WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt....

22
1 of 22 WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL IMPLEMENTATION REPORT Prepared by: Bureau for Public Health Environmental Engineering Division Infrastructure and Capacity Development Section November 2014

Transcript of WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt....

Page 1: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

1 of 22

WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL IMPLEMENTATION REPORT

Prepared by:

Bureau for Public Health Environmental Engineering Division

Infrastructure and Capacity Development Section November 2014

Page 2: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 2 of 22

This page intentionally left blank

Page 3: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 3 of 22

WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM

ANNUAL IMPLEMENTATION REPORT Table of Contents

WV Water System Statistics ............................................................................................... 5 1 Capacity Development Authority (New Systems Program) ....................................................................... 5

1.1 Legal Authority.......................................................................................................... 5 1.2 New System Control Points ......................................................................................... 5 1.3 New Systems and Their Compliance Status During FFY 2013 ............................................ 6 1.4 Future Program Plans for New Water Systems ................................................................ 7 1.5 Tracking New Water Systems - Program Performance ...................................................... 8

2 Capacity Development Strategy (Existing Systems Program) .................................................................. 8

2.1 Changes to Capacity Development Strategy during FFY2013 ............................................. 8 2.2 Providing Technical, Managerial, and Financial (TMF) Assistance to West Virginia’s Existing

Public Water Systems ................................................................................................ 8 2.2.1 Capacity Development Assessments ....................................................................................... 8 2.2.2 Financial Planning Assistance .................................................................................................. 9 2.2.3 Sanitary Surveys and Other Field Engineer Assistance ........................................................... 9 2.2.4 Operator Assistance ................................................................................................................ 10 2.2.5 Area Wide Optimization Program ............................................................................................ 10 2.2.6 Consumer Confidence Report (CCR) Assistance ................................................................... 11 2.2.7 Cross-Connection/Backflow Prevention Assistance ............................................................... 11 2.2.8 Public Education...................................................................................................................... 12 2.2.9 Third Party Activities................................................................................................................ 12

2.3 Identifying and Prioritizing Systems in Need of TMF ........................................................ 13 2.4 Statewide Concerns Identified .................................................................................... 13 2.5 Measuring Improvement - Baseline Ranking of Water Systems ......................................... 14 2.5.1 Baseline Priority Ranking Analysis.......................................................................................... 15 2.5.2 Recent Success Stories .......................................................................................................... 16

2.6 System Compliance Tracking (Now ETT formerly SNC) ................................................... 18 2.7 Future Activities ...................................................................................................... 18 2.8 Program Progress in FFY2013 ................................................................................... 19

3 Additional Reporting and Other Concerns ............................................................................................... 20

3.1 Report to the Governor ............................................................................................. 20 3.2 Drinking Water Treatment Revolving Fund (DWTRF) Procedures ...................................... 20 3.2.1 Ensuring DWTRF Applicants Achieve Compliance ................................................................ 20 3.2.2 DWTRF Funding Distribution including small and disadvantaged systems ........................... 21

Page 4: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 4 of 22

Glossary of Acronyms AM – Asset Management AWOP – Area Wide Optimization Program BPH – Bureau for Public Health C&E - Compliance and Enforcement CCR – Consumer Confidence Report CD – compact disc CDA – Capacity Development Assessment CDP – Capacity Development Program CIP – Capital Improvement Plan CUPSS – Check Up Program for Small Systems DWTRF – Drinking Water Treatment Revolving Fund EPA – Environmental Protection Agency ETT – Enforcement Tracking Tool MCET – Maryland Center for Environmental Training MCL – Maximum Contaminant Level NESC - National Environmental Services Center NETCSC – National Environmental Training Center for Small Communities NTNC – Non-transient Non Community Water System O&M – Operations and Maintenance OEHS – Office of Environmental Health Services PPL – Priority Project List PSC – Public Service Commission PSD – Public Service District PWS – Public Water System RCAP - Rural Community Assistance Program SCBG – Small Cities Block Grant SNC – Significant Non-compliance SWTR – Surface Water Treatment Rule TMF – Technical, Managerial and Financial (related to water system capabilities) TNC – Transient, Non-community water system WVETC - WV Environmental Training Center WVIJDC – West Virginia Infrastructure and Jobs Development Council WVRWA – West Virginia Rural Water Association WVWARN – West Virginia Water/Wastewater Agency Response Network

Page 5: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 5 of 22

WV Water System Statistics West Virginia had 973 total public water systems (PWS) in 2014 serving a total population of more than 1.5 million people. With a state population around 1.8 million, public water now serves 87.5% of the state’s population. The Capacity Development Program (CDP) focuses assistance efforts on community water systems (CWS) (49% of WV’s public water systems(PWS)), and will also offer assistance to the non-transient non-community (NTNC), systems. These two types of systems, on which the CDP focuses the assistance efforts, total 58.5% of all water systems. The impacts of the program potentially affect 98% of the population in West Virginia served by public water. Additional information about the size of systems and the population breakdown for the various system sizes can be found in the table below.

Table 1: 2014 Population by size and type of water system

PWS Type Values

Very Small <=500

Small 501-3,300

Medium 3,301-10,000

Large 10,001-100,000

Very Large >100,000

Grand Total

CWS Systems 159 229 65 23 1 477

Population 31080 367,390 340,013 569,574 198,521 1,506,578

NTNC Systems 78 13 2 93

Population 12,310 16,242 10,124 38,676

TNC Systems 394 8 1 403

Population 21,714 4,334 3,974 30,022

Total Systems

631 250 68 23 1 973

Total Population

65,104 387,966 354,111 569,574 198,521 1,575,276

1 Capacity Development Authority (New Systems Program)

1.1 Legal Authority

West Virginia initially documented adequate regulatory authority through a WV Attorney General certification dated November 30, 1998. On April 19, 1999, the US Environmental Protection Agency (EPA) determined the West Virginia program met EPA guidance and statutory requirements. The WV Office of Environmental Health Services (OEHS) water system regulatory authority ensuring adequate technical, managerial and financial capacity is contained in WV Code, §§16-9(a) and 16-13C-3(a). This authority has not changed between October 1, 2012 and September 30, 2013.

