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Scout Camps and EPA Violations


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What is everyone's experience with your LC scout camp and EPA compliance with water and wastewater standards? I have multiple LC camps in significant non-compliance,  some were recently fined large amounts of money.

It appears at least in my state that the LC's ignore water standards even failing to collect required samples.

Scouts deserve safe drinking water and LC's should be held accountable. 

 

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One of the NCAP standards, and I believe it is mandatory (sorry It has been a while since I had to deal with NCAP) is that camps' water must be tested ( I think yearly at a minimum) and be deemed potable. I know the NCAP standard was higher than the local standards, and we had to rush a test to open our day camp since it was at our local camp.

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I'm in the middle of finishing up the binder for my day camp so I've been seeing all the standards lately.

Quote

FA-702 Drinking Water

STANDARD:
Adequate access to safe drinking water is provided to all participants .

INTERPRETATION:

Drinking water is from an approved public water system source or is tested regularly during the season for bacteriological quality, and meets governmental health standards . In the absence of an applicable health code, piped or provided water supplies are tested at least once a year at the start of camp .

And 

Quote

FA-710 Garbage and Sewage removal

STANDARD:

Disposal of garbage, refuse, and sewage meets the demand of the maximum number of campers in attendance . Garbage storage facilities are clean, and pest control is adequate .

INTERPRETATION:

It is anticipated that raw garbage should be removed from the individual campsites daily in day camp, short-term camps, and long-term camps . Camps offering outpost or trek programs should provide guidance on garbage handling and provide reasonable options for garbage handling, consistent with the nature of the program .

The use of commercial portable toilet facilities for disposal of human waste and toilet paper, if used and maintained in accordance with manufacturer’s directions and local code, is acceptable .

VERIFICATION:

  • Visual inspection of garbage-handling practices

  • Review of sewage-handling practices

Beyond all that, camp properties are not immune from local laws or code rules. They might be old enough to be grandfathered into earlier rules, but still we are supposed to follow the rules.

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Agree everyone deserves safe drinking water, but what is safe "adequate", what is being tested, and where - campsite, camp kitchen,...

The EPA does not regulate private wells, so I would be surprised if the EPA fined camps over drinking water quality.  Regulation and enforcement  is left to state and local authorities or self-policing camp associations.

Nothing to stop a scouter from drawing a water sample and having it tested by a private lab. Testing for bacteria and E.coli might be less than $100, radon and arsenic a little more, and testing for PFAS would likely be $400.

https://www.ncsl.org/research/environment-and-natural-resources/unregulated-drinking-water-systems.aspx

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I know we had issues once or twice with the county and maybe even the state.  We had to replace the well after it collapsed due to the drought issues and age.  Then it had all be recertified.  We use a local portapotty system for camp sites and outlying activity areas, and we have a relatively new system at the pool with individual stalls and a connect system to septic tank.  The other main part of camp has some challenges due to age, but is also septic connected but needs updating.  The county keeps a very close eye on us; do not know if they do that to other camps in the area, but would hope so.  

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To the OP, enforcement of the Clean Water Act is relegated to state and local agencies; the EPA itself rarely gets down on the ground testing etc ... OPs state agency should have been monitoring and managing in conjunction with a local water district or municipal entity while enforcing the Clean Water Act on behalf of the EPA and enforcing any additional state and local regulations. My advice concerning your camp issue is to reach out to your states natural resources agency. If you think there is a violation it would be documented and public knowledge, if it is chronic and related to a water body there would be a TMDL recommendation and a remediation plan (I suspect these exist as OP stated fines have been levied). 

In response to Malrux statement of grandfathered status; exemptions and grandfathered rights related to the Clean Water Act ended in 1989. The Clean Water Act had a multi-stage implementation where some entities were grandfathered into practices and policy to give them time to retrofit or build facilities within compliance, but all of those grandfather rights were expired when the final stage of implementation of the act went into affect in 1989 (which almost all of the last exemptions were related to municipal water and waste).  
 

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Well (no pun intended) ... our camp water improved 10+ years ago.  When I started camping at scout camps, there was lots of iron and particles in the water.  Understandable as our sub-camp well was idle 10 months a year.   Then about 10 years ago, a flexible pipe was run to every sub-camp.  After that, the water was great.  ... Before ... I felt like I needed to strain and boil the water. 

Edited by fred8033
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12 hours ago, RememberSchiff said:

Agree everyone deserves safe drinking water, but what is safe "adequate", what is being tested, and where - campsite, camp kitchen,...

