Mifflin County Water Supply Plan

MIFFLIN COUNTY COMMISSIONERS MIFFLIN COUNTY, PENNSYLVANIA

December 2000

GANNETT FLEMING Harrisburg, PA

Mifflin County, Pennsylvania

Mifflin County Water Supply Plan

December 2000

GANNETT FLEMING, INC.

Harrisburg, PA Mifflin County Commissioners Mifflin County Water Supply Plan

TABLE OF CONTENTS

1. INTRODUCTION ...... 1 Objectives ...... 1 Scope...... 1 Data Sources...... 1

2. COUNTY CONDITIONS ...... 3 Comprehensive Plan...... 3 Geologic Overview...... 3 Water Resources Overview...... 4 Watershed Planning...... 8 Population and Demographics ...... 8

3. WATER SYSTEM INVENTORY ...... 11 Inventory...... 11 Organization and Management...... 11 Rate Summary...... 12

4. WATER DEMANDS...... 16 Historical Demands...... 16 Projected Demands ...... 16

5. SYSTEM EVALUATIONS...... 21 Physical System Capacity...... 21 Management Capacity...... 27 Financial Capacity ...... 28

6. ALTERNATIVE PLANS ...... 47 Stand Alone (Individual) Approach...... 47 Cooperative (Regional) Approach...... 47 Alternative Plans and Estimated Costs ...... 47 Alternative Plan Discussion...... 48 Implementation Issues ...... 52

7. WATER SUPPLY PLAN ...... 53 Plan Summary...... 53 Plan Details...... 54 Implementation ...... 59 Public Involvement ...... 59 Plan Modification...... 60

TABLES

No. Title Page

2-1 Recorded and Projected Population...... 9 3-1 Community Water System Inventory ...... 13 3-2 Community Water System Organization and Management ...... 14 3-3 Community Water System Rate Summary ...... 15 4-1 Mifflin County Water Demands ...... 18 5-1 Evaluation of Physical System Capacity ...... 32 5-1A Summary of Physical System Capacity ...... 34 5-2 Evaluation of Management Capacity...... 35 5-2A Summary of Management Capacity...... 36 5-2B SDWA Violations...... 37 5-3 Financial Capacity Criteria and Evaluation Forms...... 40 5-3A Summary of Financial Capacity...... 46 7-1 Recommend Water Supply Plan ...... 55

APPENDICES

Appendix Title

A Water Facilities Inspection Report (Blank) B Data Source Index C Water System Overviews D Physical System Capacity Evaluations E Management Capacity Evaluations F Financial Capacity Indicators G Financial Capacity Evaluations H Water System Needs I Water System Alternatives

EXHIBITS

Exhibit Title

A Existing Water Systems B Karst and Non-Karst Geology C Karst Geology and High Yield Formations D Recommended Water Supply Plan

FIGURES

No. Title Page

2-1 Historic and Projected Population by Municipality...... 10 5-1 Required Net Yield for Surface Water...... 23 5-2 Required Net Yield for Ground Water Services...... 24 1. INTRODUCTION

Mifflin County is a rural county located in central Pennsylvania with sixteen (16) municipalities and fifteen (15) Community Water Systems (CWSs). These CWSs serve approximately 62% of the County’s population. Exhibit A shows the water systems of Mifflin County.

The last comprehensive review and evaluation of Mifflin County’s long-term water needs was conducted in 1979. The Mifflin County Board of Commissioners recognized the importance of safe, adequate, reliable, drinking water to the vitality of Mifflin County and decided to take an active role in updating the 1979 County Water Supply Plan. A grant was applied for and received from the Pennsylvania Department of Environmental Protection (PADEP) to assess the condition of the existing public water supply systems and to prepare a comprehensive countywide Water Supply Plan (Plan).

Objectives

The goal of the Plan is to provide a guidance document for the Mifflin County Commissioners, County and local planners, water suppliers, and other interested groups to follow and implement as they address water supply needs throughout Mifflin County. The Water Supply Plan provides basic information and the direction needed to make planning decisions to provide residents with safe, adequate, and reliable drinking water at reasonable cost.

Scope

The scope of work was derived from the PADEP Grant Application for County Water Supply Studies. The scope of work includes: collect and review available data and information; inspect existing CWSs and conduct staff interviews; compile available data; prepare water system overviews for each CWS; estimate water demands; evaluate existing water systems; identify potential deficiencies; formulate water supply alternatives; develop preliminary cost estimates for the selected alternatives; and develop recommendations for implementing improvements.

Data Sources

Data were collected from numerous sources. Each CWS was requested to complete an initial “Water Facilities Inspection Report”. A blank copy of the inspection report is included as Appendix A. The actual inspections reports which were completed for each CWS are on file. One or more site visits were made to each CWS, with the exception of North Hills Mobile Home Park (MHP), in an attempt to confirm the information provided Each CWS was requested to provide information about their system and its operation during the system inspections. The requested information included such items as: water allocation and supply permits, system map and facility drawings, customer and demand data, engineering reports, supply data and source protection plans, financial reports, water rate schedule, O &M Manual, Business Plan, etc.

PADEP records were also researched to obtain Annual Water Supply Reports, Consumer Confidence Reports, Filter Plant Performance Evaluations, Notices of Violations, Permits, Sanitary Surveys, and water quality data. The Pennsylvania Rural Water Association (PRWA) was contacted to obtain any information concerning leak detection, water conservation, or other studies conducted by the PRWA for the CWSs. Published annual audit information was obtained from the Public Utility Commission (PUC) and Department of Community and Economic Development (DCED). The Pennsylvania State Data Center (PSDC) was researched to obtain historical and projected population data. VanLandingham Consulting of Warriors Mark, PA made detailed population projections as part of the updated County Comprehensive Plan which projections were utilized herein.

Guidelines were obtained from both the PADEP and Environmental Protection Agency (EPA) for information to be included in the County Water Supply Plan. Appendix B, the Data Index, was used as a checklist to ensure that all sources of information were contacted for each CWS in Mifflin County.

The available data and information are compiled into Water System Overviews (see Appendix C) which were reviewed and commented on by each CWS. Complete or comprehensive data were not available for many of the CWSs. Incomplete data limits the analyses that can be performed. It may also indicate a lack of commitment to or knowledge of requirements associated with providing safe, adequate, reliable drinking water. The absence of information supports the conclusion of inadequate Management Capacity for many of the existing small systems in Mifflin County.

6 2. COUNTY CONDITIONS

Mifflin County has recently updated their Comprehensive Plan. The Comprehensive Plan provides a plan for managing growth within Mifflin County. It is an important reference document for this Water Supply Plan.

Overviews of the Comprehensive Plan and of geology, water resources, watershed planning, and population and demographics for Mifflin County are presented below to provide a backdrop for this study. These conditions are considered when projecting water demands, identifying potential water supply sources, developing alternatives, and evaluating solutions to water supply problems and needs in the Water Supply Plan.

Comprehensive Plan

The Comprehensive Plan is the official policy document of the County Commissioners with respect to growth and provision of services in the County. The Comprehensive Plan provides a blueprint for the future housing, land use, transportation, community facilities and utilities of the County. Water supply is an important utility service which must be provided to sustain growth and meet the needs of residents and businesses in the County.

Geologic Overview

Mifflin County is located in the Appalachian Mountains Section of the Ridge and Valley Physiographic Province. This area is characterized by alternating series of long, narrow, and even-crested ridges and broad to narrow valleys that are oriented in a northeast to easterly direction. Some karstic terrain exists in the valleys. Both the composition and structure of the bedrock units played a major role in the shaping of these landforms. Furthermore, marked differences in resistance to weathering and erosion of the various lithologies account for differences in topographic relief. Elevations above sea level in the County range from a low of 430 feet along the Juniata River to a high of 2,340 feet on Jacks Mountain. Other areas above 2,100 feet are Stone Mountain, Shade Mountain, and Blue Mountain. Big Valley, Ferguson Valley and the Juniata River Valley are the major valleys between the main ridge lines.

Exposed bedrock in Mifflin County is sedimentary in origin and includes 23 different geologic formations that range from Middle Devonian-Age to Ordovician-Age. The formations consist of conglomerate, sandstone, siltstone, shale, limestone and dolomite. In general, the limestone and dolomite formations underlie the valleys, the shale and siltstone formations underlie the foothills, and the formations containing conglomerate, sandstone, siltstone and shale underlie the ridges. The formation names, grouped in the three main periods, are as follows:

Devonian Age: Trimmers Rock Formation (siltstone and shale), Hamilton Group (sandstone, siltstone and shale), Onondaga and Old Port Formations (sandstone, shale and limestone).

Silurian Age: Keyser and Tonoloway Formations (Limestone), Wills Creek Formation (limestone and shale), Bloomsburg and Mifflintown Formations (siltstone, shale and limestone), Clinton Group (sandstone, siltstone and shale), Tuscarora Formation (sandstone)

Ordovician Age: Juniata Formation (sandstone, siltstone and shale), Bald Eagle Formation (sandstone and conglomerate), Reedsville Formation (siltstone and shale), Coburn, Salona, Nealmont, Benner, Snyder, Hatter, and Loysburg Formations (limestone), Bellefonte Formation (dolomite), Axemann Formation (limestone and dolomite).

