v>EPA
          United States
          Environmental Protection
          Agency
           Office of Water
           (WH-550)
EPA 570/9-89-009
July 1989
Drinking Water Systems

Three Approaches
To Improve
Mobile Home  Park
Compliance

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510-
                    A Study of Improving
                Compliance of Mobile Home Parks
                         Final Report

                         June 30,  1989
                          Prepared By
             The National Rural Water Association

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                        ACKNOWLEDGMENTS

    In  conducting  this  study  for  the  U.S.  Environmental
Protection  Agency,  Office  of  Drinking  Water, the National
Rural  Water  Association  has  been  assisted  by  many indi-
viduals.    We  would like to thank especially Ms. Lois Canada
and  Ms.  Jane  Ephremides  who  provided guidance during each
phase of the study.

    The  other individuals who diligently participated in this
study were:

    o  Mr. Tom Duck, Executive Director, Texas Rural Water
       Association

    o  Mr. Larry Brown, Program Manager, Texas Rural Water
       Association

    o  Mr. David Snead, Circuit Rider, Texas Rural Water
       Association

    o  Mr. Bill Sparks, Field Representative, Texas Rural
       Water Association

    o  Mr. Rick Tanner, Circuit Rider, Texas Rural Water
       Association

    o  Ms. Janie Duderstadt, Administrative Secretary, Texas
       Rural Water Association

    o  Mr. Dan Gilligan, President, National Manufactured
       Housing Federation

    o  Ms. Charlotte Zimmerman, Vice President, Texas
       Manufactured Housing Association

    o  Mr. Charles Maddox, Chief,  Water Supply Division,
       Texas Department of Health and his Staff

    o  Mr. Warren Norris,  Environmental Engineer, U.S. EPA,
       Region VI

    o  Mr. Mark Burrows, Environmental Protection Specialist,
       U.S. EPA, Headquarters

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               TABLE OF CONTENTS
EXECUTIVE SUMMARY

CHAPTER 1:  INTRODUCTION
      1.1
      1.2
      1.3

CHAPTER 2:

CHAPTER 3:

      3.1
      3.2
      3.3
      3.4

CHAPTER 4:

      4.1
      4.2
      4.3
      4.4

CHAPTER 5:

      5.1
      5.2
      5.3
      5.4

CHAPTER 6:

CHAPTER 7;
APPENDIX
Background
Purpose
Objectives

STUDY APPROACH

CLUSTER A - HOUSTON AREA

Profile
Principal Noncompliance Problems
Approach
Results

CLUSTER B - SAN ANTONIO AREA

Profile
Principal Noncompliance Problems
Approach
Results

CLUSTER C - DALLAS AREA

Profile
Principal Noncompliance Problems
Approach
Results

CONCLUSIONS

PROPOSAL FOR A NATIONAL PLAN TO
IMPROVE COMPLIANCE OF MOBILE
HOME PARKS
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               A STUDY OF IMPROVING COMPLIANCE
                     OF MOBILE HOME PARKS

                      Executive Summary
Background
    Small   systems  account  for  most  of  the  compliance
problems  that exist in water systems today.  The segment of
small  systems  that  are  identified  as  mobile home parks
(MHPs)  represents  17  percent  of  the  universe  of small
systems  and  account  for  about  20  percent  of all small
systems having microbiological violations nationwide.

    Problems  which  contribute  to  the  inability  of  the
mobile   home  park  owners/operators  to  comply  with  the
requirements   of   the   National  Primary  Drinking  water
Regulations  (NPOWRs)  are:  lack of education; confusion as
to  which  regulations  to  follow,  State  or  EPA; lack of
appropriate  personnel;  reluctance  of  owners to put money
into  their  water  systems;  economic  conditions; and cost
requirements   of   the   1986   Safe   Drinking  Water  Act
Amendments.    In  addition, mobile home parks, for the most
part,  have  not  been a target for education, training, and
technical  assistance  offered by Federal and State drinking
water programs.

    Because  of  the  magnitude of the noncompliance problem
in  mobile  home  parks,  a  pilot  project  was designed to
assess  the  effectiveness  of three different approaches to
improve  compliance.    The approaches used were information
dissemination,    training   and  technical  assistance,  and
notification   of   possible   liabilities   due  to  system
noncompliance coupled with technical assistance.

    Three  clusters  of  mobile  home parks were selected in
the  State  of  Texas  to  receive  a  particular  approach.
Cluster  A  -  the  Houston  area  received  the information
dissemination  approach.    Cluster B - the San Antonio area
received  the  training  and  technical assistance approach.
And  Cluster  c  - the Dallas area received the notification
of liabilities coupled with technical assistance approach.

    All  mobile  home  park  water systems were ground water
systems.    System  size ranged from the smallest serving 17
people to the largest serving 2550 people.
                             ill

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    For  each cluster a set of measures was used to evaluate
responses  to  the  approach  used.   For the purpose of this
study,  the period of October 1, 1987 thru June 30, 1988 was
the   base   for   determining   whether   systems  were  in
compliance.    Compliance  was  tracked  during  the project
period,  July  1,  1988  thru  December  31,  1988  and  was
compared to compliance during the base period.

Findings

    Cluster A:

    o  Information    dissemination    as    conducted   was
       ineffective.    There were contributing factors which
       were  detrimental  to  this  approach.    First,  the
       information  in  the Texas Department of Health (TDH)
       inventory  was  not  entirely  accurate  due  to  the
       difficulty  in  keeping abreast with frequent changes
       in   MHP   ownership,   owner   addresses  and  phone
       numbers.    Secondly,  it  was found that many owners
       are  not  located  at  the  MHP.    As  a result, the
       on-site   contact   was   often   not  aware  of  the
       material.      Thirdly,  the  Houston  District,  TDH
       routinely  sends  out sample bottles to water systems
       for  collection of compliance samples.  This may have
       confused  those  MHPs  in  the • area as to the proper
       procedure    for    dealing   with   the   compliance
       monitoring.    However,  no  MHPs  chose  to  use the
       sample bag in lieu of the sample bottle.

    o  While     compliance    for    the    microbiological
       requirements  did improve during the period of July 1
       to   December   31,   1988,  it  cannot  be  directly
       attributed  to  this  special effort.  However, it is
       interesting   to   note  that  14  MHPs  returned  to
       compliance   while  eight  went  out  of  compliance.
       Further  examination  of TDH compliance records could
       reveal if this pattern is typical or not.

    Cluster B:

    o  The  training  seminars  were successful as judged by
       the   evaluation   forms   completed   by   the   MHP
       participants   at   the  Kerrville  and  San  Antonio
       seminars.    Information  dissemination, however, was
       marginally   effective.    The  technical  assistance
       visits  were  successful  from  the  perspective that
       twenty-eight  MHP  contacts had a positive or neutral
       reaction to the visit.  Two MHP contacts were not
                              IV

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   receptive   to   the   circuit   rider.    "Hands-on"
   technical  assistance  was  rendered  successfully in
   four cases.

o  Compliance   did   improve  slightly  but  cannot  be
   directly  attributed  to  this  effort.    Only three
   systems  that  were visited were out of compliance at
   the  time  of  the visit.  Additional compliance data
   is  needed  to  verify  continued  improvement in the
   future.

Cluster C:

o  The   effectiveness  of  the  enforcement  effort  is
   difficult  to  judge.  Comments from the TRWA circuit
   riders  indicate  that  MHP owner/operator visits may
   have  been  more  productive had a TDH representative
   been  present during the visit.  Technical assistance
   visits    were    marginally   successful   in   that
   information  was  disseminated and received by the 10
   MHP  owners/operators,  however,  only  one MHP owner
   accepted   "hands-on"   technical  assistance.    The
   result  that only one MHP was not receptive to the TA
   is  encouraging.  The direct approach as employed for
   this  cluster  opens  the  door for potential work in
   the future.

o  Compliance   did   improve,  however,  it  cannot  be
   directly  attributed  to  this  effort.    Additional
   compliance   data   is  needed  to  verify  continued
   improvement   and  the  TDH  needs  to  complete  the
   follow-up MHP inspections.

General:

o  A  coordinated  or  team approach used to address the
   MHP   noncompliance  problem  was  beneficial.    All
   parties  gained from the sharing of ideas and working
   together   to   help   solve  the  MHP  noncompliance
   problem.   The effort provided a firm base from which
   additional   activities  can  be  undertaken  in  the
   future.

o  Manufactured    housing    associations   or   groups
   representing   the   MHPs   should   be  utilized  in
   promoting  and  encouraging better compliance amongst
   MHPs  nationwide.   EPA should encourage the National
   Manufactured  Housing  Federation  to  place  special
   emphasis on this issue over the next few years.

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    o  Generally,  MHP  contacts  were open to listening and
       participating  in some discussion concerning drinking
       water information.

    o  Attempting  to  improve  MHP  compliance  through the
       dissemination  of  information  via  the  mail was an
       ineffective  means of transferring information.  This
       was  particularly  true  since  the information often
       failed to reach the intended owners/operators.

    o  MHP   owners/operators   do  not  see  themselves  as
       purveyors  of  drinking  water.    Supplying water to
       residents  is  just  one  of many responsibilities in
       operating   their   business.      This  attitude  is
       reinforced  and  reflected  in fact that most MHPs do
       not  separate  the cost of supplying water from other
       operating costs when billing MHP residents.

    o  Training  seminars  can  be effective in transferring
       information  to MHP owners/managers and operators but
       extensive   ground   work  must  be  laid  to  assure
       attendance at seminars.
NRWA Proposal to EPA

    o  A  proposal  for  a  national  plan  to  address  MHP
       noncompliance  was  developed  using  the findings of
       this  project  and  the experience of NRWA in dealing
       with small water systems.
                              vi

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                         1.0 Introduction

1.1  Background

    The  highest  priority  of  Federal  and State drinking water
programs  is  to  assure  the compliance of public water supplies
(PWSs)  with  the  National  Primary  Drinking  Water Regulations
(NPDWRs).    The  Environmental Protection Agency's (EPA) FY 1987
Compliance  Report  indicates  that microbiological noncompliance
is  primarily  a small systems problem.  Systems defined as small
or  very  small (i.e., those serving between 25 and 3,300 persons
on  a  regular  basis)  account  for  both the greatest number of
systems  and  the  greatest  number  of systems out of compliance
with   the  microbiological,   turbidity  and  TTHM  requirements.
Specifically,  95  percent  of  all  significant noncompliers and
91.8  percent of all other noncompliers were small and very small
water systems.

    Nationally,  there  are approximately 8,760 mobile home parks
(MHPs)  which  account  for  17  percent  of  the small community
public  water  supplies  serving populations between 25 and 3,300
individuals.    Because States are not required to identify water
systems  as  MHPs  in  the  Office  of  Drinking  Water's Federal
Reporting  Data  System  (FRDS)  inventory,  the actual number of
MHPs  is  probably  greater.   The Texas Department of Health, for
example,  maintains  an inventory of approximately 790 MHPs which
are  not  identified  in  FRDS.   Sixty percent of the MHPs serve
less  than  100  individuals  and  94  percent  of the MHPs serve
populations  under  500  individuals.  In addition, 97 percent of
all MHPs rely on ground water.

    Based  on  the  FRDS  inventory,  Region  IV  has the highest
concentration  of  MHPs while Regions I, II and X have the lowest
concentrations  (Exhibit  1.1).   The use of manufactured housing
is  particularly widespread throughout rural areas of the country
and  around  small  to medium-sized cities with populations under
half  a  million.   Mobile homes have been an important source of
new  housing over the past two decades because they are generally
more  affordable,  particularly  in rural areas where incomes are
often low.

    According  to a market study conducted by Foremost Insurance,
traditional  tenant  MHPs  are  declining  in  popularity as more
manufactured  homeowners locate their homes on their own property
or property belonging to either a friend or relative.  Foremost
    ^Meeks,  Carol  B.   "Mobile Homes - A Viable Alternative in Rural
America," Rural Development Perspectives.  Feb. 1988. pp. 29-32.

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                          Exhibit  1.1
                      NUMBER OF MHPs IN
                        U.S. EPA REGIONS*
Insurance  speculates  that a primary reason for this change lies
in  the  continued  rise  in  lot  rents which averaged $138.00 a
month in 1987.2

    MHPs  account  for  17  percent of all small public community
water  supplies  and  represent  20  percent  of  all  systems in
violation.    The  MHP problem is national in scope, however, the
greatest  problem  areas  are  concentrated in the south, Midwest
and  western States.  Region III has the highest concentration of
MHPs  in  violation  as a percentage of the total number of small
systems  in  violation.   In comparison, Region II has the fewest
MHP  violations  (Exhibit  1.2).    Data  further  indicates that
microbiological   monitoring   and   reporting  (M/R)  violations
account  for  approximately  70 percent of the MHP violations and
maximum   contaminant   level   (MCL)  violations  represent  the
remaining 30 percent.

    Factors  contributing to the problems associated with the MHP
water supplies include: absentee ownership; lack of trained
    Manufactured   Homes  -  The  Market  Facts.  Foremost  Insurance
Group, p. 10, 1988.

