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ADEM Compliance Assistance Program Review of the

Prichard Water System

February 6, 2023
Prepared for the Prichard Water Works and Sewer Board

Pamela Monaghan/ADEM
Jim Grassiano/ADEM
PWSID No. AL0001015
Prichard Water Compliance Assistance Review - Page 2

The following is a discussion of site conditions and issues, prepared by ADEM’s Compliance
Assistance Program. The evaluation of site conditions is based on a cursory system review and
is not intended to be a thorough assessment of compliance, nor is this write-up intended to
represent the recommendations of ADEM. This information is presented for the Permittee’s use,
as the Permittee should more fully assess what is needed to achieve and maintain long-term
permit compliance.

Intent of Document
The Alabama Department of Environmental Management’s (ADEM’s) Compliance Assistance
Program has prepared this brief assessment of the Prichard public drinking water system, a
Community Water System owned and operated by the Water Works and Sewer Board of the
City of Prichard (PWWSB or Prichard Water).
ADEM’s Compliance Assistance Program offered to provide a limited assessment of the Prichard
public water system to help identify priorities that could improve the quality, reliability and
efficiency of water distribution and rate collection, and that could improve the overall financial
status of PWWSB. From an infrastructure standpoint, this report provides a special focus on
Alabama Village. Identifying water system priorities is the objective of this report.

Introduction and Initial Findings


Prichard Water does not produce or treat its own drinking water. It is a purchase water system
with no water treatment capability, including no ability for providing disinfection. As well,
Prichard Water presently has no booster pump capability. Prichard Water functions solely as a
water distribution system. Prichard is a provider of water to Chickasaw residents who are
customers of the Prichard Water system, just the same as citizens of Prichard. Prichard owns
and operates the Chickasaw water tank and the water distribution system serving Chickasaw
residents.
PWWSB is permitted by ADEM to provide drinking water to its customers in accordance with
Public Water System Identification Number (PWSID No.) AL0001015.
PWWSB purchases water only from the Mobile Area Water and Sewer System (MAWSS).
MAWSS holds a Community Water System permit (PWSID No. AL0001005). Though known
generally as MAWSS, the full permittee name is “The Board of Water and Sewer Commissioners
for the City of Mobile”. MAWSS owns and operates two surface water treatment plants that
provide water directly to citizens of Mobile. MAWSS also sells water to PWWSB and to the
Spanish Fort Water System.
Prichard Water Compliance Assistance Review - Page 3

PWWSB has been subject to unusually high water loss, along with media inquiries alleging
water service reliability concerns1,2. In December 2022, there was even a call to publicly
dissolve PWWSB3, in part due to “crumbling infrastructure”.

We understand that Prichard Water retained W.R. Mitchell as a contractor to investigate and
repair water lines located in Alabama Village. The ADEM Compliance Assistance Program is
unaware of the project scope for the work that W.R. Mitchell undertook or completed.
However, in May 2022, W.R. Mitchell’s Project Manager (Mr. Tyler Beersdorf) delivered a brief
document to PWWSB dated on or about 5/22/22. In this report, Mr. Beersdorf presented
“BLUF” findings [a military communications term meaning “Bottom Line Up Front”] about water
service lines located in Alabama Village. Mr. Beersdorf suggested that PWWSB “…investigate
funding for completely replacing all the existing water pipe in and around Alabama Village”.
Prichard’s former Operations Manager (Mr. Dan McCrory) also provided a report to ADEM’s
Compliance Assistance Program regarding Alabama Village. This second report was also issued
to the PWWSB and is dated 11/9/22. In this recent report, the former Operations Manager for
Prichard Water recommended that PWWSB “shut down” water service to Alabama Village, a
subdivision in Prichard, due to an unsustainable water loss in this subdivision.

Site Visit
ADEM’s Compliance Assistance Program conducted a site visit to Prichard, Alabama on
December 15-16, 2022. During the site visit, Pamela Monaghan and Jim Grassiano of ADEM
were accompanied by (now former) Prichard Water Operations Manager Dan McCrory. We
also met with PWWSB Board Chair Russell J. Heidelberg and Office Assistant Ja’Net Joiner to
discuss water system issues, most notably to address water distribution issues related to
Alabama Village.

1
Alabama Village still at risk for water getting shut off, looking for answers | WPMI (mynbc15.com)
2
NBC 15 Reality Check Investigation: Alabama Village household without water for 2 months | WPMI
(mynbc15.com)
3
December 14, 2022, NBC News 15 (WPMI): Public call to dissolve the Prichard water board | WPMI
(mynbc15.com)
Prichard Water Compliance Assistance Review - Page 4

Overview of Water System


PRICHARD WATER CUSTOMERS

Prichard’s public drinking water system permit was issued by ADEM on July 25, 2022 and will
expire on July 31, 2028. This Community Water System provides potable water service to
citizens of Prichard and also to citizens of neighboring Chickasaw.

As of the 2020 census, the


population of Prichard was
about 19,300 and the
population of Chickasaw
was about 6,400; the total
population served by
Prichard Water is
approximately 25,700
people. However, the
population of the area is
notably decreasing,
according to census
trends. Data from
census.gov4 indicates a
declining population in the
City of Prichard from
about 22.7 thousand (K) in
2010 to 19.3K in 2020, and
further to about 19.0K in
2021. Thus, we can
perhaps expect Prichard’s
population in 2023 to be
lower still.

As of the date of this


report (February 2023),
Prichard Water provides
potable water to a total of
9,664 customers, broken
down as follow:
Figure 1 PWWSB Service Areas: Prichard and Chickasaw

4
Prichard Population: U.S. Census Bureau QuickFacts: Prichard city, Alabama
Prichard Water Compliance Assistance Review - Page 5

TALLY OF PRICHARD WATER CUSTOMERS


Prichard Chickasaw
RESIDENTIAL 6,868 237
COMMERCIAL/INDUSTRIAL 415 144

The total number of residential customers served by Prichard Water is 9,107. The total overall
number of residential and commercial/industrial customers is 9,664.
We have a tally of Prichard’s water bill records identifying its highest industrial and commercial
water users. On average, Prichard’s top ten industrial and commercial customers consume only
about 8 Million gallons of water per month. In the last documented record of total monthly
water usage [from the December 2022 Monthly Operating Report (MOR)], Prichard purchased
123 Million gallons of water. Thus it is clear that most of Prichard’s monthly water
consumption is residential.