In general, the older Ordovician rocks occur in the northern part of the County, and the younger Silurian and Devonian rocks in the southern part. However, because of extreme folding there is considerable repetition of the geologic formations, and often ridges several miles apart are underlain by the same formation. The resistant sandstone formations, such as the Tuscarora, Juniata and Bald Eagle Formations, form the steep topography and provide limitations to development in the County. The less resistant limestone and shale formations, such as the

7 Keyser and Tonoloway Formations and Clinton Group, form the valleys where present and future development can occur in the County. Exhibit B depicts the geology of Mifflin County.

Water Resources Overview

Mifflin County has four major watersheds that lie entirely within the Susquehanna River drainage basin. Two of these watersheds, the Juniata River and Penns Creek, drain directly into the Susquehanna River. The other two major watersheds in the County, the Kishacoquillas Creek and Jacks Creek, drain into the Juniata River. These watersheds form a trellis and angulate drainage pattern, with karstic drainage in some of the limestone settings. The four watersheds in the County are outlined below.

Juniata River Watershed: The Juniata River Watershed is located in the southwest section of the County between the slopes of Jacks Mountain and Blue Mountain. The municipalities located in this watershed are Newton Hamilton, Kistler, McVeytown and Juniata Terrace Boroughs, as well as Oliver, Bratton, Wayne and a portion of Granville Townships.

Penns Creek Watershed: The Penns Creek Watershed is located at the northeastern tip of the County on state forest land. Only a small portion of Armagh Township is located in this watershed.

Kischacoquillas Creek Watershed: The Kishacoquillas Creek Watershed is located in the northern half of the County and consists essentially of the land area north of Jacks Mountain. The municipalities located in this watershed are Burnham and a portion of Lewistown Boroughs as well as Menno, Union, Brown and portions of Granville, Armagh, Derry and Decatur Townships.

Jacks Creek Watershed: The Jacks Creek Watershed is located in the southeastern portion of the County bounded by the steep slopes of Jacks and Shade Mountain. The municipalities located in this watershed are a portion of Lewistown Borough as well as all of Decatur and a portion of Derry Townships.

Mifflin County has abundant water resources resulting from an average annual precipitation of about 37.5 inches. Based on water budget analyses of watersheds within the Juniata River basin, stream discharge represents about 40 to 48 percent of precipitation, or about 15 to 17 inches. In a normal year, about 0.763 million gallons of water per day per square mile is recharged to the surface water and groundwater systems in the County. Because Mifflin County is about 431 square miles in size, on average there are about 329 million gallons per day of total water resources available countywide.

Groundwater base flow data can be used to calculate the average groundwater discharge per unit of land surface. This is a practical estimate of the limits of development for a particular basin or aquifer. Long-term groundwater withdrawals in excess of the average discharge can cause a progressive lowering of water levels and severely reduce the flow of streams. Approximately 66 percent of stream discharge is supplied by groundwater, either by flow from springs or by direct seepage to streambeds. Groundwater constitutes a greater percentage of stream discharge in carbonate rock settings than in other rock settings. This is demonstrated by data from the Kishacoquillas Creek Watershed, which is substantially underlain by carbonate rock, where base flow averaged 76 percent of stream discharge. Based on these percentages, groundwater available in the County ranges between 217 million and 250 million gallons per day.

Groundwater supply available to a drilled well is controlled largely by the size, number, distribution and degree of interconnection of the water-filled openings in the rock. Rock type is the most important factor to locate a high yielding well, because the degree of porosity and permeability varies according to lithology. For example, limestone and calcareous sandstone formations within the County generally yield more groundwater than the shale, siltstone and siliceous and conglomerate sandstone formations.

Geologic formations within the County that tend to store and yield larger quantities of groundwater are the Hamilton Group, Old Port Formation, Keyser and Tonoloway Formations, Wills Creek Formation, Clinton Group, Bellefonte Formation and the Axemann Formation. Reported yields of wells drilled in all but one of these formations range

8 from 1 to 675 gallons per minute. The highest yielding unit reported in the County is the Ridgeley Sandstone member of the Old Port Formation. This unit tends to yield excellent-quality water and two wells drilled in the unit are reported to yield 1,350 and 1,400 gallons per minute. The higher yielding formations typically contain calcareous rocks and form the valleys in the County. The Old Port Formation, which contains the Ridgely Sandstone, underlies the lower elevation hills in the County, including Big Ridge, Front Ridge, Middle Ridge, Church Ridge, Gearhart Ridge, Long Hollow Ridge, and Sandy Ridge. Other factors that influence well yields are the topographic setting, particularly as it relates to available recharge area, and the underlying geologic structures, which include faults, folds and rock bedding orientation.

PADEP has developed water quality standards for all surface waters in the Commonwealth. These standards, which are designed to safeguard the streams, rivers and lakes throughout Pennsylvania, include use designations (e.g., “special protection waters,” “cold water fishery,” “warm water fishery,” etc.) and water quality criteria necessary to protect the designated uses. Special protection is provided for streams designated as “exceptional value” or “high quality” waters. Most streams in Mifflin County are classified as “cold water fishery”. Many of these streams, particularly smaller streams with reaches in higher elevations, are classified as “high quality” waters and include Furnace Run, Beaverdam Run, Wharton Run, Shanks Run, Musser Run, Town Run, Wakefield Run, Carlisle Run, Strodes Run, Minehart Run, Granville Run, Tea Creek, Honey Creek and Penns Creek. Wastewater treatment plant effluent and any other discharges to streams classified as “high quality” are only permitted by the PADEP if the discharge is the result of necessary social and economic development, water quality standards are maintained, and all existing uses of the stream are protected. This has the effect of requiring all wastewater treatment plants to provide “tertiary” treatment to meet discharge criteria. The Kishacoquillas Creek (and its tributaries, below Tea Creek), Jacks Creek and Buck Run, are classified as “trout stocked fisheries”. These creeks maintain stocked trout from February 15 to July 31 and maintain and propagate fish species and additional flora and fauna that are indigenous to a warm water habitat. The Juniata River is the only surface water body in the County classified as a “warm water fishery.”

Based on water quality studies performed by the Susquehanna River Basin Commission (SRBC) in 1996 and 1997, the Juniata River supports healthy biological communities and has good quality water throughout its length. Likewise, most of the streams in the Juniata River Watershed have good to excellent water quality. However, water pollution problems exist in a few stream reaches due to agricultural, municipal and industrial sources. The Frankstown and Beaverdam Branches of the Juniata River, which are up-stream of reaches within Mifflin County, suffer from industrial and municipal discharges. This condition is expected to improve as municipal systems are upgraded. The 1996 and 1997 study results indicate that of the 24 miles of the Kishacoquillas Creek assessed, only 9 miles fully attained designated use criteria (physical, chemical and biological data) established by the SRBC in earlier studies. Major and minor causes of the Kishacoquillas Creek use impairment were siltation and nutrients caused by agricultural and urban runoff, and unidentified point sources.

Groundwater quality in Mifflin County is generally very good and suitable for potable uses. The major differences in the water chemistry in the various rock units exists primarily between water from calcareous rock units and from noncalcareous rock units. The calcareous rocks typically have groundwater with higher dissolved solids, higher hardness, and greater susceptibility to elevated nutrient and bacteriological loadings from sewage and agricultural activities. The most troublesome natural constituents in water from the noncalcareous rocks are iron, manganese and hydrogen sulfide.

Groundwater quality is at risk in localized areas of the County that have commercial, industrial and concentrated agricultural businesses. These types of businesses should be inventoried prior to public groundwater supply development activities to minimize the potential for contaminated sources. The EPA currently lists three sites contaminated with hazardous waste in Mifflin County on its Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) database. These sites are located in Lewistown and Maitland. The EPA also lists approximately 80 hazardous waste handlers within the County on its Resource Conservation and Recovery Information System (RCRIS) database.

Other pollution sources of concern are concentrated animal feeding operations (CAFOs). These operations are defined by PADEP as facilities with either more than one million pounds of live animal weight, or concentrated animal operations with 301,000 to 1,000,000 pounds of live animal weight that are located in “special protection

9 watersheds” or have potential to discharge to surface waters. Concentrated animal operations (CAOs) are defined by PADEP as an operation with 2,000 pounds of live animal weight per acre of land suitable for manure application and owned or managed by the farmer. Many CAOs exist in the County as shown on Exhibit C. In addition, one CAFO exists in Granville Township and another has been proposed in Wayne Township. Farms with a high concentration of animals must have adequate storage facilities for the manure they generate. When the storage facilities are properly designed, constructed and managed, manure is an environmentally safe source of nutrients and organic matter necessary for the production of food, fiber and good soil health. CAFOs must also develop Nutrient Management Plans and Erosion and Sediment Control Plans to help protect water quality. CAFOs should also construct monitoring wells at the site for periodic monitoring of groundwater quality and early detection of manure storage leaks. In carbonate rock settings, it is also prudent to monitor the water quality at off-site locations. PADEP requires proposed operators to obtain permits. The permit requirements are derived from the Federal Clean Water Act and PADEP's National Pollution Discharge Elimination System (NPDES) Program regulations. Fortunately, public participation is required for all CAFO permits. Therefore, existing or potential groundwater supply sources can be protected via public involvement. Furthermore, PADEP plans to begin assessment of potential manure discharges from existing large CAFO manure storage facilities by 2002. PADEP will assess facilities in “high quality” and “exceptional value” watershed areas first.