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                          EXHIBIT 1.2
           REGIONAL MOBILE HOME PARK (MHP) STATISTICS





REGION


REGION


REGION


REGION


REGION


REGION


REGION


REGION


REGION


REGION







I 'SMALL
MHP
*
II SMALL
MHP
*
III SMALL
MHP
*
IV SMALL
MHP
*
V SMALL
MHP
%
VI SMALL
MHP
%
VII SMALL
MHP
%
VIII SMALL
MHP
%
IX SMALL
MHP
%
X SMALL
MHP
%
MHP
MICROBIOLOGICAL
TOTAL VIOLATION TYPE
SYSTEMS IN
VIOLATION MCL M/R
SYS 412
50 21 33
12%
SYS 5,451
70 7 65
1%
SYS 6,009
540 243 424
9%
SYS 5,642
1,130 392 1,006
20%
SYS 2,502
460 134 396
18%
SYS 2,695
176 127 88
7%
SYS 1,578
172 93 111
11%
SYS 3,069
590 172 451
19%
SYS 2,320
261 115 222
11%
SYS 6,575
168 19 161
3%


STATES
NOT REPORTING
MHP DATA I/
RHODE ISLAND


NEW YORK
VIRGIN ISLANDS
PUERTO RICO



GEORGIA





TEXAS





UTAH


CALIFORNIA
HAWAII
GUAM/SAMOA
WASHINGTON


TOTAL       SMALL SYS  36,253
TOTAL       MHP         3,617     1,323    2,957
            %              10%

1987 FRDS DATA (2/22/88)
I/ States are not required to code water systems as MHPs

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personnel;   poor   management  practices  including  a  lack  of
on-going   maintenance;   regional   economic   conditions;  cost
requirements  to  implement  the  1986  Safe  Drinking  Water Act
(SDWA)  Amendments;  and  a  general reluctance by MHP owners and
operators to work with primacy agencies.

    MHPs,  for  the  most  part,  are  profit-making  enterprises
dependent  upon  ground  water  and  are  very  simple in design,
usually  having  only  a  pressurized storage tank and possibly a
chlorinator.   Because of their small size, rural composition and
apparently  low  profit  margins,  MHPs  are  very susceptible to
slight  economic  changes.    Unlike  the  small community public
water  supply  systems  whose  management is by an elected public
official,  MHP  owners  and  operators  are  often  motivated  by
maintaining  the  greatest  profit margin possible.  As a result,
many  MHP  owners  and  operators  have  been  reluctant  to make
improvements  to  their water systems in order to comply with the
current SDWA Amendments.

    In  addition,  MHPs  have  not  been  a target for education,
training,  and  technical assistance offered by Federal and State
drinking   water  programs.    Efforts  and  materials  that  are
available  from  the national and State levels have not addressed
the  issues,  problems  and needs that relate directly to the MHP
community.

1.2  Purpose

    The  purpose of this project is to document the effectiveness
of   three  approaches  to  improving  compliance  of  MHP  water
systems.      The   three   approaches   are:    (1)  information
dissemination,  (2)  training  and technical assistance (TA), and
(3)  notification  of  possible  liabilities due to noncompliance
coupled with on-site technical assistance.

    By   determining   the  effectiveness  of  these  approaches,
primacy   agencies   and  EPA  can  develop  and  implement  more
effective  compliance  improvement programs directed at MHPs.  In
addition,  any  brochures  or pamphlets developed as part of this
project   could  be  useful,  with  some  slight  changes,  on  a
nationwide or regional basis.

1.3  Obj ectives

    Specific objectives developed for this pilot project are:

    1.  To  demonstrate  that  a  coordinated effort is essential
        and   effective   in  solving  compliance  problems  with
        targeted group of MHPs.

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2.  To  field test three approaches for improving MCL and M/R
    compliance of MHP water systems.

3.  To  assess  the  field test and prepare a final report to
    include:    materials  used for information dissemination
    and  seminars,  a  summary  of  the  TA  provided, and an
    assessment  of  the  overall effectiveness of the program
    considering each element individually and together.

4.  To  identify  other  methods,  materials,  or initiatives
    that   could   be   utilized   to   effectively  increase
    compliance  among  MHPs  either on a national or regional
    basis.

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                     2.0  The Texas MHP Study


    The   National   Rural   Water  Association  (NRWA)  and  EPA
representatives  considered  Texas  to  be the best State for the
MHP  study.    Several  factors were considered including: 1) the
number  of  MHPs,  2)  strong commitments to support the study by
both  the  Texas  Rural  Water  Association  (TRWA) and the Texas
Manufactured   Housing  Association  (TMHA),  and  3)  State  and
regional support.3

    Once  Texas  was selected, the NRWA established and managed a
Steering   Committee   comprised   of  representatives  from  EPA
Headquarters  and  Regional  Offices,  Texas Department of Health
(TDH),   TMHA   and   the   TRWA.      The  Steering  Committee's
responsibility  was  to  oversee  the  project  and  review final
plans,  training  and  educational  materials,   and assist in the
development  of  the  outline  for  the  final  report.   For the
purpose  of  this  project  the  Steering  Committee decided that
technical  assistance  include:     (1)   furnishing  of  technical
advice,   educational   materials  or  referrals  to  sources  of
information  via  telephone  or  mail,  and (2)  furnishing advice,
educational materials, or training on-site.

    Three   approaches   to   improving   compliance   with   the
microbiological   requirements  were  designed  by  the  Steering
Committee  early  in the project period.  Three separate clusters
of  MHPs  were  identified  by  EPA  and TDH and were targeted to
receive   one  of  the  approaches  to  improve  compliance  (see
Appendix A for Location and Inventory).

    Cluster   A   (Houston   Area)   received   the   information
dissemination  approach.   This approach consisted of providing a
pamphlet  and  booklet  to  all  MHP  owner/operators  containing
information   on   SDWA   requirements  and  offering  additional
information  and  assistance  upon  request.    The  pamphlet and
booklet  (Appendix B) were provided by EPA and distributed by the
TMHA.    A coded sampling form was included for use by the system
operator.

    Cluster  B  (San  Antonio  Area)  received  the  training and
technical   assistance  approach.    This  approach  conisted  of
conducting  two  one-day training seminars organized and designed
to  meet  the  needs  of  the MHP owners/operators.  The sessions
focused  on  the  requirements  that  are  the  major  causes  of
noncompliance.    In conjunction with the training seminars, TRWA
offered on-site technical assistance to systems in attendance.
    3Because  Texas  is  not required to identify public water systems
as  MHPs  in  the  Office  of  Drinking Water's FRDS inventory, it was
necessary use State MHP data for this study.

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    Cluster  C  (Dallas  Area) received the notification of legal
liabilities  due  to  noncompliance  coupled  with  the  offer of
technical  assistance.    This approach targeted ten MHP systems,
each  having  a history of microbiological violations.  They were
identified  by  the TDK, and mutually agreed upon by the TRWA and
EPA   Region   VI   as   viable   systems  to  receive  technical
assistance.    These ten systems were notified by the TMHA of the
SDWA  requirements  and  possible  liabilities  for noncompliance
with  the  requirements.    The  notification  was  coupled  with
on-site technical assistance by the TRWA.

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                   3.0  Cluster A - Houston Area
3.1  Profile
    Cluster  A  has  a total of 290 MHPs covering an eight county
area  in  the  Houston  Region (see Appendix A for map).   Exhibit
3.1  shows  the  total  number of MHPs by county.  Harris county,
which  includes the city of Houston, contains the most MHPs (163)
and  represents  56  percent  of the total number of MHPs in this
cluster.      All  the  systems  are  ground  water  systems  and
collectively  serve  a  population  of  35,997.  The smallest MHP
water  system serves 17 people and the largest serves 1200 people
and  is  located  in  Montgomery  County.   The average MHP water
system serves 124 individuals.
                           Exhibit 3.1

                 Houston  Region Mobile Home  Parks

County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller


Total MHPs
49
8
11
4
163
15
34
6
Total 290
Total
Pop. Served
4,111
1,061
588
196
20,671
1,706
7,340
324
35,997
3.2  Principal Noncompliance Problems

    During  the  base compliance period 25 MHPs or 8.6 percent of
the  total  290  MHPs  were  out of compliance one or more times.
Exhibit  3.2  shows  the  number  of  MHPs  in  violation  of the
mirobiological  requirements which are categorized as MCL and M/R
violations.   The major area of violation was microbiological M/R
requirements (15) followed by microbiological MCL (10).
                                8

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                           Exhibit 3.2

                 Houston  Region Mobile Home  Parks
                        Compliance Summary
                 October 1, 1987 - June 30,  1988

County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
Total
Number of
Systems Having
Microbiological
Violations
MCL M/R
4 0
0 1
1 2
1 0
4 9
0 1
0 2
0 0
To Is
3.3  Approach - Cluster A

    Dissemination  of  educational  information was the only tool
used  to promote compliance of MHPs in Cluster A.  A pamphlet and
a  booklet  were  developed for and distributed to MHP owners and
operators  (see  Appendix  B).    The  pamphlet "Keeping Drinking
Water   Safe  to  Drink  -  It's  Up  To  You"  provided  general
information  about  drinking  water  quality,  SDWA requirements,
Texas  drinking  water regulations and specific information about
testing  and  sampling  for  microbiological  contaminants.   The
booklet  "Straight  Talk About Water Sampling" was developed in a
question  and  answer  format  and  provides  information on when
microbiological  sampling  is  necessary,  where  and how to take
samples  using  the  provided  plastic sample bags, where to send
the  sample,   and  what  to  do  if  there  was a positive result
(microbiological contamination present).

    The  pamphlet  and  booklet  together with a pre-coded sample
form  (Appendix  C)  and plastic sample bag were sent to each MHP
in  Cluster  A.  A cover letter (Appendix D) was written and sent
by  TMHA.  The tone of the letter was designed to "soft sell" the
responsibility   of   MHP  owners  and  operators.    The  letter
explained  that  their  understanding  of the information in both
the  pamphlet  and  booklet  would  make  their  job easier.  The
letter   also  offered  assistance  through  the  TMHA.    Within
                                9

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a  two  to  three week period after sending the information, TMHA
contacted  20  percent  of  the MHPs in Cluster A to determine if
the  package had been received and what general reaction each had
to the information.

    The  Steering  Committee agreed that the following parameters
would measure the success of this approach:

    1.  The  number of MHPs requesting additional information and
        the type of information requested.

    2.  The  number  of  MHPs sending in a water sample using the
        pre-coded sample form and sample bag.

    3.  Compliance  improvement  of  entire  cluster based on the
        compliance  record  prior  to  the  project (Oct. 1, 1987
        thru June 30, 1988).

    4.  Compliance  improvement  of MHPs who requested additional
        information.
3.4  Results

    Phone  calls  were  placed  by  the  TMHA to 197 MHPs in this
Cluster.    A  total  of  58  MHP  owners/operators/managers were
contacted  by  phone.  General observations made by the TMHA as a
result of talking to the 58 MHP contacts were, as follows:

     o  Many respondents had not read the material thoroughly.

     o  Very  few  respondents  grasped  the fact that the letter
        was  for general information and was an attempt to assist
        them.

     o  Many  questioned  why  they were "singled out" by EPA and
        the  TDK  to  receive  the letter.  Some respondents were
        hostile to the caller.

    As  to  the  remaining  measures  of  effectiveness  for this
approach, the following observations were made:

     o  TMHA,  TRWA  and  TOH  did  not  receive  any  calls  for
        technical assistance.

     o  No  MHPs  returned  the  pre-coded sample forms or sample
        bags to be analyzed.

     o  Many  MHPs  could  not  be  reached because of inaccurate
        inventory  data;  names  of systems' owners/operators and
        their telephone numbers change frequently over time.


