ERP via email,after the survey. MassDEP
requires Linda Manor to submit an updated complete ERP by May 2,2019.Since it is likely that
Linda Manor will connect to City water during emergencies as an alternative to trucking in water,
MassDEP recommends that it be included in the Emergency Plan.The updated ERP was one of the
2016 Sanitary Survey requirements,this is a violation and it is addressed in a separate
correspondence.
Consumer Confidence Report:
All Community Water Systems must prepare an annual Consumer Confidence Report(CCR)as specified
in 310 CMR 22.16A. The CCR must be completed and delivered to consumers by July 1 of each year.
MassDEP will complete CCR reviews on a selected number of systems each year.
MassDEP has prepared Source Water Assessment Reports for all Public Water Systems. Each system
must include in the CCR Report,notification to customers of the availability of the report and the means
to obtain it.
During the MassDEP inspection,the Operator was not able to present the Consumer Confidence Report
(CCR)for a review.MassDEP requires Linda Manor to submit a copy of the 2017 CCR by May 2,
2019.
SECTION 2: OPERATIONS AND MAINTENANCE
During the MassDEP inspection,the new operator who had joined the PWS as a contract operator in 2018
did not seem to have familiarized himself with the Linda Manor PWS very well.He was not able to
present or explain critical operational elements like the Emergency Response Plan(ERP),Operations and
Maintenance(0&M)plan, 0&M logs,location of hydropneumatic tank etc.The inspector left two
copies of the 2016 sanitary survey at Linda Manor for the operator to review and better understand the
Linda Manor PWS.MassDEP requires that the Operator at Linda Manor fully understand the
Linda Manor PWS.Notify MassDEP that the Operator has completed the task and provide
MassDEP with a copy of the ERP,the 0&M plan,and the 0&M logs before May 2,2019.
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE: MARCH 7,2019 Page 8
During the MassDEP inspection,the inspector noted threaded sample taps. One threaded sampling tap
was located next to the hydropneumatic tankand other two threaded sampling taps were located in the
well pit next to the meter.The assessment on the two threaded sampling taps located in the well pit next
to the meter was based on the picture review.MassDEP requires that Linda Manor install smooth
nosed raw water sampling taps by May 2,2019.
During the MassDEP inspection,the inspector noted that the operator left a portion of the"Certified
Operator Inspection Form and Check List—Contract Operation"blank.MassDEP requires Linda
Manor to make sure that the PWS is inspected every month and the"Certified Operator Inspection
Form and Check List—Contract Operation"form is completely filled by May 2,2019.
SECTION 3: TREATMENT
Linda Manor does not treat its water.
SECTION 4: DISTRIBUTION,STORAGE,AND PUMPING FACILITIES
During the MassDEP inspection,the inspector noted a heating system, ice machines and dishwashers at
Linda Manor.The facility manager at Linda Manor also informed the inspector of the presence of
Laundry services.The manager and the operator were not able to provide information on the backflow
prevention devices.At the time of inspection, Linda Manor was also not able to provide the cross
connection survey report for a review.During the file review,the inspector was able to find a reference to
a cross connection survey report of 2013 in the 2017 sanitary survey report but the inspector was not able
to locate the actual cross connection survey report. Since it has been six years after the referenced
cross connection survey and the water usage has increased by 22%and the operator lacked the
knowledge of cross connection devices.MassDEP requires Linda Manor to conduct a full cross
connection survey and provide a copy of a completed cross connection survey report by August 2,
2019.
Based on the file review,Linda Manor replaces the well pump every 2 years as a maintenance protocol
due to water emergencies experienced in 2008 and 2010. Since MassDEP was not able to review a copy
of the Operation and Maintenance(0&M) plan with the pump change information during the
inspection,MassDEP requires Linda Manor to provide the last pump replacement date if any by
May 2,2019.
A diagram for the external distribution system outside is shown in figure 1.According to the Operator,this
PWS has since been updated with separate water meters for each source which are not indicated in the
diagram.MassDEP requires Linda Manor to send an updated schematic diagram of Linda Manor
PWS by May 02,2019.
All systems may be subject to a cross connection audit by MassDEP,to ascertain whether the water system is
in compliance with the cross connection regulations as outlined in Section 22.22(16)I of the Massachusetts
Drinking Water Regulations.
SECTION 5: WATER QUANTITY
During the file review,MassDEP noted a consistent increase in the annual water use based on Annual
Statistical Report(ASR). The water use has increased every year.The water usage has increased 22%in
the years 2014(4.2 MG)to 2017(5.1 MG).Provide an explanation to MassDEP about the consistent
increase in the water usage at Linda Manor by May 2,2019.
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE: MARCH 7,2019 Page 9
The average daily demand for Linda Manor was 13,860 gallons per day based on the 2017 Annual
Statistical Report. Annual average daily water withdrawal at Linda Manor is less than 100,000 gallons
per day. Therefore Linda Manor does not exceed the threshold requirements of the Water Management
Act and does not require a Water Withdrawal Permit at this time.
SECTION 6: WATER QUALITY MONITORING AND REPORTING
MassDEP reviewed the most recent Linda Manor Water Quality Sampling Schedule(WQSS)dated
February 23, 2017. Linda Manor is required to collect water quality samples according to that schedule.
The most current WQSS is available on-line at:
pt ://www.mass.aov/eea/anencies/massdeo/water/drinkinIIPws-documents-search-tool.htmI.
