1. Effective Project Planning, Community Capacity Building, & Partnership Development in Indian Country LT Bradley Sherer Environmental Engineer Indian Health Service Albuquerque Area Office Office of Environmental Health & Engineering Sanitation Facilities Construction

2. Topics 1.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

3. 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

4. Background & History

5. Project Planning  Current IHS Sanitation Facilities Construction Project Management Guideline 1.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

6. 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

7. 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

8. 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

9. 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/LBin 1 Required to monitor for Crypto0.075 to < 1.0 oocysts/LBin 2 Required to monitor for Crypto1.0 to < 3.0 oocysts/LBin 3 Required to monitor for Crypto≥ 3.0 oocysts/LBin 4 Serves<10,000, no monitoringN/ABin 1

11. 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

12. 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

14. 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

15. Evaluation Criteria Risk, Cost, O&M, Sophistication RiskLevel of RiskScore EPA approved technology, no pilot testing requiredNone5 Well drilling in area with existing wells, alternative filtration system Low4 Pilot testing required or drilling well where no groundwater data is available Medium3 Bank filtrationMedium High2 Technology unlikely to meet SDWAHigh1 Capital CostScore <$250,0005 $250,000 - $500,0004 $500,000 - $1.0M3 $1.0M - $1.5M2 > $1.5M1 O&M CostScore <$50,0005 $50,000 - $70,0004 $70,000 - $90,0003 $90,000 - $110,0002 > $110,0001

16. Evaluation Criteria SophisticationLevelScore No power, no chemicals, no disposal of backwashLow5 Low maintenance and power requirements, chlorine onlyMed-Low4 Moderate power and maintenance, chlorine onlyMedium3 Power, chemicals for backwash/cleaning, complex parts, additional reporting, chlorination, controls Med-High2 Power, chemical feeds, complex parts, filter backwash recycling rule applies High1 OptionRiskCapital CostO&M CostSophistication Well DrillingMedium$1,900,000$102,000Med-Low Direct FiltrationNone$1,461,000$130,000High DE FiltrationNone$706,000$97,000Med-High Slow SandNone$1,560,000$91,000Medium MembraneLow$1,960,000$91,000High Cartridge FiltrationLow$950,000$39,000Med-High Bank FiltrationMed-High$621,000$101,000Low

17. Presenting Alternatives Analysis AlternativeRiskCapital CostO&M CostSophisticationTotal Score Cartridge Filtration435214 DE Filtration532212 Well Drilling422412 Bank Filtration232512 Slow Sand512311 Direct Filtration52119 Membrane31217

18. 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

19. Questions?