1.2 New System Control Points The WV Code noted in the previous section requires a permit to construct a PWS. WV OEHS implements this through control points that include a permit application, review and issuance/denial process. During the application process, OEHS permitting section personnel identify any potential new PWSs upon receiving a permit application. These potential new PWSs are forwarded to CDP staff. The CDP program staff confirms whether the application proposes:

New PWS construction

Existing PWS modification

Page 6: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 6 of 22

The permitting staff determines if the system is existing or new and initiates the following actions:

Existing system modification applications are processed

New water systems are provided Form EW-100 Addendum to Permit Application to Install, Extend, or Modify a Community or Non-Community Non-transient Public Water System – Capacity Development Requirements (EW-100 Addendum)

The permitting staff take no further permit application action until CDP program staff have received, reviewed, and approved or rejected the EW-100 Addendum. When new systems lack adequate budgeting and financial planning, program staff will provide budgeting assistance to the system management. Using the Financial Capacity Guidance Document for Small Systems, CDP provides budgeting assistance that helps the new system develop:

A complete inventory

Total replacement and annualized replacement cost estimates

A capital improvement plan

A yearly budget

A five year budget projection

This review process is outlined in section 2.0 of the Capacity Development Strategy and remains unchanged since EPA approved the Strategy. The PWS review process is not anticipated to change during the next fiscal year.

1.3 New Systems and Their Compliance Status During FFY 2014

West Virginia has implemented the EPA’s enforcement tracking tool (ETT). Utilizing this tool, water system violations are weighted based on the public health significance. The more serious the violation, the higher the points attached to it. All systems scores are monitored. New systems that have come online during the year and the previous 2 years, are scrutinized quarterly for compliance to ensure that their ETT scores are not >11. During FFY 2014, continued focus was placed on identification of new NTNC and CWS. Several new water systems came online and several new systems went offline as well. No new systems applied for permits requiring capacity development approval. The CDP tracked a total of fourteen (14) systems throughout the FFY 2014. During the reporting period five systems have gone offline or moved past the three year tracking mark and will no longer be tracked. Four of those five systems were in significant compliance and the one out of compliance has ceased operation as a PWS. During FFY 2015, seven of the current nine systems being tracked will surpass their three year operational time period during the year. Tracking of the ETT score for each of the new systems shows that one system (Hardy Co. – Baker) had an ETT > 11 in one quarter. This score was due to problems with stage 1 disinfection byproducts. None of the other new systems came close to the ETT action level of >11 during FFY 2014. This success in operational compliance can be attributed to the diligence of the District Engineers and enforcement staff in working with these new systems to ensure that they understand the reporting and sampling requirements. Detailed information about each new system and their operational compliance during FFY 2014 is included in Table 2.

Page 7: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 7 of 22

Table 2: New System Compliance (as of September 30, 2014)

PWSID# System Name System

Start Date

End

Tracking

Date

ETT

scores

4th Qrt.

2013

ETT

scores

1st Qrt.

2014

ETT

scores

2nd Qrt.

2014

ETT

scores

3rd Qrt.

2014

Population

Served

System Status

1 WV3301414 -

CWS

Global Capital

of World

Peace

12/1/2011 12/1/2014 0 5 0 0 50 Tracking

compliance

2 WV3301612 -

CWS

Hardy Co. -

Marvin Chapel

1/1/2012 1/1/2015 0 0 0 0 90 Tracking

compliance

3 WV3303707 -

CWS

Pleasants Co

PSD

2/1/2012 2/1/2015 0 0 0 0 200 Tracking

compliance

4 WV9903114 -

NTNC

Gateway

Eagle Coal

7/15/2012 7/15/2015 0 0 0 0 70 Tracking

compliance

5 WV3301613 -

CWS

Hardy Co -

Baker

8/1/2012 8/1/2015 0 0 10 15 150 Tracking

compliance

6 WV3302536 –

CWS

Mannington –

Metz PSD

11/13/12 11/13/2015 0 0 0 0 263 Tracking

compliance

7 WV9903113 -

NTNC

Coal River

Mine #10

4/1/2012 4/1/2015 1 1 2 1 100 Tracking

compliance

8 WV3304913 –

CWS

Hodgesville –

Sauls Run

9/1/2013 9/1/2016 0 0 0 0 307 Tracking

compliance

9 WV3303033 -

CWS

Mingo Co. –

Marrowbone

9/20/2013 9/20/2016 0 0 0 0 241 Tracking

compliance

1.4 Future Program Plans for New Water Systems Through the permitting process, CDP staff will continue to discourage the creation of new, small water systems and encourage these proposed systems to connect or become part of existing, larger, more viable and sustainable water systems. The new systems program is effectively preventing formation of new non-viable (unsustainable) PWSs when they can connect to or partner with existing systems. Typically, new systems have had difficulty understanding and implementing required reporting and monitoring. Hence, OEHS staff will continue to focus on the initial system start-up assistance and guidance process. This initial monitoring oversight has increased system management’s awareness and initial new system compliance. The permitting program is working well and changes to the control points during the next fiscal year do not appear to be necessary. The process outlined below will continue to be implemented:

Identifying proposed new water systems

Evaluating their managerial, financial, and technical capabilities through construction permit application review

Encouraging new systems to connect or partner with existing viable water systems

Controlling new systems by approving or rejecting their construction permit applications When a new system does experience violations, the OEHS staff works together to ensure assistance is provided to systems in resolving violations.