Bacteriological Monitoring Under the Revised Total Coliform Rule
During the MassDEP inspection,the operator was not able to locate the raw water tap due to snow
accumulation.MassDEP requires Linda Manor to locate the raw water tap and send a visual
confirmation of the location to MassDEP by May 2,2019.Also send a copy of the ERP plan and the
0&M plan that includes how the raw water would be collected in case of emergency,including
emergencies during winter months.
During the MassDEP inspection,the inspector noted the presence of threaded sample taps.With the
threaded sampling tap,the chances of contamination increases during sampling.MassDEP requires that
Linda Manor install smooth nosed raw water sampling taps by May 2,2019.
The required number of total routine monthly coliform samples is based primarily on population and
system characteristics. Under the Revised Total Coliform Rule, monthly routine sampling locations
representative of entry points and storage must also be provided in the Coliform Sampling Plan. If the
Linda Manor population changes such that it exceeds or falls below a threshold listed in Table I of 310
CMR 22.05 Linda Manor must contact the MassDEP regional office to update its Coliform Sampling
Plan. System characteristics such as storage,treatment facilities, source water quality, and the number of
sources also affect the total number of required coliform sampling locations. For those systems that treat
the source water,the Coliform Sampling Plan must include an additional routine monthly sample
collected from the raw water source(s)per 310 CMR 22.05(1)(a). The Coliform Sampling Plan must also
list all groundwater sources to be sampled to meet the requirements of the Groundwater Rule.
MassDEP reviewed the current Coliform Bacteria Sample Plan dated December 17,2007. The Plan was
determined to satisfy the following criteria from the regulations at 310 CMR 22.05 (1):
o Site(s)representative of the water throughout the distribution system: Main Kitchen— 1"
Floor
o Site(s)representative of raw water prior to treatment: Raw water tap Well#1 and Well#2
o Site(s)representative of treated water: N/A
o Site(s)representative of storage: Near Hydropneumatic tank
MassDEP is in the process of updating all Coliform Sampling Plans to make them compliant with the
Revised Total Coliform Rule. Changes made to these plans will be reflected in the WQSSs. MassDEP
advises Linda Manor that the Revised Total Coliform Rule was implemented on April 1,2016 (see
Section 8 for Revised Total Coliform Rule(RTCR)highlights). All Coliform Sampling Plans will
be updated to incorporate RTCR provisions and will be issued to PWSs when they are completed.
PWSs are still responsible for collecting all samples required under the RTCR,including seasonal
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 10
start-up samples(when applicable),even prior to receiving the updated Coliform Sampling Plans.
Please contact the Drinking Water Program in your regional office if you wish to update your
Coliform Sampling Plan now.
See Section 8 for Revised Total Coliform Rule(RTCR) highlights.
Chemical Monitoring
The current monitoring period for 2017-2019 represents the third period of a 9-year monitoring cycle,.
All monitoring waiver decisions have been made. Your Water Quality Sample Schedule(WQSS)for:
2017-2019 has been issued and reflects those decisions. The schedules reflect changes to the Iron and
Manganese requirements and Disinfection Byproduct monitoring that includes sampling in specific
months and particular weeks of those specific months. Some Community and Non-transient Non-
community systems that monitor disinfection by-products,e.g.,Trihalomethanes(THMs)and Haloacetic
Acids(HAA5s),during the"month of warmest water temperature"must take these samples in August.
The schedule will show"AUG"for those systems. Other systems will have specific months specified in a
given quarter(e.g.,June, September,December,etc.). The particular week of the month in which
sampling must occur is included on the schedule if required.
MassDEP has not received Linda Manor's Certification of Lead and Copper Consumer Notification, and
90th Percentile Report for its 2018 sampling. The consumer notification was required within 30 days of
your receipt of the analytical results.MassDEP requires Linda Manor to notify the consumers of the
lead and copper results, using the appropriate form,and send a copy of Certification of Lead and
Copper Consumer Notification and 901°Percentile Report for its 2018 sampling to MassDEP. This
is a federal violation and it is addressed in a separate correspondence.
Radiological Monitoring
Monitoring waivers are not considered for radiological monitoring. Monitoring frequencies for
radionuclides are pre-determined by the Standardized Monitoring Framework and have been incorporated
into the WQSS by MassDEP/DWP/WERO. These frequencies are based on either the grandfathered
results of samples collected before December 8,2003 or from results collected since that date.
MassDEP reviewed the most recent Linda Manor Water Quality Sampling Schedule(WQSS)dated
February 23, 2017. Linda Manor is required to collect water quality samples according to that schedule.
During the MassDEP inspection,the inspector noticed mixing valves and aerators in the repeat sampling
taps.MassDEP does not permit sampling taps with mixing valves. MassDEP requires Linda Manor to
remove mixing valves from all potential sampling locations before May 2,2019.MassDEP also
reminds Linda Manor that the filters and aerators have to be taken out when sampling for water.
Lead and Copper Monitoring
A review of MassDEP records indicates that Linda Manor has been approved for reduced Leadand Copper
monitoring to 5 samples every three years. Linda Manor is required to collect the next round of 5 samples
during the period between June and September of 2021.
The following tips may be useful in complying with the Lead and Copper regulations in the future:
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 11
• All samples must be collected within the required time frame. Late sample data submitted will
not be accepted.
• Once a sample bottle has been accepted by the water system and delivered to the laboratory,the
results cannot be invalidated due to sampling practices.