                                10

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o  Fourteen  systems  out  of  compliance  during  the  base
   period  returned  to  compliance during the period July l
   to  December 31, 1988 (project period).  Eight MHPs which
   were  in  compliance  during  the base period went out of
   compliance during the project period.

o  During  the  six  month  period (July 1 thru December 31,
   1988)  compliance  improved.   Three more systems were in
   compliance  with  each of the microbiological MCL and M/R
   requirements  (see Exhibit 3.3).  Although compliance did
   improve,  it is difficult to attribute the change to this
   special  effort.    Further examination of TDK compliance
   records may reveal if this pattern is typical or not.
                      Exhibit 3.3

            Houston Region Mobile Home Park
                   Compliance  Summary
           Period July 1 - December 31, 1988


County
Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
Total
Number of
Systems Having
Microbiological
Violations
(Change)
MCL M/R
1 (-3) 1 (+1)
0 0 (-1)
1 2
0 (-1) 0
5 (+1) 7 (-2)
0 0 (-1)
0 2
0 0
7 (-3) 12 (-3)
                           11

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                 4.0 Cluster B - San Antonio Area
4.1 Profile
    Cluster  B  has  a total of 76 MHPs covering a 10 county area
in  the  San  Antonio Region (see Appendix B).  Exhibit 4.1 shows
the  total  number  of  MHPs  by county.  Two counties, Bexar and
Kerr,  have  the  largest number of MHPs and together account for
39  percent  of  the  MHPs  in  the Cluster.  All MHP systems are
groundwater  systems  and  collectively  serve  a  population  of
11,981.   The smallest MHP water systems serves 25 people and the
largest  serves  1,200  people  and  is located in Travis county.
The average MHP serves 158 residents.
                           Exhibit  4.l

               San Antonio Region Mobile  Home Parks

County
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Williamson
Total

Total MHP
22
1
1
5
4
8
18
4
9
4
76
Total
POD. Served
3,493
60
120
834
465
736
2,320
449
3,020
484
11,981
4.2 Principal Noncompliance Problems

    During  the  base compliance period 9 MHPs or 11.0 percent of
the  total  76  MHPs  had one or more microbiological violations.
Exhibit  4.2  shows  the  number  of  MHPs  in  violation  of the
microbiological  MCL  and  M/R  requirements.   The major area of
violation   was   the   microbiological   MCL   (5)  followed  by
microbiological M/R (4).
                                12

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                           Exhibit  4.2

               San Antonio Region Mobile Home Parks
                        Compliance Summary
                 October 1, 1987 - June 30, 1988


County
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr (1)
Medina
Travis
Williamson
Total
(1) One system had MCL and
was counted as both.
Number of
Systems Having
Microbiological
Violations
MCL M/R
1 0
0 0
0 0
1 1
1 0
0 0
2 3
0 0
0 0
0 0
~~5 ~4
M/R violations and
4.3 Approach

    Information    dissemination,    training,    and   technical
assistance  were  used to encourage compliance in Cluster B.  The
information  dissemination  package  (Appendix  E)  differed from
Cluster  A  by  offering  a  free  seminar  to the MHP owners and
operators.    Date and location of each seminar was given and and
an  agenda  was  provided  (Appendix  F)  as  an enclosure.  Also
included  in  the  information package was a seminar registration
form  and  the  pamphlet entitled "Keeping Drinking Water Safe To
Drink - It's Up To You."

    A  important  feature  of the seminars was that the TDH would
give  operator  certification  credit  to  the participants.  The
seminars  were  organized  by  TRWA  with the TDH being the chief
contributor  to  the  program.  Information on each topic covered
during   the  seminar  (Appendix  G)  and  the  booklet  entitled
"Straight  Talk  About  Water" together with the pre-coded sample
form  and plastic sample bag were given to each participant.  The
attendees were asked to fill out a registration form and a
                                13

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training  evaluation form  (Appendix H).  At the conclusion of the
training  session on-site technical assistance was offered to the
participants.

    A  slight  modification  was made in this approach due to the
small  number  of  MHP  owners/operators/managers  attending  the
seminars.    Originally,  it  was  assumed  that 30 to 35 on-site
technical  assistance  visits  would  be  made  to  MHPs  in this
cluster.    Assistance would be given to seminar participants and
any  MHPs  calling  TMHA for on-site TA.  However, as a result to
the  lower than anticipated attendance, TRWA also provided random
on-site  technical  assistance  to  other MHPs in the cluster not
represented at the seminar.

    The  Steering  Committee  agreed to the following as measures
of success using this approach:

    1.  The number of MHPs attending the seminars.

    2.  The   number   of   MHPs   requesting  on-site  technical
        assistance.

    3.  Compliance  improvement based on compliance records prior
        to   project   versus   compliance   after   receipt   of
        information.

    4.  Evaluation of seminar participants:

        - number of certified operators/years experience
        - number of operators
        - number of owners
        - number of others
        - number of years with MHPs.

    5.  Evaluation of seminar content (participant evaluation
        forms).

    6.  Assessment of pamphlet and booklet:

        - content
        - format
        - improvements needed (does it meet your needs for
          information).


4.4 Results

    The  TMHA  tried  to  contact  20  MHPs  by telephone in this
Cluster,  however,  only  15  were  actually  reached.   All MHPs
contacted  had received the information.  None of the 15 were out
                                14

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of  compliance  during  the  base  period.   One system which was
contacted  violated  the  microbiological  M/R requirement during
the  period  July  1  thru  September  30,  1988, but returned to
compliance  during the subsequent period, October 1 thru December
30, 1988.

    Response  to  the  training sessions was limited.  A total of
22   persons   attended  the  training  session  in  San  Antonio
(Appendix   I).      Seven   individuals   were   MHP  officials,
representing  five  different  MHPs.   The remaining participants
were  associated  with  the  sponsoring  groups.    The seven MHP
representatives   were   all   owners/managers.    None  of  them
represented  systems  that were out of compliance during the base
compliance  period.    However, one system went out of compliance
with  the microbiological MCL during the October - December, 1988
period.    Two  had  received  training  previously  from the TDH
and/or  TRWA.    Four  of  the  MHP representatives completed the
training  evaluation  forms.    All felt that the training helped
them   professionally  and  rated  the  overall  session  in  its
usefulness  between  7  and  10 on a rating scale of 1 to 10 with
one  being  poor  and  10  being good.  As a side note, the other
participants  (EPA, TDH, TMHA and TRWA) rated  the session in the
range of 6-10 (see Appendix J for all evaluations).

    The  Kerrville  training  session had 21 attendees with eight
individuals  representing eight different MHPs (Appendix K).  All
MHP  representatives were system owners/managers.  Of these MHPs,
one  system  was  out  of  compliance  during the base period and
remained  out  of  compliance during the project period.  Two MHP
participants  had  received TDH or TRWA training previously.  Six
of  the  eight  MHP  participants completed the evaluation forms.
They  rated  the  session  in  its  usefulness between 8-10.  The
remaining  participants  representing  sponsoring  groups did not
fill  out  evaluation  forms, but many felt that the session went
smoother  than  the  San  Antonio  session  (see  Appendix  L for
evaluation).

    None  of  the  participants  in  either  session  voluntarily
requested  on-site  TA.  Results that can be ascertained from the
circuit  rider's contact of 30 MHPs in this cluster  (see Appendix
M) are as follows:


    o  No  phone  calls  were  received by TMHA or TDH asking for
       additional information (off-site technical assistance).

    o  Reaction  of  the  people  contacted  by the circuit rider
       during  the TA visit was largely neutral in that they were
       willing  to  listen,  and  participate  in some discussion
       about   the   project.      Ten   contacts   were  clearly
                                15

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   positive  in
   idea.     Two
   rider.
that  they  thought  the  project was a good
contacts  were  not receptive to the circuit
o  Five  MHP  contacts  remembered  receiving the information
   and  materials mailed to them about the project.  Of these
   five  contacts,  two  indicated  that  they understood the
   materials  and  three were confused and did not understand
   it.

o  During  the  six  month  period  June  1 thru December 31,
   1988,  two  more systems came into compliance with the MCL
   while  one  more system was out of compliance with the M/R
   requirements (see Exhibit 4.3).
                       Exhibit 4.3

           San Antonio Region Mobile Home Park
                    Compliance Summary
            Period July 1 - December 31, 1988
County
Number of
Systems Having
Microbiological
Violations
(Change)
MCL
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Williamson
Total
0
0
0
0
0
1
1
l
0
0
3
(-D


(-D
(-1)
(+D
(-D
( + 1)


(-2)
M/R
0
0
0
0
0
0
3
0
2
0
5



(-D




(4-2)

( + D
   Four  MHPs  contacted  had  technical  problems which were
   addressed  by  the  circuit  rider.  One MHP had a leaking
   chlorinator  and  was  not  familiar  with proper sampling
   procedures.    One  MHP  had  mapping problems and two had
                            16

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   metering  problems.   Technical assistance was rendered in
   all  of these cases.  The remaining 26 MHPs indicated that
   they had no problems, and did not request any assistance.

o  Six   MHPs  out  of  compliance  during  the  base  period
   returned  to  compliance during the project period.  Three
   MHPs  in  compliance  during  the  base period went out of
   compliance during the project period.
                           17

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                   5.0 Cluster C - Dallas Area
5.1  Profile
    Cluster  C  has  a total of 142 MHPs covering an eight county
area.    Johnson  County  has  the  largest  number of MHPs (41),
representing  18  percent  of  the  total  MHPs  in this cluster.
Exhibit  5.1  shows  the  total  number  of  MHPs by county.  All
systems  are  ground  water  systems  with  the  smallest  system
serving  18  people  and the largest serving 2,550 people located
in Johnson County.  The average MHP serves 175 individuals.
                           Exhibit 5.1

                 Dallas Region Mobile Home Parks

County
Collin
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise


Total MHPs
1
10
26
15
41
11
31
7
Total 142
Total
POD . Served
800
1,303
7,505
2,385
6,280
2,529
3,342
620
24,764
5.2  Principle Noncompliance Problems

    During  the  base  compliance period 17 MHPs or 12 percent of
the  total  of  142 MHPs were out of compliance one or more times
with  the  microbiological  requirements.   Exhibit 5.2 shows the
number    of   MHPs   in   violation   of   the   microbiological
requirements.    There were nine systems with microbiological MCL
violations and eight systems with M/R violations.
                                18

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                           Exhibit 5.2

                 Dallas Region Mobile Home Parks
                        Compliance Summary
                 October 1, 1987 - June 30, 1988


County
Collin
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise

Number of
Systems Having
Microbiological
Violations
MCL M/R
0 0
0 1
2 2
1 0
1 3
0 1
5 1
0 0
Total ~~9 ~8
5.3  Approach

    Information  dissemination  followed  by an offer for on-site
technical  assistance  were  used to encourage compliance in this
cluster.    Ten  MHPs  were  selected  from this cluster based on
their  history  of  noncompliance  and whether a routine sanitary
survey,  by  the  TDH, was scheduled in the near future.  The TDK
and  the  TRWA  mutually  agreed  on  the  selection  of  the ten
systems.    Initially a letter from TMHA was sent to the ten MHPs
in  this  cluster  (Appendix  N).    The tone of the letter was a
"hard  sell"  to point out the responsibilities of providing safe
drinking  water  and  the  possible  consequences  of not meeting
current  requirements.    The pamphlet entitled "Keeping Drinking
Water  Safe  to  Drink  - It's Up To You" was an enclosure to the
letter.    The letter indicated to the reader that the TRWA would
contact them to schedule an on-site technical assistance visit.

    Each  system  was contacted to schedule an on-site visit.  It
was  agreed  by  the  Steering  Committee  that  a maximum of two
on-site  visits  would  be  made  in  an attempt to encourage the
owner/operator  to  receive help.  Where TA was rendered the TRWA
prepared  a  routine  report (Appendix O) of the visi't and action
taken.   Following the TA visits by the TRWA, the TDH scheduled' a
routine sanitary survey on each system.
                                19

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    The Steering Committee agreed that the following criteria
would be used to evaluate this approach:

    1.  Number of MHP receiving on-site technical assistance

    2.  Compliance improvement of the Cluster

    3.  Evaluation of on-site technical assistance given

        - did compliance improve as a result?
        - did TDK ranking improve as a result of TA?
        - did the system make the recommended change(s)?
        - type of TA given?
        - type of material(s) provided?
        - did TDK follow-up on TA provided by TRWA?


5.4  Results

    The  TMHA  made  phone  calls  to  54 MHPs in this cluster to
determine  if  the  letter  was  received.    Twenty systems were
actually  contacted,  others were busy, disconnected or the wrong
number  was  reached.  Six of the MHPs did not receive the letter
while  14 did receive the letter.  Those that received the letter
generally  had  the same reaction as those in the other clusters.
The  primary  reaction  was concern for why they were singled out
for this project and many did not fully understand the project.

    Technical  assistance  visits  were  conducted  by  the TRWA.
Prior  to  each initial visit, phone calls were made to the MHPs.
In  four cases, appointments for on-site visits were made and the
remaining  initial  visits  were all "cold calls".  A total of 18
TA  visits  were  made;  three  MHPs received one visit each, six
MHPs  received  two  visits  each  and  one  MHP  received  three
visits.    Hands-on  TA was rendered to one MHP.  The TA provided
was  for  proper  sampling  procedures,  flushing water lines and
measuring  chlorine  residual.    All  MHPs  visited received the
letter, pamphlet and booklet.

    One  MHP  visited  in this cluster was hostile to the circuit
rider.   In this case the issue was State and Federal regulations
and  there  appeared  to  be  little  concern  for complying with
them.     As  a side note, the person contacted indicated that the
MHP  was  for  sale and that he was very anxious to get out "from
under  the  entire  thing."  On the second visit to this MHP, the
circuit  rider  indicated  that  the contact would not answer the
door.    The remaining TA visits are characterized by the response
of  the  contact  person.  The two categories are indifferent and
interested.    Five  contacts  expressed  interest in the project
and/or   improving   their   system.    Four  contacts  expressed
indifference  to  the  project  and  to  receiving  any technical
assistance.