Page 8: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 8 of 22

1.5 Tracking New Water Systems - Program Performance Focused support is provided to new water systems by the compliance and enforcement (C&E) staff and district engineering staff to assist new systems in understanding and implementing the requirements of the SDWA. The CDP staff continues to track new water systems during the first three years of operation to help ensure that all CWS and NTNC water systems maintain compliance. Compliance with the regulations has a direct correlation to the system’s overall viability and long term TMF capacity. Utilizing the ETT score as a method to track the compliance of new systems, CDP staff watches for systems that show signs of struggling; intervening to determine the system’s need and reasons for potential non-compliance. Having had only one system that exceeded the ETT of 11 for one quarter during FFY2014 suggests that the efforts of OEHS staff are appropriate and effective.

2 Capacity Development Strategy (Existing Systems Program)

2.1 Changes to Capacity Development Strategy during FFY2014

The Strategy for Capacity Development was submitted to the EPA on August 4, 2000, and was approved on September 27, 2000. During this reporting period, implementation of the approved Strategy continued. Although changes to the Strategy were considered in the past, after consultation with the EPA Regional Capacity Development Coordinator, no changes to the Strategy have been made.

2.2 Providing Technical, Managerial, and Financial (TMF) Assistance to West Virginia’s Existing Public Water Systems

The CDP Strategy outlines a support structure which provides water systems with technical/onsite assistance, tools, resources, and training to enable them to improve their financial, managerial and technical capabilities; ultimately achieving and maintaining operational viability. The support structure includes many activities that are addressed throughout this report including:

Periodic update to a Baseline ranking (see section 2.5 of this report)

Drinking Water Treatment Revolving Fund (DWTRF project) funding (see section 3.2 of this report)

Providing Water Systems with assistance that includes: o Assessments at targeted water systems for improved compliance o Sanitary Surveys and onsite technical assistance from Engineering staff o Other technical assistance (cross connections, consumer confidence reporting, etc) o Operator training, third party assistance, etc

2.2.1 Capacity Development Assessments

The CDP Strategy outlines all assistance provided to water systems. Typically, the CDP’s first assistance step is conducting a detailed technical, managerial, and financial (TMF) water system Capacity Development Assessment (CDA). Assessments are conducted at systems for various reasons which are discussed in Section 2.3 on page 14 of this report. The CDA provides the water system a complete evaluation of their TMF capabilities, identifies TMF needs, and provides recommendations, resources and tools to address their needs. The CDA report is a tool for the water system to use to implement the recommendations resulting in long term viability. Throughout the CDA process, CDP staff also provides verbal feedback to water system staff, identifying

Page 9: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 9 of 22

problems, recommending water system actions, and identifying sources for further assistance. For one year following a CDA, the CDP staff continues to monitor the water system’s progress in implementing the recommendations from the CDA. The CDA procedure and report format are continually reviewed and improved. During FFY2014, a total of nine water systems were selected and assessed. A summary of water systems assessed over the past year is provided in Table 3 (page 19). In addition to direct contact by conducting CDAs and follow-up assistance activities, CDP staff provides additional assistance through phone and e-mail contact. Staff also provides water systems with a disc of resources such as generic plans, templates, and guidance documents. This year the resource disc was updated to include sustainability and energy efficiency information for water systems. All systems, regardless of their size, are eligible for direct water system assistance from CDP staff, water system industry organizations and other state and federal agencies. Assistance includes:

direct on-site, hands-on assistance

workshops, seminars and training sessions

self-help guidance documents The CDP staff provides assistance to help water systems develop:

Budgeting

Asset Management Plans and Capital Improvement Plans (CIPs)

Health and Safety Programs

Consumer Confidence Reports (CCRs)

Cross-Connection and Backflow Prevention Programs

Operation and Preventive Maintenance Programs

Emergency Response Plans

2.2.2 Financial Planning Assistance

During the CDA process, any system that is identified as having inadequate financial capability is encouraged to complete the Financial Capacity Guidance Document for Small Systems. This self-help tool includes an Excel spreadsheet(s) for use by a system with adequate computer resources. However, where necessary or appropriate, this financial planning assistance can be completed using the tables provided in the guidance document and a calculator. The CDP program staff provides copies of this document to water systems upon request, during assessments, and in training sessions. For FFY2014, the asset management (AM) support to water systems continued to expand. One capacity development staff member with the assistance of a Tetratech Staff member continued to provide support to water systems in the development of their AM plans (including the Check Up Program for Small Systems - CUPSS). Development of an approved asset management plan is required for all systems which receive DWTRF funds. Funding is also being made available to water systems to secure the services of engineering firms to assist with the asset management plan development. This year five systems developed and had approved a comprehensive asset management plan. In addition, twenty-three (23) systems are currently developing AM plans with several being very close to plan approval. The CDP continues to actively market the importance of establishing an asset management program and provide training on asset management at events attended by water systems personnel.