To evaluate residential water use in further detail, we estimated Prichard’s anticipated


municipal domestic water use for residential purposes. The average US residence consumes
about 138 gallons of water per day for indoor water use5. In the summertime, we can expect
additional water use for gardening, car washing, etc. Thus, we will conservatively estimate
domestic water use as 200 gal/day/residence.
On this basis, the estimated residential water usage for Prichard Water should be about:

9,107 𝑥 20 𝑥 200 ≈ 54,600,000 𝑔𝑎𝑙𝑙𝑜𝑛𝑠⁄𝑚𝑜𝑛𝑡ℎ

5
https://www.watercalculator.org/footprint/indoor-water-use-at-home/
Prichard Water Compliance Assistance Review - Page 6

MAWSS MASTER METERS

MAWSS accounts for the wholesale delivery of water to PWWSB via seven master meters. The
locations of the seven master meters are shown in Figure 2. The name of each meter is listed
below, along with the designation of the nearest intersecting road:

 Bay Bridge at Grover Street;


 Sweeneys Lane at Dubose Street;
 Viaduct Road at Howell Street;
 Jarrett Road at Bear Fork Road;
 Short Street at Chastang Street;
 Industrial Street East at North Beltline Highway; and
 O’Neal Lane at State Route 43 (this meter is dedicated to Chickasaw and fills the
Chickasaw Tank).
PRICHARD WATER DISTRIBUTION LINES

The Public Water System permit issued by ADEM in 2022 indicates that the Prichard Water
distribution system consists of about 246 miles of cast/ductile iron pipe, 10 miles of PVC pipe,
and 10 miles of ‘other pipe material’.
In general, the condition of buried water service lines and water mains in Prichard is reportedly
very poor. Portions of the water distribution system have a service life exceeding 80 years.
Prichard Water Compliance Assistance Review - Page 7

Figure 2 Map of Prichard Water Tanks (blue circles) and Master Meters (green stars). Location of Alabama Village is identified with a purple square.
Prichard Water Compliance Assistance Review - Page 8

PRICHARD WATER STORAGE TANKS AND GENERAL WATER PRESSURE CONCERNS

Prichard owns and operates five water storage tanks (also shown in Figure 2) to maintain
suitable system sub-network pressures at various locations throughout Prichard’s water
distribution system. Prichard’s five water storage tanks are collectively filled from the seven
master meters described above (i.e., filled with water purchased from MAWSS). Prichard’s
water storage tanks are designated and located as follows:

 1.0 million gallon (MG) “Vigor” elevated tank at 101 W Pershing Street;
 1.0 MG “Anderson” elevated tank at 3634 West Main Street;
 0.25 MG “Blount” elevated tank (aka “Lott Road”) at 4000 Lott Road (near Eight Mile);
 1.0 MG “Chickasaw” elevated tank at 100 O’Neal Lane, Chickasaw; and
 0.5 MG “Standpipe Tank” standpipe tank at 125 Clark Avenue (Prichard Water Office)
The state of disrepair of Prichard’s water lines cannot be overstated. This is particularly true in
the Alabama Village area, though there may be other communities within Prichard or
Chickasaw that have notable degradation of water service line infrastructure. In an attempt to
bracket the degree of concern in and around Alabama Village regarding water reliability, ADEM
requested that Prichard’s water operator measure static pressure readings at various fire
hydrants located in the area of Alabama Village.

PRESSURE MEASUREMENTS AT HYDRANTS IN AND NEAR ALABAMA VILLAGE

While on site in December 2022, we requested that Prichard’s certified water operator take
pressure measurements at several fire hydrant locations in Alabama Village. Static pressure
readings were recorded at eight hydrants of various capacity. Ultimately, the location of the
hydrants was unclear to ADEM, but the approximate hydrant location and the pressure gauge
readings are presented below:
Red Hydrant near Lamar Street: 48 psi
Red Hydrant (unidentified Location): 33 psi
Yellow Hydrant (unidentified Location): 46 psi
Yellow Hydrant (unidentified Location): 47 psi
Yellow Hydrant (unidentified Location): 46 psi
Yellow Hydrant near Escambia Street: 44 psi
Yellow Hydrant (unidentified Location): 49 psi
Yellow Hydrant (unidentified Location): 48 psi
Red Hydrant (unidentified Location): 38 psi
Yellow Hydrant (unidentified Location): 40 psi

In general, red hydrants are usually rated at 500 gallons per minute (gpm) and 20 psi minimum
dynamic or ‘residual’ pressure. Yellow hydrants often do not indicate a flow rating. Rather
Prichard Water Compliance Assistance Review - Page 9

yellow hydrants typically indicate only that the hydrant is connected to a potable municipal
water system.
Static pressure readings are of minimal value for assessing pipe network flow. The dynamic, or
residual, pressure at the rated hydrant flow is the National Fire Protection Association (NFPA)
requirement. Nevertheless, ALL the static hydrant pressure ratings shown above appear
insufficient to supply adequate fire protection water capacity. The hydrant static pressure
values of 33 and 38 psi are extremely low and likely indicate water main leakage.
On January 3, 2023, ADEM requested that Prichard’s certified water operator take additional
static pressure readings at definitive hydrant locations in Alabama Village. The following
pressure gauge results were presented to ADEM:
Yellow Hydrant (W. Side of Marengo Dr, N. of Geneva St): 29 psi
Yellow Hydrant (E. Side of Marengo Dr, between DeKalb Dr and Conecuh St): 32 psi
Red Hydrant (near Geneva St and Madison Ave): 32 psi

The locations of these three definitive low static pressure readings in Alabama Village are
shown in Figure 3. Based on these low pressure readings and our understanding of the
excessive system water loss in Alabama Village, it is unlikely that suitable fire suppression water
can presently be provided in this area of Prichard via these hydrants. Furthermore, if anyone
opened a hydrant, the likelihood of a notable drop in system water pressure in the vicinity
would be significant.

Currently, there remains a significant possibility of low system water pressure at any time and
location in Alabama Village. ADEM’s Division 7 (Public Water Supply) Regulation requires that
Prichard’s water system: “…be designed and operated such that a minimum of 20 psi of water
pressure is supplied at the water system meter under all normal operating conditions”.
The ‘meter’ referenced in the above citation is any customer water meter.

The likelihood of Prichard’s public water supply not meeting the 20 psi requirement at each
customer service meter in Alabama Village is significant. There may be other low pressure
locations in Prichard (and perhaps Chickasaw) as well.
Prichard Water Compliance Assistance Review - Page 10

Hydrant
Hydrant

Hydrant
Ponding

Ponding

Figure 3 Alabama Village Hydrants and roadway ponding.