                                20

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    During  the  six  month period July 1 thru December 31, 1988,
there  were  five  fewer  systems  in  violation  of  the  micro-
biological  MCL  and  four  fewer  systems  in  violation  of the
microbiological  M/R  requirements   (see  Exhibit 5.4).  Fourteen
systems  out  of  compliance  during  the base period returned to
compliance   during   the   project  period.    Five  systems  in
compliance  during  the base period went out of compliance during
the project period.
                           Exhibit 5.3

                 Dallas Region Mobile Home Parks
                        Compliance Summary
                Period July 1 - December 31, 1988
Number of
Systems Having
Microbiological
Violations
(Change)
County
Coll in
Dallas
Denton
Hood
Johnson
Parker
Tarrant
Wise

MCL
0
0
0
0
1
1
1
1
Total 4



(-2)
(-1)

(+D
(-4)
(+D
(-5)
M/R
0
0
0
0
1
0
3
0
4


(-1)
(-2)

(-2)
(-1)
(+2)

(-4)
    The  TDH  scheduled follow-up sanitary surveys on each of the
ten  systems  selected  for  the  second and third quarters in FY
1989.    As  of  this writing, however, none have been completed.
As  a  result,  the evaluation of this TA effort is not possible.
                               21

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                 6.0  Texas MHP  Study  Conclusions


6.1  Conclusions

    The  project  objective  was  to  assess the effectiveness of
three  different  approaches  to  improving  MHP compliance.  MHP
compliance  improved  in  all  three  clusters  with the greatest
change  occurring  in  Cluster  C  —  the  Dallas  Region, which
received  the  notification of liabilities coupled with technical
assistance  approach.    However,  given  the  limitations of the
study,  the  improved  compliance  cannot  be correlated directly
with  the  approach  used.    This  is  also  true  for the other
approaches.    Further study of the TDK compliance records, which
is  beyond  the  scope of this study,  may provide more insight on
this  matter.   Specific conclusions and recommendations for each
approach follows.


    Cluster A:

    o  Information  dissemination  as conducted was  ineffective.
       The  objective  of the information  dissemination approach
       was  to  encourage  requests  for  information  concerning
       drinking  water  and  to  improve compliance.  No requests
       were  received  by  TMHA or TRWA for TA from this cluster.
       Even  when  phone  calls  were  made  to MHPs, no contacts
       requested additional information.

       There  were contributing factors which were detrimental to
       this   approach.    First,  the  information  in  the  TDK
       inventory  was not entirely accurate due to the difficulty
       in   keeping   abreast  with  frequent  changes  in  owner
       addresses  and  phone  numbers.  Second, it was found that
       many  owners  are  not  located at the MHP.  Consequently,
       the  information  received  by  the off-site owner was not
       made  available  to  the  on-site operator.  Third, it was
       discovered  that the Houston District, TDH routinely sends
       out  sample  bottles  to  water  systems for collection of
       compliance  samples.   This may have confused those MHPs in
       the  area  as to the proper procedure for dealing with the
       compliance  monitoring.  However, no MHPs chose to use the
       sample bag in lieu of the sample bottle.

       In  the future,  consider activities or events which stress
       personal  contact  as  a means of providing information to
       MHP  owners/operators  such  as such as at annual meetings
       of  State  manufactured  housing associations, local civic
       meetings, and community fellowship activities.
                               22

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o  State   inventories  of  MHPs  should  include  the  name,
   address  and  current  phone  number  of the local contact
   person  in  addition to the owners name, address and phone
   number.    This  information can be updated during routine
   site   inspections,   sanitary   surveys,   or  compliance
   monitoring  by State personnel.  Require systems to notify
   the  State  when  there is a change of address, ownership,
   etc.

o  The  reaction  of  the  MHPs  to  the letter from TMHA was
   surprising  because  it was assumed that using TMHA as the
   focal  point  that  the  MHPs  would  not be threatened by
   potential  enforcement  by  TDK  or  EPA,  and  therefore,
   respond   more   favorably   to   the   information.    In
   retrospect,  however,  the letter did include the names of
   the  participating  organizations so that the reader could
   easily  associate  and  probably did associate or link the
   letter to TDK and/or EPA.

o  The  fact  that  those  that  read  the information seemed
   confused  is  more attributed to their concern about being
   singled  out  than  to confusion over the substance of the
   material.   TMHA has been in the business of communicating
   effectively  with  its  membership  for many years.  Their
   experience  was  used  in  preparing  the  letters and the
   pamphlet and booklet.

o  While  compliance for the microbiological requirements did
   improve  during the period of July 1 to December 31, 1988,
   it  cannot  be  directly attributed to the special effort.
   However,  it  is interesting to note that 14 MHPs returned
   to  compliance  while  seven    went  out  of  compliance.
   Further   examination  of  TDK  compliance  records  could
   reveal if this pattern is typical or not.

Cluster B:

o  Information  dissemination  was marginally effective.  The
   MHPs  contacted  by  phone  that  remembered receiving the
   information  had  the  same  general  reaction as those in
   Cluster  A.    However,  thirteen MHPs participated in the
   seminars  in San Antonio and Kerrville.  This response may
   be  attributed  to  the letter to Cluster B which included
   the  offer  of  free  seminars  and  receipt  of classroom
   credits towards State certification as a water operator.

o  If  training  seminars are conducted for MHPs,  ground work
   must  be laid to assure good attendance.  On-site contacts
   should   be   made   well  in  advance  of  the  seminars.
                            23

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   Informational  materials  should  be delivered at the time
   of  the  contact  and followed up with a phone call and an
   announcement.

o  TDK's  inventory  information was not sufficient to assure
   the    seminar   announcement   would   be   received   by
   managers/operators  on-site  who  are  responsible for the
   day-to-day  operations.    Many  of  the  letters  went to
   absentee owners.

o  The  training  seminars  were  successful as judged by the
   evaluation  forms  completed by the MHP participants.  The
   Kerrville   seminar  was  more  successful  than  the  San
   Antonio  seminar  based  on the number of MHP participants
   and   their  general  reaction  to  it  as  discovered  in
   discussions  with  them during break periods and after the
   conclusion   of  the  seminar.    Two  things  contributed
   greatly  to this.  It.was the second seminar conducted and
   the  trainers  were conveying the message more effectively
   and  the  location  was  conducive  to attracting more MHP
   participants.     On  this  last  point,  several  of  the
   participants  in  the  San  Antonio seminar had difficulty
   finding   the   site   whereas   no   such  problems  were
   encountered   by   the   participants   of  the  Kerrville
   seminar.    The San Antonio site was located adjacent to a
   major  freeway  but  was  in an area of traffic congestion
   and  confusing  traffic  patterns.  The Kerrville site was
   in a rural area at a well known hotel.

o  The  technical  assistance visits were successful from the
   perspective  that the majority of MHP contacts were either
   neutral  or  receptive  to  the  circuit rider.  Technical
   assistance  in  the  form of information dissemination was
   delivered   to   all   contacts.     "Hands-on"  technical
   assistance was rendered successfully in four cases.

o  Compliance  did  improve  slightly  but cannot be directly
   attributed  to  this effort.  Only three systems that were
   visited  were  out of compliance at the time of the visit.
   Second  quarter  FY 1989 compliance data, not available at
   the time of this writing, may provide further insight.

Cluster C:

o  The  effectiveness  of the enforcement effort is difficult
   to  judge.  Comments from the TRWA circuit riders indicate
   that   MHP   owner/operator  visits  may  have  been  more
   productive  had  a  TDK representative been present during
   the  visit.    Technical assistance visits were marginally
   successful   in  that  information  was  disseminated  and
                            24

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   received  by  the  10  MHP  owners and operators, however,
   only   one   MHP   owner   accepted  "hands-on"  technical
   assistance.    The  result  that  only  one  MHP  was  not
   receptive  is  encouraging.   At least the direct approach
   as  employed for this cluster opens the door for potential
   work in the future.

o  Compliance  did  improve,  however,  it cannot be directly
   attributed  to this effort.  Additional compliance data is
   needed  to  verify continued improvement and the TDH needs
   to complete the follow-up MHP inspections.

General:

o  The  team  approach  used to address the MHP noncompliance
   problem  was  beneficial.    All  parties  gained from the
   sharing  of  ideas  and working together to help solve the
   MHP  noncompliance  problem.    The effort provided a firm
   base  from  which  additional activities can be undertaken
   in the future.

o  Manufactured  housing  associations or groups representing
   the  MHPs  should be utilized in promoting and encouraging
   better  compliance  amongst  MHPs  nationwide.  EPA should
   encourage  the National Manufactured Housing Federation to
   place  special  emphasis  on  this issue over the next few
   years.

o  Generally,   MHP  contacts  were  open  to  listening  and
   participating   in  some  discussion  concerning  drinking
   water information.

o  Dissemination   of   information   via  the  mail  was  an
   ineffective  means of transferring information to the MHPs
   and   attempting   to   improve   compliance.    This  was
   particularly  true since the information did not reach the
   intended owners/operators.

o  MHP  owners/operators  do  not see themselves as purveyors
   of  drinking  water.  Supplying water to residents is just
   one   of   many   responsibilities   in   operating  their
   business.    This  attitude is reinforced and reflected in
   fact  that most MHPs do not separate the cost of supplying
   water   from   other  operating  costs  when  billing  MHP
   residents.

o  Training   seminars   can  be  effective  in  transferring
   information  to  MHP  owners/managers  and  operators  but
   extensive  ground  work  must be laid to assure attendance
   at seminars.
                            25

-------
o  TA  visits  were  marginally  successful.  Information was
   disseminated   in   all   cases   and   hands  on  TA  was
   successfully  given  (received)  in one case.  However, at
   this  writing,  it  cannot  be  determined  if that system
   returned  to  compliance  during  the  second  quarter  FY
   1989.    The result that only one MHP was not receptive is
   encouraging.    The  direct approach a3 practiced for this
   cluster  opens  the  door for potential work in the future
   and  it  appears  that given additional time more positive
   results would have been seen.

o  A   proposal   for   a   national   plan  to  address  MHP
   noncompliance  was  developed  using  the findings of this
   project  and  the experience of NRWA in dealing with small
   water systems.
                           26

-------
        7.0  NRWA Proposal for A National Plan to Improve
                 Compliance of Mobile Home Paries


    The  timing  for  a  special effort could not be better.  New
microbiological  regulations  became Federal law in June 1989 and
States  will  begin  adopting  them during the following eighteen
months.    Much  information must be transferred to water systems
concerning  these  new  requirements.    This  presents  a unique
opportunity  for  EPA  to incorporate changes in current policies
and procedures used in dealing with noncompliant MHPs.

    Based  on  EPA's  compliance  data,  NRWA recommends that EPA
initially  focus  it  efforts  in  two  Regions  — Region IV and
VIII.    Approximately 44 percent of the MHP systems in violation
of   the   microbiological  requirements  are  located  in  these
Regions.    The Agency should consider efforts in selected States
in  other  Regions  if  resources  permit.  The Agency is already
partially funding some innovative MHP work in Pennsylvania.

    Three  tools  —  enforcement,  financial,  and  training and
technical assistance are the focus of this proposed plan.

Enforcement

    Enforcement  has  been  minimal  on  MHPs.    Yet many States
generally   have   more   enforcement   tools   to   use  against
noncompliant  MHPs.  Many States have permitting and/or licensing
requirements  for  MHPs.   However, responsibility for permitting
and/or  licensing is usually not under the primacy agency.  Where
this  is  the  case,  primacy  agencies  should  develop  working
agreements  with  the  licensing  agencies.  The end result being
that    permits/licenses    be    suspended   (provisionally   or
permanently)  based on level of noncompliance with drinking water
requirements.    State agencies involved in the permitting and/or
licensing  process  should  elevate  the importance of delivering
safe drinking water.

    An  escalation  of  tougher permit and licensing requirements
could  result  in  some difficult political realities, especially
if  the  State  considers  withdrawing the permit or license on a
permanent  basis.    However,  with  a  clear statement of policy
up-front  and  the  State  playing  the  role  of  a  "benevolent
regulator"  the  policy  would  be  workable.  On this point, the
State  could  devise  a  phased  approach over two to three years
based    on    MHP    size   (population),   violation   history,
recalcitrance, etc.

    The  State  may  require noncompliant MHP owners and managers
to  attend  training  courses and/or seek technical assistance in
order  to  maintain the MHP permit/license.  Mandatory attendance
                                27

-------
at  training  sessions would serve two purposes:  an incentive to
comply  because  of the cost of time and money (although minimal)
to  attend,  and  an  opportunity  to  learn how to meet the safe
drinking water requirements.


Financial

    With   few  exceptions,  MHPs  are  operated  as  a  business
enterprise.    The  incentive  for  owning such a business is the
potential  for  income  and  profit.    Using this basic premise,
primacy  agencies  should focus efforts on appealing to financial
incentives for owners to improve MHP water systems.

    A  basic financial information package should be developed by
EPA   in   cooperation   with   National   Manufactured   Housing
Federation.    It  should  be  modeled  after  the Small Business
Administration   packages   and   should  include  the  following
information:

    o  Financial  Management  of  MHP  with  special  emphasis on
       utilities   (Consider   the   concept   of   MHPs  billing
       separately   for  utility  service  and  space  rental  to
       encourage  the  idea  of  making  both utilities and space
       rental as profit centers);

    o  Tips  on  improving  income  in  a competitive environment
       (i.e., encouraging MHPs to install water meters); and

    o  Sources of additional information.