2.2.3 Sanitary Surveys and Other District Engineer Staff Assistance

The OEHS staff primarily provides direct water system assistance through OEHS field personnel. This assistance includes sanitary surveys, technical guidance and meetings with water system operators and managers. The district engineering staff conducts sanitary surveys on a schedule that results in each

Page 10: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 10 of 22

water system receiving a sanitary survey every three years to five years based on the system size, treatment methods, water source, etc. During FFY2014, a total of 255 sanitary surveys were conducted. Between surveys, the field engineers contact water systems regularly, checking for compliance and providing advice or assistance. This ongoing water system assistance using district engineering staff is highly effective with capable water systems. The district engineering staffs’ assistance focuses primarily on technical issues. While, financial or managerial guidance may also be provided by the district engineering staff, systems that have substantial financial or managerial deficiencies are referred to the CDP program for a full assessment. EPA also continues placing increased emphasis on effective water system management. This emphasis has resulted in their sustainable infrastructure initiative, full cost pricing focus, asset management and other financial evaluation tool development. The West Virginia CDP has been actively involved in bringing these EPA initiatives to West Virginia water systems. Often, this is accomplished through training coordinated by the Public Service Commission of West Virginia (PSC) (see section 2.2.8).

2.2.4 Operator Assistance The CDP continues to provide assistance in training water system operator courses by teaching various parts of the water operator’s courses including:

Distribution and Storage for Class I Drinking Water Operator training

Class II Drinking Water Operator training

Cross-Connections and Backflow Prevention to Class I, II and III operators and to Backflow Testers

Safety to Class I, II, and III operators During FFY2014, 111 water operators (of all classes) attended courses conducted by the Certification and Training staff. Additionally, 1011 operator certifications/renewals were provided and 175 were certified in backflow prevention. Finally, 186 people were certified as water well drillers and 50 people were certified as pump installers. The CDP staff reviews and critique portions of the training courses and materials for the water operator courses. Materials reviewed include Cross-Connection and Backflow Prevention, Safety, Management, Security, and Emergency Preparedness training modules by West Virginia University (they are under contract to us to create these water operator training modules). OEHS staff also proctor the exams for various water and wastewater classes when needed. OEHS participates with other stakeholders in providing input and funding for the Drinking Water and Wastewater Training Calendar prepared by the WV Rural Water Association (WVRWA). The calendar is used to keep system personnel informed of important drinking water education and training opportunities. During FFY2014 approximately 3,800 training calendars were provided to water operators, board members, system managers, and others concerned with operator certification and training. For FFY 2015 the OEHS will continue its partnership with the WVRWA in producing the training calendar.

2.2.5 Area Wide Optimization Program Since 2004, West Virginia’s Area Wide Optimization Program (AWOP) has maintained a yearly microbial public health risk ranking based on relevant data review. The AWOP data review or “scorecard” incorporates plant optimization goals, past violations, and unresolved sanitary survey deficiencies. OEHS district engineering staff update turbidity spreadsheets, generates a master ranking list, and shares it among staff each March. Additional information related to AWOP work with water systems can be found in the 2014 DWSRF annual report. This report is located on the Infrastructure and Capacity Development website at: http://www.wvdhhr.org/oehs/eed/i&cd/dwsrf_annual_reports.asp .

Page 11: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 11 of 22

2.2.6 Consumer Confidence Report (CCR) Assistance West Virginia’s CWSs must submit a copy of their annual CCR and a certification form to the OEHS. CCRs can be submitted for review/critique prior to official submittal, but many water systems do not take advantage of this offer. Consequently, each year a number of these systems’ CCRs have errors or missing information. Each water system’s CCR is reviewed against a required information check-list resulting in follow up which can provide:

A letter and/or a sample CCR, including instructions

The required information check-list

The required certification forms

Individual corrected information enabling non-compliant CWSs to correctly complete their CCR the following year

During this reporting year, 448 out of 478 CCRs were received. The staff review found 89 CWS CCRs had errors or lacked necessary information. This resulted in the following activities:

Sent 32 systems letters and information to help them correct their 2013 CCR

Responded to 190 phone queries concerning CCRs

CCR Violations for systems as follows: o 55 for not submitting a CCR (26 submitted late, 29 still outstanding) o 94 for not submitting a certification form (10 submitted late, 84 still outstanding)

Correct CCR preparation is facilitated using a generic, fill-in-the-blank CCR CD. It provides the water system a correct CCR format for the next reporting year and future years. While it was available to all water systems, none requested it during FFY2014. CCR and certification reminders of due dates were sent to 478 systems. Due to a large number or errors and non-compliance issues in some water system’s CCRs, the CDP staff prepared thirty-two (32) CCRs and provided twenty (20) systems with an accompanying CD containing the complete CCR package (CCR, certification letters for signature, etc) CDP staff, working with the WVRWA, conducted four CCR preparation workshops throughout the state. Thirty-eight (38) participants took advantage of these workshops.

2.2.7 Cross-Connection/Backflow Prevention Assistance The CDP staff has developed a cross-connection and backflow prevention manual and other related training materials. These assistance documents were distributed to students in water operator training classes over the past year, including those who were trained specifically in backflow prevention. The water system can use this manual to develop and implement a cross connection and backflow prevention program. The manual can be used by either public service districts or municipalities. Copies of this manual are available in each of OEHS’s five district engineering offices and are provided to water systems during sanitary surveys. Additional copies are provided to other water systems and private water related businesses upon their request. When distributing the manual, the following EPA publications are included:

Cross-Connection Control Manual (EPA 816-R-03-002)

Consumer Confidence Reports (EPA 816-K-03-003)

Consumer Confidence Reports (EPA 816-H-03-002) During FFY2014, 26 phone calls were answered from the public with questions regarding Cross-Connection and Backflow Prevention installation/enforcement. Five training classes for Backflow Preventer Testing were taught. One cross connection policy was distributed.