SECTION 7: SOURCE AND SOURCE PROTECTION
The protection of a groundwater recharge area is critical to maintaining a safe and ample supply of water
to the Linda Manor customers. Protection zones become more critical to water quality,and the activities
within the zone more restrictive,as the wellhead is approached. Zone I is the most vulnerable and
restrictive protection zone around a well. Depending upon pumping volume,a Zone I ranges from a
radius of 100 to 400 feet around the wellhead. The Regulations at 310 CMR 22.21 (3)specify that only
activities that are directly related to the water system and/or non-threatening to water quality occur within
this zone. Zone I should be owned or controlled by the water supplier. The Zone.I1 or Interim Wellhead
Protection Area(IWPA)encompasses a larger area around a wellhead. Zone Iis are established using
pumping test observations and groundwater modeling to estimate the contributing area to a groundwater
source. Table 02 lists the sources and the dimensions of their wellhead protection zones.
Suffix Source Name Wellhead Units Zone I(ft.) Method IWPA(ft.)
Protection
Rate
01G WELL#1 (NORTH) 10 galm 276 galm 733
02G WELL#2(SOUTH) 9 galm 267 Balm 688
Table 02: Wellhead Protection Zones
Linda Manor is hereby notified that the well(s)with nonconforming activities noted in Table 03 are in
nonconformance with the MassDEP's requirement(310 CMR 22.21(1)(b)(5))that Zone I activities be
limited to those directly related to the provision of public water or will have no significant adverse impact
on water quality(as specified in Policy 94-03A). To the extent possible,efforts should be made to reduce
or eliminate the impacts of non-conforming uses within the Zone 1. Pursuant to 310 CMR 22.04(1)and
22.21(a),Linda Manor must notify MassDEP if it plans to modify,increase water use,or expand its
source or to replace any wells. At the time of such notification of a proposed modification,
expansion,or replacement,MassDEP may require Linda Manor to comply with the Zone I
requirement that all Zone I activities be limited to those directly related to water supply or will
have no significant impact on Water quality. The following table lists the potential contamination
sources observed in the inspection.
PWSID Source Name Non-Conforming Activities in Activities in IWPA-Zone II
Zone I—Zone A
1214001- Well# 1 Parking, Septic System Parking, Septic System
91G Components Components,Nursing Home
1214001- Well#2 Parking, Septic System Parking, Septic System
02G Components _ Components,Nursing Home
Table 03: Nonconforming Activities within wellhead or surface water protection areas
MassDEP conducted an assessment of the system for the Source Water Assessment and Protection
Program(SWAP)and a report was sent on November 19,2003.
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 12
Linda Manor's Zone I for Well#1 (North)contains multiple activities and crosses property lines.
MassDEP requires that Linda Manor review ownership of the Zone I and identify activities within
Zone I and report the status of ownership activities to MassDEP by July 30,2019.
SECTION 8: CURRENT AND FUTURE REGULATORY REQUIREMENTS
Revised Total Coliform Rule(RTCR)Highlights
Massachusetts incorporated EPAs' Revised Total Coliform Rule(RTCR) into its revised Drinking Water
Regulations which became effective April,2016. The RTCR contains the following provisions to
increase public health protection by focusing on measures that will reduce potential pathways for the
entry to fecal contamination into public water system(PWS)distribution systems. Under the RTCR,
PWSs that are vulnerable to microbial contamination are required to conduct detailed investigations to
identify and fix problems. The RTCR establishes an MCL for E. coil, since it is a more specific indicator
of fecal contamination and a potentially more harmful pathogen than other coliform bacteria. The Total
Coliform Rule's previous MCL violation for total coliform bacteria has been replaced by a Treatment
Technique trigger that requires a Level 1 Assessment.
Sampling
The number of routine monthly samples is still population-based,but there are requirements for additional
entry point and storage samples. All routine monthly samples must be collected,even if a Treatment
Technique trigger has been exceeded or there is an E. coli MCL.
Three repeat samples are required for every total coliform positive(TC+)location;regardless of system
size and even if the TC+location is at the end of the distribution system. Additional rounds of repeats
must be collected until a treatment technique trigger is exceeded or one clean round of samples has been
obtained.
Only systems on quarterly monitoring are required to collect additional routine samples in a month
following a TC+. All other systems collect their normal number of monthly routine samples.
Seasonal Systems
Seasonal systems that are not operated as PWSs on a year-round basis and start up and shut down each
operating season,must demonstrate completion of a state-approved Start-up Procedure and Certification
prior to serving water to the public each season. The Certification must be submitted to MassDEP 7 days
prior to serving water to the public. The approved procedure must demonstrate completion of the
following activities,at a minimum:
• Notification to MassDEP and the Certified Operator of the planned date on which water will be
served to the public;
• Inspection of all water system components(i.e., sources,treatment components,distribution lines
and storage tanks)along with completion of any required repairs and maintenance;
• Activation of source(s);
• Flushing of the entire distribution system(s); and,
• Collection of seasonal start-up samples from all routine monthly locations, as well as any additional
locations required within any re-activated portions of the distribution system.
Additional start-up activities may include chlorination of the tanks and distribution system,re-installation
and maintenance of required disinfection equipment, and re-installation of water meters and backflow
preventers, if applicable.
Treatment Technique Triggers and Assessments:
LINDA MANOR NURSING HOME PWS IDN: 1214001
INSPECTION DATE:MARCH 7,2019 Page 13
PW Ss must conduct Assessments after exceeding a Treatment Technique(TT)Trigger and must notify
MassDEP no later than 5 days after the collection date of the sample that triggered the assessment.
Level 1 Treatment Technique Triggers:
• More that 5%of monthly samples are TC+for a system collecting 40 or more samples per month
(former TC MCL)—NO PUBLIC NOTICE(PN)REQUIRED;
• More than 2 TC+samples per month for systems collecting fewer than 40 samples per month(former
TC MCL)—NO PN REQUIRED; and,
• • Failure to take every required repeat sample after any single TC+sample—NO PN REQUIRED.