Further work is needed to assess system-wide dynamic pressure and flow throughout Prichard’s
water distribution network. As well, the in-place condition of Prichard’s service lines and water
mains is unknown. Presently, it is impossible for ADEM’s Compliance Assistance program to
fully understand the reliability of Prichard’s water distribution network. A real-time network of
pressure readings is needed at many locations over a defined period to ascertain system
dynamics. However, given the recent low static pressure readings, the May 2022 W.R. Mitchell
report, and the December 2022 report by the Prichard Operations Manager, it appears that the
water distribution lines serving areas of Prichard are in dire shape.
During the December 15-16, 2022 site visit, ADEM’s Compliance Assistance Program noted
significant water ponding in certain Alabama Village locations. Examples include the southwest
region of Marengo Drive (West of Hale Drive) and nearly the entire length of Madison Avenue.
It is conceivable that notable flooded roads and right-of-way in Alabama Village are the result
of leaking water mains and/or service lines. These troubling flooding/ponding locations are
also presented in Figure 3.
Prichard Water Compliance Assistance Review - Page 11

Water Loss Discussion


WATER LOSS DOCUMENTED ON MONTHLY OPERATING REPORTS (MORS)

The ADEM Compliance Assistance Program completed a thorough review of Prichard’s Monthly
Operating Reports (MORs) submitted to ADEM from November 2019 through December 2022.
For a Purchase Water System, the key metrics are water purchased (from MAWSS) vs water
sold (to the PWWSB customers). The difference equates to water loss.

𝑤𝑎𝑡𝑒𝑟 𝑝𝑢𝑟𝑐ℎ𝑎𝑠𝑒𝑑 − 𝑤𝑎𝑡𝑒𝑟 𝑠𝑜𝑙𝑑 = 𝑤𝑎𝑡𝑒𝑟 𝑢𝑛𝑎𝑐𝑐𝑜𝑢𝑛𝑡𝑒𝑑 𝑓𝑜𝑟 or "𝑡𝑜𝑡𝑎𝑙 𝑤𝑎𝑡𝑒𝑟 𝑙𝑜𝑠𝑠"

Some portion of a utility’s water loss can often be accounted for, estimated, and tallied each
month. Examples include water used for fire suppression, fire-fighting training, flushing of
system water lines, and water loss quantitatively identified during repair of water main breaks.
When these “known” losses are tallied and eliminated from the overall “total” system water
loss, then the remaining unaccounted for water loss is defined as the “corrected” water loss.

total water loss − accounted for = 𝑐orrected or unaccounted for water loss
In its MORs from November 2019 through March 2021, PWWSB reported estimates of very
notable water losses due to firefighting, line flushing and water line breaks. PWWSB’s
estimates for firefighting and line break losses were commonly in the range of 20 to 25 million
gallons (MG) per month, and line flushing values of 5 MG per month were also typical. PWWSB
accounted for a known monthly water loss due to line breakage as high as 79.4 MG in June
2022.
From March 2021 through December 2022, PWWSB stopped providing any estimate of water
loss due to firefighting. The City of Prichard is still providing firefighting services, so the reason
for PWWSB changing its accountability of water loss on Prichard’s MORs is unclear. We suspect
that the estimated water losses reported on MORs prior to March 2021 due to firefighting are
incorrect. The change in omitting firefighting water-use estimates has a significant impact on
the calculation of ‘corrected’ water loss on monthly MORs, but the change does not affect the
true total system water loss.
From November 2019 through March 2021, Prichard’s total monthly water loss averaged 49%
with a maximum of 56% in January 2020 and a minimum of 39% in July 2020. This is a strikingly
high water loss for a community water system. Prichard’s corrected water loss for this period
averaged 23%, with a maximum of 37% in September 2020 and a minimum of 12% in January
2021. Once again, these older historical corrected water loss values are likely skewed low due
to errant estimates of ‘known’ water loss.
Since March 2021, total monthly water loss averaged 56% with a minimum of 47% in April 2021
and a maximum of 64% in November 2022. The corrected water loss for this period averaged
37% with a minimum of 1% in June 2022 when all the water loss was attributed to line breaks.
The maximum corrected water loss was 56% in February 2022.
Prichard Water Compliance Assistance Review - Page 12

That Prichard Water is struggling with an excessive nominal water loss of nearly 60% [it was
64% in November 2022) is concerning. Such high water loss can be indicative of general
reliability concerns, particularly as water loss continues to increase over a long-term period of
years. This is the case for Prichard Water. Note that ADEM typically recommends that total
system water loss be lower than 15 %, primarily to control lost revenue.
Even today, the protocol Prichard Water is using to report its corrected water loss appears to
be flawed. Unless definitive water leak points are observed and readily estimated or measured,
then such water losses should remain “unaccounted”; the values should not be reflected as
“corrected water loss” on Prichard’s MORs.
The total and corrected water losses for roughly the past three years are presented in Figure 4.

% Total Water Loss vs % Corrected Water Loss


November 2019 - December 2022
total water loss % corrected water loss
Linear (total water loss) Linear (% corrected water loss)
70%
60%
50%
40%
30%
20%
10%
0%
Jul-20

Jul-21

Jul-22
Apr-20

Apr-21
Nov-19

May-20
Jun-20

Nov-20

May-21
Jun-21

Apr-22
Nov-21

May-22
Jun-22

Aug-22

Nov-22
Dec-19
Jan-20
Feb-20
Mar-20

Aug-20
Sep-20

Dec-20
Jan-21
Feb-21
Mar-21

Aug-21
Sep-21

Dec-21
Jan-22
Feb-22
Mar-22

Sep-22

Dec-22
Oct-20

Oct-21

Oct-22
Figure 4 Drinking Water Monthly Operating Reports – Total Water Loss and Corrected Water Loss

Perhaps the most significant issue in Figure 4 is that not only was the Total Water Loss initially
very high in November 2019 (the beginning of this study period), but Prichard’s ongoing
nominal monthly Total Water Loss has consistently continued to increase for nearly over 3
years.
WHY WATER LOSS MATTERS

Prichard’s unusually high total water loss reflects challenges with system reliability and even
water availability to customers. Excessive water loss can adversely affect system pressure,
potentially leading to public health concerns that would warrant boil water notices.