Page 12: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 12 of 22

2.2.8 Public Education During the reporting period OEHS continued implementing public outreach. Some of the education projects were aimed primarily at water systems, their managers, operators and employees. However, others are also intended to educate the general public. Through these educational efforts the objective is to reach as many people as possible with information on the capacity development program, inform them of what they should expect from their water system and let system personnel and the general public know assistance is available. These programs inform persons served by unsatisfactory or marginally viable water systems of available help and alternatives to improve poor quality water. A West Virginia CDP brochure, ruler and other handouts are distributed to the public at the WV EXPO, WVRWA conference, and Public Health Day at the Legislature. These handouts are available in the central and district offices and are provided to any interested persons including those at speaking engagements and conferences. A capacity development web site providing detailed information about the CDP was maintained during the reporting period. The web site provides links to numerous other web sites with capacity development information. The CDP personnel work with OEHS technical support staff and regularly update and integrate new information into the web site. The CDP program staff and other OEHS personnel (enforcement, permitting, field inspection, infrastructure/DWTRF, etc.) developed and made numerous presentations to a variety of audiences. These presentation opportunities enabled us to educate people about CDP’s assistance services and the consequences of inadequate capacity. OEHS staff assists in the delivery of PSC’s Public Service District Board Member Seminar, Municipal Officials Training, and Advanced Utility Topics Seminars. Training topics include a capacity development program overview, system security, operator certification requirements, sustainable infrastructure and asset management.

2.2.9 Third Party Activities Third party assistance has been provided through existing contractual agreements or by other state, federal, or non-profit entities. The primary third party assistance providers available to West Virginia water systems include:

Public Service Commission of West Virginia (PSC)

West Virginia Rural Water Association (WVRWA)

National Environmental Services Center (NESC)

Rural Community Assistance Program (RCAP)

WV Environmental Training Center (WVETC)

Maryland Center for Environmental Training (MCET)

National Environmental Training Center for Small Communities (NETCSC)

Regional Planning and Development Councils

Peer assistance from other WV water systems

WV Water/Wastewater Agency Response Network (WVWARN) All of these organizations have actively provided water system assistance throughout the reporting period. In addition to OEHS’s direct assistance, water systems are regularly referred to these third party organizations. These organizations routinely provide:

Technical (hands on) assistance and information

Trouble shooting problems in operation and distribution

Support, resources and tools for managerial and financial stability and infrastructure resilience

Training and education opportunities

Coordination of borrowing of equipment and operators

Page 13: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 13 of 22

2.3 Identifying and Prioritizing Systems in Need of TMF CDA’s are conducted for multiple reasons, including:

Baseline score indicates the system is struggling to develop or maintain their TMF

DWTRF funding applicants

Receptive systems with an elevated ETT score

Systems identified by engineering field staff as needing special assistance

At the request of the system Again this year, a strong emphasis for CDA’s was placed on systems that had an elevated ETT score as this seems to be an indicator of financial, managerial, and technical instability. This was achieved through cooperative efforts between the CDP staff, enforcement staff, and district engineering staff. CWS’s that had an ETT score > 11(not including orphaned systems) were possible candidates as were those CWS’s that were on the threshold of 11 (score of 9-10). More information on this process can be found in section 2.6 on page 18 of this report. By far, the majority of the CDA’s conducted this year were systems that had been identified through this process. Nine assessments were conducted during FFY2014. Of those, eight (88%) were conducted for an elevated ETT score. One (12%) was conducted with a system that applied for the DWTRF funding to ensure that the system is sustainable and had adequate capability to complete the project and repay the loan funding.

2.4 Statewide Concerns Identified As part of the CDA process, the CDP staff reviews baseline data/scores, a TMF capability questionnaire, EPA’s enforcement tracking tool (ETT), Public Service Commission annual report submissions, sanitary surveys, etc. The study identifies short comings and gaps that are indicative of the system’s inability to be sustainable. These deficiencies can be categorized as site-specific or global, as described below.

As systems have made progress to become more viable over the years, many of the deficiencies have moved from global to system-specific as more and more of the systems have addressed issues. Site-specific TMF capability deficiencies: These deficiencies are unique to a specific water system. In addition, site-specific deficiencies often require on-site, hands on assistance. Site-specific deficiency examples are:

Treatment and distribution system leaks and breakdowns.

Lack of knowledge of critical system components and their condition.

Inadequate spare parts inventory.

Failure to follow the sampling schedule.

Failure to enact adequate rates to sustain system operations.

Failure to create and enact both long term and short term budgets.

Failure to create/implement standard operating procedures, operations and maintenance tasks, and long range asset replacement plans.

OEHS staff can assist water systems in addressing site-specific deficiencies through:

District engineering staff assistance.

CDP staff assistance.

Educational resources such as draft plans/templates and free software, written material and training seminars.

Referral to third party resources.

Page 14: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 14 of 22

Global TMF capability deficiencies:

The following deficiencies are common to numerous water systems. Many of these deficiencies can be addressed through guidance documents or workshops. Examples of global deficiencies are:

Failure to update/maintain system maps.

Failure to ensure that system management/board members are adequately trained.

Failure of operators to obtain proper, adequate training to keep up to date with changing regulations.

Use of reserve funds for everyday expenses due to inadequate rates to meet operational expenses.

Failure to monitor the system’s financial health (i.e., expenses vs income).

Failure to include the public in long-term planning.

Need to explore energy efficiencies/conduct an energy audit. Global deficiencies are addressed using tools such as:

Workshops

Group training sessions or seminars

Guidance documents While there are a number of short-comings found when systems are reviewed, there are several deficiencies that are noted more often and are seen as key indicators in system viability. Those deficiencies are:

No long-term repair/replacement planning such as asset management.

Little or no long-term (and sometimes short-term) financial planning.