Level 2 Treatment Technique Triggers:
>An E. coli MCL Violation(Requires TIER 1 PN and same day notification to MassDEP):
• EC+ repeat sample following a TC+routine sample(former acute MCL);
• TC+repeat sample following an EC+routine sample(former acute MCL);
• Failure to take all required repeats following a EC+routine sample;and,
• Failure to analyze for E. coli in a TC+ repeat sample.
>A second occurrence of a level 1 Trigger within a rolling 12-month period—unless MassDEP
determines the reason for the TC+detection related to the first Level 1 Trigger and the PWS has
corrected that problem.
Level 1 and Level 2 Assessments are conducted to identify the possible presence of sanitary defects and
defects in distribution system monitoring practices. The elements of a Level 2 Assessment are generally
the same as those of a Level 1 Assessment,but each element is investigated in more detail.
At a minimum,both Level 1 and Level 2 Assessments must evaluate the following elements: atypical
events, changes in distribution system maintenance and operation, condition of the source and treatment,
and inadequacies in sample sites,sampling protocol and sample processing. Level 1 and Level 2
Assessments must describe any Sanitary Defects found,describe all completed Corrective Actions,and
propose a timetable for completing any Corrective Actions that have not been completed by the time the
Assessment Form is submitted(i.e., 30 days from the triggering event). MassDEP must be notified when
each of these Corrective Actions has been completed.
RTCR Violations and Public Notice Requirements
There are a number of new violations under the RTCR. All violations require some form of public notice.
There is also new mandatory health effects language for public notices and Consumer Confidence Reports
(CCAs). MCL,Monitoring and Treatment Technique Violations must be reported in CCRs along with
appropriate health language. CCRs must also contain information on E. coli detections and Level 1 and
Level 2 Assessments. All RTCR violations are listed below.
E. coli MCL Violations(individual types listed above) (Require TIER 1 PN within 24 hours and same
day notification to MassDEP)
Treatment Technique Violations(Require l lER 2 PN within 30 DAYS and notification to MassDEP no
later than end of next business day after learning of violation.):
• Failure to conduct a Level 1 or 2 Assessment or implement Corrective Actions within the
specified timeframe.
• Failure of a Seasonal System to complete a MassDEP-approved Start-up Procedure and
Certification prior to serving water todhe public.
Monitoring Violations(Require TIER 3 PN within 1 YEAR and notification to MassDEP within 10 days
of learning of violation):
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 14
• Failure to take every required routine or additional routine sample in a Compliance Period.
• Failure to analyze for E. coli in a TC+ routine sample.
Reporting Violations(Require TIER 3 PN within I YEAR):
• Failure to submit a monitoring report or Assessment Form by the required deadline,after
completing timely monitoring or Assessment.
• Failure to notify MassDEP of an EC+result by the end of the day on which the PWS was
notified of the result.
• Failure to notify MassDEP of an E. coli MCL violation by the end of the day on which PWS
learns of the violation.
• Failure to submit Certification of completion of a MassDEP-approved Seasonal Start-up
Procedure 7 days prior to the date on which the PWS will begin serving water to the public.
• Failure to notify MassDEP of a Treatment Technique Trigger within 5 days of the collection date
of the sample that triggered the Assessment.
• Failure to notify MassDEP of a coliform monitoring violation within 10 days of learning of the
violation.
Recordkeeping Violations(Require TIER 3 PN within 1 YEAR):
• Failure to maintain Assessment Forms, Corrective Action documentation or other summary
documentation of Sanitary Defects for at least 5 years.
• Failure to maintain a record of any repeat sample taken that meets state criteria for an extension
of the 24-hour period for collecting repeat samples(per 310 CMR 22.05(2)(a).
Emergency Plans,Response and Reporting Requirements:
On May 2, 2008,MassDEP issued revised regulations regarding emergency plans,response and reporting
requirements. As of that date,Public Water Systems were required to have prepared an Emergency
Response Plan,which includes appropriate response actions to potential or actual emergencies, including
but not limited to:
1. Loss of water supply from a source;
2. Loss of water supply due to major component failure;
3. Damage to power supply equipment or loss of power;
4. Contamination of water in the distribution system from backflow or other causes;
5. Collapse of a reservoir,reservoir roof, or pump house structure;
6. Break in a transmission or distribution line that could result in a loss of service to customers
for more than four hours;
7. Potential or imminent threat of chemical or microbiological contamination of the water supply
over limits specified by MassDEP's Office of Research and Standards' as set forth in the
Standards and Guidelines for Contaminants in Massachusetts Drinking Waters. (available on-
line at http://www.mass.gov/dep/water/laws/14egulate.htm#chems);
8. Potential or imminent threat of an overfeed of an approved drinking water treatment chemical
into the system;
9. An act of vandalism or sabotage that has the potential to impact or impacts water quality or
the quantity of water available to the system.
10. A shortage or lack of resources that could affect the operations of the system, such as:
a. Staffing shortages:
b. Receipt of notice from a power utility of lengthy power outages; or
c. Imminent depletion of treatment chemical inventory;and
11. Any other failure of part or all of the water supply system due to equipment failure,human
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE: MARCH 7,2019 Page 15
acts(deliberate or accidental)or natural or human made disasters.
These requirements are described in sections 310 CMR 22.0403)of the Regulations.
Section 310 CMR 22.15(9)of the regulations incorporates 2-hour and 24-hour emergency notification
requirements to both MassDEP and the Board of Health,for specified emergency. Within 30-days of a
reportable emergency,the water supplier must complete an Emergency Response Report and submit a
copy of that Report to MassDEP for Level III,Level IV or Level V emergencies,Cross Connection
incidents, and any of the emergency incidents listed in Items#1 through#11 above.