As a general planning guideline, CAFOs and CAOs should not be located in close proximity to existing or proposed development, in areas which overlay karst terrain, within special protection watersheds, near public water supply sources and the areas which contribute flow to the source, and in areas where future public water supply development is likely. Exhibit C shows areas where CAFOs and CAOs should generally be restricted due to karst geology and public water supply development potential. It should be noted, however, that these guidelines do not give the County the legal right to prohibit CAFOs and CAOs. That right rests with the individual municipalities based on adopted ordinances. PADEP and other regulatory agencies also are involved with permitting of these operations as noted previously.

Because groundwater is the primary source of supply for many CWSs and there is karst geology in certain regions of Mifflin County, it is prudent to protect these sources of public water supply. Those areas with karst geology which provide, or will provide, public drinking water through either groundwater or surface water sources should be protected from potential sources of contamination such as commercial or industrial discharges, concentrated agricultural or animal run-off, and other hazardous wastes, to the maximum extent practical.

Watershed Planning

On October 4, 1978, the Pennsylvania General Assembly approved the Stormwater Management Act, P.L. 864, No. 167. Act 167 was adopted based on the Statewide recognition of the adverse effects of inadequate management of excessive rates and volumes of storm water resulting from development. Act 167 requires all Pennsylvania counties to prepare and adopt storm water management plans for each watershed located in the county. The plans are to provide for uniform standards and criteria throughout a watershed for the management of storm water flowing from development sites through implementation by local municipal ordinances. In Mifflin County, an Act 167 Stormwater Management Plan has been completed for the Jacks Creek Watershed. This plan was approved by the PADEP in February 1996. Furthermore, Phase 2 of an Act 167 Plan for the Kishacoquillas Creek Watershed, which includes Honey, Tea and Laurel Creeks, is under preparation.

Population and Demographics

The recorded and projected population data for Mifflin County and its municipalities are presented in Table 2-1 and Figure 2-1. The population of Mifflin County increased from 45,268 persons in 1970 to 46,908 persons in 1980, and then decreased to 46,197 persons in 1990. County population is projected to increase from 1990 to 2000 to 47,744 people.

County projections indicate an overall growth of 10.0% between 2000 and 2020. Municipal population trends and projections are detailed in Table 2-1 and Figure 2-1, and are taken directly from projections made by

10 VanLandingham Consulting for the Mifflin County Planning and Development Department. The highest percentage growth areas are projected in Armagh, Brown, Decatur, Granville, and Oliver Townships. Significant negative growth (percentage basis) is projected for Burnham, Kistler and Lewistown Boroughs.

County data shows that the median household income is $22,778, 9.5% of the families are living in poverty, and approximately 13.2 % of households are headed by persons 65 years of age or older.

11 INSERT TABLE 2-1

INSERT FIGURE 2-1

13 3. WATER SYSTEM INVENTORY

A community water system, as defined by the Pennsylvania Safe Drinking Water Act (SDWA), is a system that provides water for human consumption to at least 15 service connections or 25 persons year round. By this definition, there are 15 CWSs serving residents in Mifflin County. Water system locations and general service areas are shown on Exhibit A. Important information about each system is summarized and provided herein. An evaluation for each CWS is presented in Section 5 of this Plan and Appendices D, E and G.

Inventory

Water system overviews for each CWS were prepared and are presented as Appendix C. Table 3-1 lists each CWS, public water identification number, area(s) served, source information, 1998 maximum day demand, treatment processes and permitted capacity, finished water storage, and general customer service pressure. This inventory summarizes the physical features and capabilities of each system, and can allude to potential source water, treatment capacity, finished water storage, and/or customer pressure deficiencies.

In general, 9 of the 15 CWSs have an existing source of supply deficit; 2 of the 15 have a treatment capacity deficit; 9 of the 15 have a finished water storage deficit; and, while all of the 15 CWSs have customer service pressures greater than 25 pounds per square inch (psi), several of the small systems may not meet hydraulic requirements under peak demand conditions.

Organization and Management

Mifflin County water systems are classified by their ownership as follows: Authority, Municipal, or PUC. The ownership type will become important in the Financial Evaluation of each CWS (see Section 5). Indicators such as the existence of a Management and Administrative Plan and Operations and Maintenance Manual, or having at least two (2) part-time Certified Operators, give preliminary indications of a CWS either having, or not having, Management Capacity. An organization and management inventory is presented in Table 3-2. There are 5 systems organized as Authorities, 2 systems are classified as Municipal organizations, and 8 systems are private and regulated by the PUC.

None of the 15 CWSs have a Management and Administrative Plan, except Lewistown and Granville. Most of the CWSs have an Operations and Maintenance Manual or related materials, except Allensville, Edgewater, Fairview and Menno. Only 6 of the 15 CWSs have Certified Operators.

14 Rate Summary

A summary of available rate data are presented in Table 3-3. Detailed financial information is available for 6 of the 15 CWSs, and a total of 9 were able to provide rate information. This table compares quarterly rates of each CWS and can indicate a potential under billing for water service. Using rate schedules provided by each CWS, a typical quarterly charge for residential customers is estimated based on a usage level of 5,000 gallons per month. The resulting quarterly charge for a residential connection ranges from $37.00 to $87.00 for Authorities; $42.75 to $73.20 for Municipal systems; and $11.25 to $44.07 for PUC regulated systems. Most of the small, private systems (MHP’s) do not charge for water services separately.

15 INSERT TABLE 3-1

INSERT TABLE 3-2

17 INSERT TABLE 3-3

18 4. WATER DEMANDS

The projection of CWS water demands is based on analysis of past and present demands, and historic population trends and future population projections for the municipalities of Mifflin County. Water demands are projected for each system through the year 2020, and are used to evaluate the ability of the system to supply future demands.

Historical Demands

Annual Water Supply Reports (AWSRs) for each CWS were compiled for the past five (5) years to establish trends in water usage by customer type (residential, commercial, industrial, institutional, bulk, and other) and unaccounted for water. Historic average daily demand and maximum daily demand for each system were also compiled. Average customer demand (gpd/customer) was calculated, along with the maximum day to average day demand ratio.

It is noted that several of the CWSs do not routinely submit AWSRs to the PADEP. This is an indication of poor Management Capacity (see Table 5-2) and makes it difficult to develop future water demand projections.

Projected Demands

The water demand data reported in the AWSRs was often incomplete (see Table 4-1) or contradictory to the information obtained and reported in the Water System Overviews (Appendix C). In order to supplement the missing or reported demand data, estimated demands were prepared for these CWSs and are presented in Table 4-1.

Table 4-1 projects future water demands based upon analysis of past demands, consideration of recorded and projected population data, customer projections and other assumptions. These projections were reviewed by each CWS.

Average daily demand (ADD) is the total amount of water supplied to the water system during the year divided by 365, and includes consumption and unaccounted-for water. Unaccounted-for water is the difference between the amount of water delivered to the system, ADD, and the amount of water consumed by the customers. It includes such unmetered uses a hydrant flushing, fire fighting, main leakage, distribution storage overflow, and unmetered service to special customers. It is also influenced by meter registration inaccuracies. Until recently, the common industry standard is to keep unaccounted-for water below 15% of ADD. However, the American Water Works Association (AWWA) Leak Detection and Water Accountability Committee, in a July 1996 AWWA Journal article advised “Advances in technologies and expertise should make it possible to reduce lost and unaccounted-for water to less than 10 percent”.

If ADD was reported but no metered consumption data was available, the unaccounted-for water is included, by default, in the ADD. No interpretation of the data was attempted to quantify the unaccounted-for water.

Maximum daily demand (MDD), which represents the maximum amount of water supplied to the water system in any one day, is also important in evaluating system capacity. If MDD was not reported, it is typically estimated at 1.5 times the ADD.

Total projected water demands for 2005 and 2020 are presented for each CWS in Table 4-1.

Current and projected water demands are used as the primary indicator for current and future Physical System Capacity.

19 INSERT TABLE 4.1

TABLE 4.1

5. SYSTEM EVALUATIONS

A capacity evaluation of the existing Community Water Systems (CWSs) in Mifflin County was performed to assess the capabilities and needs of each water system. The assessment is divided into three parts: Physical System Capacity (Table 5-1); Management Capacity (Table 5-2); and Financial Capacity (Table 5-3). Each CWSs capacity was evaluated by comparing the available data against selected indicators.

The Physical System, Management, and Financial Capacity criteria are based on guidelines and regulations set forth in the following regulations and PADEP publications:

• Safe Drinking Water Regulations (Chapter 109) • Public Water Supply Manual • County Water Supply Plan Content Document • Planning Criteria for Determining Adequacy of Water Supply Sources • Evaluating Business Plans for Small Drinking Water Systems Manual

Industry standards contained in American Water Works Association (AWWA) references and other professional publications are also used to develop the evaluation criteria. PADEP reviewed the criteria for consistency with the above mentioned documents. All comments have been incorporated into the final evaluation criteria.