No preventive maintenance procedures or policies.

No budgeting or poor financial planning and tracking.

No health and safety procedures or policies.

No emergency/contingency plans.

System management staff not understanding their ultimate responsibility for ensuring the water system’s technical capability to provide reliable, safe drinking water and an adequate budget and rates supporting long-term water system viability.

2.5 Measuring Improvement - Baseline Ranking of Water Systems Section 1420(c)(2)(D) of the Safe Drinking Water Act, requires all states to develop a baseline priority ranking of their water systems. The initial 2002 baseline ranked the 737 West Virginia community and NTNC water systems that were in operation in 2002. Compiling the initial 2002 baseline and the updates of 2005, 2008, 2011, and 2014 involved gathering information from the water systems and the OEHS District Engineers (district offices are located in Wheeling, St. Albans, Beckley, Philippi and Kearneysville). CDP staff evaluated the information collected and developed a score for each water system. Once evaluated, every water system was assigned a score between 0% and 100%. The updated baseline data are being used (in conjunction with other measures) to help evaluate the overall status of West Virginia water systems and the effectiveness of the CDP. This year the 2014 updated baseline was compiled for the CWS and NTNC water systems in a manner similar to the initial baseline; yielding a current score for every water system (0% - 100%). The most current baseline ranking of water systems is available at the Capacity Development website: http://www.wvdhhr.org/oehs/eed/i&cd/baseline_assessment.asp.

Page 15: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 15 of 22

2.5.1 Baseline Priority Ranking Analysis The systems were ranked (0% – 100%) and categorized as viable, marginal and failing based on score. A high baseline score indicates a viable water system with adequate TMF capability. Similarly, a low score indicates a failing water system with inadequate TMF capability. Systems whose score was 70% or greater are considered viable, those with a score between 40% and 70% are considered marginal and those 40% or below are considered failing. The 2014 baseline ranking data showed that 470 (82%) of the community and NTNC water systems in West Virginia are viable systems having adequate TMF capacity; 83 (14%) are marginal and 19 (3%) are failing. Viable water systems serve 1.47 million people (96.4% of the population) while failing and marginal systems serve 54,650 people (or 3.6% of the population). There has been a decrease of more than 125 of the smallest (<300 population) water systems, (many of which were failing systems) since 2002 and a population shift away from failing systems to viable systems. The failing and marginal systems pose a constant threat of disrupting their customers’ drinking water supply thereby endangering the customers’ health and welfare and acting as an impediment to economic development. While West Virginia still has 102 water systems that are marginal or failing, the 2014 baseline data shows CDP staff work has resulted in steady improvements in the water systems’ capacities. As seen in Figure 1, since 2002, the number of viable systems has increased from 399 to 470 (15.2%) while the number of failing systems is down from 94 to 19 (80%) and the number of marginal systems is down from 244 to 83 (66%). Figure 1: WV Water System Viability Trends

Figure 2 indicates that there is only one failing systems and very few marginal systems that have more than 1000 customers; reinforcing the need for an adequate customer base to achieve and maintain water system viability.

0

50

100

150

200

250

300

350

400

450

500

2002 2005 2008 2011 2014

399 411 442 435

470

244

187

130 118 83 94

67 65 39

19

WV Water System Viability Trends

Viable

Marginal

Failing

54% 33% 69%

Page 16: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 16 of 22

Figure 2: 2014 WV Water System Viability Designation by Population Served

2.5.2 Recent Success Stories

Following are 2 examples of success stories for West Virginia’s Capacity Development Program: Town of Capon Bridge - Distribution System Upgrades and Water Line Extension

Project Purpose and Public Health Need: The purpose of the project is to update the Town’s water system to make it more reliable and sustainable. The Town of Capon Bridge proposes to install a new booster pump station to replace the existing station. A satellite controlled telemetry system will also be installed to allow the Town to monitor the booster station operation more effectively. The project will replace existing water lines that have been identified by the Town as requiring high maintenance due to frequent line breaks. As a proactive measure, the Town is proposing to replace much of the existing 4 inch water lines with new 6 inch and 8 inch water line. This will allow for more reliable distribution of flow, allow for modest future development or additional demand, and allow the Town to provide fire protection in areas where fire flows can be achieved. Project Benefits Included the Following:

The project will result in the following benefits:

Allow for more efficient and reliable distribution of water through the system

Reduce the amount of water loss

Provide the Town with more fire protection

Project Scope: The Town of Capon Bridge project is to make upgrades to the system’s booster station, replacement and upgrade of the telemetry system, and replacement of portions of the water lines. The scope of the proposed project consists of the following:

130

94

149

97

41 30

9 3

17

1 1 0 0

20

40

60

80

100

120

140

160

<300 systempopulation

300-999 systempopulation

1000-2999 systempopulation

>2999 systempopulation

2014 WV Water System Viability Designation by Population Served

viable

marginal

failing

Page 17: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 17 of 22

Installation of approximately 3.9 miles of 8-inch and smaller diameter waterline

Installation of a 150 GPM booster pump station

Installation of a new telemetry system

Installation of various valves and appurtenances Project Financing: The total project cost is $2,539,814. The DWTRF provided a base loan for $1,989,000 (0.5% for 30 years with a 0.5% administration fee) and a principal forgiveness loan for $450,814 for the project. Other funding sources that comprised the total project cost are $100,000 from the County Commission.