Every public water supplier was required to submit an Emergency Response(ERP)Compliance Checklist
to MassDEP by December 31,2009.
UIC Issues
The Underground Injection Control(UIC)Program regulates discharges to the ground via Class V wells
such as dry wells,septic systems tied to industrial processes,leaching catch basins and other subsurface
leaching systems. The UIC Regulations list authorized activities in 310 CMR 27.05, including heat
exchanger return water, non-contact cooling water,storm water drainage,waste fluids other than sanitary
waste, aquifer recharge wells,and salt water barrier intrusion wells. Prohibited activities are listed in 310
CMR 27.04, and generally,include the introduction of fluid containing any pollutant that would likely
cause a violation of the Massachusetts Drinking Water Regulations,the groundwater discharge standards
listed in 314 CMR 5.10 or adversely affect the health of persons. One common unpermitted UIC
application is for floor drains in a boiler room piped to a drywell or septic systems in facilities that are
unsewered. Contact Joe Cerutti-at(617)292-5859 if the PWS source area has any unregistered UICs.
Radionuclides Rule
This rule applies to community water systems of all sizes and is currently in effect. This rule retains the
existing MCLs for combined radium-226 and radium-228,and gross alpha particle radioactivity,and
specifies an MCL of 30 ug/L for uranium. Please refer to the Linda Manor Water Quality Sampling
Schedule for specific testing requirements.
Arsenic Rule
On January 23,2001,The Environmental Protection Agency(EPA)issued a Final Rule to reduce the public
health risk from arsenic in drinking water by changing the Maximum Contaminant Level(MCL)for
arsenic from the current 50 parts per billion(ppb)to 10 ppb. EPA's Rule is in response to the
requirements of the 1996 amendments to the Safe Drinking Water Act. This rule will affect community
and non-transient,non-community water systems and was effective January 23,2006.
Groundwater Rule
EPA finalized this rule on October 12,2006 and MassDEP adopted the Rule into regulation on December
25,2009. The rule applies to all public water systems that rely on groundwater sources. PWS
compliance with this rule is now mandatory. Major components of the rule include:
1. MassDEP must conduct regular,comprehensive sanitary surveys on Ground Water Systems
(GWS—PW Ss with groundwater sources that do not disinfect)and identify significant
deficiencies. Beginning in 2009, all community GW Ss must be surveyed every three years
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 16
unless they are classified as exceptional by the State. All non-community GWSs must be
surveyed every five years.
2. All GWSs are required to sample and test their groundwater sources for fecal contamination
(fecal indicator)within 24 hours of any detection of Total Coliform in any routine
distribution system bacteria monitoring sample. The triggered monitoring sample must be
taken at a location representative of the source,prior to storage. MassDEP requires that all
GWSs have the ability to get this source sample on short notice and requires that sampling
ports be installed on all groundwater sources if not available.
3. The fecal indicator for Community systems serving greater than 3,300 persons is enterococci.
The fecal indicator for all other GWSs is ecoli. Furthermore, if ecoli is detected in any
groundwater source,regardless of population,the fecal indicator is ecoli. If a source sample
is collected on the same day as a distribution system sample, and the distribution system
sample is total coliform positive,then the source sample can be used to satisfy the triggered
monitoring component of the GWR,and consequently the fecal indicator is ecoli.
4. Any GWS with significant deficiencies or source sampling indicating fecal contamination
must take corrective action including using alternative sources of water,correcting and
removing the source of contamination,or providing 4-log removal of viruses.
5. The rule specifies that nanofiltration,certain types of microfiltration,chemical disinfection
using chlorine or ozone will provide 4-lag removal of viruses when used in stand-alone
applications.
6. The rule does not specify that ultraviolet(UV)disinfection can be used in a stand-alone
application to achieve 4-log removal of viruses.
7. GWSs that install a treatment technique to comply with the GWR are required to conduct"
compliance monitoring"that verifies the effectiveness of their virus removal. GWSs that
employ a treatment technique and serve greater than 3,300 persons must install continuous
chlorine monitoring at or before the first customer. GWSs that employ a treatment technique
and serve 3,300 persons or less are required to monitor their process once per day at or before
the first customer.
The text of the regulations is available on-line at http://www.epa.gov/safewater/disinfection/gwr/.
Beaver Conflict Resolution
In July 2000,the Massachusetts Legislature enacted a new law that provides any parties who are
experiencing public health threats as a result of beaver or muskrat flooding may apply to the local
municipal Board of Health(BOH)to abate those threats. The Division of Fisheries&Wildlife
regulations that oversee this process(321 CMR 2.08)further state that the MassDEP's Drinking Water
Program would make the determination of a threat in all cases involving Public Water Systems. This
determination is to be used to obtain an Emergency Permit from the local BOH. Depending upon the
situation,the local Conservation Commission may also become involved. MassDEP's policy applies to
surface water reservoirs, ground water wells and pump stations.
MassDEP may determine a threat to human health and safety exists if beaver or muskrats or dams or active
lodges are observed within designated areas. In some cases,documented water quality degradation is
required before a threat to human health and safety is determined.
The MassDEP contact for beaver conflict resolution issues in western Massachusetts is James Gibbs (413-
755-2299).