The general criteria for Physical System, Management, and Financial Capacity are given in the following sections.

Physical System Capacity

Physical System Capacity criteria are outlined in Table 5-1. This document was completed for each CWS as part of the systems evaluation. The criteria establish a uniform set of standards for evaluating the water supply sources, treatment system, finished water storage, and pumping, transmission and distribution facilities capacity. Each CWSs facilities are compared to the indicators to determine system capacity and identify areas that require attention. The indicators themselves are presented in the form of a question and are intended to be self-explanatory. A warning flag is triggered when a “Yes” or “No” response is assigned to a given indicator. A blank space indicates that no warning flag has been generated. A Yellow Warning Flag indicates that a given indicator may not meet the criteria presently (1998) or in the future (2020) and time is available prior to the promulgation of new regulations to correct the potential deficiency. A Red Warning Flag indicates that the criteria are not being met for a given indicator and/or it does not comply with regulations. The Physical System Capacity evaluations for each CWS are presented in Appendix D and summarized on Table 5-1A and herein below.

Daily Demands

The average and maximum day demands for each CWS are indicated for the years 1998 and 2020 as a reference for some of the indicators.

Water Supply Source Capacity

CWSs in Mifflin County use surface water, groundwater, interconnections with neighboring systems, and combinations of sources to satisfy water system demands. Different evaluation criteria are used for systems using surface water sources and interconnections, systems using ground water sources, and systems using combined sources. The key outcome of each evaluation is the capability of the existing water supply source or sources to supply the net demand or yield for the system.

The systems net yield is a function of total raw and finished water storage in the system and system water demands. The required source net yield ranges between system average daily demand and maximum daily demand, depending on the volume of total storage in the system and the type of source or sources a system is using. The required net yields for the systems are compared to the permitted water allocation for systems using surface water sources and interconnections with neighboring systems. For systems using groundwater sources the required net yields are compared to the documented safe yield of the well or to the well pump capacity, which ever is limiting. Other criteria used to evaluate water supply sources include drought impact, the availability of a contingency or backup source, and the implementation of source water protection measures. The age and condition of the supply structures are also included in the evaluation criteria.

Surface Water Sources and Interconnections

The required net yield for systems using surface water sources or interconnections with neighboring systems is calculated by determining the storage/demand ratio for the system, and then using the storage/demand ratio to determine the portion of the system demands the source(s) must yield. The storage/demand ratio is calculated by dividing the total system storage, including raw and finished water storage, by the average daily demand of the system. The finished water storage capacity is shown in Table 3-1. Water demands are summarized in Table 4-1. The calculation of the storage/demand ratios is done individually for each system.

If total system storage is greater than seven times the average daily demand (storage/demand ratio greater than 7), the required net yield for the system is equal to the average daily demand. If total system storage is less than the average daily demand (storage/demand ratio is less than one) the required net yield for the system is equal to the maximum daily demand. If total system storage is between one and seven times the average daily demand (storage/demand ratio is between one and seven) the required net yield for the system is defined by a linear relationship between the maximum day demand and the average day demand. A plot of the relationship between required net yield, demand, and total system storage is shown in Figure 5-1 for surface water and interconnect sources of supply.

MDD

Required Net Yield Required Net Yield (gpd)

ADD 012345678 Storage / Demand Ratio

Figure 5-1 Required Net Yield for Surface Water and Interconnect Sources

Source adequacy evaluations for the water systems using surface water sources and interconnections with neighboring systems show that 4 of the 7 CWSs that use surface water or interconnections have inadequate source capacity; including Allensville, Fairview, Menno and Mount Union.

In addition, 4 of the 7 systems do not have supplemental raw water sources of supply, including Allensville, Fairview, Newton-Hamilton and Wayne.

Groundwater Sources

The required net yield for systems using groundwater wells and springs as water supply sources is calculated similarly to systems using surface water and interconnections with neighboring systems. As with surface water sources, the required source net yield is calculated by determining the storage/demand ratio for the system and then using the storage/demand ratio to determine the portion of the system demands the source must yield. Because groundwater systems typically do not have raw water storage, the storage/demand ratio is calculated by dividing the total system finished water storage by the average daily demand of the system. The calculation of the storage/demand ratios is done individually for each system based upon information from Tables 3-1 and 4-1.

The yields from groundwater wells and springs can be influenced by numerous unforeseeable factors. To allow for these uncertainties a safety factor of 1.2 is applied to the portion of the demand the source must yield. If total system storage is greater than seven times the average daily demand (storage/demand ratio greater than 7), the required net yield is equal to 1.2 times the average daily demand. If total system storage is less than the average daily demand (storage/demand ratio less than one), the required net yield is equal to 1.2 times the maximum daily demand. If total system storage is between one and seven times the average daily demand (storage/demand ratio is between one and seven), the required net yield is defined by a linear relationship between 1.2 times the maximum day demand and 1.2 times the average day demand. A plot of the relationship between required net yield, demand, and total system storage is shown in Figure 5-2 for groundwater sources.

1.2 X MDD

Required Net Yield Required Net Yield (gpd)

1.2 X ADD

ADD 012345678 Storage Demand Ratio

Figure 5-2 Required Net Yield for Ground Water Sources

Most of the 8 water systems that use groundwater sources have adequate source capacity, except for the Edgewater MHP. Groundwater well yield and well pump data were unavailable for several of the smaller systems. These include the Edgewater MHP and North Hills MHP. In addition, 3 of the 8 CWSs using groundwater do not have supplemental sources of supply, including Edgewater MHP, Granville and Meadowview Manor.

Multiple Sources

A weighted-average net yield is used to determine the required net yield for systems that use a combination of surface water and ground water sources to supply system demands. The required net yield for the surface water source and the ground water source is calculated as described above. The net yield weighted-average is then calculated using the following equation (Equation 5-1):

ARcombined = {(G) ARg + (S) ARs} / {G + S}

where ARg = Ground Water Net Yield ARs = Surface Water Net Yield G = Yield of Ground Water Source S = Yield of Surface Water Source

The Lewistown Municipal Water Authority and Menno Water Association are the only Mifflin County CWSs that use a combination of surface and groundwater sources. Based on the evaluation criteria, Lewistown has adequate source capacity, while Menno’s water supply sources are not capable of meeting the projected demands of the system.

Treatment System Capacity

Water treatment facilities in Mifflin County range from complex ozonation, flocculation, clarification, and filtration systems to simple chlorination systems. Treatment system capacity is evaluated for the systems that provide some form of filtration. An inventory of the water system filtration facilities is shown in Table 3-1. Water systems that only have chlorination facilities are assumed capable of meeting the projected system demands because of the relatively low cost for upgrading chemical feed equipment and the adjustable outputs of such equipment. The age and condition of the filtration facilities are also included in the evaluation criteria.

Water systems with filtration facilities are evaluated based on the ability of the treatment system to produce finished water at a rate equal to the systems maximum daily demand with one (1) filter off- line. A comparison of permitted hydraulic capacity, calculated capacity and maximum daily demands for the years 1998 and 2020 are presented in Appendix D for those systems which provide filtration treatment.

There are 4 CWSs that provide some form of filtration. Three systems use gravity filtration and 1 system uses pressure filtration. Allensville, Lewistown and Mount Union utilize gravity filters and treat surface water supplies, while Hillside Terrace uses pressure filters for their groundwater supply.

The Fairview and Menno systems utilize water surface supplies without filtration treatment, and are in violation of SDWA requirements, specifically the Surface Water Treatment Rule.

Finished Water Storage Capacity

The water supply source capacity evaluations did not specifically assess finished water storage requirements nor did they assess fire storage needs in the CWSs. Therefore, a separate evaluation of finished water storage is performed to assess the available volume of storage to offset daily peak demands and fire storage in the systems. The finished water storage capacity is evaluated based upon the average daily demand for 1998 and 2020. The information is presented in the Physical System Capacity evaluations in Appendix D for each CWS.

At a minimum, each water system should have at least one average day’s demand in finished water storage to offset daily peaks and protect against temporary system failures. The finished water storage volume in each water system was compared to present and projected average daily demands to identify finished water storage needs. Six of the 15 CWSs do not have finished water storage facilities, and one system has less than an average day’s demand in finished water storage. Those systems include Edgewater, Elsessers, Fairview, Hillside Terrace, Meadowview Manor, and North Hills. Newton Hamilton does not have its own storage, but is covered by distribution storage provided by the Mount Union system.

Fire storage capacity was evaluated for each CWS that contained fire hydrants. To evaluate fire storage capacity, an estimated system fire demand based on the type of connections served in the system is added to the projected average daily demand. This combined storage requirement is compared to the system finished water storage volume which is useable to the system to assess fire storage capacity. Nine of the 15 CWSs have fire hydrants, but only six of those provide sufficient finished water storage to satisfy daily system demands and the estimated fire storage needed for the system. The 3 that are deficient include Allensville, Forest Hills and Menno.