Town of Chapmanville - Water System Improvement Project – Phase I

Project Purpose and Public Health Need: The Town of Chapmanville (Town) is located along US Route 119 in Logan County, West Virginia, approximately 45 miles south of the City of Charleston. The Town provides water services by purchasing finished water from the Logan County Public Service District and through a Town owned and operated distribution system for approximately 963 residential customers. The existing distribution system consists of cast iron & PVC pipe and three existing water storage tanks. The proposed action is to replace the deteriorating cast iron lines with ductile iron pipe (DIP) and polyvinyl chloride (PVC) lines, replace two (2) deteriorating water storage tanks with a single tank and refurbish a water storage tank. The two water storage tanks to be replaced are adjacent to each other. These tanks will be demolished and removed prior to constructing the new tank at the same site. The new tank will have the same overflow elevation as the old tanks. The majority of the cast iron lines are over 60 years old. Over time, the minerals present in drinking water interact with the interior of the pipe and form a buildup known as tuberculation. Tuberculation increases pipe roughness and reduces the cross sectional area which increases pressure losses and reduces flow. In addition, old cast iron lines typically develop minor leakage at the joints. Replacing the aging cast iron lines with DIP and PVC lines will reduce the number of leaks and increase pressure and flow. A Water Loss Study documented leaks from July 2009 through June 2012. There were 8 to 10 major leaks per year with an estimated water loss of 151,556,000 gallons out of 305,326,000 gallons purchased for the system during the three (3) years. These leaks were normally found and repaired in a few days; however, some took as long as two (2) weeks. One of the 100,000 gallon storage tanks is currently leaking and the other 100,000 gallon storage tank is badly corroded. This rehabilitation project will be beneficial to all of its customers, by reducing the number of leaks and the loss of service during leak repairs. There are also public health benefits by minimizing the exposure of drinking water to contaminants that can be introduced through deteriorating water storage tanks, leaking pipes and during leak repairs. Project Benefits Included the Following: The benefits that this project will provide to the Town include system wide upgrades to improve existing problems such as:

Improved pressure and flow throughout the water distribution system.

Protection of potable water from potential microbial contaminants such as viruses and bacteria during water line leaks and repairs.

Reduce unaccounted for water loss due to leaks.

Protection of potable water from potential microbial contaminants such as viruses and bacteria from deteriorated water storage tanks.

Will allow the system to continue to provide safe and reliable service to its customers.

Page 18: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 18 of 22

Consistently providing adequate water storage capacity

Project Scope: The project will consist of the following improvements:

Approximately 10,240 linear feet of water line

A total of 92 gate valves

A new 218,000 gallon storage tank

The refurbishing of an existing water storage tank

The demolition of two existing water storage tanks

Approximately 3,300 linear feet of service line

A total of 123 customer connections

A total of 15 fire hydrants

A flushing hydrant

Project Financing: The total project cost is $3,005,000. The DWTRF provided a $1,505,000 loan (0.5% for 30 years with a 0.5% administration fee). The remainder of funding was provided through Small Cities Block Grant for $1,500,000.

2.6 System Compliance Tracking Through ETT

System compliance tracking has always been a task assigned to the OEHS C&E staff. The C&E staff utilizes the ETT tool to target compliance assistance to those systems with an elevated ETT score. The EPA requires OEHS to take action on systems with an ETT score >11. The ETT report with the quarterly compliance status for all systems is sent to EPA. The enforcement action taken is a decision from the consensus of the C&E staff, the CDP staff, the district engineering staff, and the EPA. Utilizing the ETT tool, the C&E staff also targets those systems that have not yet reached the actionable score assigned by EPA. The C&E staff is pushing systems that are on the cusp of reaching the action level (those with an ETT score >8) to begin proactive measures that will remedy violations and lower their ETT score.

The CDP staff and the C&E staff have teamed up in the selection of systems that will be targeted for a CDA. The very low scoring, failing systems (those considered to be orphaned systems) are not to be the target of the CDA process as most of these systems have no one designated as a responsible party for the system and therefore, no ability nor desire to improve. It is hoped that shifting CDP’s attention from “hopeless” systems to “struggling” systems will enable the CDP to focus our efforts on systems that have the capability to achieve and improve their compliance.

Starting in FFY 2012, with input from the district engineering staff, the C&E staff works hand in hand with CDP staff to identify by both the ETT score (>11)and the baseline score (marginal or upper failing scores) those systems that will be targeted for an assessment. These non-compliant systems will be the focus of a CDP staff member whose task will be to help identify these system’s TMF deficiencies along with defining a reason for their inability to remain in compliance. Once the analysis has been completed, this staff member is responsible for assisting that system to attain and maintain compliance, build TMF, and improve overall system sustainability.

2.7 Future Activities The CDP will continue to use a proactive, hands-on approach in supporting water systems. The need for a CDA will be determined through the recommendations of field staff, request of a system, request of OEHS’s compliance/enforcement staff, and by CDP staff review of baseline scores. All initial

Page 19: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 19 of 22

assessments are onsite and include resources, tools and guidance needed to improve water systems’ TMF.

The CDP monitors the ETT list and continues to work with the OEHS C&E Section and other water utility related organizations (e.g., Public Service Commission, Rural Community Assistance Program, Regional Planning and Development Councils, adjacent Public Service Districts, etc.) to aid water systems having long-term compliance problems.

The CDP will follow-up with systems for a full year following an assessment to monitor their progress in implementing the CDP recommendations to improve their TMF.

The CDP also monitors newly formed water system’s ETT scores for violations related to failure to follow the monitoring and compliance schedules.

The CDP will continue to provide a CDA to all public water systems requesting DWTRF funds for projects. This will be an opportunity to:

Identify systems that need a CDA;

Obtain improvement in TMF for facilities requesting funding; and

Suggest additions to the projects that can address identified shortcomings in the system.

CDP staff will continue to provide training opportunities to water systems including:

Teaching portions of the water system operators courses.