Training and Technical Assistance

    Training  should  be  focused  on  financial  management  and
utility  operations  and  could  be  offered  by State regulatory
agencies  and  other  appropriate organizations such as the NRWA,
the  Rural  Community Association Program, AWWA, and the National
Environmental  Health  Association.    The  financial information
package  as  above  could  be  used as the focus of the training.
Technical  assistance could be offered to the participating MHPs,
however,   sufficient  ground  work  must be made prior to holding
these  sessions.    On-sight  MHP visitations would be one way to
ensure good attendance at the training sessions.
                                28

-------
Plan

    Primacy  Agencies,  in  States  with  large  numbers of MHPs,
should  form  a  funded  advisory  committee to deal specifically
with  MHPs.    It  should consist of representatives from the MHP
industry   and   association(s),    State   regulatory   personnel
representing  the MHP licensing agency, State training personnel,
public  utility  commissions,  Rural Community Assistance Projects
and  other  associations  as  appropriate.  The responsibility of
the  committee  is  to  advise  the  State  on its activities and
effort  to  improve  MHP  compliance and assist in development of
specific plans and recommend policies concerning MHPs including:

    1. Identifying   organizations   and   groups  that  have  an
       interest or are able to assist MHPs;

    2. Agreeing  on the MHP problem(s) to address and designing a
       plan of action to address them; and

    3. Publicizing activities and results.

    A   training   and   technical   assistance  plan  should  be
established  for a two to three year period that covers the State
geographically  and  offers financial and utility management.  At
least   one  course  should  be  conducted  quarterly.    On-site
technical  assistance  could  be  offered in conjunction with-the
training courses.

    The  primacy agency would focus its enforcement activities on
the  permitting/licensing  process  and/or issuing administrative
orders.    At  the  same  time  primacy  agencies  should require
recalcitrant  MHP  system  owners to attend training sessions and
to seek technical assistance.
                                29

-------
               APPENDIX
Appendix A


Appendix B


Appendix C

Appendix D

Appendix E

Appendix F

Appendix G

Appendix H



Appendix I

Appendix J


Appendix K

Appendix L


Appendix M


Appendix N

Appendix O
Cluster Location
Cluster Inventory

Pamphlet  — "Keeping Drinking Water
Safe to Drink"

Preceded Sample Form

Cover Letter to Cluster A

Cover Letter to Cluster B

Seminar Agenda

Seminar Materials

Seminar Registration Form
Seminar Evaluation Form
(Example)

San Antonio Seminar Registration

San Antonio Seminar Evaluations
(Example)

Kerrville Seminar Registration

Kerrville Seminar Evaluations
(Example)

Technical   Assistance  Reports  for
Cluster B (Example)

Cover Letter to Cluster C

Technical   Assistance  Reports  for
Cluster C (Example)
                  30

-------
Appendix A

-------
                    PUBLIC HEALTH REGIONS
                                            CLUSTER C
REGIONAL OFFICES
                                               CLUSTER A
          CLUSTER B
                                               TDK  AG-5

-------
                          TDH INVENTORY - 1986 DATA
Cluster A

County No.

    20
    36
    79
    84
   101
   146
   170
   237
County

Brazoria
Chambers
Ft. Bend
Galveston
Harris
Liberty
Montgomery
Waller
* PWS

  49
   8
  11
   4
 163
  15
  34
   6
Cluster B

    15
    16
    28
    46
   105
   130
   133
   163
   227
   246
Bexar
Blanco
Caldwell
Comal
Hays
Kendall
Kerr
Medina
Travis
Wi 11 i amson
  22
   1
   1
   5
   4
   8
  18
   4
   9
   4
 "76
Cluster C

    43
    57
    61
   111
   126
   184
   220
   249
Collin
Dal las
Denton
Hood
Johnson
Parker
Tarrant
Wise
   1
  10
  26
  15
  41
  11
  31
   7
 w

-------
                         Texas Mobile Home Parks - 1986 Data
(CLUSTER A)

PWS ID    POP. SERVED
0200017
0200055
0200064
0200099
0200102
0200105
0200118
0200119
0200122
0200129
0200133
0200134
0200137
0200144
0200151
0200153
0200158
0200181
0200183
0200190
0200191
0200219
0200223
0200226
0200227
0200229
0200242
0200244
0200248
0200251
0200252
0200255
0200258
0200273
0200274
0200275
0200282
0200307
0200329
0200337
0200353
0200379
0200382
0200390
0200403
0200413
0200415
0000108
0000080
0000075
0000025
0000195
0000026
0000032
0000030
0000039
0000033
0000045
0000105
0000060
0000075
0000042
0000045
0000084
0000045
0000135
0000054
0000080
0000111
0000045
0000066
0000066
0000093
0000108
0000150
0000033
0000069
0000045
0000048
0000045
0000120
0000144
0000108
0000141
0000057
0000030
0000042
0000087
0000051
0000027
0000345
0000090
0000069
0000033
PUS NAME

Black's Ferry Water Company
Mansfield Mobile Home Park
Berger Trailer Park
Colony Criik Mobile Home Park
Manvel Road Terrace Subdivision
Kagy's Mobile Home Park
Graves Trailer Park
Broadway Mobile Home Park
B & B E-Z Way Mobile Home Park
West Brazos Mobile Home Park
West's Mobile Home Park
Countryside Mobile Home Park
Wade's Mobile Home Park
Frontier Water Company
Flora No. 7
Flora No. 6
Thomas Water Service
Chapline's Mobile Home Development
Oak Ridge Mobile Home Park
Centennial Place
Mansfield Mobile
Quail Meadows No,
Pleasant Meadows
Morel and
Morel and
Windsong
Palmetto
COUNTY

Brazoria
                                           Home  Park
                                          .  1
                                           Subdivision
                                   Subdivision Block
                                   Subdivision Block
                                   Subdivision
                                   Subdivision
                         Angle Acres Water  System
                         Pleasantdale  Subd.  Water  System
                         Anchor  Road Mobile  Home Park
                         Chenango  Trailer Park
                         Sandy Ridge Subdivision
                         Sharondale  Subdivision
                         Country Meadows
                         Country Acre  Estates
                         Coronado  Country
                         Pearl and  Heights Mobile Home
                         Willow Wedge  Mobile Home  Park
                         Bayou Breeze  Mobile Home  Park
                         Country Creek  Estates Water
                         Country Village Mobile  Home
                         Country Oaks  Mobile Home  Park
                         Gibbens Mobile Home Park
                         Raintree  Acres Mobile Home
                          Iowa Colony Utilities  Inc.
                         South Meadows
                         Ashley  Oaks Mobile  Home Com.

-------
             Texas Mobile Home Parks - 1986 Data
                                       Page 2
(CLUSTER A)

PWS ID    POP. SERVED
0200419
0200435
0360004
0360006
0360008
0360024
0360029
0360069
0360072
0360076
0790002
0790039
0790042
0790048
0790052
0790054
0790088
0790139
0790185
0790190
0790205
0840016
0840045
0840046
0840067
1010085
1010140
1010149
1010162
1010164
1010219
1010282
1010283
1010285
1010288
1010307
1010322
1010339
1010349
1010354
1010364
1010452
0000075
0000400
0000084
0000132
0000044
0000198
0000069
0000378
0000096
0000060
0000150
0000051
0000060
0000039
0000036
0000039
0000039
0000045
0000060
0000033
0000036
0000066
0000025
0000030
0000075
0000076
0000492
0000180
0000228
0000072
0000153
0000342
0000130
0000069
0000486
0000450
0000567
0000105
0000360
0000036
0000025
0000150
PWS NAME

Pine Colony Mobile Home Park
Autumn Shadows MH Subdivision

Cotton Bayou Manor Mobile Home
Abbe Subdivision
Shady Oaks Mobile Home Park
Cedar Bayou Mobile Home Park
Sunny Villa Mobile Home Park
G & S Utility Co.
Solesbee Construction Inc.
Chambers County FWSD No. 1

Laterna Villa Subdivision
3411 - 5th Street Trailer Park
Sklar's Mobile Home Park
Marek's Mobile Home Park
Steinkamp Trailer Park
Fresno Mobile Home Park
Brdecka Water System
Hoyt Mobile Court
Brown's Mobile Home Park
H F Christman Water System
Ford Road Trailer Park

Pine Oak Trailer Court
Tranquility Mobile Home Park
Windsong Mobile Home Park
Greenvilla Mobile Home Park

Apache Land Mobile Home Sub.
North Pines Mobile Home Park
Greenspoint Trailer Park
Atascocita Village Mobile H
Aldine Mobile Home Park
Tall Cedars Mobile Home Sub.
Colonial Mobile Home Park
Cottonwood Park Water System
Highland Mobile Home Subdivision
Mobile Home Estates
Redwood Estates Mobile Home
White Oak Manor Mobile Home
Advance Country Mobile Home
Green Acres Mobile Home Park
Cypress Brook Estates
Aldine Mobile Home City
Gospel Assembly Water System
COUNTY

Brazoria


Chambers
                                                                         Ft.  Bend
                                                                         Galveston
                                                                         Harris

-------
             Texas Mobile Home Parks -  1986  Data
                                        Page  3
(CLUSTER A)

PWS ID    POP. SERVED
1010459
1010514
1010520
1010524
1010531
1010533
1010546
1010560
1010566
1010570
1010574
1010579
1010583
1010584
1010587
1010603
1010628
1010629
1010642
1010651
1010657
1010661
1010663
1010664
1010665
1010666
1010667
1010669
1010672
1010674
1010680
1010681
1010686
1010690
1010691
1010693
1010695
1010700
1010706
1010734
1010735
1010736
1010737
1010743
1010744
0000450
0000114
0000420
0000039
0000025
0000093
0000075
0000060
0000090
0000025
0000064
0000066
0000060
0000066
0000174
0000045
0000049
0000120
0000033
0000032
0000027
0000030
0000069
0000060
0000075
0000030
0000049
0000060
0000060
0000110
0000477
0000480
0000075
0000050
0000066
0000027
0000039
0000243
0000087
0000022
0000030
0000025
0000042
0000123
0000033
PWS NAME
                         El Dorado Mobile  Home  Corporation
                         Lorri Heights Mobile Home
                         Royal Coach Mobile  Home  Park
                         Pin Oak Mobile  Home Park No
                         Harvey & Gary Mobile Home  Park
                         Sundown Mobile  Home Park
                         Mt. Houston Trailer Park
                         Golden Carriage Mobile Home
                         Windfern Mobile Home Park
                         Quinlan Mobile  Home Park
                         Apache Mobile Home  Park
                         Royal Lake Mobile Home Park
                         Mohoot Village  Mobile  Home
                         Holliday Mobile Home Park
                         Longhorn Mobile Home Park
                         Kluge's Trailer Park
                         Cokers Mobile Home  Park
                         Cypress Crossing
                         Acres North Mobile  Home  Park
                         Peake's Park
                         Pyburn Enterprises  Incorp
                         Jordan Mobile Home  Park
                         Lone Willow West  Mobile  Home
                         Lone Willow Mobile  Home  Park
                         Aldine MHW & KOA
                         Don Fitch Water System
                         Space Estates Mobile Home  Park
                         Lauder Mobile Home  Park
                         Belleau Wood Trailer Park
                         Moorpark Village  Water System
                         Kings Row Mobile  Home  Park
                         Fruitland Water Corporation
                         Deer Trail Mobile Home Park
                         Blimp Mobile Home Park
                         Bluebonnet Mobile Home Comm
                         Buschong 1121 Mobile Home  Park
                         G & C Trailer Park
                         Huffman Heights Subdivision
                         Fair Acres Mobile Home Park
                         Jones Road Mobile Home Park
                         Judge's Mobile  Home Park
                         Spindle Mobile  Home Park
                         River Oaks Mobile Home Comm
                         Mel rose Mobile  Home Park No
                         Mentalbano Mobile Home Park
COUNTY
                                                Harris

-------
             Texas Mobile Home Parks - 1986 Data
                                       Page  4
(CLUSTER A)

PWS ID    POP. SERVED
1010746
1010747
1010760
1010763
1010783
1010788
1010792
1010795
1010801
1010805
1010808
1010809
1010810
1010811
1010814
1010821
1010825
1010826
1010827
1010832
1010887
1010904
1010914
1010933
1010934
1010935
1010947
1011032
1011049
1011067
1011075
1011084
1011112
1011219
1011236
1011253
1011268
1011302
1011321
1011382
1011433
1011441
1011442
1011459
1011460
1011492
0000087
0000039
0000057
0000048
0000105
0000081
0000228
0000072
0000035
0000150
0000225
0000040
0000207
0000105
0000026
0000048
0000103
0000140
0000075
0000090
0000100
0000036
0000090
0000030
0000030
0000017
0000069
0001167
0000138
0000054
0000081
0000025
0000048
0000215
0000150
0000075
0000065
0000267
0000117
0000078
0000276
0000040
0000054
0000081
0000140
0000087
PUS NAME

