Appendix II
Water System Plan Comments
DOH COMMENT RESPONSE FORM
DOH
Comment
No.
1
2
DOH Comment
Water System Response
The Water System Plan must be stamped and
signed by a professional engineer licensed in
the State of Washington.
With regard to the plan approval period,
throughout the document:
• Please state the last year of the
planning period in the Executive
Summary of Section 1 (e.g. 2023 for a
6-year plan, 2027 for a 10-year plan)
• Many projections are provided
through 2025, though, the CIP is
notably only through 2021. This
would result in no more than a 4-year
approval period. Please provide
projections through the last year of
the desired planning period.
• Please document what effect a longer
(or shorter) plan approval period
would have on the update schedule
for the Regional Water Forecast and
Conservation Plan (RWFCP).
Water System Plan is now stamped and signed.
The document has been updated to include year
2027 for a 10-year planning period.
The following was added to the executive
summary. “This document’s planning period is
through year 2027.”
Page
Number
of
Response
Cover
ES-1
The CIP has been updated to be through year
2027 (2016-2027) instead of through year 2021
(2016-2021).
ES-3, ES-6
136, 139,
149
The following was added to Section 2 first
paragraph, “With the approval of a 10-year
planning period (WAC 246-290-100), the next
water system plan update is planned to be year
2027. If the Regional Water Forecast and
Conservation Plan (RWFCP) is not written on the
same planning period year, then demands will
be interpolated and/or projected from the
RWFCP.
9
The following tables were updated to include
year 2027: Tables 2.7, 2.8, 3.8, 3.9, 3.10, 3.11,
3.12, 3.14, 4.2, and 4.3.
16, 17,
60 – 66,
84
Figure 8-2 was updated to reflect the change
from 6-year (2021) to 10-year (2027) CIP.
144
Other Water System
Comments
DOH
Comment
No.
DOH Comment
Water System Response
3
As a municipal water supplier, the City of
West Richland has a duty to provide water
within its retail service area. Please provide a
duty to serve statement, limited only by the
four threshold factors listed in DOH
Publication 331-366 Duty to provide service
requirement.
The following was added to section 1.5 under
the definition for “Retail Service Area”:
The City has a duty to provide service to all new
connections within the retail service area shown
in Figure 1-1 when the circumstances meet the
four threshold factors:
1) The municipal water supplier has
sufficient capacity to serve water in a
safe and reliable manner.
2) The service request is consistent with
adopted local plans and development
regulations.
3) The municipal water supplier has
sufficient water rights to provide
service.
4) The municipal water supplier can
provide service in a timely and
reasonable manner.
4
Regarding the Service Area as presented in
the WSP:
• As presented, it appears that the
service area is identical to the current
boundaries of the City of West
Richland. Is this correct?
• What is the status of the Red
Mountain Interchange development
area? Is the City expected to provide
service to it?
Yes, the service area is identical to the City
boundaries.
There are no current or future plans to develop
or provide service to the Red Mountain
Interchange Development area.
Page
Number
of
Response
5
Other Water System
Comments
DOH
Comment
No.
5
6
DOH Comment
Water System Response
The narrative and the water facilities
inventory (WFI) in Appendix A are occasionally
in conflict. For example, in Section 3.2, the
narrative states that Well 3 is for
emergencies, but it is documented on the WFI
as inactive and therefore unusable. Please
ensure consistency between the WSP and the
WFI.
Please update Table 3.2 Effective regulations
to recognize that this water system is:
• Subject to the Groundwater Rule
• Subject to the Stage 2
Disinfectant/Disinfection Byproduct
Rule, and
• Not subject to the Surface Water
Treatment Rule.
The following changes were made to be
consistent with the WFI:
Instead of 9 water sources listed, it was changed
to 7 (Wells No. 1, 2, 6, 7, 9, 10, and intertie
booster station). Wells No. 6 and 10 are on
emergency status.
Instead of 8 wells, it was changed to 6 wells
Table 3.2 has been updated with the following:
Groundwater Rule – Effective
Stage 2 Disinfectant/Disinfection Byproduct Rule
– Effective
Surface Water Treatment Rule – Not Applicable
to West Richland
Page
Number
of
Response
4
21
27
56
78
82
22
Other Water System
Comments
DOH
Comment
No.
DOH Comment
Water System Response
7
Please update the coliform subsection on
Page 23 to reflect the effect of the Revised
Total Coliform Rule (RTCR).
8
In subsection 3.1.1, please note the DOH
Source Number in each source description.
Table 3.11 on Page 63 shows significant
storage deficit for Zone 3. Does this represent
a true storage deficit (meaning the City would
be unable to meet its reliability standards for
providing water under peak flow/ fire flow
conditions), or is there another way to present
the analysis to show how the City would be
able to meet its obligations?
Section 3.2.3 was updated as follows:
Coliform: Coliform monitoring requirements
detailed in WAC 246-290-300 are based upon a
presence or absence of total coliform in any
given sample the Revised Total Coliform Rule
(RTCR). The City is required to collect fifteen (15)
total coliform weekly samples each month from
representative points within the distribution
system. Acute violations of the
bacteriological requirements occur when a fecal
coliform of E. coli is detected in repeat samples.