High water loss also adversely affects PWWSB finances by causing lost direct revenue from
customers, excessive costs for purchased water, and high maintenance costs due to utility staff
and contractors having to frequently repair water leaks.
Prichard Water Compliance Assistance Review - Page 13

Water Meters and Water Tanks


CUSTOMER’S WATER METER REPLACEMENT

In the fall of 2021, PWWSB began replacing nearly all customer meters with Advanced Metering
Infrastructure (AMI) water meters, often known as “radio-read meters”. When the meter
replacement project was bid in mid-2021, Prichard reportedly had 10,791 customer accounts
(i.e., 10,791 billable customers with water meters). At that time, Prichard provided this number
of customer accounts to Core & Main (its contractor selected to provide and install the AMI
meters). Per the most recent (December 2022) MOR, Prichard indicated that it presently has
only 9,655 meters. Thus, in the prior 18-month period, Prichard’s billing records indicate it now
has 1,136 fewer customers than it had in mid-2021.

[Note that at ADEM’s request, Prichard recently confirmed that there are a total of 9,664
customers, which aligns closely with the 9,655 referenced in the December MOR. Earlier in this
report, in the discussion of Prichard Water Board customers, the Compliance Assistance
Program referenced the 9,664 value.]
Prichard purchased a total of 9,848 meters from Core & Main– the vast majority were standard
residential (i.e., 5/8 x ¾”) meters. To date, 8,824 meters have been installed throughout
Prichard and Chickasaw, leaving a difference of 1,024 meters.
As of October 25, 2022, the actual tally and status of newly installed AMI meters installed by
Core & Main is as follows:
Meter Size Meters Ordered Meters Installed Meters Yet to Be Installed
5/8 x 3/4-inch 9,7016 8,791 910
1-inch 101 21 80
1-1/2-inch 7 5 2
2-inch 8 8 78
(78 meters beyond scope)
TOTAL 9,817 8,825 1070

The number of meters installed to date, presented in the table above, should be confirmed.
ADEM received conflicting values for individual meter replacements. Exact numbers are not
essential to this report; however, ADEM wanted to present this meter installation tally for the
sake of completeness.
We understand that Core & Main was unable to install > 1200 residential meters due to a
variety of installation issues [e.g., meter could not be located (most common issue); access
obstruction; meter no longer in service; wrong/different meter size; issue with meter box;

6
Includes 352 meters that were reportedly cancelled from the project because they were identified as meters not
requiring replacement. This subset of residences was found to either no longer exist (vacant lot) or the residence
already had a new AMI meter that Prichard replaced prior to the Core & Main project.
Prichard Water Compliance Assistance Review - Page 14

customer refusal; or unusual plumbing condition. Also, quite a few “residences” were found to
be vacant lots].
In any event, when Prichard completes its ongoing meter replacement campaign, there will
likely be about 10,000 new AMI meters installed in the Prichard service area (including
Chickasaw).
MAWSS MASTER METER REPLACEMENT

In recent years, MAWSS has made significant changes to its master meter arrangement for the
potable water it supplies to PWWSB. We have been able to understand these historical master
meter change-outs from the Monthly Operating Reports (MORs) submitted by Prichard Water
to ADEM and through conversations with MAWSS personnel.
Prior to November 2018, MAWSS provided water to Prichard via 13 master meters. In
November 2018 MAWSS took the “O’Neal Steel 2” meter out of service. In September 2019,
MAWSS took another master meter out of service. Then in March 2020, MAWSS took four
additional master meters out of service. Thus in March 2020, MAWSS provided water to
Prichard via only seven master meters. However, in March 2020, MAWSS also replaced four of
its remaining seven Prichard master meters. At that time, MAWSS specifically replaced the
meters at Short Street, Bay Bridge (aka Grover Street), Viaduct Road and Industrial Street East.
The current arrangement of 7 master meters owned by MAWSS is shown in Figure 5 (see green
pins).
Prichard Water Compliance Assistance Review - Page 15

Figure 5 Prichard Water Service area. Purple=City of Prichard; Gold=City of Chickasaw. Prichard Water supplies water to both cities. LSP
pins designate PWWSB’s sewage lift stations
Prichard Water Compliance Assistance Review - Page 16

Though we do not fully understand the water supply network changes made by MAWSS since
2018, we accept that MAWSS saw fit to replace its old master meters to provide better service
to Prichard. Perhaps another objective is that MAWSS wanted to more accurately account for
the non-billable water that MAWSS was providing to Prichard prior to March 2020.

UNUSUAL WATER TANK CONCERNS: CHICKASAW AND ANDERSON

Chickasaw Tank

The Prichard Operator recently indicated that there may be a water leak in/overflow from the
Chickasaw tank. Over a 3-4 week period in November and December 2022, the Prichard
Operator noted an unusual amount of ponded water along a service road (adjacent to the
railroad tracks) near the Chickasaw tank. She believes the cause of the leak is an inoperable
altitude valve at the Chickasaw tank. A replacement valve has been ordered and this leak
should be resolved soon.

Allegedly, there may also be a water leak in an 8-inch water main located along Kansas Street.
This leak would also be in the Chickasaw service area.
Anderson Tank

In November 2022, the Prichard Water Operator noted that the ground around the Anderson
tank was unusually saturated with water. She then inspected the tank and found that the
Anderson Tank had gone dry. In December, PWWSB hired a contractor to perform a video
inspection of the tank interior. The contractor confirmed the tank was indeed empty, but the
video recording detected the sound of water movement. Based on this finding, the Prichard
Water operator immediately visited residential customers located near the Anderson Tank to
ask each household whether or not they had problems with water pressure. Reportedly no
residents indicated low water pressure concerns, even though the Anderson Tank had been
empty for an unknown period of time.
Prichard Water Compliance Assistance Review - Page 17

Water Loss Assessment


EVALUATION OF COSTS DUE TO NON-REVENUE ACCOUNTS

As discussed earlier in this report, Prichard began replacing nearly all its customer’s water
meters in about September 2021, and this water meter effort is nearly complete. Typically, old
failing water meters under-measure water usage during the extended service life of the meters.
Thus, the water meters for Prichard’s customers will not likely be accurate prior to the start of
Prichard’s meter replacement campaign. Likewise, Prichard’s older water loss measurements
will not be accurate. Since late 2021, water usage and loss values should have become
progressively more accurate as meter replacements were completed.

It is also important to note that during the meter replacement campaign, Prichard’s non-
revenue water customers (i.e., malfunctioning meters, homes without meters, etc.) should
have also been progressively identified and resolved with time.

As mentioned earlier, ADEM anticipates that Prichard expects to soon complete the
replacement of about 10,000 AMI water meters.

Per the most recent (December 2022) MOR, Prichard’s certified operator indicated that
Prichard has only 9,655 billable meters. Thus, over an 18-month period from about July 2021 to
December 2022, Prichard’s billing records appear to show that it lost 1,136 customers.

