By Gary Battenberg and Norma Lara Leep

In July 1989, a summit meeting was held in Paris, France and attended by heads of governments, scientists, engineers and senior officials to discuss protection of the environment. Since then, environmental protection has become a major [global] topic and while there has been much done at the political level, the problems mankind has created and damage caused to our natural environments have resulted in major advancements in water purification technologies. Many enforceable regulations have been established for water systems serving consumers as well as private water system owners.

Our industry is blessed with a wide range of technical expertise and knowledge acquired over many years by men, women and companies who have developed, tested, certified and applied techniques that built the solid water treatment fundamentals we adhere to when specifying treatment for contaminated water supplies. Notwithstanding, we are faced with daunting challenges for many years to come. To ensure that products are safe for consumers to use, we have such organizations as WQA, NSF/ANSI, AWWA, IAPMO, CE, RoHS, public health departments, etc., charged with ensuring product safety for the consumer.

Case in point
The following is a case where a service station/convenience store that sells food and beverages prepared with well water received a Small Public Water System Inspection Report that found water quality in non-compliance with local public health department ordinances and required correction for insufficient storage and cross connection control. The well provides water for the gas station/convenience store, a manufactured home, an RV dump station and an irrigation system. There was no water treatment or filtration installed. This water source was found to be vulnerable to:

  • Potentially contaminating activities related to the current and former gas stations, and
  • A methyl tertiary butyl ether (MTBE) detection in the groundwater supply above the primary maximum contaminant level (PMCL) of 24 parts per billion (ppb) in 2015

The well head located adjacent to the store was surrounded by a fence with a gate that can be locked to prevent unauthorized access to the immediate area. Inspection of the enclosed area disclosed inert debris and litter surrounding the well head. The store owner was instructed to clean up and maintain the area going forward.

Additionally, the well head casing had two holes in it that were not watertight. One hole was used for routing the electrical service to the submersible pump. The purpose of the second hole was unknown and was a source of surface intrusion from atmospheric conditions, such as dust, pollen, insects, rodents, etc. The store owner took necessary actions to ensure the well head was watertight and would conduct routine inspections to make sure the well head remained watertight going forward.

The store owner was informed that annual MTBE monitoring would be required to address these specific vulnerabilities. The monitoring report was filed in 2016 but reports for 2017 and 2018 were missed. Due to failure to complete the annual MTBE monitoring during 2017 and 2018, the local primacy agency (LPA) issued a notice of violation (NOV) to the store owner in July of 2019. This NOV included multiple directives focused on protecting public health from direct consumption of the MTBE contaminant in the water, which included:

  1. Ceasing distribution of water intended for direct human consumption
  2. Increasing MTBE monitoring frequency from annual to quarterly

The table below summarizes available MTBE results including those that were obtained from the increased monitoring directive that was included in the 2019 NOV.

Remediation process
A POE system, dedicated for water supplied to the gas station/convenience store only, was installed in August of 2019 to treat water for beverages, ice, coffee and hand washing. The POE system consisted of a fiberglass 8” X 35” media tank loaded with 0.3 cubic feet of granular activated carbon and fitted with an automatic backwash valve. The manufactured home, RV dump station and irrigation system were bypassed and continue to use untreated water. The store owner filed a corrective action plan (CAP) in 2020 to expand the existing POE system for a centralized system intended to provide remediation for the entire service plumbing on the property. The LPA found the design to be adequate, but not required at this point (given the current MTBE levels and trends) but reserved the right to mandate application for permit amendment to install the centralized upgrade if needed to comply with applicable maximum contaminant levels (MCLs). The LPA, however, directed the store owner to provide a separate POE system for the manufactured home to comply with US EPA drinking water standards.

Distribution system
In 2015, several potentially hazardous plumbing connections were identified as cross connections where a potable water service was directly connected to the sanitary system without a code-compliant air gap device. The store owner was directed to correct these plumbing infractions. A follow-up report by a cross connection specialist confirmed that all cross connections had been abated and submitted to the LPA for recording.