A non-acute violation occurs for systems that
collect fewer than 40 samples per month when
more than one sample is positive for total
coliform. The City’s Coliform Monitoring Plan is
located in Appendix L.discussed in Section 6.
Review of the City’s bacteriological data since
2009 indicates that the The City is in compliance
with this regulation. A copy of the updated
Coliform Monitoring Plan is provided in Appendix
L.
Source numbers were added to Table 3.4, and to
each description is subsection 3.3.1
Zone 3 currently has all of its storage in Zone 4.
Table 3.11 and Table 3.12 have been updated to
show this.
9
Page
Number
of
Response
23
27 - 36
63
64
Other Water System
Comments
DOH
Comment
No.
Page
Number
of
Response
78
DOH Comment
Water System Response
Please provide an evaluation of the capacity of
the various elements of the water system in
terms of ERUs in order to document the
limiting factor of capacity. The process of
determining physical capacity is set forth in
Chapter 6 of the DOH Water System Design
Manual (particularly Section 6.7). In addition
to showing the calculations, Worksheet 6-1 in
the WSDM provides a nice way to summarize
the results, so please provide a completed
Workhseet 6-1 or something similar.
Please explain the relationship between Table
4.2 and Figure 4-1. Table 4.2 appears to state
that there is an instantaneous water rights
deficiency by 2035, but Figure 4-1 shows no
such deficiency.
“Section 3.7 – ERU Physical Capacity” has been
added to the document. This incorporates
information from Worksheet 6-1 to show the
calculation of ERUs and the physical capacity of
the system in terms of ERU.
Table 4.2 has been updated to reflect what is
shown correctly in Figure 4-1. The forecasted
source production in year 2035 is 8,460 gpm not
11,495 gpm.
80
12
The Department of Ecology has issues a
comment letter regarding this submittal. A
copy of the review letter dated December 8,
2016 from the Department of Ecology is
enclosed. Please address the issues, if any,
contained in the letter in the second draft
submittal.
Table 4.2 and 4.3 have been updated to show
current water rights. A note has been added to
Table 4.2, Table 4.3, Figure 4-1, and Figure 4-2
regarding the pending water rights.
This modification should address the Dept. of
Ecology comment sufficiently.
80
13
In Appendix B, please provide a Local
Government Consistency Determination form
for the City of West Richland in the next
submittal. If the City decides to include any
area outside of its current city limits within
the Service Area, please deliver one for
Benton County Planning Department as well.
Appendix B now contains a local Government
Consistency Determination from the City of
Richland and Benton County.
The city does not have plans to include any area
outside of its current city limits within the
Service Area.
App. B
10
11
Other Water System
Comments
DOH
Comment
No.
Page
Number
of
Response
App. L
DOH Comment
Water System Response
14
On Page 4 of Appendix L, please note that
Walla Walla Health Department no longer
operates a certified lab.
Walla Wall Health Department has been
changed to Cascade Analytical, Inc. Edge
Analytical was added as an alternate lab.
15
In Appendix X, because his letter appears to
have unsatisfied assumptions, the Fire Chief
has not issued an unambiguous letter in
support of nesting. Please address this in the
next submittal.
Appendix X now contains support from the Fire
Chief on nesting.
App. X
16
The water system must meet the consumer
input process outline in WAC 246-290-100(8).
Please include documentation of a consumer
meeting discussion the Water System Plan
prior to its approval.
Documentation is provided in Appendix II to
show water system notification of consumers,
and a public hearing to allow public input. No
public comments were received at the public
hearing or on the City website.
App. II
17
When DOH is ready to approve the document
we will notify you. At the time the governing
body will need to officially approve the Water
System Plan and send DOH documentation of
plan approval by the governing body, such as
a copy of the signed meeting minutes or a
copy of the signed resolution. When the
documentation is received we will send a
letter documenting DOH approval.
Thank you
N/A
Other Water System
Comments
The following are additional changes that have been made to the Water System Plan:
•
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The second paragraph of the introduction in the executive summary (page ES-1) was changed to: “The existing water system meets current standards
. There are, with some minor exceptions…”
Section 3.2.5 Anticipated Regulations was updated to reflect the change from 6-year to 10-year water system plan approval.
Section 3.3.1, Well #2 descriptions was updated to list the current screen interval, and the bottom of the hole.
Appendix N was updated with the City’s 2015 Consumer Confidence Report. The appendix previously had the 2014 Consumer Confidence Report.
Section 3.4.3 Storage, the storage for the Zone 2 reservoir was changed from 1.2 MG to 1.0 MG. This reflects the approved engineering report for the
new Zone 2 (Brotherhood) Reservoir. The storage calculations were update to reflect this.
Table 9.3 was updated to correctly show the outstanding water debt.
Section 9.4 was updated to show the correct water rates.
Section 9.7 was updated to show the ten-year CIP.
Table 9.7 and Table 9.10 were updated to show the ten-year CIP.
Section 9.10 was updated to show the water rate schedule that was adopted in 2016.