Pumping, Transmission, and Distribution Capacity

The pumping, transmission and distribution facilities of each water system are assessed to identify areas in need of improvement. Evaluations of pumping facilities were limited to raw water pumping and finished water (high service and interconnect) pumping. Appendix D evaluations summarize the capacity, condition, and remaining useful life of the pumping facilities. Pumping capacity was difficult to assess in some systems due to lack of data. Pumping deficiencies were identified at 5 of the CWSs, including Edgewater, Granville, Hillside Terrace, Meadowview Manor and Menno.

Transmission and distribution system facilities are evaluated to assess pipe size versus its intended use; the ability of the CWS to provide 25 psi pressure to the highest customer under average day demand conditions; the metering of individual customers; and the system’s unaccounted-for-water. A summary of the transmission and distribution system adequacy evaluations is presented in Appendix D. For those systems with fire hydrants, main sizes need to be 6-inches or larger for fire service adequacy. Main sizes are based upon a review of available system mapping and reported conditions. A hydraulic analysis was not conducted for each CWS to assess the ability of the transmission and distribution system facilities to deliver flows at sufficient pressures. A key parameter in assessing the condition of the distribution system is unaccounted-for water. Unaccounted-for water is water lost to unmetered uses and/or leaks in the system. Unaccounted-for water that exceeds 15 percent of the average daily demand is present in 2 of the 4 CWSs, for which data is available. Data is unavailable for 10 of the remaining 11 systems because these systems are not metered. Customer metering is needed to assess unaccounted-for water. Leak detection studies are recommended for those systems with unaccounted-for water greater than 15 percent.

Management Capacity

Management Capacity criteria are outlined in Table 5-2. The criteria establish a uniform set of standards for evaluating the Management Capacity of each CWS. The evaluations were based on review of available records, reports and information secured from the CWS and regulatory agencies. The assessment generally revolves around the history of the CWS to comply with current or future SDWA regulations. The criteria are compared to the indicators to determine system capacity and identify areas that require attention. The indicators themselves are presented in the form of a question and are intended to be self-explanatory. A warning flag is triggered when a “Yes” or “No” response is assigned to a given indicator. A blank space indicates that no warning flag has been generated. A Yellow Warning Flag indicates that there is a potential regulatory violation. A Red Warning Flag indicates that there is a regulatory violation.

No single indicator provides a clear indication of Management Capacity (adequacy). A negative indication in a particular area does not necessarily mean that a system is inadequate. Judgment must be used in interpreting the data presented in Table 5-2. The Management Capacity evaluations for each CWS are presented in Appendix E and summarized on Table 5-2A and herein below.

Raw Water Quality

Certain contaminants in the raw water supply may require treatment if they exceed the regulatory maximum contaminant level (MCL). No warning flags are triggered for this category because compliance issues are addressed in the Finished Water Quality section.

There are several ways in which a source of drinking water supply may be contaminated. If source water protection measures are not in-place a Yellow Warning Flag is triggered.

Finished Water Quality

Warning flags are triggered for this category if regulatory parameters are not being met. See Table 5- 2B for a description of PADEP violations. A Yellow Warning Flag is triggered if minor improvements are necessary to comply with future regulations. A Red Warning Flag is triggered when major improvements are necessary to comply with future regulations. Further explanations of the warning flag indicators are given in each CWS’s evaluation. In general, the existing CWSs are in compliance with Safe Drinking Water Regulations. The two exceptions are the Fairview and Menno systems which are not in compliance with the Surface Water Treatment Rule. Many of the smaller systems may have difficulty meeting future regulations.

Other Management Capacity Indicators

The remaining Management Capacity indicators are referenced in the Public Water Supply Manual, County Water Supply Plan Content Document and 25 Pa. Code Section 109.701. Many of the smaller systems, especially non-municipal systems, are not in compliance with these indicators of Management Capacity.

Financial Capacity

Financial Capacity indicators are outlined in Table 5-3. The criteria establish a uniform set of standards for evaluating the Financial Capacity of the CWS. The existing water systems are compared to the indicators to determine financial capacity and identify areas that require attention. As of October 1, 1996, any new Community Water System (CWS) applying for a construction permit under the Safe Drinking Water Act (SDWA) must prepare a Business Plan and submit it to PADEP as part of the permit application. The document entitled, “Evaluating Business Plans for Small Public Drinking Water Systems Manual”, by Apogee Research, Hagler Bailly and Cadmus Group, Inc., date unknown, was designed to provide guidance on how to evaluate Business Plans for CWSs. This document can also be used as an indicator of an existing CWSs financial capacity. It should be noted that the aforementioned document focused on small drinking water systems in Pennsylvania with 1,000 connections or less. While the information in Table 5-3 can be applied to larger systems (greater than 1,000 connections), care must be used in applying the data.

Definitions of Financial Indicators

Definitions of the financial indicators used in developing a new system Business Plan are included as Appendix F. Please note that not all indicators apply to all water system ownership categories. Table 5-3 presented at the end of this section, group the indicators by ownership category (Authority, Municipal and PUC).

Financial Indicators

The following Table 5-3 presents the numerical distributions for indicators and the warning flags for Financial Capacity indicators. There is a separate table for each ownership group, including Authorities, Municipalities, and PUC’s.

For each indicator, values are provided for every ten-percentile points. A percentile is a value on a scale of one to one hundred that indicates the percent of the distribution that is equal to or below it. As an example, a score of 90 percentile means that the value for the indicator is larger than or equal to the scores of 90% of the systems in the database, and that 10% of the systems had larger values. Remember that the database used for these guidelines included all Pennsylvania community drinking water systems serving less than 1,000 customers. For the Financial Capacity indicators, the database includes only those small systems of the same ownership type. The attached tables use the information available from each CWS to determine the system’s value for a given indicator. Then, that value is compared to the percentile table for the appropriate ownership category. The percentile score of the range is selected for the value that most closely fits without exceeding. This then becomes the percentile score for that indicator for the CWS.

Each indicator has to be read individually. For some indicators, the higher the percentile scores, the better. For some, the lower the better. For many indicators it is better to be near the median as opposed to being in either tail of the distribution. Please also remember that the sample includes many systems that have one or more areas of capacity which are weak. Therefore, saying a system is near the median, and therefore like may other small systems of the same ownership type, is not necessarily an endorsement of that system’s capacity and viability. In addition, while there is a common sense relationship between the indicators and small drinking water system capacity, by definition, a correlation has not been statistically validated except for the indicators cited.

However, the percentile scores do provide an idea of where the CWS stands. If a system has many scores in the extreme ends of the distribution it indicates that a more serious look at the system is needed.

For each indicator, warning flag scores are provided in addition to the percentile distributions. Both yellow and red flag scores are given. Some financial capacity indicators may apply to one ownership category, but not for all. For demographic and system characteristic indicators, the percentile distributions are unique for each ownership class, but the warning flags scores are consistent among ownership categories.

Warning Flags

Values which signal that a system’s performance or projected performance is similar to other systems that lack capacity is the basis for concern. “Yellow Warning Flags” (YWFs) indicate the point where systems begin to show indications of poor performance in critical areas and “Red Warning Flags” (RWFs) are when key indicators slip even further to a point where most systems exhibiting similar characteristics are having problems meeting important planning and service objectives. A warning flag should not be confused with a finding of a capacity or lack of capacity. It is simply a point at which many (but not necessarily all) water systems with similar characteristics are experiencing trouble. Thus, for example, a water system that has just one indicator that triggers a warning flag may not be in trouble. But a system that exhibits numerous characteristics in common with troubled water systems is very likely to be in need of assistance.

Interpretation of Financial Performance Indicators

The completed Financial Capacity evaluations yield a quick snapshot of where each system stands in relation to other systems and to the validated warning flag values. It is important to remember that no single indicator is sufficient to tell the whole story. This is particularly true within the financial indicators where a weakness in one area may be offset by compensating strength in another area. It is the overall patterns of weakness or strength that

tell the overall Financial Capacity of a given system. In addition, there is no standard formula for combining indicators into an overall picture of the Financial Capacity of a given system. Each system will present a different pattern. These patterns must be interpreted individually. Net Income is significantly correlated with the performance of all small water systems.

Without adequate revenue the system will not be able to support itself. A system needs sufficient revenue to cover operating and non-operating expenses, capital improvements, replacements and emergencies. If there is not sufficient revenue to cover current expenses and contribute to reserve funds, it is likely that the system will face an emergency, or need new or upgraded equipment that will require a significant rate increase or outside funding.

Each ownership group (Authorities, Municipalities, PUCs) has its own indicators that have been significantly correlated with small system performance.

Authorities

Current Ratio

When the equity ratio increases significantly (75% or above), it could be an indication that the system is failing to invest in new plant and equipment, or that it is not managing its finances properly (for instance, by failing to issue new debt).

Expense per 1000 gallons, Revenue per Connection ($/connection), and Expense per Connection ($/conn/year)

All three of these indicators show that lower unit costs (and revenues) are desirable. The municipal authorities that are well-operated have lower production costs (measured both by expenses divided by average production and by expenses per service connection).

Average Revenue as a Percent of Median Household Income

Municipal authorities whose revenues approach 1.5% of median household income appear to be having trouble in several areas. There could be several reasons for the importance of this indicator. For example, it could be identifying systems that are in high-income areas. The desirable level appears to be in the range of 1.0 to 1.2% of median household income. When this ratio approaches 1.5%, it appears to be an indication of problems in several areas.