The EPA does not regulate private wells, so I would be surprised if the EPA fined camps over drinking water quality.  Regulation and enforcement  is left to state and local authorities or self-policing camp associations.

Nothing to stop a scouter from drawing a water sample and having it tested by a private lab. Testing for bacteria and E.coli might be less than $100, radon and arsenic a little more, and testing for PFAS would likely be $400.

https://www.ncsl.org/research/environment-and-natural-resources/unregulated-drinking-water-systems.aspx

The Ohio EPA where I live does regulate any water supply over 25 people. This includes scout camps.

My LC camp has been fined thousands for failure to sample. And the wastewater system is in significant noncompliance. 

They are working on fixing wastewater but I think it will take a fine to get it done.

The camp is Beaumont Scout Reservation. Nice camp but poor water and wastewater.

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32 minutes ago, 1980Scouter said:

The Ohio EPA where I live does regulate any water supply over 25 people. This includes scout camps.

My LC camp has been fined thousands for failure to sample. And the wastewater system is in significant noncompliance. 

They are working on fixing wastewater but I think it will take a fine to get it done.

The camp is Beaumont Scout Reservation. Nice camp but poor water and wastewater.

Oh I see my confusion,  Ohio EPA is a department of the Ohio state government as opposed to the US EPA.

Edited by RememberSchiff
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13 hours ago, malraux said:

They might be old enough to be grandfathered into earlier rules

Generally, one cannot be grandfathered in with respect to health and safety matters.

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I certainly don't have any answers on this topic, but the information and questions I have from a number of sources, namely, testing and treating the drinking water supply system at my local camp, portable water treatment for Philmont crews,  and treating and testing pools, has all been brought to mind by the discussion above.  So I just have a few observations and questions.

Drinking water system at camp.  The ranger would describe turning on the water system and driving the buried water lines looking for leaks each Spring.  When a leak was found, it had to be dug out and repaired.  Once all leaks appeared to be identified and repaired, the water would be treated.  Treatment involved loading up the entire system with a healthy dose of purifying chemical.  Our camp has about a dozen separate dead end water line runs.  Spigots need to be open to permit heavily treated water to flush out last year's remaining normally treated water.  Once the heavily concentrated water was detected at each spigot, The spigot was closed and that line had to steep for a given time period.  Longer lines take longer to replace the old water with heavily treated water.  The ranger is testing for a given level of "chlorine" or whatever it is.

Then, the heavily concentrated water in the lines has to be flushed with normally treated water, and that water tested to insure that it is not the heavily treated water.

All of this is merely flushing the lines.  There are al lot of steps, and I'd think a lot of record keeping involved.

Then the normally treated water needs to be tested, and EACH line has to be tested.  

I suspect that there are several categories of things to test for (largest size to smallest):

1.  Particulate matter like clay, sticks, leaf particles-all things introduced by digging down to a leak and repairing it. Presumably, digging a hole around a leak will create a mud hole in which the work is done.

2.  Bacteria.

3.  Viruses.

4.  Heavy metals, pesticides, herbicides, fungicides, and algicides.  (Maybe viruses are smaller than molecules.)

I suspect that some of these things can be tested in the field but others would require a lab.  So how often do these things get tested for, are the testing chemicals, reagents, etc., current? Is the person testing trained to follow the protocols to avoid false negatives?  Are records kept reliably?   Are tests actually being conducted?  Are positive tests run again?  What procedures if there is a true positive test?  Shut down the system, re-treat the water, etc.

I really question if all these steps are followed and executed.  Camp life for a ranger and staff can be a bit chaotic.

Water quality control is a bit more complicated than I have previously thought.

Backcountry Philmont Crew water treatment. These systems are obviously much simpler than a camp-wide system.  I only note that these systems have no testing component.  Water is treated with a chemical, or a filtering pump, or both, and consumed on the presumption that the treatment was effective.  Presumed to be safe, not shown to be safe.  There are also ultra violet light purifying systems.  My take-away is that these treatments must be very effective to be presumed safe, but some do not protect against viruses, and none protect against heavy metals, pesticides, etc.  Also, plant matter, such as  algae, or cloudy water can reduce effectiveness.  (One backcountry expert wrote somewhere that one had to be careful getting water from a stream as there might be a dead elk a hundred yards upstream...I can't get that idea out of my head.)

Swimming pools.  These are different from drinking water in two respects:  pool water is not intended for drinking, but everyone swallows some once in awhile, and lots of people are actually swimming in your drinking water.  Hmmm.  I would expect that the level of chemical treatment for a pool is higher than for drinking water.  But, as you are putting your eyes in the pool it cannot be too strong.

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