10,791 𝑐𝑢𝑠𝑡𝑜𝑚𝑒𝑟𝑠 𝑖𝑛 𝐽𝑢𝑙𝑦 2021 − 9,655 𝑐𝑢𝑠𝑡𝑜𝑚𝑒𝑟𝑠 𝑖𝑛 𝐷𝑒𝑐𝑒𝑚𝑏𝑒𝑟 2022 = 1,136 lost 𝑐𝑢𝑠𝑡𝑜𝑚𝑒𝑟𝑠

Some of these lost customers are the result of residents that moved and homes that became
abandoned over a period many years prior to 2021. Perhaps Prichard’s customer billing
records/addresses were not accurate, and many non-functioning meters remained in-place
back in 2021 when the AMI meter project was bid.

There may also be some amount of ‘stolen’ water included in the ‘unmetered’ water category.
For instance, a car wash that illicitly tied onto a water main or service line.

Presumably, most of the 1,136 “lost” meters are residential. If indeed about 10,000 meters will
ultimately be replaced by the ongoing AMI meter replacement project, and if Prichard has only
9,655 billable customers, then this would indicate that Prichard has 345 non-revenue water
customers that are yet to be identified. However, as described earlier, Prichard’s meter
replacement contractor identified greater than about 1,200 old meters with AMI installation
issues. While perhaps 200 of these locations may be unoccupied vacant lots, we understand
that there are likely at least 1,000 poorly functioning old meters and/or unmetered residences
in place at this time.
Prichard Water Compliance Assistance Review - Page 18

ADEM’s Compliance Assistance Program is unclear how Prichard may be accounting for the
water loss associated with these roughly 1,000 poorly functioning meters and/or unmetered
water consumers.

We are considering the water loss from these unidentified 1,000 locations to be lost revenue.
Below we show how we estimated this component of lost revenue.

Assuming each residence uses about 130 gallons per day on average, this equates to about 4,000
gallons per month of non-revenue water per residence, calculated as follows:

𝑔𝑎𝑙 𝑑𝑎𝑦 𝑔𝑎𝑙 𝑔𝑎𝑙 "𝑛𝑜𝑛 − 𝑟𝑒𝑣𝑒𝑛𝑢𝑒" 𝑤𝑎𝑡𝑒𝑟


130 × 30 = 3900 ≅ 4000
𝑑𝑎𝑦 𝑚𝑜𝑛𝑡ℎ 𝑚𝑜𝑛𝑡ℎ 𝑚𝑜𝑛𝑡ℎ

For 1,000 customers, this amounts to a potential water loss for Prichard of about 400,000 gallons
per month.

Prichard’s current water billing rate is $25.61 for a base 2,000-gallons of water use plus $6.41 per
thousand gallons thereafter.

$25.61 = Base amount (for 2,000 gallons)


$6.41 per 1000-gal x 2 = $12.82

Total monthly residential water cost = $25.61+ $12.82 = $38.43 per month

Adding an estimated 8% sales tax, a nominal residential water bill for a Prichard customer should
be about $41.50 per month

From a revenue standpoint, Prichard has lost potential revenue of $41.50 per month from 1,000
residential customers who are perhaps no longer tied onto the distribution system.

That yields a monthly average financial loss to Prichard of $41,500.

This equates to an annual lost revenue amount for Prichard of ≅ $500,000 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟.
Prichard Water Compliance Assistance Review - Page 19

EVALUATION OF WATER LOSS THROUGH SWEENEYS LANE MASTER METER

The average monthly water volume purchased by Prichard from each of the seven master
meters since April 2020 is presented in Figure 6. This graph shows that during the review
period, the master meter at Sweeneys Lane measured about 40% of the potable water
delivered to Prichard from MAWSS. As discussed earlier, Prichard’s nominal “total” water loss is
presently believed to be about 56%. That is, Prichard cannot account for about 56% of the
water it receives (i.e., purchases) from MAWSS.
For the 12-month period from January 2022 through December 2022, the master meter at
Sweeneys Lane recorded a nominal usage of 57.2 MG of water per month. If we conservatively
assume that 50% of the Sweeneys Lane meter water is unaccounted for (i.e., lost/non-revenue
water), then the water loss from this one meter alone would be about 28.6 MG.
MAWSS currently charges a flat rate of $2.48 per 1000 gallons to Prichard. Thus, the cost of
unaccounted water flowing through Sweeneys Lane can be estimated as follows:
28.6 𝑀𝐺 water loss $2.48 $70,928 12 𝑚𝑜𝑛𝑡ℎ𝑠 $851,000 𝑐𝑜𝑠𝑡 𝑜𝑓 𝑆𝑤𝑒𝑒𝑛𝑒𝑦𝑠 𝐿𝑎𝑛𝑒 𝑤𝑎𝑡𝑒𝑟 𝑙𝑜𝑠𝑠
× = × ≅
𝑚𝑜𝑛𝑡ℎ 1000 𝑔𝑎𝑙 𝑚𝑜𝑛𝑡ℎ 𝑦𝑒𝑎𝑟 𝑦𝑒𝑎𝑟

Prichard Water Average Monthly Water Usage


in Million Gallons by Master Meter
April 2020 - November 2022
70.00
AVERAGE MONTHLY USAGE (MG)

60.00

50.00

40.00

30.00

20.00

10.00

0.00
Bay Bridge Industrial Sweeneys
Jarrett Road O'Neal Steel Short Drive Viaduct Road
(Grover St) Street Lane
2020 11.47 0.09 20.90 16.61 15.34 3.53 43.67
2021 13.80 0.86 15.60 20.64 14.92 4.02 49.31
2022 15.12 0.38 14.67 23.55 15.36 4.41 57.20

Figure 6 Average Monthly Water Usage in Million Gallons -- Per Master Meter
Prichard Water Compliance Assistance Review - Page 20

The delivery of water throughout Prichard’s water network is unclear to the ADEM Compliance
Assistance Program. The unusually high portion of metered water recorded at the Sweeneys
Lane meter indicates to us that this meter likely serves the Alabama Village community.
Sweeneys Lane is the southernmost MAWSS master meter. The Sweeneys meter is not
proximate to Alabama Village (see Figure 7 below).
There are several other master meters physically closer to Alabama Village -- 1. Bay Bridge; 2
Viaduct Road; and 3. Industrial Street. However, if we accept that there are extremely large
potable water leaks in Alabama Village, then neither the Industrial Street meter nor the Viaduct
Road meter seem to provide the monthly volume to account for such leakage.
The Bay Bridge master meter accounts for approximately 25% of the water usage of the
Sweeneys Lane meter. Just based on water usage, Prichard should investigate the Sweeneys
Lane meter first. However, it’s also possible that investigating the Bay Bridge master meter
usage could yield valuable information.