Fatima Family Village Mobile Home
Northwest Mobile Home Park
Tallow Mobile Home Park
Satsuma Park Villa Mobile Home
Genoa Trailer Park
Sjolander Mobile Home Park
Meadows Mobile Home Park
Fairway Mobile Home Village
Kimich Mobile Home Park
Woodloch Mobile Home Park
Pointe South Mobile Home Park
Bammel Oaks Estates No. 1
Bammel Oaks Estates No. 2
Chapman's Mobile Home Park
Lake Woods Mobile Home Park
Mahlmann Mobile Home Park
Aldine Gardens Mobile Home
Pin Oak Mobile Home Park No
Intercontinental Mobile Home
Deluxe Mobile Home Park
Brandywine Oaks
Greenwood Lake Subdivision
Roach Water System
Bob's Trailer Park No. 2
Farmette Meadows Mobile Home
Colletts Water System No. 2
Crickett Hill Estates
Northwest Pines Mobile Home
Oakland Village Mobile Home
Sunland Park
Fairmont Estates
Boudreaux Gardens
L & D Mobile Home Park
Brandywine Pines
Alice Acres Mobile Home Subdivision
Azalea Estates Mobile Home
Mar Dalf Mobile Home Park
Heathergate Water System
Royal Palms Mobile Home Park
Western Mobile Home Park
Van Manor Mobile Home Park
Coachlight Mobile Home Park
Bonanza Mobile Home Park
Sellers Estates Mobile Home
Atlasta Glen
Pa-Co Incorporated
COUNTY

Harris

-------
             Texas Mobile Home Parks  -  1986  Data
                                        Page  5
(CLUSTER A)

PWS ID    POP. SERVED
1011493
1011515
1011519
1011536
1011553
1011556
1011627
1011632
1011637
1011638
1011648
1011687
1011708
1011713
1011714
1011734
1011747
1011766
1011796
1011803
1011805
1011806
1011810
1011812
1011828
1011832
1011859
1011860
1011861
1011923
1011939
1011947
1011955
1011956
1011971
1011972
1011977
1011995
1011996
1011999
1012003
1012019
1012048
1012061
1012090
1012130
1012166
0000660
0000045
0000025
0000075
0000048
0000141
0000048
0000126
0000042
0000030
0000060
0000303
0000105
0000240
0000420
0000084
0000033
0000090
0000048
0000096
0000110
0000081
0000110
0000160
0000063
0000360
0000039
0000123
0000084
0000042
0000135
0000350
0000210
0000048
0000060
0000025
0000093
0000051
0000078
0000591
0000054
0000078
0000072
0000027
0000165
0000135
0000090
PWS NAME

Maple Leaf Mobile Home Subdivision
Houston Suburban Hts. MHP No
Twin Palms Mobile Home Park
Kitzwood
West Haven Mobile Home Park
Cedar Oaks Mobile Home Camp
Decker Investments MHP
Mel rose Mobile Home Park No
6403 Mobile Home Park
Tall Pine Mobile Home Park
Buffalo Bayou Mobile Home Park
Atascocita Acres
Whisper Meadows Mobile Home
Hooks' Mobile Home Park
Point West Mobile Home Comrn
Homestead Oaks Mobile Home
Guhn Road Mobile Home Park
Kickapoo Farms Subdivision
Woodgate Mobile Home Village
Oakwood Vi11 age Mobi1e Home
Telge Terrace Mobile Home S
Colony Mobile Home Subdivision
Timberdale Mobile Home Subdivision
Willow Oaks
Bentwood Estates Mobile Home
Five Oaks Mobile Home Subdivision
Deer Trails
Berry Hill Estates
Rolling Oaks
Rose Hill Ranchettes Mobile Home Subdivision
Telge Manor Mobile Home Park
West field Garden Mobile Home
Katy Country Estates
Northwoods Mobile Home Park
Rose Mobile Home Park
Romona Mobile Home Park
Ed-Lou Mobile Home Park
Bayou Forest Village Mobile
Grant Road Estates Mobile Home
North Belt Forest Subdivision
Herman Oaks Mobile Home Village
Weiman Mobile Home Park
Cypress Gardens Mobile Home
Youngblood Mobile Home Park
Spring Oaks Mobile Home Park
Padok Timbers Subdivision
Vernan Miller Mobile Home Park
COUNTY
                                                                         Harris

-------
             Texas Mobile Home Parks - 1986 Data
                                        Page  6
(CLUSTER A)

PWS ID    POP. SERVED
1012231
1012240
1012276
1012292
1012333
1012403
1012450
1012466
1460031
1460040
1460043
1460044
1460047
1460091
1460092
1460094
1460095
1460096
1460098
1460099
1460100
1460101
1460110
1700078
1700113
1700121
1700149
1700216
1700245
1700287
1700299
1700301
1700307
1700321
1700322
1700323
1700324
1700331
1700344
1700356
1700365
1700386
1700389
1700393
1700394
0000093
0000048
0000180
0000060
0000048
0000033
0000066
0000090
0000025
0000105
0000039
0000033
0000100
0000588
0000090
0000048
0000036
0000060
0000240
0000117
0000090
0000045
0000090
0000183
0000057
0000270
0000450
0000180
0000052
0000300
0000130
0000246
0000090
0000141
0001062
0000135
0000234
0000159
0000090
0000042
0000036
0000165
0001200
0000483
0000090
PWS NAME

Mohdot Village Mobile HP No
Barkaloo Homeowners Association
2920 West Subdivision
South Four Mobile Home Park
Acorn Mobile Home Park
River Oaks Mobile Home Community
Orchard Crossing Subdivision
Windfern Mobile Home Park

R's Mobile Home Park
Rainbow Lake Mobile Home Park
Cleveland Mobile Home Park
Pine Oaks Mobile Home Park
Derrington Mobile Home Park
Woodway Subdivision Water S
Northpark Subdivision No. 1
Uoodcreek Subdivision - Sec
Wildwood Subd Water Association
Oak Meadows II Subdivision
Lakeview Water System
Woodcreek Subdivision - Sec
Oak Meadows III Subdivision
Meadow Glen
North Park Subdivision No. 2

Pine Vista Mobile Home Village
Sweetgum Forest
Heritage Oaks
Hunters Retreat
Oakwood Acres
Pleasant Forest Subdivision
Turtle Creek
Greenwood County
Cypresswood Estates
Deer Ridge
Wilshire Subdivision
Deer Glenn Water System
Country Estates Water System
Huntington Estates
Crystal Springs Subdivision
Lazy Lane Mobile Home Park
Bear Branch Estates
Jays Mobile Home Park
Park Place Subdivision
Walnut Cove Subdivision
Shadow Bay Subdivision
Hilltop Village Mobile Home
COUNTY

Harris
                                                                         Liberty
                                                                         Montgomery

-------
             Texas Mobile Home Parks  -  1986 Data
                                        Page  7
(CLUSTER A)

PWS ID    POP. SERVED
1700431
1700432
1700433
1700434
1700435
1700447
1700454
1700478
1700481
1700482
1700483
1700490
2370044
2370045
2370047
2370048
2370049
2370051
(CLUSTER
0150088
0150120
0150125
0150131
0150135
0150156
0150186
0150187
0150199
0150204
0150207
0150208
0150230
0150233
0150248
0150252
0150253
0150256
0150265
0150290
0150430
0150478
0000240
0000051
0000084
0000072
0000339
0000135
0000090
0000090
0000081
0000111
0000132
0000120
0000040
0000040
0000093
0000025
0000036
0000090
B)
0000026
0000700
0000270
0000130
0000550
0000066
0000100
0000125
0000075
0000030
0000125
0000055
0000080
0000283
0000070
0000050
0000070
0000078
0000300
0000105
0000175
0000030
PWS NAME

Summer Hills Subdivision
Oak Creek II
Tower Glen Subdivision
Chaparral Place Water System
Country West Subdivision
Armadillo Woods
Oakwood Water System
Eastwood Hills Subdivision
Woodhaven Estates
Pinedale Mobile Home Park
Serenity Woods Subdivision
Westmont Mobile Home Community

Leaning Oak Mobile Home Park
Hidden Country Mobile Home
Beacon Estates Utility Company
Elite Mobile Home Park
Willowbrook Subdivision
Oak Hollow Subdivision
COUNTY

Montgomery
                                                                         Waller
                         Robinson's Trailer Park
                         Leon Springs Villa Mobile Home
                         Mobile City Estates
                         Trailer City Water Company
                         Oaks North Mobile Home Estates
                         Oak Hill Acres Mobile Home
                         Lazy Acres Mobile Home Park
                         Brookdale Mobile Home Park
                         Grandview Mobile Home Park
                         Cardoza Trailer Park
                         Cozy Cove Trailer Park
                         North Breeze Mobile Home Park
                         90 West R V Park
                         Park West Estates Mobile Home
                         AAA Lookout Trailer Park
                         HPR Trailer Park
                         Shady Acres Trailer Park
                         Little Joe's Ice House & Trailer
                         Elm Valley Water Company
                         Vail's Mobile Home Park
                         Country Oaks Mobile Home Park
                         South Oaks Estates
                                                Bexar

-------
Texas Mobile Home Parks - 1986 Data
(CLUSTER
PUS ID
0160007
0280017
0460079
0460151
0460161
0460166
0460175
1050023
1050057
1050063
1050072
1300005
1300006
1300007
1300008
1300010
1300013
1300014
1300027
1330002
1330017
1330018
1330019
1330020
1330024
1330029
1330044
1330101
1330110
1330120
1330121
1330122
1330123
1330131
1330132
1330133
1330134
1630011
1630014
1630025
1630030
B)
POP. SERVED
0000060
0000120
0000483
0000125
0000100
0000069
0000057
0000090
0000080
0000270
0000025
0000200
0000045
0000041
0000200
0000040
0000025 .
0000140
0000045
0000219
0000200
0000243
0000087
0000066
0000093
0000045
0000120
0000420
0000080
0000054
0000063
0000096
0000150
0000150
0000072
0000087
0000075
0000090
0000180
0000035
0000144

PWS NAME
Oaks Trailer Park
Pecan Trailer Park
Canyon Lake Hills Units No
Rockford Place Mobile Home
Tamiga Acres Mobile Home Park
Oak Valley Water Supply
Hart-N-Hart Mobile Home Park
Sunny Acres Mobile Home Park
Mockingbird Mobile Home Park
Aztec Village
Schulle Mobile Home Park
Cascade Mobile Home Park
Bel-Aire Mobile Home Park
Elms Mobile Home Park
Foothills Mobile Home Ranch
Cardinal Trailer Park
Foothills Mobile Home Ranch
Shady Rest Mobile Home Park
Merchants Mobile Home Park
Scenic Valley Mobile Home Park
Wilderness Park
Oak Grove Mobile Home Park
Cedar Springs Mobile Home V
Midway Mobile Home Park
Woodhaven Mobile Home Park
Hill Country Mobile Home Park
Hideaway Mobile Home Park
Hill Country Utility -Sleepy
Forest Oaks Mobile Home Park
Windcrest Mobile Home Park
Del Valle Mobile Home Park
Cherokee Mobile Home Park
Kerr Villa Mobile Home Park
Westwood Oaks Mobile Home Park
Rancho Oaks Mobile Home Park
Blue Ridge Mobile Home Park
Oak Ridge Estates Water System
Valley Mobile Home Properties
Highway 90 Ranch Water Company
Zinsmeyer Trailer Park
Cattlemans Crossing
Page 8
                                                            COUNTY
                                                            Blanco
                                                            Cal dwell
                                                            Comal
                                                            Hays
                                                            Kendal1
                                                            Kerr
                                                            Medina

-------
             Texas Mobile Home Parks -  1986  Data
                                                       Page  9
(CLUSTER B)

PWS ID    POP. SERVED
2270166
2270173
2270175
2270186
2270187
2270219
2270232
2270258
2270271

2460031
2460054
2460104
2460108
0000250
0000650
0000125
0000090
0000080
0000400
0001200
0000150
0000075

0000250
0000120
0000029
0000085
(CLUSTER C)

0430069   0000800
0570081
0570082
0570090
0570094
0570097
0570100
0570103
0570105
0570110
0570159
0610009
0610011
0610016
0610017
0610046
0610052
0610053
0610055
0610056
0610057
0610058
0610059
0610060
0610061
0610072
0610086
0000120
0000225
0000100
0000120
0000080
0000125
0000050
0000143
0000250
0000090
0000400
0001408
0000150
0000325
0000120
0000825
0000925
0000100
0000450
0000360
0000150
0000300
0000350
0000250
0000038
0000060
PUS NAME

Live Oaks US - Leander Hill
Hill Country Northwest WS
Eagle Ridge on Lake Travis
Sadik Mobile Home Park
Travis South Mobile Home Park
Branch Creek Estates
Northeast Utilities Inc. - N
Sweetwater Mobile Home Estates
Forest Oaks  Mobile Home Co

Hardrock Mobile Home Park
Green Acres Water Supply
Liberty Hill Mobile Home Park
Rays Retirement Village
               Spring Creek Village