LINDA MANOR NURSING HOME PWS 1D#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 17
SANITARY SURVEY COMPLIANCE PLAN
RESPONSE FORM for TABLE A or B
Within 30 days of receipt of this inspection report,you must complete and submit this response form if your
system has TABLE A—Violations and/or TABLE B-Deficiencies (see attached Compliance Tables). Attach a
copy of the completed tables listing the date that the corrective action was or will be taken by your system and
all other applicable documentation. (310 CMR 22.04(12))
Please note that violations listed in TABLE A of the Compliance Plan are also a Notice of Noncompliance
(NON) pursuant to M.G.L. c.21A, §16 and 310 C.M.R. 5.00 and may require the submission of quarterly
written progress reports on the identified violations.
The following corrective actions listed in the Sanitary Survey Compliance Plan(s)TABLE A and/or B has been
taken by the public water system.(Please check all that apply).
❑ My system has taken ALL of the corrective actions listed within the timeframes specified in the Sanitary
Survey Compliance Plan(s).
• For each item,I have listed the completion date of the corrective action within each table.
• I have attached copies of supporting documentation as required.
❑ My system has taken SOME BUT NOT ALL of the corrective actions listed within the timeframes
specified in the Sanitary Survey Compliance Plan(s). My system HAS NOT complied with ALL of the
requirements set forth in the Sanitary Survey Compliance Plan(s).
• For each item,I have listed the actual or anticipated completion date of the corrective action within
each table.
• I have attached copies of supporting documentation as required.
• I have attached a revised corrective action schedule establishing timelines for my system to address
outstanding items and I will submit a written progress report each quarter(every 3 months) until all
items have been addressed. I understand that my system may be subject to further enforcement
action.
❑ My system is UNABLE to comply with some or all of the corrective actions within the timeframes
specified in the Sanitary Survey Compliance Plan(s). I understand that my system may be subject to
further enforcement action.
• An explanation is attached.
I hereby acknowledge receipt of the inspection findings and compliance plan table(s)of the sanitary survey conducted
by the Department of Environmental Protection's Drinking Water Program. I certify that under penalty of law I am
the person authorized to fill out this form and the information contained herein is true, accurate and complete to the
best of my knowledge and belief.
Water Commissioner,Owner,Owner Representative or Other Responsible Party:
Signature: Date:
Print Name: Title:
Return this form,a copy of each Compliance Plan Table and all attachments to:
DEP-BRP Drinking Water Program,436 Dwight Street,Springfield,MA 01103
Attention:Hem Pokharel
LINDA MANOR NURSING HOME PWS ID#: 1214001
INSPECTION DATE:MARCH 7,2019 Page 18
LINDA MANOR NURSING HOME PWS ID*: 1214001
INSPECTION DATE:March 7,2019 PAGE 19 OF 26
SANITARY SURVEY
COMPLIANCE PLAN- SECTION A - VIOLATIONS
Sanitary survey items that are required to be corrected to improve the protection of drinking water and public health pursuant to M.G.L. 111§ 160.MassDEP/DWP
will provide technical assistance to systems responding to these required actions. Please call your regional DWP office for referral to the appropriate staff person
Section Violations Corrective Actions Deadline for Taking Corrective Sig. Completed
of Actions Def.? Date
Regulation
or Statute
Administration MassDEP requires Linda Manor to submit an updated Separate correspondence No
complete ERP. Since it is likely that Linda Manor will connect
to City water during emergencies as an alternative to trucking
in water,MassDEP recommends that it be included in the
Emergency Plan.The updated ERP was one of the 2016
Sanitary Survey requirements,this is a violation and it is
addressed in a separate correspondence.
0&M The flow meter calibration record was one of the 2016 Separate correspondence No
Sanitary Survey requirements,this is a violation and it is
addressed in a separate correspondence.
Water Quality MassDEP requires Linda Manor to notify the consumers of the Separate correspondence Yes
lead and copper results, using the appropriate form, and send a
copy of Certification of Lead and Copper Consumer
Notification and 90th Percentile Report for its 2018 sampling
to MassDEP.This is a federal violation and it is addressed in a
separate correspondence. _
Sanitary survey items that are required to be corrected to improve the protection of drinking water and public health pursuant to M.G.L. Ill§ 160.MassDEP/DWP
will provide technical assistance to systems responding to these required actions. Please call your regional DWP office for referral to the appropriate staff person.
SANITARY SURVEY
COMPLIANCE PLAN- SECTION B - REQUIREMENTS
Sanitary survey items that are required to be corrected to improve the protection of drinking water and public health pursuant to M.G.L. 111§ 160.MassDEP/DWP
will provide technical assistance to systems responding to these deficiencies. Please call your regional DWP office for referral to the appropriate staff person.
Section Deficiencies Corrective Actions Deadline Sig. Completed
for Def.? Date
Taking
Corrective
Actions_ _
Administration During the MassDEP inspection,the Operator was MassDEP requires Linda Manor to submit a copy of May 2, _ No
not able to present the Consumer Confidence Report the 2017 CCR. 2019
(CCR)for a review.
Administration Maintain the general housekeeping around the pump Keep the pump house clean;remove unwanted May 2, No
house. Clutter like empty jars,and unwanted tanks wastes away from the pump house.The operator has 2019
and buckets in the pump house invite rodents and provided a verbal confirmation to the inspector that
other disease carrying animals. the pump house has been cleaned after the survey.
Provide a written notice that this task has been ,
accomplished.
O and M During the MassDEP inspection,the inspector noted MassDEP requires Linda Manor to make sure that May 2, No
that the operator left a portion of the "Certified the PWS is inspected every month and the "Certified 2019
Operator Inspection Form and Check List-Contract Operator Inspection Form and Check List-Contract
Operation"blank. Operation" form is completely filled.