Once again, the flow of water through Prichard’s distribution system is not defined at all. This
includes water flowing through major water mains and water conveyed to and from Prichard’s
storage tanks.
Prichard should develop a numerical model of the water flow through its water distribution
pipe network to ensure that a safe and adequate supply water is provided at each customer
location. However, if the existing pipe network has major infrastructure decay, as we believe to
be the case, then Prichard should first complete a redesign of portions of its water distribution
system in addition to completing dynamic modeling of network flow

Figure 7 Relative location of meters and tanks in the Prichard Water Service area.
Prichard Water Compliance Assistance Review - Page 21

We also note that conceivably there are non-functioning isolation valves that perhaps
inappropriately allow connectivity of sub-network flow, particularly when certain storage tanks
are empty. This issue is one of the many design aspects of Prichard Water’s distribution system
that requires further evaluation.
EVALUATION OF PRICHARD’S MONTHLY WATER COSTS FROM MAWSS

ADEM’s Compliance Assistance Program more closely reviewed purchase water costs incurred
by Prichard during the period from January 2020 through November 2022. Specifically, we
reviewed the invoices Prichard received from MAWSS. During this nearly three-year period,
MAWSS significantly increased the rate it charged Prichard for purchase of water. The rate
increases imposed during this time were as follow:

Month and Year of Rate charged % rate


rate increase by MAWSS per increases from
1000-gal January 2020
January 2020: $1.77 ---
February 2020: $1.87 5.6%
March 2020: $1.95 10%
April 2020: $2.32 31%
February 2021: $2.48 40%

Over a 14-month period from January 2020 to February 2021, Prichard incurred a 40% rate
increase for the water it purchased from MAWSS.
The table below presents Prichard’s “purchase water costs”; that is, the rate charged by
MAWSS per thousand gallons times the usage measured at the master meters. This table
presents total annual and average monthly purchase water costs incurred by Prichard for 2020
through 2022.
% increase in
Purchase Average
Annual Total monthly cost
water costs Monthly
from 2020
2020 $ 3,083,541 $ 256,962 ---
2021 $ 3,629,793 $ 302,483 18%
2022 $ 3,878,187 $ 323,182 26%

The average monthly water cost in 2020 was $256,962, in 2021 it was $302,483, and in 2022 it
was $323,182. The annual percentage change in water costs increased by 18% from 2020 to
2021 and 26% from 2020 to 2022.
At the time of this report (February 2023), the water billing rate from MAWSS remains
unchanged from two years ago (February 2021). Due to inflation, the likelihood of future (near-
term) rate increases is high, meaning Prichard may soon be paying more for its purchase of
water.
Prichard Water Compliance Assistance Review - Page 22

PATTERN OF INCREASED WATER USAGE VS DECREASED POPULATION

Figure 8 presents a graph showing Prichard’s overall monthly water purchase volumes and also
Prichard’s incurred purchase water costs during the three-year period from January 2020
through November 2022. (At the time the analysis was conducted, December 2022 MAWSS
Invoice was not available, so the analysis ends with November 2022.) As mentioned earlier,
master water meters underwent a restructuring early in 2020. This appears to have caused an
error in the water usage amounts recorded on master meters prior to about April 2020. The
error is clearly evident during the months of January through March 2020, as highlighted in the
yellow balloon in Figure 8. Thus, we also present Figure 9, which omits the three month period
of January-March 2020.

Prichard's Monthly Purchase Water


Note water loss/unregistered
Usage and Costs
water, Jan-Mar 2020 January 2020 through November 2022
Water Costs Usage (1000 gals) Linear (Water Costs) Linear ( Usage (1000 gals) )

$400,000.00 160,000

WATER USAGE (1000 GALS)


$350,000.00 140,000
$300,000.00 120,000
WATER COSTS

$250,000.00 100,000
$200,000.00 80,000
$150,000.00 60,000
$100,000.00 40,000
$50,000.00 20,000
$- -
Jul-20

Jul-21

Jul-22
Jun-20

Jun-21

Jun-22
Apr-20
May-20

Nov-20

Apr-21
May-21

Nov-21

Jan-22
Feb-22

Apr-22
May-22

Nov-22
Dec-21
Jan-20
Feb-20
Mar-20

Aug-20
Sep-20

Dec-20
Jan-21
Feb-21
Mar-21

Aug-21
Sep-21

Mar-22

Aug-22
Sep-22
Oct-20

Oct-21

Oct-22

Figure 8 MAWSS Monthly Invoices from January 2020 through November 2022 (Source: MAWSS Invoices)
Prichard Water Compliance Assistance Review - Page 23

Prichard Monthly Purchase Water


Costs and Volumes
April 2020 through November 2022
Water Costs Usage (1000 gals) Linear (Water Costs) Linear ( Usage (1000 gals) )

$400,000.00 160,000

WATER USAGE (1000 GALS)


$350,000.00 140,000
$300,000.00 120,000
WATER COSTS

$250,000.00 100,000
$200,000.00 80,000
$150,000.00 60,000
$100,000.00 40,000
$50,000.00 20,000
$- -
Jul-20

Jul-21

Jul-22
Jun-20

Jun-21

Jun-22
Apr-20
May-20

Nov-20

Apr-21
May-21

Nov-21

Apr-22
May-22

Nov-22
Aug-20

Aug-21
Sep-20

Dec-20
Jan-21
Feb-21
Mar-21

Sep-21

Dec-21
Jan-22

Aug-22
Feb-22
Mar-22

Sep-22
Oct-22
Oct-20

Oct-21
Figure 9 MAWSS Monthly Invoices from APRIL 2020 through November 2022 (Source: MAWSS Invoices)

Over the most recent three-year study period (specifically after March 2020), Prichard’s water
use notably increased by 21%. That water loss is continuing to rise with time is indicative of a
growing problem. More accurate customer meters (resulting from AMI installation) should
reflect higher customer water usage and should result in a lower rate of water loss. However,
Prichard’s water loss continues to increase.
Long-term federal census data from 1990 to 2021 indicate a significant decrease in population
in Prichard and a slight decrease in population in Chickasaw. The duration of this three-year
study period is too short to define recent population trends (i.e., census data are lagging).
However, we find no reason to think the decreasing population trend has changed.
The higher water loss with time is evidence of decaying water distribution system infrastructure
that is worsening with time. Unaccounted water leakage continues to increase without suitable
repair, adversely affecting customer service and adversely affecting PWWSB’s finances.