Municipalities

Operating Revenue, Operating Expenses, and Total Assets (dollars)

Larger systems are significantly more likely to be in better condition than smaller systems. These three indicators that measure the size of the system were strongly related to the amount of water produced by the system.

Expenses per Connection ($/conn/year), and Revenue per Connection ($/connection)

The level of both operating expenses per connection and revenue per connection are significantly higher in systems that were evaluated to be “good/excellent”. It is reasonable to conclude that these systems are accounting for full costs of operation and/or several large customers may exist resulting in higher revenues and expenses per connection. The existence of one or more large customers would be problematic, however, if they significantly reduce water usage or leave the system.

PUCs

Current Ratio and Other Basic Income Measures (Cashflow and Net Income)

It is important for the system to have revenues that are well in excess of expenses. The operating ratio for these privately-owned systems appears to be even higher than it was for the government-owned systems, probably because of the income tax obligations and higher debt costs of privately-owned systems (operating expenses here do not include depreciation, debt service, or income taxes). This fact also would account for the correlation of viability with other basic income measures.

Expenses per 1000 gallons, Revenue per Connection ($/connection), and Average Revenue as a percent of Median Income

Relatively higher levels of revenue, expense, and net income appear to be required for privately-owned systems. It appears that the small privately-owned systems that are experiencing trouble are spending too little and collecting revenue that is too low. This may indicate that the problem is not one of size, but rather that the system is failing to spend enough money to ensure adequate operations. In particular, the better systems in this category are spending more money per customer (revenue per connection), and have a slightly higher ratio of revenue as a percentage of median household income (average revenue as a percent of median income).

Individual Community Water System Financial Evaluations

Each CWS was evaluated based upon the previously explained Financial Capacity criteria. Financial Capacity evaluations were made for each CWS from the information obtained from various sources and the CWSs annual audit. The evaluations are included as Appendix F and summarized herein. Except for Lewistown, most of the systems have inadequate Financial Capacity.

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TABLE 5-2B SDWA VIOLATIONS

Mifflin County Commissioners Mifflin County Water Supply Plan

MAXIMUM CONTAMINANT LEVEL (MCL) VIOLATIONS:

PADEP has set MCLs for specific contaminants. Water systems must monitor for these contaminant levels on fixed schedules and report to PADEP when an MCL has been exceeded.

• MCL, acute (TCR) - System tested positive for fecal coliform or repeated a positive test for E. Coli or total Coliform or tested positive for E. Coli following a Fecal Coliform Routine Test • MCL, monthly (TCR) - For systems testing more than 40 samples, more than five percent tested positive for Total Coliform or for those systems testing less than 40 samples more than one sample tested positive for Total Coliform • MCL, Single Sample - Single sample of contaminant exceeds MCL • MCL, Average - Average sample of contaminant exceeds MCL

TREATMENT TECHNIQUE (TT)VIOLATIONS:

PADEP sets Treatment Techniques that systems must follow. Systems must report to PADEP when they fail to meet specified treatment techniques.

• Treatment Technique (SWTR) - System did not perform the required treatment technique under the Surface Water Treatment Rule. • TT Violation - Applies only to systems using acrlamide and epichlorohydrin as part of a treatment, system failed to certify annual use of these chemicals as required. • Optimum Corrosion Control Treatment Study Recommendation - System fails to complete recommendation on time, submit an acceptable study on time, or provide sufficient information to make a treatment decision as required under the lead and copper rule. • Entry Point Water Quality Noncompliance - Water quality parameter values for system are below minimum value or outside range set by state under the lead and copper rule. • Tap Water Quality Parameter Noncompliance - Water quality parameter values for system are below minimum value or outside range set by state under the lead and copper rule. • Source Water Treatment Recommendation - Water system fails to submit source water protection recommendations as required by the lead and copper rule. • Source Water Treatment Installation - Water system fails to install source water treatment within twenty-four months or to submit proper certification to the state as required by the lead and copper rule. • Action Level Non-Compliance - Water system fails to meet acceptable levels of lead and copper after the installation of source water treatment. TABLE 5-2B (CONT’D) SDWA VIOLATIONS

• Lead Service Line Repair - Water System fails to replace required number of lead service lines, demonstrate lead service lines concentrations are less than the action level, or report required lead service line information on time.

MONITORING AND REPORTING (M/R) VIOLATIONS:

PADEP sets minimum monitoring schedules that drinking water systems must follow. These minimum reporting schedules (systems may monitor more frequently) vary by system size as well as by contaminant. Some contaminants are monitored for daily, others need to be checked far less frequently (every nine years is the longest

monitoring cycle). For instance, at a minimum, drinking water systems will monitor continuously for turbidity, monthly for bacteria, and once every four years for radionuclides. A Monitoring and Reporting Violation means the system did not perform the required testing, take adequate samples, or report a violation as required. • Monitoring, Routine Major (TCR) - No samples collected for period under the total coliform rule. • Monitoring, Routine Minor (TCR) - Some but not all samples collected for reporting period under the total coliform rule. • Monitoring, Repeat Major (TCR) - No follow-up samples collected after a sample that tested positive for total coliform or no speciation under the total coliform rule. • Monitoring, Repeat Minor (TCR) - Some but not all follow-up samples collected or speciated for compliance period under the total coliform rule. • Monitoring, Sanitary Survey (TCR) - Failed to have a sanitary survey conducted at the required frequency under the total coliform rule. • Monitoring, major (SWTR) - System took less than 10 percent of required samples during period under the Surface Water Treatment Rule. • Monitoring, minor (SWTR) - System took more than 90 percent of required samples but less than 100 percent during period under the Surface Water Treatment Rule. • Monitoring, Regular - Failure to conduct initial or repeat sampling, or to accurately report an analytical result. • Monitoring, Confirmation - Applies to nitrate only, system fails to collect or report required nitrate sample. • Public Notification - Failure to report violations as required . • Monitoring, Regular (Contaminant) - Failure to conduct initial or repeat sampling, or to accurately report an analytical result for a specific contaminant. • Monitoring, Regular - Failure to collect any samples. • Monitoring, Minor - Some but not all samples collected. • Violation, Variance - Failure to meet the schedule established for a variance or exemption. • Public Notification, Variance (PN) - Failure to notify the public of a granted variance • Initial Lead and Copper - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time . TABLE 5-2B (CONT’D) SDWA VIOLATIONS

• Follow-up or Routine Lead and Copper - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time .. • Initial Water Quality Parameter - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time. • Follow-up or Routine Entry Point Water Quality Parameter - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time. • Follow-up or Routine Tap Water Quality Parameter - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time. • Lead and Copper Source Water - Failure to use appropriate sampling procedures, collect the required number of samples, ensure proper analysis of samples, or submit information on time . • Public Education - System fails to properly educate the public about a lead action level violation; including, failure to provide mandatory language or mandatory information, mandatory frequencies, or a letter to the state to document efforts.

Reference: Office of Ground Water and Drinking Water SDWIS/Federal Development Model dated 3/5/1997.

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AUTHORITY

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MUNICIPAL

TABLE 5-3, PUC

EVALUATION, PUC

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6. ALTERNATIVE PLANS

Alternative plans are developed for each CWS to help them improve their Physical System, Management and Financial Capacity. The capacity evaluations from Section 5.0 result in identification of certain water system needs for each CWS. These needs are summarized for each CWS and presented in Appendix H.

The alternatives which address these needs fall under two (2) broad categories of improvement, namely a stand alone or individual approach and a cooperative or regional approach involving a larger, nearby water system. Under either approach, the goal is to improve the system’s ability to provide quality (safe and reliable) water service to its customers in a cost effective manner.

Stand Alone (Individual) Approach

Under this approach, each system is responsible for implementing improvements to address system needs and improve their capacity. This means providing the requisite physical facilities (supply, treatment, pumping, storage, distribution and customer facilities) to insure an adequate supply of safe drinking water under all conditions, at suitable pressures. It also means operating, maintaining and managing the system in accordance with Safe Drinking Water Regulations. Finally, it requires each system to provide sufficient funds through water rates and other charges to meet operating expenses, provide for routine maintenance and repair costs and build a reserve for future capital expenditures.

Cooperative (Regional) Approach

Small systems often have difficulty meeting capacity criteria and complying with ever-increasing, stricter Safe Drinking Water Regulations. In many cases, the burden of providing water service is too great. If this occurs, or might occur in the future, a cooperative or regional approach with a neighboring system (usually a larger system with capacity) represents a possible solution. This could take the form of a physical interconnection, satellite operation and management or acquisition. If a large system is unavailable, consolidation of several small, troubled systems through interconnections or some sort of restructuring arrangement represents another cooperative/regional approach worthy of consideration.

Alternative Plans and Estimated Costs

Alternative plans have been developed for the CWSs and are presented in Appendix I.

The stand alone alternative for each CWS addresses system facility improvements and management needs. Estimated capital costs (construction and project-related) are determined for the various improvements. Costs are based on estimating procedures contained in PAWATER and also engineering judgment. Likewise, debt service costs and annual operating and maintenance costs are determined resulting in an estimated total annual cost. This is then divided by the number of existing customers to determine the additional annual cost per customer.