               Meadowlark Mobile Home Park
               D Bar B Mobile Home Ranch
               Stillmeadow Water System
               Cottonwood Creek Mobile Home
               Parkerville East Mobile Home
               Bush Mobile Home Park
               Traveler's End Mobile Home
               Shady Creek Mobile Estates
               Forty Acres Mobile Home Park
               B & D Utilities

               Denton NW Estates - Wren Water
               Twin Lakes Mobile Home Park
               Denton Estates Mobile Home
               Rocky Point Mobile Home Park
               Corral City Mobile Home Park
               Vacation Village
               Denton West Mobile Home Park
               Trail Dust City
               Marshall Creek, Town of
               Royal Oaks Estates
               Capricorn Mobile Home Park
               Stonecrest Water Department
               Silver Dome Mobile Home Park
               Sherwood Mobile Home Park
               Triangle Mobile Home Park
               Cedar Creek Mobile Home Park
COUNTY

Travis
Williamson
                                               Collin

                                               Dallas
                                                                         Denton

-------
             Texas Mobile Home Parks - 1986 Data
                                       Page 10
(CLUSTER C)

PWS ID    POP. SERVED
0610090
0610120
0610149
0610162
0610169
0610171
0610172
0610179
0610181
0610191
1110028
1110031
1110034
1110044
1110045
1110059
1110074
1110076
1110077
1110078
1110079
1110080
1110083
1110086
1110088
1260028
1260031
1260037
1260060
1260061
1260062
1260064
1260065
1260066
1260069
1260070
1260071
1260072
1260073
1260074
1260075
1260076
1260077
1260078
1260079
1260080
0000075
0000075
0000066
0000350
0000360
0000075
0000050
0000030
0000045
0000168
0000375
0000070
0000075
0000264
0000120
0000525
0000105
0000186
0000035
0000066
0000185
0000065
0000054
0000050
0000210
0000141
0000087
0000045
0000078
0000065
0000096
0000141
0000156
0000200
0000063
0000135
0000120
0000141
0000090
0002550
0000087
0000162
0000068
0000153
0000264
0000120
PWS NAME

Acorn Ranch Mobile Home Park
Villager Mobile Home Park
Westpark Water Corporation
Ranch Mobile Home Park
Pine Creek Mobile Home Park
Water Association of North Lake
Cherokee Meadows
Double Rock Estates
Brittany Hill Water Association
Creekside Water System

Brazos River Acres
Lakeview Mobile Home Park
Lakeside Mobile Home Park
Montego Bay Estates
River Country Acres
Lake Country Acres
North Fork Creek  I
River Run Subdivision
Sunset Acres Mobile Home
Lakeside Hills
Blue Water Shore
Nolan Creek Estates
Country Meadows
Rolling Acres Mobile Home  Park
North Fork Creek  No. 2

Green Valley Estates
Oakridge Square Mobile Home
Tex Rides Subdivision
Skyline Drive Landowners Association
A & A Mobile Home Park
Shorty's Mobile Home Village
Rolling Oaks Subdivision
Spring Valley Water Co-op
Mansfield South
Hilltop Water-Sunshine Acre
Woodland Oaks Estates
Shady Hills  Estates Water
Shady Meadows Estates
Cahill Country  Water System
Metroplex Homesteads Water
Whispering Meadows
Falcon Crest Water  System
West  Park Village
Rancho Villa Subdivision
Lark  Meadow  Subdivision
Bell  Manor Subdivision
COUNTY
                                                                         Denton
                                                                         Hood
                                                                         Johnson

-------
             Texas Mobile Home Parks -  1986 Data
                                        Page  11
(CLUSTER C)

PUS ID    POP. SERVED
1260081
1260082
1260083
1260084
1260085
1260086
1260088
1260089
1260090
1260092
1260094
1260095
1260097
1260098
1260100
1260101
1260103
1260105
1260106
1260107
1840002
1840024
1840040
1840041
1840045
1840077
1840078
1840089
1840095
1840099
1840104
2200105
2200107
2200109
2200115
2200119
2200123
2200126
2200127
2200129
2200130
2200132
2200134
2200136
0000033
0000138
0000060
0000087
0000026
0000024
0000033
0000066
0000054
0000018
0000030
0000036
0000084
0000081
0000080
0000180
0000075
0000057
0000126
0000030
0001050
0000225
0000033
0000200
0000130
0000210
0000141
0000130
0000270
0000060
0000080
0000120
0000105
0000087
0000114
0000174
0000156
0000054
0000200
0000200
0000055
0000195
0000140
0000120
PUS NAME

Whispering Meadows Triangle
Rock Creek Estates
Wagon Wheel Estates
Buffalo Creek
Fox Hollow
Sanders View
North Whispering Meadows
Lander Bell Subdivision
John Dame
Garden Acres Subdivision Water  System
Southern Acres Water System
Ace Mobile Home Park
Mountainaire Mobile Home Park
Westlake Village Mobile Home
Willow Bend Subdivision Water System
Wai den Estates Water Company
Shaded Lane Estates
Golden 60's Subdivision
Williams Mobile Home Park
Union Hill Water System

Horseshoe Bend Water Works
Crazy Horse Ranches
Western Mobile Manor
Aledo Mobile Home Park
Towne Oaks Mobile Home Park
Mountain River Water System
Hudson Heights
Spring Valley Estates
Oak Hill Mobile Home Park
Trinity River Estates
Harpoles Mobile Home Park

Friendly Oaks Water Supply
Hilltop Mobile Home Park
Oak Hills Mobile Home Park
Spring Creek Water Cooperative
Corbin Mobile Home Park
Charriot Mobile Home Park
Yates Mobile Home Park
Green Acres Mobile Home Park
Texas Mobile Home Park No
Horizon Mobile Home Park
Twin Points Resort
River Oaks Mobile Home Park
Lake Worth Mobile Home Park
COUNTY

Johnson
                                                                         Parker
                                                                         Tarrant

-------
             Texas Mobile Home Parks - 1986 Data
                                        Page  12
(CLUSTER C)

PWS ID    POP. SERVED
2200139
2200140
2200141
2200146
2200147
2200148
2200150
2200151
2200157
2200168
2200172
2200190
2200211
2200269
2200278
2200284
2200288
2200290
2490013
2490018
2490027
2490028
2490029
2490034
2490035
0000180
0000075
0000072
0000094
0000054
0000125
0000100
0000030
0000135
0000080
0000036
0000100
0000075
0000030
0000150
0000075
0000066
0000145
0000100
0000090
0000090
0000140
0000090
0000060
0000050
PWS NAME

Country Oaks Mobile Home Park
Quiet Acres Mobile Home Park
Barnes Lakeside Resort
Acorn Mobile Home Park
Jordan's Mobile Home Park
Circle "R" Ranchettes
Oaks Mobile Home Park
Tenderfoot Trail Mobile Home
Lakeview Village Mobile Home
Shady Hill Mobile Home Park
Hi 11 crest Estates Mobile Home
Twin Lakes Water Company
Western Oaks Village
Bontke-Hodges Water System
Webb Water Supply No. 2
Avondale Heights Mobile Home
Meadow Glen Estates
Triple H. Estates

Killough Addition
Jones Acres
Miller Mobile Manor
Glider Base Estates
Town & Country Mobile Home
Griffin Country Addition
Golf Mobile Home Park
COUNTY
                                                                         Tarrant
                                                                         Wise

-------
Appendix B

-------
    KEEPING
DRINKING WATER
 SAFE TO DRINK
  Straight Talk
     About
Water Sampling
                             Prepared For The Texas Mobile Home Park Industry
                                        By
                              The Texas Manufactured Housing Association
 IT'S UP TO YOU!

-------
Appendix C

-------
WATER BACTERIOLOGY
Form No G-19 (rev 1044)
                                     Teua Department ol Health
                                     Bureau of Utxjritorles
Date and Time Rec'd
Sample No.
                          Date
                          Reported
                 Do nol mark above Ihrt line — Please print with ballpoint pen or typewriter
NAME OF WATER SYSTEM

       SEND RESULTS TO:
                                            COUNTY
       NAME
       STREET ADDRESS (PO Bo.)
                                      I  II  II  I	II  I
                                           JjTx
       CITY
                                                       ZIP CODE
  POINT OF COLLECTION        COLLECTED BY

Water System Identification Number
                                          mm
                                          MONTH   PAY
   TYPE OF SYSTEM
G  Public    G Dairy

G  Individual G Bottled

G  School
       SAMPLE  IS
    (Public Sysiems Only)
G Distribution   G  Raw

G Construction  G  Check

G Special
Ownership or other information1
                                                          YEAR
                                                                   TIME
                                                  ED
                                                   AMIPM
   WATER SOURCE
D River  D Lake

G Well  Well Depth.

Chlorine Residual 	
                       LABORATORY REPORT (Do not write below)
     Water of satisfactory bacteriological quality should be free from Conform organisms
 Coliform Organisms   C Found   D Not Found
 MF Coliform Count (presumptive).
                ./100ml
 M F Coliform Count (verified)
                ./100ml
 UNSUITABLE FOR ANALYSIS-PLEASE RESUBMIT
 D  Sample too old Sample not received
     within 30 hours  of collection
 D  Date discrepancy or form incomplete
     (See encircled item)
 D  Quantity insufficient for analysis
     (100ml minimum)

 D  Leaked In transit
 D  Not an approved container
             D Only one sample per time and point of collection
                required
             D Heavy (silt/bacterial growth) (with coliforms) present
                possibly obscuring and compromising test results

             G Quantity too great to permit agitation

             G Other
     MHPP

-------
Appendix D

-------
TEXAS MANOFACTOSED HOUSING ASSOCIATION
                      P.O. BOX 14428 • AUSTIN, TEXAS 78761
                             July 20, 1988
    TO:       Texas Mobile Home Parks On Public Water Systems

    FROM:      Texas Manufactured Housing Association
                  (In cooperation with:
                   U. S. Environmental Protection Agency
                   Texas Health Department
                   Texas Rural Water Association
                   National Rural Water Association)


         The Texas Health  Department  and  the  U.  S.   Environmental
    Protection Agency are the state and federal agencies responsible
    for seeing that  the  public has clean  water to drink  and use.
    Because your  mobile home park has a public water system, you are
    also responsible  for seeing that your residents are  protected.

         Enclosed vitb tbis letter are two  very important brochures.
    Please  take   the  time to  read them;  they  contain  not  only
    necessary  information,  but  helpful  tips  on  how  to  test your
    system's water quality.  The brochures were written to help you
    collect water samples properly.   They cover a variety  of
    important topics  such as when  to  collect,  how to  collect,  and
    where to send the collected samples.

         You, as  a mobile home park owner/operator, have a great deal
    to do during  the  month, and these brochures were designed to help
    make your job a little easier.   That, in itself, is  reason  enough
    to take the time  to read the enclosed materials.

         If  you  have any questions  after  reading  the  enclosed
    materials, or need assistance of any kind, please call  Charlotte
    Zimmerman; Texas  Manufactured Housing Association; Austin,  Texas,
    512/459-1221.

    enclosures
                  2215 EAST ANDERSON LANE • AUSTIN, TEXAS • 512/459-1221

-------
Appendix E

-------
TEXAS
 HOUS NG  ASSOC ATION
                           P.O. BOX 14428 • AUSTIN, TEXAS 78761
          August 22, 1988

          TO:    All Texas Mobile Home Parks With  Public Water Systems

          FROM:  Texas Manufactured Housing Association
              The Texas Department of Health and the U.S. Environmental Protection
          Agency are the state and federal agencies  responsible for seeing that the
          public has clean water  to drink and use.   Because your mobile  home park has
          a  public water system,  you are also responsible for seeing that your
          residents are protected.

              In trying to make  your job a little easier, the Texas Manufactured
          Housing Association and the Texas Rural Water Association are  offering a
          free 8-hour seminar which will be held in  San Antonio and repeated in
          Kerrville.  As outlined in the enclosed agenda, each seminar will cover
          such topics as (1) Texas Department of Health rules and regulations, (2)
          how to obtain operator  certification, (3)  water sampling, (4)  principles of
          disinfection, (5) management and financial planning, and (6) how to get on-
          site technical assistance.  Also enclosed  is an informative brochure
          explaining how and when to collect water samples and where to  send the
          samples for analysis.

              Each hour of seminar attendance will  qualify participants for one hour
          of classroom credit toward state certification as a waterworks operator.
          Attendees will also be  eligible for on-site technical assistance.

              The seminars will  be held as follows:
          September 13, 1988
          8:00  a.m.-4:30 p.m.

          La Mansion del Norte Hotel
          37 NE Loop 410 at McCullough
          San Antonio, Texas

          (512) 341-3535
          1-800-531-7208 (reservations)
September  15, 1988
8:00 a.m.-4:30 p.m.

Y.O. Ranch Hilton
Interstate 10 at Highway 16
Kerrville, Texas

1-800-531-2800
                     2215 EAST ANDERSON LANE • AUSTIN, TEXAS • 512/459-1221

-------
                          REGISTRATION PROCEDURES
Preregistrati on for each seminar is required.  Please fill out the-
registration form below and return it to: Texas Manufactured Housing
Association, P.O. Box 14428, Austin, Texas, 78761.