O and M During the MassDEP inspection,the inspector noted MassDEP requires that Linda Manor install smooth May 2, No
threaded sample taps. One threaded sampling tap nosed raw water sampling taps by May 2,2019. 2019
was located next to the hydropneumatic tank and
other two threaded sampling taps were located in the
well pit next to the meter. The assessment on the two
threaded sampling taps located in the well pit next to
the meter was based on the picture review.
O and M During the MassDEP inspection,the new operator MassDEP requires that the Operator at Linda Manor May 2, No
who had joined the PWS as a contract operator in fully understand the Linda Manor PWS.Notify 2019
2018 did not seem to have familiarized himself with MassDEP that the Operator has completed the task
the Linda Manor PWS very well.He was not able to and provide MassDEP with a copy of the ERP,the 0
present or explain critical operational elements like &M plan,and the 0 &M logs.
the Emergency Response Plan(ERP),Operations
and Maintenance(0&M)plan,0 &M logs,
location of hydropneumatic tank etc.The inspector
left two copies of the 2016 sanitary survey at Linda
Manor for the operator to review and better
understand the Linda Manor PWS.
Distribution During the MassDEP inspection,the inspector noted Since it has been six years after the referenced cross August 2, No
a heating system, ice machines and dishwashers at connection survey and the water usage has increased 2019
Linda Manor.The facility manager at Linda Manor by 22% and the operator lacked the knowledge of
also informed the inspector of the presence of cross connection devices.MassDEP requires Linda
Laundry services.The manager and the operator Manor to conduct a full cross connection survey and
were not able to provide information on the provide a copy of a completed cross connection
backflow prevention devices.At the time of survey report.
inspection,Linda Manor was also not able to provide
the cross connection survey report for a review.
During the file review,the inspector was able to find
a reference to a cross connection survey report of
2013 in the 2017 sanitary survey report but the
inspector was not able to locate the actual cross
connection survey report.
Distribution Based on the file review,Linda Manor replaces the Since MassDEP was not able to review a copy of the May 2, No
well pump every 2 years as a maintenance protocol Operation and Maintenance(0&M)plan with the 2019
due to water emergencies experienced in 2008 and pump change information during the inspection,
2010. MassDEP requires Linda Manor to provide the last
pump replacement date if any.
Distribution A diagram for the external distribution system outside MassDEP requires Linda Manor to send an updated May 2, No
is shown in figure I.According to the Operator,this schematic diagram of Linda Manor PWS. 2019
PWS has since been updated with separate water
meters for each source which are not indicated in the
diagram.
Water During the file review,MassDEP noted a consistent Provide an explanation to MassDEP about the May 2, No
Quantity increase in the annual water use based on Annual consistent increase in the water usage at Linda 2019.
Statistical Report(ASR). The water use has Manor.
increased every year.The water usage has increased
22%in the years 2014(4.2 MG)to 2017 (5.1 MG).
Water Quality During the MassDEP inspection,the inspector MassDEP requires Linda Manor to remove mixing May 2, No
noticed mixing valves and aerators in the repeat valves from all potential sampling locations before 2019
sampling taps.MassDEP does not permit sampling May 2,2019.MassDEP also reminds Linda Manor
taps with mixing valves. that the filters and aerators have to be taken out
when sampling for water.
Water Quality During the MassDEP inspection,the inspector noted MassDEP requires that Linda Manor install smooth May 2, No
the presence of threaded sample taps. With the nosed raw water sampling taps. 2019.
threaded sampling tap,the chances of contamination
increases during sampling.
Water Quality During the MassDEP inspection,the operator was MassDEP requires Linda Manor to locate the raw May 2, No
not able to locate the raw water tap due to snow water tap and send a visual confirmation of the 2019
accumulation. location to MassDE.Also send a copy of the ERP
plan and the 0 &M plan that includes how the raw
water would be collected in case of emergency,
including emergencies during winter months.
Source Linda Manor is.hereby notified that the well(s)with Pursuant to 310 CMR 22.04(1)and 22.21(a),Linda Ongoing No
Protection nonconforming activities noted in Table 03 are in Manor must notify MassDEP if it plans to modify,
nonconformance with the MassDEP's requirement increase water use,or expand its source or to replace
(310 CMR 22.21(1)(b)(5))that Zone I activities be any wells. At the time of such notification of a
limited to those directly related to the provision of proposed modification, expansion,or replacement,
public water or will have no significant adverse MassDEP may require Linda Manor to comply with
impact on water quality(as specified in Policy 94- the Zone I requirement that all Zone I activities be
03A). To the extent possible,efforts should be made limited to those directly related to water supply or
to reduce or eliminate the impacts of non- will have no significant impact on water quality.
conforming uses within the Zone I.
* MassDEP reserves the right to exercise its Order authority under M.G.L. Chapter 111, Section 160,or to take other appropriate action as permitted by law, in order to prevent the pollution and to
secure the sanitary protection of the water supply and to ensure the delivery of a fit and pure water supply to all consumers, including without limitation if sufficient progress to meeting a
recommended deadline is not achieved.
**MassDEP requests that periodic progress reports be submitted,e.g.,quarterly(each January 1",April P`,August 1",December 1st,etc.,for as long as necessary)or otherwise.
