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ITEM 3.7 Agreement for Gross Alpha/Radium 226 228©tSTeF 0 MINNESOTA V DEPARTMENT INFORMATION Request for City Council Action ORIGINATING DEPARTMENT REQUESTOR: MEETING DATE: Utilities Utility Manager Neidermeier May 8, 2017 PRESENTER(s) REVIEWED BY: ITEM #: Consent City Administrator/Finance Director Flaherty 3.7 AGENDA ITEM DETAILS RECOMMENDATION: Staff recommends executing the Memorandum of Agreement for Gross Alpha/Radium 226 and 228 for Combined Discharge 3 of the East Public Water System with the Minnesota Department of Health. ARE YOU SEEKING APPROVAL OF A CONTRACT? IS A PUBLIC HEARING REQUIRED? No No BACKGROUND/J USTI FICATION: The City of Otsego maintains a Memorandum of Agreement with the Minnesota Department of Health (MDH) to comply with water quality standards for Gross Alpha & Combined Radium for the East Public Drinking Water Supply. The Agreement was initiated in 2013 from an annual exceedance of Radium 226/228 and Gross Alpha in Well 8 raw water sampling. Well 8 is one of several water production contributors to the East Public Water System. To meet drinking water standards physical blending from Wells 3 & 8 is required based on calculations from analytical results and water production volumes, identified in the agreement. Water supplied to the system is in compliance with National Primary Drinking Water Regulations. The Memorandum of Agreement is reviewed annually to ensure continued compliance. Highlights of the agreement: • No water production from Well 8 from October 16th through April 141H • A limited Well 8 water production - no more the 45% of the total annual Water Production. • Annual and Bi -Annual Radium Sampling for Well House #2 (wells 3 & 8). • Annual compliance notification through the Consumer Confidence Report. SUPPORTING DOCUMENTS ATTACHED: • Memorandum of Agreement POSSIBLE MOTION PLEASE WORD MOTION AS YOU WOULD LIKE ITTO APPEAR IN THE MINUTES: Motion to approve and execute the Memorandum of Agreement with the Minnesota Department of Health for Gross Alpha and Radium 226 and 228 for the East Public Water System to keep within compliance of National Primary Drinking Water Regulations. BUDGET INFORMATION FUNDING: BUDGETED: NA Minnesota ;,�► `Ijll Department ii( Ar,r IL 'ill; fl of Health-'� I PROTECTING, MAINTAINING & IMPROVING THE HEALTH OF ALL MIN NESOT-kN-S - April 17, 2017 Otsego City Council c/o Ms. Jessica Stockamp, Mayor 13400 901h Street NE Otsego, Minnesota 55330 Dear Council Members: Subject: Memorandum of Agreement — Flow -Weighted Averaging for Gross Alpha and Radium 226 and 228 Compliance, City of Otsego, Wright County, PWSID 1860026 As a reminder, Memorandums of Agreement to use Flow -Weighted Averaging (FWA) for compliance must be renewed annually. Systems are responsible for ensuring that items necessary to update the agreements (such as meter calibrations) are received by the Minnesota Department of Health (MDH), by the deadlines in the agreements. Due to the difficult nature of ensuring that all customers receive water with an annual average below the MCL, including customers that live nearest to entry points with high Gross Alpha and Radium 226 and 228, FWA agreements are considered a Pon -permanent solution, and MDH encourages systems to investigate all permanent options for compliance, such as finding a new source, installing treatment, etc. Systems may apply for grant funding to assist in achieving compliance. There are several challenges that impact the usefulness and protectiveness of FWA, that MDH and systems should keep in mind: • Systems can provide additional information above and beyond the Consumer Confidence Reports on how FWA is used. • FWA creates limits on capacity, which may become challenging to meet if a system is growing, or there are quantity restrictions on other sources. • Calculations to determine compliance must include a 10% safety factor. • Systems need to maintain/submit up -to date distribution maps and flow models of their systems to ensure that no customers receive water with annual concentrations above the MCLS. If your system is considering alternative compliance options please contact me to discuss and develop a new compliance agreement. It is our understanding that your system met the conditions of the 2016 signed FWA from May 2016 through March 2017. If you have any questions, or need to provide additional information, please contact me at 651/201-4667 or email anna.schliepPstate.mn.us. Sincerely, Anna Schliep, Compliance E i e Community Public Water Supp Unit Minnesota Department of Health 625 N Robert Street St. Paul, MN 55164-0975 KRP:AS:nkk An equal opportunity employer Otsego 1860026 MEMORANDUM OF AGREEMENT Contaminant: Gross Alpha/Radium 226 and 228 Otsego Public Water System This Memorandum of Agreement (hereinafter "Agreement", by and between the City of Otsego, 1860026 (hereinafter "System"), and the Minnesota Department of Health (hereinafter "MDH") becomes effective on the date signed on behalf of the MDH. I. Authorities and Findings A. Pursuant to the Safe Drinking Water Act, Minnesota Statutes, sections 144.381 to 144.387, and Minnesota Rules chapter 4720, the MDH enforces the National Primary Drinking Water Regulations. In Minnesota Rules, part 4720.0350, the MDH has adopted the federal National Primary Drinking Water Regulations, 40 CFR, Part 141, by reference. 