The well was drilled in 1991 to a depth of 380 feet below ground surface (BGS) with a static water level at 110-feet BGS. The pump was a 1.5 hp submersible controlled by a pressure switch connected to an 85-gallon pneumatic pressure tank. Review of daily water usage for this location revealed the maximum daily demand (MDD) of 1,570 gallons and represents the minimum storage capacity the facility is required to have.

Storage facilities
The existing 85-gallon pressure tank did not meet the minimum storage capacity standards as required by the local LPA. The owner was required to submit a proposal to install sufficient water storage capacity to meet MDD standards. To comply with this requirement, the owner contacted a local company who proposed a 1,550-gallon atmospheric storage tank with automatic disinfection controls. The combination of the 85-gallon pressure tank with the proposed storage yielded a total storage capacity of 1,635-gallons, which exceeds MDD of 1,570-gallons. The plan was required to include:

•  Projected completion date
•  Updated site plan illustrating all components of the water system (i.e., well head, pressure tank, POE system, atmospheric storage tank, transfer pump, distribution piping layout, etc.)
•  Plan review that would include storage tank disinfection procedures consistent with AWWA C652-02 or newer version.
•  Storage tank design shall meet NSF 61 specifications and will include a drawing illustrating the following storage tank specifications:

  • Vent filter and features for prevention of entry of rainwater or runoff, birds, insects, rodents, or other creatures. A #24 mesh, non-corrodible screen is recommended for placement on these features.
  • Drain valve to allow the tank to be drained for sediment removal
  • Controls to maintain and monitor water levels
  • Equipped with isolation valves and designed and operated to allow continued distribution of water when the storage tank is bypassed for cleaning or maintenance.
  • A spray aeration system (SAS) designed for provision of precautionary treatment where MTBE may be present. This method is deemed best available technology for treatment of MTBE volatilization.

Data monitoring and reporting
Quarterly sampling for MTBE and bacteria are required for reporting to the State Water Resources Control Board-Division of Drinking water (DDW). Additionally, nitrate testing and reporting will be required every year and nitrite testing and reporting will be required every three years.

The store owner is currently not required to have a certified water operator due to the transient non-community classification of the water supply. Should centralized treatment be required in the future, however, the owner will be required to have a certified treatment operator for reporting and maintenance purposes.

As we can see, the requirements in place to protect the consumer have placed additional burdens on business owners and other commercial establishments to provide remediation for water contamination. As a culture, we made the mess due to ignorance in the early days when it was not known or deliberately overlooked the ramifications of open dumping of chemicals into our environment and ecological systems. Fortunately, the technology and application specific details are available to qualified water treatment specialists to provide recognized treatment methods for reliable and consistent water purification to protect the consumer.

In fairness to local, state and federal agencies regarding compliance with regulations, permits and inspections, which are in place to protect the public, it is always wise to work with these authorities when infractions occur. You have heard the adage, “You can’t fight City Hall,” so work with the authorities and not against them. When you comply, they may very well approach you to promote you as a local resource to help those businesses that need your valuable expertise.

About the authors

Gary Battenberg is a Business Development Manager-Senior for Argonide Corporation. Previously, he was Technical Manager, Water Treatment Department of Dan Wood Company. Prior to that, Battenberg was Technical Support and Systems Design Specialist with Parker Hannifin Corporation. His nearly four decades of experience in the water industry include a proven, successful track record in areas of sales, service, design and manufacturing of water treatment systems. Battenberg’s technology base covers mechanical and adsorptive filtration, ion exchange, UV sterilization, RO and ozone technologies. He has worked in the domestic, commercial, industrial, high-purity and sterile water treatment arenas. A contributing author to WC&P International magazine and a member of its Technical Review Committee since 2008, Battenberg was voted one of the magazine’s Top 50 most influential people in the water treatment industry in 2009. He can be reached by email at or by phone (407) 488-7203.

Norma Lara Leep has been a water treatment contractor for a little under 18 years and in the industry for a total of 23 years. She is a distributor for many different brands, including Hague Quality Water, AO Smith Special Water Solutions, Harmsco, Viqua and Dow Membranes, to name a few. Leep owns a store that provides parts and supplies for all water treatment needs. Currently, she is the contractor for a local Environmental Health Department on a grant project that provides clean water for low income families. She attended school for both Water Treatment Technologies and Water Treatment Operations.


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