Under the cooperative or regional approach, both physical interconnection and cooperative/restructuring alternatives are identified where practical. Costs for physical interconnections are calculated in a similar fashion to the stand alone approach. Costs for a cooperative/restructuring option are more difficult to estimate.

Alternative Plan Discussions

Allensville Municipal Authority operates a water system that meets most viability criteria used for this study.

Allensville is located in the extreme northwest part of the County and Menno Township, remote from other water systems. A stand alone approach is appropriate. The existing water supply has always met demand but the absence of safe yield documentation for the source raises concerns relative to meeting future demands. A backup water supply well needs to be developed to ensure an adequate supply at all times. The estimated project cost to provide a back-up well supply and to implement distribution system needs and management improvements is $68,800. Total annual costs are estimated at $13,800, which results in an additional cost per customer of $70 per year. Implementation of this Plan may encounter opposition from the Authority and its customers due to lack of water shortages in the past.

Edgewater Mobile Home Park requires significant system improvements to meet viability criteria including supply, storage, customer metering and management improvements. Edgewater is located in Derry Township, close to Lewistown. The project cost to stand alone and provide needed improvements is estimated at $70,700. Total annual costs are estimated at $13,580, which results in an estimated cost per customer of $400 per year. The project cost to interconnect with Lewistown Municipal Authority is estimated at $300,000. Total annual costs are estimated at $28,600, which results in an estimated cost per customer of $840 per year. If Lewistown provides satellite operation and management services, coupled with stand alone facility improvements, the overall per customer cost is estimated at $415 per year. The recommended alternative plan for Edgewater includes system improvements with existing management. Because Edgewater Mobile Home Park will no longer exist in the near future due to a major highway project, plan implementation is not anticipated.

Elsessers Mobile Home Park operates a water system that meets viability criteria used for this study. Elsessers is located in Granville Township, in close proximity to Lewistown. Although it is not recommended to interconnect Elsessers to Lewistown Municipal Authority, the estimated project cost to do so is $132,000. Total annual costs are estimated at $12,600, which results in an estimated additional cost per customer of $450 per year. The recommended stand alone alternative includes customer meter installation, unaccounted-for water determination and management improvements. It is estimated the project cost for these improvements is $26,100. Total annual costs are estimated at $7,850, which results in our estimated additional cost per customer of $280 per year. Implementation of this recommended plan may be affected by both physical and economic resistance. Physically, installation of water meters for mobile homes can be difficult due to concerns with meter freezing. Economically, the $280 yearly cost may be more than the owner is willing pass along to its tenants for fear of losing renters. A cooperative approach was also evaluated including satellite operation and management by Lewistown. The estimated per customer cost of $255 per year is attractive compared to the recommended stand alone plan. However, the owner has indicated a desire to remain independent.

Fairview Water Association needs to develop a viable water system. Fairview is located in Granville Township, somewhat remote from Lewistown. The estimated project cost to interconnect with Lewistown Municipal Authority is $510,000. Total annual costs are estimated at $48,650, which results in an estimated additional cost per customer of $1,100 per year. The stand alone project cost to provide a viable water system including supply, treatment, storage, metering and management improvements is estimated $180,600. Total annual costs are estimated at $26,380, which results in an estimated additional cost per customer of $595 per year. In addition, Fairview Water Association does not have the capacity to operate and manage a water system. Therefore, it is recommended the water system be operated and managed by Granville Township Water and Sewer Department (or Lewistown). The per customer cost for stand alone facility improvements and satellite operation and management by Granville or Lewistown is estimated at $650 per year. Providing safe reliable water to customers of Fairview Water Association will have a significant economic impact. Implementation of the satellite operation and management plan will encounter political opposition from the customers, as they believe their current water supply is safe, good quality water.

Forest Hills Apartments is located in Granville Township near Lewistown, and needs systems improvements to meet viability criteria used for this study. These include storage, distribution, customer meters and management improvements. The estimated project cost to stand alone and provide these improvements is $122,400. Total annual costs are estimated at $12,520, which results in an estimated additional annual cost per customer of $130 per year. This compares unfavorably with the estimated project cost of $50,000 to interconnect with the Lewistown Municipal Authority as a bulk customer. The estimated additional customer cost is $50 per year. It is recommended Forest Hills apartment interconnect with the Lewistown Municipal Authority as a bulk customer. The benefits of interconnection should make implementation relatively easy. Significant fire service improvements to the apartment

complex and elimination of Safe Drinking Water Act requirements for Forest Hills should encourage implementation.

Granville Township Water and Sewer Department operates a water system that meets most viability criteria used for this study. Granville’s water system has only one source of supply; a second supply is needed. The project cost to provide this back-up well is estimated at $41,300. Total annual costs are estimated at $5,300, which results in an estimated annual customer cost of $240. Implementation of this alternative may encounter resistance based on economic considerations. Although the project cost is relatively small the cost is divided by only a few customers that are economically disadvantaged. Granville Township should seek grant money to construct this project.

Hillside Terrace Community Mobile Home Park operates a water system that meets most viability criteria used for this study. Hillside Terrace is located in Derry Township and is remote from other water systems. Hillside’s water system needs to provide additional storage to meet its operational and emergency requirements. In addition, unaccounted-for water needs to be determined and management improvements are needed. The estimated project cost to provide these improvements is $29,800. Total annual costs are estimated at $8,180, which results in an estimated annual customer cost of $245 per year. The estimated project cost to interconnect the water systems with Lewistown is $156,000. Total annual costs are estimated at $14,900, which results in an estimated annual customer cost of $440. If satellite operation and management is provided by Lewistown, coupled with stand alone facility improvements, the annual cost per customer is estimated at $260. It is recommended that Hillside undertake water system improvements under the stand alone approach. Implementation of the plan may encounter resistance due to the economic cost to the customers.

Lewistown Municipal Authority meets all viability criteria established for this study. This water system has the physical, management and financial capacity to provide safe reliable water to its current customers and to assist nearby small water systems with their water supply problems. Assistance could be in the form of physical interconnection, or satellite operation and management responsibilities including technical assistance. It is recommended that Lewistown reduce its unaccounted-for water to less than 15 percent. The estimated project cost to address its unaccounted-for water problem is $50,000, with total annual costs estimated at $9,400 which results in an estimated annual customer cost of $5 per year. Implementation of this project should not cause any problems for the Authority.

McVeytown is located in the south-central part of the county remote from other water systems. A stand alone approach is appropriate. McVeytown Borough Authority meets most viability criteria established for this study. The Authority should implement an unaccounted-for water reduction plan and management improvement activities. The estimated project cost to provide these improvements is $25,000. Total annual cost are estimated at $8,200, which results in an estimated customer cost of $50 per year. Implementation of these improvements should not cause any problems for the Authority.

Meadowview Manor is located in Wayne Township in the extreme southwest part of the County, remote from other water systems.. A stand alone approach is appropriate. Meadowview Manor is not the typical public water supply system. Although it supplies a large number of people, it has no customers. Instead of distribution mains it has plumbing. It serves rooms instead of customers. This system has only one well, it needs to develop a backup supply. In addition, management improvements need to be developed. The estimated project cost to provide the needed improvements is $56,300. Total annual costs are estimated at $11,550, which results in an estimated customer cost of $225 per year. Implementation of this plan will encounter resistance due to the economic impact on the Meadowview Manor resident. The residents at Meadowview Manor do not have the financial resources to support the recommended improvements.

Menno is centrally located in the extreme western part of the county, remote from other water systems. Menno Water Association needs to develop a viable water system or obtain its water from Lewistown Municipal Authority. The estimated project cost to interconnect with Lewistown Municipal Authority is $744,000 which results in an estimated customer cost of $1,510 per year. The project cost to provide required supply, storage, distribution mains, customer meters, reduce unaccounted-for water and management improvements is estimated at $677,600. Total annual costs are estimated at $71,430, which results in an estimated customer cost of $1,520 per year. It is recommended Menno provide the needed water system facilities and Lewistown Municipal Authority operate and manage the facilities as a satellite system. Implementation of this plan will encounter considerable resistance due to

the cost and political resistance to operation of the water system by Lewistown.

Mount Union is located in Huntingdon County across the Juniata River from southern Mifflin County. Mount Union Area Water Authority needs to develop additional water supply source(s) to correct current supply deficiencies. It is recommended that at least a 200 gpm capacity well supply be provided with necessary treatment and transmission capacity. In addition, unaccounted-for water reduction and management improvements are needed. The estimated project cost for these improvements is $144,000. Total annual costs are estimated at $29,500, which results in an estimated customer cost of $25 per year. Implementation of this project should not be difficult as the Authority is actively prospecting for water at this time. There could be some environmental concerns with implementation relative to well siting. However, there are enough identified potential well sites to permit alternate site relocation if environment concerns become an issue.

Newton Hamilton Borough is located in extreme southern Mifflin County and receives its water from Mount Union Area Water Authority. It is recommended Newton Hamilton continue to be a bulk customer of Mount Union. However, if Mount Union does not resolve its current water supply deficiencies, Newton Hamilton should consider developing its own water supply and treatment capacity. In addition, unaccounted-for water and management improvements are needed in the Newton Hamilton system. The estimated cost for these improvements is $76,300. Total annual costs are estimated at $11,500, which results in an estimated customer cost of $110 per year. If Mount Union resolves its capacity problems it is not recommended Newton Hamilton develops its own supply and treatment capacity. Under this scenario an estimated project cost of $20,000 for unaccounted-for reduction and management improvements is recommended. Total annual costs are estimated at $3,800 which results in a $40 per year customer cost. Obstacles to implementation of these improvements is not anticipated.