Teaching Public Service District and Municipalities Courses on Capacity Development, TMF, and Asset Management through the West Virginia Public Service Commission.

The CDP will further programmatic improvements by:

Continuing the development of asset management plan processes, tools, resources and skills of CDP staff, water system staff, and engineering firms staff.

CDP secession planning including the development of standard operating procedures for review of CCR which are submitted by water systems as an annual water quality report for their customers.

Incorporating recently developed databases for CDA, baselines, consumer confidence reports, and asset management into the daily practices of the Engineering Division staff more broadly than just CDP.

Exploring the need to include, in the CDA process, questions/discussions regarding the understanding of and compliance with source water protection planning requirements.

Exploring options for additional onsite, hands-on support to systems for implementation of CDA recommendations for identified shortcomings.

2.8 Program Progress in FFY2013 Overall CDP progress as well as individual system progress is measured every three years through the Baseline survey. The baseline report is available online to show progress from 2002 to 2014. Individual system progress is also measured through the follow-up process to each assessment and will be measured again as part of the 2017 Baseline. See Table 3 for assessments conducted in FFY2014.

Page 20: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 20 of 22

Table 3: Summary of Water System CDA’s in FFY2014 and Reasons for Assessment

3 Additional Reporting and Other Concerns

3.1 Report to the Governor SDWA § 1420(c)(3) requires a report to the governor every three years. This report was completed and forwarded to Governor Earl Ray Tomblin on September 23, 2014. Report availability to the public was advertised in the State Register on September 26, 2014. A letter providing a copy of the report and documentation of transmittal and public notice was sent to Victoria P. Binetti, EPA Associate Director for Drinking Water and Source Water Protection, September 26, 2014. The report can be accessed online at the following link: http://www.wvdhhr.org/oehs/eed/i&cd/Governors_Report_Page.asp . The next report will be submitted on or before September 30, 2017.

3.2 Drinking Water Treatment Revolving Fund (DWTRF) Procedures

3.2.1 Ensuring DWTRF Applicants Achieve Compliance The Capacity Development Strategy specifies systems seeking DWTRF loans will be assessed and to determine if the system has sufficient capacity and is sustainable. The CDP staff assesses the capacity of water systems most likely to receive DWTRF loan monies; evaluating their TMF capabilities to ensure that the system will be able to repay the loan. While assessing the water system, direct assistance and advice is provided. The CDA report recommends actions addressing the system’s capacity needs and provides a list of assistance providers. Systems not having sufficient capacity must address their capacity deficiencies before receiving a DWTRF loan or as part of the construction project. Deficiencies noted during assessments are technical, financial and/or the managerial in nature. In such instances the technical deficiencies (e.g., fencing, water loss, tank replacement, etc) must be addressed in the proposed project while the managerial/financial deficiencies (e.g., cross connection program, asset

System Name Date of Assessment

FFY DWTRF Water Sys Request

OEHS Staff Request

ETT Outside Request

Baseline

Marlinton, Town of Oct. 2013 2014 x

Northfork Water Works

Nov. 2013 2014 x

Cardinal Ventures Nov. 2013 2014 x

Anmoore, Town of Jan. 2014 2014 x

Shepherdstown Corp

Jan. 2014 2014 x

Sistersville Municipal Water

Feb. 2014 2014 x

Pierpoint PSD March 2014 2014 x

Keystone Municipal Water

April 2014 2014 x

Elkins Road PSD May 2014 2014 x

Page 21: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 21 of 22

management plans, capital improvement plans, budget, five-year budget projection, etc.) must be developed/implemented before the completion of the project. The DWTRF Project Priority Ranking System awards the highest points possible in several categories for projects correcting problems causing public health and non-compliance issues, increasing the overall project ranking. The project must address the causes for non-compliance to receive these points. In keeping with EPA regulations, DWTRF funds are not loaned to systems with an ETT score elevated to 11 or greater and those systems without adequate TMF unless the funding will build the system’s TMF and address the reasons for chronic non-compliance.

3.2.2 DWTRF Funding Distribution including small and disadvantaged systems

Since the DWTRF program began in 1998, 104 loans totaling in excess of $187 million dollars have been committed in loans for water system upgrades in West Virginia. In SFY 2014, these funds were distributed to a range of systems sizes; systems ranging from 270 customers to 4,475 with the average population served, for projects funded, of 2,263. It should be noted that the EPA defines a small system as any system <10,000 customers and more than 90% of systems in West Virginia meet this definition. Figure 3 illustrates the funding distribution to various system sizes over the past 3 years. Figure 3: Distribution of Loan Dollars by System Population Size

Figure 4 illustrates the percentage of SFY2014 funds disbursed to various size systems with 0% funds going to systems with more than 100,000 population.

0123456789

10

<500

po

pula

tion

50

1-3

,300

po

pula

tion

3,3

01

-10,0

00

po

pula

tion

10

,00

0-1

00

,000

po

pula

tion

>100

,00

0

$ D

isb

ure

d i

n M

illio

ns

Distribution of Loan Dollars by System Population Size

2012

2013

2014

Page 22: WEST VIRGINIA CAPACITY DEVELOPMENT PROGRAM ANNUAL ...€¦ · 4th Qrt. 2013 ETT scores 1st Qrt. 2014 ETT scores 2nd Qrt. 2014 ETT scores 3rd Qrt. 2014 Population Served System Status

Page 22 of 22

Figure 4: SFY2014 Funding Distribution by System Population Size

14%

52% 1%

33%

SFY2014 Funding Distribution by System Population Size

<500 population

501-3,300 population

3,301-10,000 population

10,000-100,000 population

>100,000