GWR SD=Ground Water Rule Significant Deficiency
Form 201941-23 Massachusetts DEP Drinking Water Program Small Systems<1,000
NO Treatment
COLIFORM SAMPLING PLAN I Distribution System
•
PWS 1D#: 1214001 PWS Name: Linda Manor Nursing Home Town: Northampton
Type of PWS: Community X Non-transient,Non-community(NTNC) Transient,Non-community(TNC)
Number of Active Sources: GW: 2 Number of Distribution Systems: 1
Total#of Monthly Samples Required per 310 CMR 22.05: 2
Population Winter: .120 Population Summer: 120 Source of Information: 2017Annual Statistical Report
No. of routine samples(RS)required(based on population): 1 per Month
Atmospheric Storage Tanks are
No.of tank(STOR)samples required: 1 per Month
Manijolded
Brief Water System Description
Two sources,Well#1(01G)and Well#2(02G)serve the skilled nursing facility building. Both wells operate in leadllag mode. From each well,
water flows a short distance in distinct discharge lines to two sample pits where the raw water taps are located. After the sample taps,water from
both wells flows into a single water main. The water main then extends to a three-way valve chamber for two 8,000-gallon buried fiberglass
atmospheric storage tanks. The valve pit allows that tanks to be isolated for maintenance and repairs. From the three-way valve chamber,water
enters the atmospheric storage tanks. Both outlets from the atmospheric tanks join in a single water main that extends into a small room below the
boiler mom that is located in the east-central section of the building. Inside the small room below the boiler room,the water main extends to a
booster pump skid containing three pumps which pressurize a 120-gallon hydropneumatic tank and the distribution system. The system currently
has no treatment.
Key to RS Routine Sample site (tap representative of the distribution system)
Sample Upstream Repeat sample site (tap upstream ofthe RS sample tap)
Types DR Downstream Repeat sample site (tap downstream of the RS sample tap)
& AR Additional Repeat Sample site (alternative sample site to be used in absence of UR or DR tap,or other MassDEP-approved site)
RW Raw Water sample site (untreated source water)—RTCR and GWR compliance sample
Codes STOR Tank sample site (storage tank sample site for atmospheric tanks and hydropneumatic tanks with effective storage>500 gallons)
Sample Sample MassDEP Approved Sample Site r r Sampling Frequency
Type Code# Sampling Point Name and/or Street Address '
RS 002 Three-bay Sink in Main Kitchen on lst Floor 1 per Month
UR 002a Sink in 1st Floor Nurses' Station(Northern Wing) As required per RTCR
DR 002b Sink in 1st Floor Nurses' Station(Southern Wing) As required per RTCR
Tap at 120-gallon Hydropneumatic Tank that is Representative of Both 8,000-
RS STOR I per Month
gallon Atmospheric Storage Tanks
AR STORa Three-bay Sink in Main Kitchen on]n Floor As required per RTCR
DR STORb Sink in 1st Floor Nurses' Station(Northern Wing) As required per RTCR
RW RW 1 Raw Water Tap for Well#1 (01G)in Meter Pit As required per GWR
Page I oft
PWS ID#: 1214001 Massachusetts DEP Drinking Water Program Small Systems<1,000
NO Themmeni
COLIFORM SAMPLING PLAN — Continued Distannna System
Sample Sample MassDEP Approved Sample Site
Type Code!' Sampling Point Name and/or Street Addresst'z Sampling Frequency
RW RW2 Raw Water Tap for Well#2(02G)in Meter Pit As required per GWR
'Preferred routine sampling locations at sampling points/street addresses,in order of preference,are: kitchen sinks,followed by bathroom
sinks,followed by bubblers. Outdoor faucets and slop sinks are not allowed as routine sampling locations without prior approval of
MassDEP.
°The Groundwater Rule(GWR: 310 CMR 22.26)requires triggered source water monitoring of all individual sources when total coliform
bacteria are detected in routine monthly bacteria samples from the distribution system,unless the public water system(PWS)has a
MassDEP-approved Representative Triggered Monitoring Plan(GWR Form C). If individual source taps don't exist,then the PWS must
develop a procedure for sampling the wells individually when GWR triggered monitoring is required. This may be accomplished by using
existing valves to isolate and run wells individually to allow the required GWR sampling.
Notes to lab: Sample Types,Sample Codas,and MassDEP Approved Sample Sites listed above must be used to complete the MassDEP Bacteriological Report form.
Corresponding eDEP data fields: Sample Type=Routinelndicator; Sample Code=SampleLocationldentifier; DEP Approved Sample Site=TextLocatiord4ame;and,
SampiedcidaSdndicater=T
Revised Total Coliform Rule(RTCR)310 CMR 22.05: When a RS sample is total coliform positive,a set of repeat sampling of the corresponding RS,
UR,and DR sites must be conducted within 24 hours of notification of the total coliform-positive sample. Additional samples,such as after astorage tank
may also be required to ascertain a cause of contamination.
Groundwater Rule(GWR)310 CMR 22.26: Compliance samples(total coliform/E.coli)must be collected at the same time or within 24 hours of
notification of a RS total coliform-positive sample,from each ground water source(RW)in use at the time(or within 24 hours prior to the time)of the total
coliform-positive sample collection. Source samples must be collected from raw water sample sites representing each individual source prior to any
treatment,and not combined unless approved through a GWR representative monitoring plan.
Is a map/sketch of your water distribution system attached,showing the locations of the bacteria sampling sites,wells,and storage
tanks,etc.? YES NO
Public Water Supplier/Designee Signature Printed Name DATE
Please submit this form to your Regional MassDEP Office. Add er subtract rows from tables,as appropriate. Use
additional sheets if necessary.
Please provide your analytical laboratory with a copy of this updated Coliform Sampling Plan. Monthly
Bacteriological Reports must include Sample Type,Sample Code#and MassDEP-approved Sample Site
information from this plan. Any discrepancies may affect your compliance status.
For MassDEP/DWP Use:
Action:
DWP Name: Signature: Date:
Page 2 of 2