North Hills Mobile Home Park is located in Derry Township and needs water system improvements to meet viability criteria used for this study. These improvements include emergency power, customer meters, unaccounted-for water reduction and management improvements. Estimated project cost to provide these improvements is $32,000. Total annual costs are estimated at $8,530, which results in an average customer cost of $180 per year. Interconnection with Lewistown Municipal Authority as a bulk customer will result in an estimated project cost of $62,500 and a total annual cost of $5,900 which results in an additional customer cost of $130 per year. Although, the project cost to interconnect with Lewistown is almost double the estimated cost of the system improvements, the annual customer cost is $50 less. It is recommended North Hills interconnects with Lewistown Municipal Authority as a bulk customer. The benefits of interconnection should make implementation relatively easy. Significant fire service improvements to the mobile home park and the elimination of Safe Drinking Water Act Requirements for North Hills should encourage implementation.

Wayne Township is located in extreme southern Mifflin County. Wayne Township Municipal Authority receives water from Mount Union Area Water Authority via Newton Hamilton Borough. It is recommend Wayne Township Municipal Authority continue to obtain its water from Mount Union via Newton Hamilton. However, if Mount Union does not resolve its current water supply deficiencies. Wayne Township should consider developing its own water supply and treatment capacity. In addition, unaccounted-for water and management improvements are needed in the Wayne Township system. The estimated cost for these improvements is $71,300. Total annual costs are estimated at $10,400, which results in an estimated customer cost of $130 per year. If Mount Union resolves its capacity problems it is recommended the unaccounted-for water and management improvements be undertaken. Under this scenario an estimated project cost of $20,000. The total annual cost are estimated at $3,800, which results in an annual customer cost of $50. Obstacles to implementation of these improvements are not anticipated.

Implementation Issues

There are various advantages and disadvantages to either approach for each CWS. The biggest issue is always cost. Many of the small systems will experience significant rate increases for water service under stand alone or physical interconnection alternatives. In these cases, some sort of cooperative/restructuring approach may be called for.

Another big obstacle to any of the alternatives is gaining acceptance on the part of the CWS to take action and implement recommended improvements. During our visits to the CWSs and discussions with key representatives, we often heard that their system is fine and does not need improvement. Several expressed their desire to remain

50 independent and wanted no part of a cooperative or regional approach to water service in their area.

Other obstacles to implementation of recommended alternatives also exist. These relate to certain physical or environmental issues, but are generally minor as compared to the economic and political issues previously mentioned.

7. WATER SUPPLY PLAN

The Mifflin County Water Supply Plan is intended to be a guidance document for the County, Advisory Committee and individual water systems to follow in addressing identified water system needs. The overall Plan objective is to ensure that safe, adequate and reliable drinking water is available to Mifflin County residents at a reasonable cost. Since there are many ways in which the overall Plan objectives can be reached, the Recommended Water Supply Plan offers both general strategies and specific solutions for achieving objectives. This Plan should be treated as a dynamic tool, to be modified and improved on as needed, to address evolving water supply conditions in Mifflin County.

Plan Summary

Based on the findings of this study, input from local water system owners and operators, PADEP, and other interested parties, the following general guidelines are provided for the improvement and development of water supply in Mifflin County.

• Discourage the establishment of new small water systems. • Encourage existing small water systems to create and maintain financial records including annual budget, revenue and expenses. • Encourage existing water systems that lack the capacity to provide safe, reliable, adequate water service (Fairview, Menno and North Hills) to transfer service responsibilities to water systems with capacity (Lewistown and Granville) for long-term viability. • Encourage small water systems to take advantage of programs PADEP has available to assist small water systems including the Monitoring Reimbursement Program, Small Water Systems Regionalization Grant Program, Formation of Water Authorities Program, Small Water System Consolidation Construction Grant Program and Water and Waste Water Assistance and Outreach Program. • Encourage all individual small water systems to identify, evaluate and implement cooperative/restructuring solutions to water service needs when possible; this would include Lewistown-Forest Hills and Lewistown- North Hills acquisitions and satellite operation and management approaches for Fairview and Menno involving Lewistown and/or Granville. • Maintain a countywide Water Advisory Committee to identify, monitor, evaluate, encourage, facilitate, etc. water service solutions that are in the public interest. • To the extent practical, work within the existing water service industry to implement solutions to water service needs. • When appropriate or necessary, use governmental mechanisms to effect water service solutions that are in the public interest and prevent those which are not. • Assume responsibility at the County level, when and if required, to effect water service solutions.

Plan Details

The Recommended Water Supply Plan provides solutions to address the physical, management and financial needs of the County water systems. Table 7-1 lists the County water systems and the recommended approach and improvements for each system. The recommendations are intended to outline reasonable solutions to the needs identified during the study and serve as a starting point for initiating discussion between water systems regarding implementation of physical, cooperative and/or restructuring alternatives. Implementation schedules are also noted.

A large portion of Mifflin County is served by the Lewistown Municipal Water Authority. Many of the smallest water systems are located adjacent to Lewistown’s service area and could easily be incorporated into the Lewistown system. However, a number of systems are distant from other water systems which limits physical incorporation with another system. These water systems could benefit from cooperative/restructuring alternatives such as satellite management. In the western part of the County, the Mount Union system could play a similar role.

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Implementation

The County does not have the authority to require the water systems in Mifflin County to implement the Recommended Water Supply Plan. The County can facilitate the implementations of the Plan through active involvement in the identification, evaluation and discussion of water service needs with existing water systems and PADEP. The County can also guide the development of water service and regional water systems capable of providing safe, reliable and adequate water service. Specific implementation activities worthy of consideration include:

1) Maintain a County Water Supply Advisory Committee to: - monitor the status and condition of water supply - advise the County Commissioners - investigate and evaluate special problems - reviews and update the Water Supply Plan

2) Interact with regulatory representatives, water systems and other interested parties to maintain an awareness of water supply problems and to assess methods to solve existing and future problems.

3) Form special project steering committees when necessary to address local or regional water service problems and assist with effective implementation of desired regional solutions.

4) Educate government and water system officials on the findings of this Water Supply Plan and encourage them to define and implement optimum ways to address water system needs.

5) Perform other public involvement activities related to water supply issues as deemed necessary.

Table 7-1 also lists a schedule for implementing the recommended Plan, estimated project duration and responsible official/organization for each water system. The County can also guide the implementation of the Water Supply Plan through project funding. The Community Development Block Grant program administered through the County can be used to fund projects that address major deficiencies identified in this Water Supply Plan and thereby promote cooperative/restructuring solutions. The County can also work with PADEP, the Pennsylvania Infrastructure Investment Authority (Penn Vest) and the USDA Rural Utilities Services to encourage funding of projects that address deficiencies and promote regional solutions in Mifflin County.

Public Involvement

In today's active social and political environment, the simple technical integrity of a water provider or municipality is no longer sufficient to justify and support project implementation. Public water systems and government agencies must demonstrate public responsiveness and accountability on selected projects. The development and expansion of comprehensive public affairs programs, often

involving long-term system and government commitments, is now considered a necessary ingredient of implementing beneficial improvement projects. Programs need to encompass understandable technical and financial communications, customer relations, the dissemination of general public information, media and community relations, public affairs, and public involvement. Problem- solving and alternative dispute resolution techniques, for example, are two important skills that often need to be incorporated within effective public affairs programs. Successful public involvement processes require digging under and behind specific water system and customer positions to discover and define potential mutually beneficial interests on which parties can agree.

The American Water Works Association (AWWA) has published numerous articles and reference guide books for accomplishing effective public participation programs. One such publication is the AWWA Research Foundation handbook titled, Public Involvement Strategies: A Manager's Handbook. This handbook discusses ten (10) important steps for identifying, understanding and planning for a project's public needs. The 10 steps detailed in this practical, how-to handbook, are titled as follows:

1) Frame the problem. 2) Identify constraints. 3) Identify and describe decision steps and project milestones. 4) Identify and understand potentially affected stakeholders. 5) Determine vulnerability and must-resolve issues. 6) Determine the appropriate level of public involvement. 7) Select processes and techniques. 8) Develop a public involvement work plan. 9) Implement and monitor the work plan. 10) Manage change.

Appropriate public water provider or governmental groups need to be formed in conjunction with each of the beneficial improvement projects, so as to explore the details of the projects and embark upon necessary public education and public involvement programs. Only through such cooperative and focused approaches can necessary beneficial improvement projects be implemented in a timely manner at optimally low rates.

Plan Modification

The Mifflin County Water Supply Plan is based on certain assumed, estimated and projected conditions that are supported by currently available information. Since future conditions in Mifflin County may vary, it is important to review and update the Plan on a regular basis to account for changing requirements. A review and update of the Plan at a minimum of every five years is desirable to keep the Plan content up-to-date.