Effective Project Planning, Community Capacity Building, & Partnership Development in Indian CountryLT Bradley Sherer

Environmental Engineer

Indian Health Service

Albuquerque Area Office

Office of Environmental Health & Engineering

Sanitation Facilities Construction

Topics1. Project Planning – Implementation of the PMPro model

2. Analysis of Filtration Technology – Meeting the needs of a rural Indian community

3. Community Capacity Building – Methods used to equip the community with knowledge of project planning

4. Strengthening Relationships Between IHS/Tribe/EPA

Background & History Mescalero Apache Tribe, New Mexico

2006: Two water systems that utilize fresh water springs were classified by EPA as Groundwater Under the Influence of Surface Water

2010: Order on Consent Issued – EPA wanted compliance within 18 months

IHS & Tribe partnered to develop and implement a plan to identify solutions to meeting the EPA requirements

Background & History

Project Planning Current IHS Sanitation Facilities Construction Project

Management Guideline1. Project Development

Identify Project – Who, What, Where, When, Why? Identify Planning Activities – What needs to be done, what information

is needed?

2. Planning & Design Execute Planning Activities – Data collection Report of Findings – Engineering Report (used for design)

3. Construction Documents

4. Construction

5. Close-out

1. Project Development Identify Project – New Water Source or Treatment Technology Identify Planning Activities – Alternatives Analysis Report

Groundwater Characteristics of Current Groundwater, Formations, etc. Hydrogeologic Study – Preliminary Siting of New Well

Filtration Conventional vs. Alternative Current Water Quality

Objective of the Alternatives Analysis – Clearly present all options to the Tribe so they can make a well informed choice on meeting compliance

Tribe Submitted Project Development to EPA

2. Planning & Design Execute Planning Activities

Data Collection Prepare Alternatives Analysis Report Seek input from stakeholders – Tribe & EPA Identify potential risks and how to mitigate Obtain chosen alternative from Tribe

Report of Findings – Finalized Alternatives Analysis Report

Regulatory Framework Surface Water Treatment Rule (1989):

MCLG of zero for girardia, viruses, & Legionella National Primary Drinking Water Regulations for PWSs using

groundwater under the direct influence of surface water (GWUDI) 99.9% (3-log) removal of girardia, 99.99% (4-log) removal of viruses Definition of GWUDI – shifts in turbidity, temperature, conductivity, pH

that correlate with climate conditions Approved Technology: Conventional/direct filtration, slow sand,

diatomaceous earth, and “other” filtration technologies

Regulatory Framework Long Term 2 Enhanced Surface Water Treatment Rule:

Cryptosporidium Bin Classification System

Filter Backwash Rule – reporting, treatment, and record keeping requirements for the recycling of spent filter backwash

Bin 1: 99.9% (3-log) removal of girardia and 99.99% (4-log) removal of viruses combined with disinfection

System that is: Crypto Conc. Bin Class.

Required to monitor for Crypto <0.075 oocysts/L Bin 1

Required to monitor for Crypto 0.075 to < 1.0 oocysts/L Bin 2

Required to monitor for Crypto 1.0 to < 3.0 oocysts/L Bin 3

Required to monitor for Crypto ≥ 3.0 oocysts/L Bin 4

Serves<10,000, no monitoring N/A Bin 1

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2011

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2011

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2011

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2011

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1.5

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2.5

Agency Springs Raw Water Turbidity6 Month Daily Average

NT

U

Analysis of Filtration Direct Filtration: coagulation and filtration, excludes

sedimentation Conventional Filtration: coagulation, flocculation,

sedimentation Diatomaceous Earth Filtration: precoat filter media on a

support filter media Slow Sand Filtration: <0.4 m/hr Alternative Filtration: membrane (micro, ultra, nano, ro), bag,

cartridge, bank

Immediate Compliance

Contingent Compliance

Alternative Filtration Immediately disregarded – not immediate compliance, pilot

testing required Section 141.73 (b) of NPDWR – Approval of alternative

filtration with the following: Combined with disinfection Demonstration to the State using pilot & integrity testing 99.9% removal and/or inactivation of Giardia 99.99% removal and/or inactivation of viruses 99% removal of Cryptosporidium The State approves the use of the filtration technology

Alternative Filtration EPA agreed compliance with the following exceptions:

Role of the “state” would be Region 6 Challenge test documents forwarded to them Pre-filters installed

Evaluation CriteriaRisk, Cost, O&M, Sophistication

Risk Level of Risk Score

EPA approved technology, no pilot testing required None 5

Well drilling in area with existing wells, alternative filtration system

Low 4

Pilot testing required or drilling well where no groundwater data is available

Medium 3

Bank filtration Medium High 2

Technology unlikely to meet SDWA High 1

Capital Cost Score

<$250,000 5

$250,000 - $500,000 4

$500,000 - $1.0M 3

$1.0M - $1.5M 2

> $1.5M 1

O&M Cost Score

<$50,000 5

$50,000 - $70,000 4

$70,000 - $90,000 3

$90,000 - $110,000 2

> $110,000 1

Evaluation CriteriaSophistication Level Score

No power, no chemicals, no disposal of backwash Low 5

Low maintenance and power requirements, chlorine only Med-Low 4

Moderate power and maintenance, chlorine only Medium 3

Power, chemicals for backwash/cleaning, complex parts, additional reporting, chlorination, controls

Med-High 2

Power, chemical feeds, complex parts, filter backwash recycling rule applies

High 1

Option Risk Capital Cost O&M Cost Sophistication

Well Drilling Medium $1,900,000 $102,000 Med-Low

Direct Filtration None $1,461,000 $130,000 High

DE Filtration None $706,000 $97,000 Med-High

Slow Sand None $1,560,000 $91,000 Medium

Membrane Low $1,960,000 $91,000 High

Cartridge Filtration Low $950,000 $39,000 Med-High

Bank Filtration Med-High $621,000 $101,000 Low

Presenting Alternatives Analysis

Alternative Risk Capital Cost O&M Cost Sophistication Total Score

Cartridge Filtration 4 3 5 2 14

DE Filtration 5 3 2 2 12

Well Drilling 4 2 2 4 12

Bank Filtration 2 3 2 5 12

Slow Sand 5 1 2 3 11

Direct Filtration 5 2 1 1 9

Membrane 3 1 2 1 7

Results Groundwater option chosen Final Report Published - EPA funded the project to drill wells IHS funding infrastructure & capital improvements

Application to another GWUDI system Tribe working more independently to scope planning projects

Results in other funding sources EPA working more closely/directly with Tribe Limited role of IHS

Application to ISWMP

Questions?