We believe divergence of water use and population strongly indicates the increase in monthly
purchased water volumes over the past three years is the result of increased water losses
within Prichard Water’s distribution network.
Prichard Water Compliance Assistance Review - Page 24

FURTHER EVALUATION OF TOTAL NON-REVENUE WATER LOSS

In December 2022, Prichard purchased a total of about 123 MG of water. Prichard’s water loss
was 59% in that month, equating to a loss of 72.6 MG.

123 𝑀𝐺 𝑝𝑢𝑟𝑐ℎ𝑎𝑠𝑒𝑑 × 59% 𝑤𝑎𝑡𝑒𝑟 𝑙𝑜𝑠𝑠 = 72.6 𝑀𝐺 𝑤𝑎𝑡𝑒𝑟 𝑙𝑜𝑠𝑡 𝑖𝑛 𝐷𝑒𝑐𝑒𝑚𝑏𝑒𝑟 2022

That is, Prichard is losing about 73 MG per month primarily due to water leakage but also from
other non-revenue water causes. At the current MAWSS billing rate of $2.48 per 1000-gallons,
the monthly water cost that Prichard is incurring due to its present total water loss is about
$180,000.

72.6 𝑀𝐺 𝑇𝑜𝑡𝑎𝑙 𝑊𝑎𝑡𝑒𝑟 𝐿𝑜𝑠𝑠 $2.48 $180,000 𝑢𝑛𝑎𝑐𝑐𝑜𝑢𝑛𝑡𝑒𝑑 𝑓𝑜𝑟 𝑤𝑎𝑡𝑒𝑟


× =
𝑚𝑜𝑛𝑡ℎ 1000 𝑔𝑎𝑙 𝑚𝑜𝑛𝑡ℎ

Prichard’s monthly economic loss is essentially the cost of the non-revenue (i.e., unmetered)
water for which Prichard is NOT receiving payment plus the purchase of “lost water” due to
system leakage. This tally is as follows:

"𝑛𝑜𝑛 − 𝑟𝑒𝑣𝑒𝑛𝑢𝑒" 𝑤𝑎𝑡𝑒𝑟 + 𝑢𝑛𝑎𝑐𝑐𝑜𝑢𝑛𝑡𝑒𝑑/𝑙𝑜𝑠𝑡 𝑤𝑎𝑡𝑒𝑟 = 𝑚𝑜𝑛𝑡ℎ𝑙𝑦 𝑒𝑐𝑜𝑛𝑜𝑚𝑖𝑐 𝑙𝑜𝑠𝑠

$41,500 "𝑛𝑜𝑛 − 𝑟𝑒𝑣𝑒𝑛𝑢𝑒" $180,000 𝑢𝑛𝑎𝑐𝑐𝑜𝑢𝑛𝑡𝑒𝑑 𝑓𝑜𝑟 $221,500 𝑒𝑐𝑜𝑛𝑜𝑚𝑖𝑐 𝑙𝑜𝑠𝑠


+ =
𝑚𝑜𝑛𝑡ℎ 𝑚𝑜𝑛𝑡ℎ 𝑚𝑜𝑛𝑡ℎ
Or

$2.7 𝑀𝑖𝑙𝑙𝑖𝑜𝑛 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟 𝑒𝑐𝑜𝑛𝑜𝑚𝑖𝑐 𝑙𝑜𝑠𝑠

Note that the $2.7 Million economic loss does not account for any losses that Prichard may
incur resulting from to its sewer system operation, accounts receivable, loans/investments, and
depreciation, etc.
Prichard Water Compliance Assistance Review - Page 25

ACCOUNTS RECEIVABLE

Prichard Water helpfully provided a tally of its accounts receivable from April 2021 through
December 2022. It is a notable concern that Prichard Water’s accounts receivable balance has
continued to increase since about July 2021. A waterfall chart depicting the rising accounts
receivable amount is shown in Figure 10.

Figure 10 Prichard WWSB Monthly Revenue

We did not calculate the exact financial impact to Prichard’s bottom line resulting from
outstanding accounts receivable. However, the above monthly accounts receivables tally
appears very significant.
Prichard Water Compliance Assistance Review - Page 26

REPORTED UNNECESSARY SEWAGE LIFT STATION COST DUE TO ALABAMA VILLAGE WATER
LOSS

Prichard’s former Operations Manager provided ADEM with a letter describing the effects of
alleged water loss in Alabama Village on a sewage lift station, which he described as a “bypass
pump”. The lift station in question is located west of N. Wilson Avenue, about 250-ft northeast
of Cullman Avenue and Baldwin Drive (which is the northeastern-most corner of Alabama
Village).

In the letter, Prichard’s former Operations Manager alleged that Alabama Village may account
for 43.2% of the water loss incurred by Prichard Water, and he implies that all of the potable
water leaks in Alabama Village collectively migrate to the N. Wilson Avenue lift station. This
water loss estimate is based on the design bypass pump rate and the measured run time of the
aforementioned sewage lift station.

This sewage lift station reportedly collects mainly potable water draining from yards and
culverts in Alabama Village. The leaking potable water allegedly is generally conveyed by
gravity to the sewage lift station.

PWWSB pays for the operation of this sewage lift station. The former Prichard Water
Operations Manager estimates that this sewage pump is conveying a volume of lost potable
water amounting to 1.08 MG per day to the Prichard Carlos Morris Waste Water Treatment
Plant (WWTP). He calculated that the combined electrical energy cost to run this pump (which
reportedly operates 12-hours per day) plus the combined monthly rental cost for the pump is
$250 per day. This amounts to $7,500 per month or $91,000 per year.

If leaking potable water is collectively making its way from Alabama Village to this sewage lift
station, then PWWSB is incurring an additional $91,000 per year economic loss (which will show
up as a sewer utility cost). As well, PWSSB is subject to additional sewage system costs for
pumping and unnecessarily treating this water at its sewage treatment plant.

The ADEM Compliance Assistance Program points out that the addition of a large amount of
potable water to a sewage treatment plant may impair sewage treatment plant performance.

We note that the Prichard Operations Manager’s calculated water loss collected by the subject
lift station (1.08 MG/day) amounts to 32.4 MG/month. This value would indeed be 45% of
Prichard’s December 2022 water loss (i.e., very close to the Operations Manager’s calculated
value of 43.2%).

