Black Gold Lodge WS - Inspection Report

Inspection Information:

This facility was given a moderate hazard rating.
More information on hazard ratings.

Violations:
A summary of the violations found during the inspection are listed below.

Code

Description / Observation / Corrective Action

201

Failure to have a written emergency response and contingency plan. Observation: VCH does not have a record of an accepted ERCP for this water supply system. Corrective Action: Submit an ERCP for review prior to the start of next season. A template has been provided for you reference which outlines the common issues and responses for a water system. Need to tailor the ERCP to your particular water system and equipment present. Should be written with sufficient detail that a person with little experience with your system can follow the procedures. The labelling all of the piping and valves which can then be referenced in your ERCP will go a long way to making the task of having to maintain a water system when the primary operator is unavailable. If you require an electronic version of the attached ERCP please contact us and we can email the Word document to you.

Actions Taken:
Issue Permit
Permit hand delivered and conditions discussed with operator; operator will post in dinning room.
Information Exchanged

Comments:
Only change since last season is that the chlorine supply tank and pump have been relocated to being outside of the primary treatment room. Chlorine pump is still activated whenever the treatment pump is activated by a drop in water pressure. When the two treated tanks require water their internal float valves will open causing water pressure in the supply lines to drop below 20psi starting the pressure pump (and thus in turn the chlorine pump). Once the tanks are full again the float valves shut off causing the pressure to exceed 40psi turning the pump off. A large pressure tank is present to absorb the pressure shock when the float valves close. Colour removal is being handled by a pair of Tahoe tannin removal filters. Flow rate on the tannin filters is 6.7 GPM on the older unit and 5.7 GPM on the newer. Operator states they is always a 1GPM difference between the units. UVT of raw water: 26.2%; post chlorine removal filters as water enters the treatment tanks: 49.9%. Currently the water system has been supershocked and is operating at 8ppm. Chlorine levels are so high all colour is being removed due to chlorine oxidation thus monitoring UVT at the end of the line at this time is not indicative of the tannin removing performance of the Tahoe units. Operator has a proper chlorine test kit. Secondary treatment room has five filters in series 5 micron - 5 micron - 1 micron absolute - 1 micron absolute - 1 micron absolute; no pressure gauges present. UV units are still operational although their reset buttons on the UV sensors have been zip-tied down to stop alarming. The "wall of plumbing" across from the UV units with the single bypass valve is still the same as last year. There are still a few taps in the operator's private area which do not have treated water. All water accessible to guest other than that in the toilets is treated water A 1/2 doz posters were left to be posted at sinks with untreated water Water sampling bottles, requisitions and sampling procedures left with operator. Discussed their Emergency Response and Contingency Plan (ERCP) and Operations Manual. RECOMMENDATIONS: 1. Other operators have noted better colour removal success by slowing down the rate at which water passes through the tannin removal filters. Should explore the option of throttling down the flow through the tannin removal filters so it can still provide the volume of water required for the lodge but have it do so in a slower fashion (1 - 2 GPM). Take the maximum daily water consumption from your water use meter and divide it by 3600 minutes to give you the absolute minimum Gallons Per Minute total flow needed through both tannin filters and still provide an adequate volume of water. However you still need to ensure the treated water tanks can provide for peak water use flows without running out so its finding that balance between slowing the water for better colour removal but still meeting both the daily total and peak water demands. 2. Free available chlorine levels need to be monitored at the outlet of the treated water tanks as well as the end of the distribution line. This helps "catch" situations where the chlorine demand of the water being treated suddenly increases (increase in tannin level in raw water or drop in the effectiveness of the colour removal filters) so additional chlorine can be added directly to the tanks and the automated feeder adjusted slightly to match the increase in chlorine demand. Using 1 floz or 1/8 cup or 30ml of commercial strength 12% bleach (such as the Hypochlorite-12 product you are using) in a 1000 gallon sized tank will raise the chlorine levels by 1 ppm which normally should be all you would need. However the elevated tannin levels of your water may "use up" the chlorine resulting in a lesser change so you might have to re-add more chlorine in order to achieve the required chlorine residual. Handling chlorine requires Personal Protective Equipment (PPE). Along with chemical gloves which extend up the forearm, rubber chemical proof apron the most important PPE for liquid chemicals is an eye/face shield and eye wash station in the areas where chlorine is handled. 3. Filter bank in the secondary treatment room is on the supply side meaning water to the lodge must be turned off for the period of time it takes to service the filter bank. A better solution for your filter bank would be to have two separate parallel filter pathways with each path consisting of a 5 micron - 1 micron absolute - 1 micron absolute series of filters. The two parallel pathways need to be plumbed so they can operate independently of each other to allow for filter changes without having to shut down the the water system. The installation of pressure gauges across each filter are required to monitor the pressure differential to determine when filters need to be changed. 4. A single valve on a treatment bypass circuit does not offer adequate prevention from raw water accidentally mixing with treated water as an internal leaking valve cannot be detected. The treatment bypass circuit needs to be redesigned with multiple shut off valves that will only have water pressure on one side of the valve. This can be accomplished by having two valves in series on the bypass circuit with a third valve in place between them left in an OPEN position to fully drain the portion of piping between the two shut off valves. Another option is to have the ability to physically remove a section of the bypass circuit piping between the valves by means of piping couplers. Avoid the use of screw type of valves for bypass lines as they lack the visual clue if they are open or not and are more prone to internal leaking over ball valves. If the valves are installed with forethought the handles for all three ball valves will align in the same orientation when the bypass is closed (both valves closed; drain line open) AND all aligned in a different orientation when the bypass valves are open (drain line closed). 5. Once you have completed your Emergency Response and Contingency Plans need to create an Operations Manual detailing operations of all aspects of the entire water system under normal circumstances.