40 CFR, section 141.66(b), establishes the maximum contaminant levels (MCL) for Gross Alpha and Radium 226 and 228. B. The System seeks to remain in compliance with the National Primary Drinking Water Regulations because the System's water supply exceeds the MCLS of 5.4 picocuries per liter (pCi/L) for Combined Radium; and 15.4 pCi/L for Gross Alpha. Through this Agreement, the parties seek to keep the System in compliance with the National Primary Drinking Water Regulations. II. Corrective Actions It is agreed between the System and MDH that until the corrective actions set forth below have been implemented and compliance with the MCLs for Combined Radium and Gross Alpha has been accomplished, the System shall meet the following conditions for the entry points known as Combined Discharge 1 and Combined Discharge 3: 1. The System shall monitor the Combined Discharge 1 and 3 entry point bi-annually for radium and gross alpha concentrations. The entry point samples shall be collected from the source of water after treatment. All samples will be collected by the System's public water supply operator and sent to the MDH Laboratory for analysis. The MDH will supply the sampling kits and pay for the cost of analyzing the samples; however, the System is responsible for the cost of shipping the samples to the laboratory. 2. Well land Well 2 will only be used in an emergency situation (such as for fire protection). 3. The System shall monitor the Well 3 and Well 8 source points annually for radium and gross alpha concentrations. The concentrations from these measurements will be used when updating future MOAs. These samples shall be collected from the source water before treatment and before water is combined via Combined Discharge 3. All samples will be collected by the System's water supply operator and sent to the MDH Laboratory for analysis. The MDH will supply the sampling kits and pay for the cost of analyzing the samples; however, the System is responsible for the cost of shipping the samples to the laboratory. Otsego 1860026 Page 2 4. Well 3 and Well 8 are connected via combined discharge at the pump -house. These two wells shall meet the following equation on an annual basis with well volume measurements taken on a daily basis: [(V3) (Ra3) + (V8)(Ra8)] / [V3+V8] < MCL with 10 percent factor of safety where: V3 = Volume produced by Well 3 Va=Volume produced by Well 8 Ra3 =Radium 226/228 concentration at Well 3 Raa= Radium 226/228 concentration at Well 8 Well 3 (1 pCi/L) and Well 8 (15.4 pCi/L), have an expected combined radium 226/228 concentration 12.72 pCi/L based on System set -points of 600 gpm at Well 3 and 1,200 gpm at Well 8 for a total of 1500 gpm (due to head pressures and friction losses with both pumps running). Based on the design of the system and the average concentrations of radium 226/228 present in the wells the following conditions will need to be achieved: a) Well 3 will be the only producing well from January 1 through April 14, 2018, and October 16 through December 31, 2017. b) MDH requires Well 8 contribute no more than 45 percent of the total volume of water during period of combined use. Both conditions a) and b) based on measured values of radium concentration will result in an annual combined radium 226/228 average concentration of 4.9 pCi/L or less. 5. If the use of Well 1, Well 2, Well 3, Well 6 and Well 8 are not operated per the requirements above from April 15, 2017 through April 14, 2018, the System must immediately notify MDH and the consuming public of the Combined Radium 226/228 and Gross Alpha exceedance. Public notification must then continue on a quarterly basis as required by MDH, and documentation must be provided to MDH within 10 days of each public notification. 6. Take the following actions according to the schedule as follows: Action Required: Complete no later than: A. Collect Combined Radium and Gross Alpha samples In Quarter 2 and Quarter 3, 2017 at the Combined Discharge 1 and 3 B. Collect Combined Radium and Gross Alpha samples In Quarter 3, 2017 from Well 3, Well 6 and Well 8 annually C. Memorandum of Agreement will be updated March 31, 2018 annually Otsego 1860026 Page 3 7. The System will continue to notify the consuming public annually in the Consumer Confidence Report. III. Further Agreements 1. If the System fails to comply with any term or condition of this Agreement that results in noncompliance with applicable rules and statutes pertaining to public water supplies the MDH may take enforcement actions authorized in Minnesota Statutes, sections 144.99 and 144.991, or any other applicable law, including, where appropriate, the assessment of monetary penalties. 2. This Agreement will be reviewed and updated annually. 3. This Agreement may not be modified or amended, except in writing and any modifications or amendments must be signed by all the parties. MINNESOTA DEPARTMENT OF HEALTH DIVISION OF ENVIRONMENTAL HEALTH City of Otsego, MINNESOTA Randy Ellingboe, Manager Jessica Stockamp, Mayor Section of Drinking Water Protection City of Otsego Date This agreement becomes effective on the date signed by the representative of the MDH