However, ADEM’s Compliance Assistance Program is unsure whether all the water migrating to
the N. Wilson Avenue lift station is leaking potable water from Alabama Village. The most
problematic area of Alabama Village comprises about 90-acres of residential area and the
entirety of Alabama Village is about 150-acres. Portions of surface water in Alabama Village
Prichard Water Compliance Assistance Review - Page 27

appear to drain elsewhere. Thus, it is conceivable that some of the incoming water pumped by
the N. Wilson Avenue bypass pump is groundwater migrating into the lift station.
PREVELANCE OF DUMP SITES ALONG ROADWAYS AND RESIDENTIAL AREAS

During our December 2022 site visit, the Compliance Assistance Program noted that there are
numerous unauthorized dump sites present in Prichard, with most of the dump sites prevalent
in Alabama Village. Dump sites of 5 to 20 cubic yards were observed in dozens of locations.
Some of the dump sites in Alabama Village impeded travel on roads. Dumped material included
everything from household trash to mattresses, tires, construction/demolition debris, and
abandoned vehicles.

The Compliance Assistance Program notified ADEM’s Environmental Services Branch about the
abandoned dump site concern. Specifically, we notified the Removals and Response Unit. They
are investigating this matter and will assess what can be done to assist the City of Prichard.
Prichard Water Compliance Assistance Review - Page 28

Bacteriological Water Quality


Review of eDWR Monitoring Data Submitted to ADEM

ADEM’s Compliance Assistance Program reviewed monthly bacteriological sampling data that
Prichard has collected in its distribution system. Positive total coliform results have been
reported to ADEM’s Drinking Water Branch at various distribution sampling locations. These
positive total coliform results occurred rather frequently in the past 24-months at sporadic
system locations. However, follow-up E. coli testing has always been negative.
Prichard’s operator also measures residual chlorine levels at each distribution sampling
location. ADEM’s Division 7 Regulation 335-7-5-.17 requires that a minimum free chlorine
residual level of 0.2 mg/L be present throughout the distribution system at all times.
Problematically, Prichard Water has identified a number of instances where residual chlorine
levels were found to be significantly lower than 0.2 mg/L. Inadequate disinfection occurred at
repeated and various locations in its distribution system. This includes locations in both
Chickasaw and in east, south, and far west areas of Prichard.

Examples of Prichard Water’s low and border-line low reported free residual chlorine levels are
presented below:
Sampling Point Date Free Chlorine Residual
RP146 12-8-22 0.07 mg/L
RT13 12-6-22 0.18 mg/L
RT24 12-7-22 0.17 mg/L
RT14 9-6-22 0.05 mg/L
RT28 8-8-22 0.21 mg/L
RT14 7-11-22 0.21 mg/L
RT09 7-18-22 0.21 mg/L
RT24 7-13-22 0.18 mg/L
RT24 6-7-22 0.22 mg/L
RT14 11-2-21 0.18 mg/L

The above list is only a short overview of reported free residual chlorine levels and
bacteriological sampling results for Prichard Water. Together with the other infrastructure
issues identified in this report, the potential for inadequate disinfection is an added concern for
Prichard Water to address.
Prichard Water Compliance Assistance Review - Page 29

Regarding inadequate chlorination, Prichard Water must ensure that it meets all of the
requirements related to ADEM’s Division (Drinking Water) regulation. For example, if the
system free residual chlorine level falls below 0.2 mg/L and if adequate free residual chlorine is
not restored within four hours, then Prichard must handle the situation as a treatment
technique violation. Should the free residual chlorine level not be restored within 24 hours,
then bacteriological sampling must also be collected in accordance with ADEM requirements.
Prichard Water Compliance Assistance Review - Page 30

Conclusions
Prichard Water has a dire situation of non-revenue water loss that results from the following:

1. Excessive Water Leaks resulting from aging distribution system infrastructure [the vast
majority of Prichard Water’s economic loss], most notably in the area of Alabama Village
2. Unmetered Water [usage PWWSB is not aware of because of meters that cannot be
read]
3. Errant/old Water Meters [i.e., meters in-place that are not working]
4. Problematic Accounts Receivable

The economic impact of items 1, 2, and 3 amounts to about $221,500 per month in lost
revenue to Prichard Water. Of this amount, about $42,000 per month appears to be the loss
resulting from items 2 and 3 above.

The most notable economic loss to Prichard Water identified in this report is the
result of excessive water leakage.

This monthly economic loss due to items 1, 2, and 3 equates to a negative


Financial impact to Prichard Water of ~$2.7 Million per year.

The overall annual economic loss to PWWSB may be significantly higher than the ADEM
Compliance Assistance Program has identified. It is essential for PWWSB to develop a forensic
audit of the entire utility to account for all potential economic losses and near-term necessary
expenses that might exist including but not limited to: sewer system operation, essential
infrastructure repair needs, accounts receivable, income and payments, contracts, investments,
debts, depreciation, salaries, retirement system, etc.

Along with the design and installation of infrastructure repairs to Prichard Water’s distribution
system, Prichard Water should develop a viable Asset Management Plan that not only identifies
all existing assets, but that also functions as an updatable management tool for the day to day
inventory and operation of PWWSB’s utility assets.

The state of disrepair of Prichard Water’s infrastructure is evident and requires


resolution. With such infrastructure conditions, providing reliable water service
remains challenging. There is a significant potential for unacceptably low public
water system pressure, a matter that warrants expedited attention for the
protection of public health.
Prichard Water Compliance Assistance Review - Page 31

The purchase water rate imposed by MAWSS will likely increase in the near future due to
inflation. PWWSB’s ongoing water losses are also increasing with time.

Without intervention to resolve ongoing and increasing water leakage, Prichard’s


financial losses will continue to increase in the coming months and years. As
such, resolving system water loss is essential for Prichard Water to attain and
maintain economic viability.

Perhaps due to the excessive water leaks and deteriorating overall infrastructure, it appears
that the residual free chlorine provided in the supply water from MAWSS may presently be
insufficient to reliably provide suitable disinfection for Prichard Water customers.

The need to provide a minimum free residual chlorination level of at least 0.2
mg/L may require booster chlorination, if repair of PWWSB infrastructure does
not resolve disinfection concerns.

PWWSB should continue to coordinate with ADEM’s State Revolving Fund and also federal
entities (e.g., USDA, EPA) to obtain financial assistance. Such funding is critical for PWWSB to
receive grant money and perhaps partially finance essential water system infrastructure
repairs.

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