FORMS MUST BE RECEIVED BY SEPT. 6, 1988.

Be sure to indicate which seminar you wish to attend. Also, please note
that you must make your own arrangements for lunch and for lodging, if
necessary.

     If you have any questions, please call Charlotte Zimmerman,
Texas Manufactured Housing Association, Austin, Texas, at (512)
459-1221.
Detach & mail to TMHA office.
       MOBILE HOME PARK WATER SYSTEM COMPLIANCE IMPROVEMENT PROJECT
                             TRAINING SEMINAR

                             REGISTRATION FORM
Please register me for the [] SAN ANTONIO SEMINAR - Sept. 13, 1988

                           [] KERRVILLE SEMINAR ~ Sept. 15, 1988

NOTE: Please submit a separate form for each registrant.
FORMS MUST BE RECEIVED BY SEPT. 6.
NAME:
ADDRESS:
CITY & STATE:
ZIP CODE:	  PHONE:.

REPRESENTING:
Mail registration form to: TMHA
                           P.O. Box 14428
                           Austin, TX 78761

-------
Appendix F

-------
     Mobile Home Park Water System
     Compliance Improvement Project
                Training Seminar
   (•JFree Attendance

      Attendees eligible for on-site technical assistance
      Hours of TDH operator certification credit offered
      for each hour of instruction
         September 13, 1988   September 15, 1988
      La Mansion del Norte   Y.O. Ranch  Hilton
         San Antonio, Texas   Kcrrvillc, Texas
This seminar is being sponsored by a grain from ilic U S Environmental Protection Agency lo assist small
systems lowaid compli.incc with the Safe Drinking Water Act Amendments and Texas Department of
Health iulc& and regulations

The National Rural Water Association is administering this grant with assistance from the Texas Rural
Water Association anil the Texas Manufactured Housing Association

-------
Appendix G

-------
 MOBILE HOME PARK WATER SYSTEM
COMPLIANCE IMPROVEMENT PROJECT
       TRAINING SEMINAR
   SEPTEMBER 13, AND 15, 1988
  TEXAS DEPARTMENT OF HEALTH
  DIVISION OF WATER HYGIENE

-------
              WHY SAMPLE YOUR WATER?

1. SAMPLING  IS REQUIRED BY LAW.
     NATIONAL PRIMARY DRINKING WATER REGULATIONS
     TEXAS DRINKING WATER STANDARDS

2. DETERMINES QUALITY OF WATER
     BACTERIOLOGICAL
     CHEMICAL

3. PROVIDES PROTECTION FOR SYSTEM OWNER

-------
        WHAT SAMPLES ARE REQUIRED BY LAW?

CHEMICAL SAMPLES
     COLLECTED BY TDH STAFF
     OR IN COOPERATION WITH TDH STAFF

BACTERIOLOGICAL SAMPLES
     COLLECTED SYSTEM OPERATOR
     OR BY DESIGNATED INDIVIDUAL

-------
         WHAT  IS A BACTERIOLOGICAL TEST?

A TEST FOR COL I FORM ORGANISMS

     MAJOR BACTERIOLOGICAL  INHABITANT  OF  THE
     INTESTINAL  TRACT OF  MAN OR  ANY OTHER  WARM
     BLOODED ANIMAL

-------
             WHY TEST FOR COL I FORMS?

PRESENCE OF COL I FORMS  INDICATES  THE POTENTIAL FOR
FECAL CONTAMINATION

TYPICAL WATERBORNE DISEASE OUTBREAKS ARE CAUSED B\
ORGANISMS FROM FECAL ORIGIN

-------
           COLLECTING COL I FORM SAMPLES

LOCATE AN OUTSIDE FAUCET WHICH POINTS DOWNWARD

FLUSH FAUCET FOR 3 MINUTES
     CHECK FOR LEAKING FROM THE STEM
     CHECK FOR CHLORINE RESIDUAL

ADJUST TO A SLOW STEADY FLOW

TEAR OFF THE TOP OF THE BAG

PULL THE SIDE TABS TO OPEN THE BAG

FILL TO THE 4 OUNCE LINE
     WATER SPLASHING  INTO THE BAG IS CONTAMINATED

HOLD THE WIRE TABS /ND WHIRL THE BAG 3 TIMES
     CHECK FOR AN AIRSPACE AT THE TOP OF THE BAG

FOLD THE WIRE TABS OVER TO SEAL THE BAG

-------
       AFTER THE SAMPLE HAS BEEN COLLECTED

COMPLETE THE ANALYSIS FORM
     COMPLETE ALL BLANKS TO INSURE SAMPLE CREDIT

SUBMIT THE SAMPLE TO THE LAB WITHIN 30 HOURS
     MUST BE STATE APPROVED LABORATORY
     FEE FOR ANALYSIS RANGES $2 TO $7

EXAMINE RESULTS WHEN RECEIVED FROM THE LAB

-------
              WHAT ARE THE RESULTS?

NOT FOUND (NEGATIVE)
     NO FURTHER SAMPLING IS REQUIRED

FOUND (POS ITIVE)
     COLLECT CHECK SAMPLES ON CONSECUTIVE DAYS

UNSUITABLE FOR ANALYSIS
     RECOLLECT SAMPLES

-------
                  CHECK SAMPLES

COLLECT ON  CONSECUTIVE DAYS UNTIL  2  SAMPLES ARE
NEGATIVE

MUST BE MARKED AS "CKECK"  FOR PROPER CREDIT

IF FIRST TWO CHECK SAMPLES ARE NEGATIVE, POSITIVE
SAMPLE IS NEGATED

-------
                 CHEMICAL SAMPLES

INORGANIC SAMPLES (MINERALS AND METALS)
     GROUNDWATER - THREE YEAR INTERVALS
     SURFACE WATER - ANNUALLY

ORGANIC SAMPLES
     REGULATED PESTICIDES
          GROUNDWATER - NOT REQUIRED
          SURFACE WATER - FOUR YEAR INTERVALS
     VOC'S (TO BE PHASED IN OVER 4 YEARS)
          GROUNDWATER - AT LEAST EVERY 5 YEARS
          SURFACE WATER - QUARTERLY FOR 1 YEAR
                          EVERY 5 YEARS
     THM'S
          POPULATION < 10,000 - NOT REQUIRED
          POPULATION > 10,000 - QUARTERLY
     OTHER ORGAN ICS - CURRENTLY  IN REVIEW BY EPA

RADIOCHEMICAL SAMPLES
     AT 4 YEAR  INTERVALS

-------
Appendix H

-------
                                       REGISTRATION
STATE:
DATE:
LOCATION:

NAME

















ADDRESS/
PHONE NO.

















MHP
WATER SYSTEM

















POSITION













•



YRS. OF
SERV. IN
POSITION



















CERT.
OPER.
YES NO


































HAVE YOU
ATTENDED
, STATE/
AGNCY TRNINC
YES NO



































-------
                     RURAL WATER TRAINING
                 ASSESSMENT QUESTIONNAIRE
Date 		        Location
1.   Please circle which best describes your position:

    A.  Operator/Manager
    B.  Board Member
    C.  Administrative
    D.  State or Federal Representative
    E.  Industry
    F.  Public
 2.  Generally speaking, this training: (Please circle one or more)

   T A. Helped me professionally on how to do a task.
    B. Helped me professionally by refreshing my memory.
    C. Helped me professionally by providing needed information.
    D. Was not interesting and/or wasted my time.
 3.  If improvement could be made I would recommend: (Please circle one or more)

    A. Having different instructors.
    B. More in-depth instruction.
    C. Having more slides and films.
    D. Having less lecture time and more learner participation.
    E. Having a better learning environment.
 4.   Was there anything that particularly pleased or bothered you about the instructors or the facility:
 '•&£*

-------
in 9 8 7
GOOD ABOVE
AVERAGE
RATING SCALE
654
AVERAGE
3 2
BELOW
AVERAGE
1
POOR
                 Please answer the following questions using a number from the scale above.
5.  In your opinion, was the topic matter clearly stated in the agenda you
    received? Please rate  by placing  a number from  the  scale above.
6.   Please rate how well the topics in the agenda were covered in the actual
     training session.

7.   Please rate your opportunity to participate in discussions, issues, and/or
     information  that was relevant  to your job.
 8.   Please  rate this  session as to its overall  use  to  you.

 9.   Please  rate the  following learning  aids if used:
     A. Slide and/or overhead projections.
     B. Handout material by  instructors.
     C. Rural  Water Training guides.

10.   Please rate your instructors in terms of their subject matter knowledge.
     Use  a number  from the above  scale.
     Instructor:
     Instructor:
     Instructor
     Instructor:
Rating:
Rating:
Rating:
Rating:
   This is my contribution to assuring that quality and effective training will continue to be provided by
the Rural Water Association in meeting the needs of rural and small water systems in this state and across
the nation.
                                                                         (Signature)
 Other Comments:
                                          Arv.

-------
Appendix I

-------
STATE:
                             DATE:
                                         nr.ciSTu/vTiON

                                          /    / -?.  '
                                                                                     l
                                                          LOCATION:
TYPE SESSION:
                                (Inslruclion Timc)
(F«,or,
                                                                          (Crcdi.s)
                                                              Have You
                                                           Attended Other:
                                                           WATER SYSTEM

                                                              AGENCY
                                 POSITION
                                                    Yes
Rural Water
  Training

        No

IHA/\L^ J-'x/J'^
To "- D Atr h\i
1 , . vr
C fj'i Pi A- S A //1,1/Y.X
M,,,.it' '/"/I-/
^~" •'' i
i'\.i-'{ /><. f4
_»• \ *- — . 7 - - , \ : • W
/ /' '*
*' V; t''*>7/f-il
// -"?<• L- y. /'- - "•"i//
/•£' f S. /.-.<.*.,, i",f- /rffe
//c'o i-. '• V m
/c/^^.V.'- ''v-7.^"*
(y/u.\/7'-.'lw""
^-> /V T \ V >- • > '/

CLfr//- ''/•i ,' /.
/A^.. /Vy/fxt
';/ A' •-. /-/
"( (•* . A
"T 'b * I
//. , A !/• /•
1 > : A
i
Cc u ..-x^ t'fV- \ IS"
S>r C -^"
fi 	 JV.^_ -^
Oi i«. i , /t .- \ [\}f\iL K n\'t.,i. ._-
x- . _fc, .-^ .
.>;/». c'y A- ^ U./ ^-— -t-
'.v\ : ""\'r;v',i r." •• \/ .^
                                                                        Slate Agency
                                                                         Training
                                                                      Yei
                     1
No

N, ^-' ^ >. - -\">-, ';'

/>, , -- - ' ,') 1 ,./'-(
-X ,, .' /'..x
'/il/l '- '/i/'MI /"

*y5T 0 /^

/). - ,. '/.%-••?
/l^"/<^/1xi/'/-!t/"'
_/ » i "(•-.'
"-,/;/-> / A
,.,-'/ / M ./i . /
-'; 1 /i.i
•'- -/, i •
t- .'^' \ |r...".l I -f ('•' - )
- .c/i // ,//. ; -^ ( /i /'./^ '
^•^j ^ 1 1 ti . 7^ / o'f'^

\ P; H
/"/- //
; ,
A . ' ^ ,|
/ j
y ,;-i
-Taufi



^ \ tii
1^.^ 4

Fjt^t , D/r-,


.__-"
r^
^l^MI^BM^^B^BMI^

^f




1




'
^
•^••••^
1
^


-------
STATE:
TYPE SESSION:
       NAME
                                     REGISTRATION
                          DATE:
                             (Inslruclion Time)
       ADDRESS

  -,0
ff Ot> Aj,

       ^sr'N
                                                     LOCATION:
                                                                           eff
                       (F2clor)
                                                                   (Credits)
                                                     WATER SYSTEM
                                                         FIRM
                                                        AGENCY

                                                     'ftx  I   f«v. '
                                                    "T. Vv/,C,
                                                    -TCJ-  C-
                                                    POSITION
                                                                              Have You
                                                                            Attended Other:
                                                                     Yes
Rural Water
 Training

       No
                                                                                      Stale Agency
                                                                                        Training

                                                                                     Yes     No

-------
Appendix J

-------
                      RURAL WATER TRAINING
                 ASSESSMENT QUESTIONNAIRE
9*  J3  -  8T>                      ation    S,flt
 Date      *      -      _       Location
 1.  Please circle which best describes your position:

    A. Operator/Manager
    B. Board Member
   (cP Administrative
    D. State or Federal Representative
    E. Industry
    F. Public
 2.  Generally speaking, this training: (Please circle one or more)

    A. Helped me professionally on how to do a task.
   £jpHelped me professionally by refreshing my memory.
    C. Helped me professionally by providing needed information.
    D. Was not interesting and/or wasted my time.
 3.  If improvement could be made I would recommend (Please circle one or more)

    A. Having different instructors.
    B.  More in-depth instruction.
    C. Having more slides and films.
   (lp Having less lecture time and more learner participation.
    E  Having a better learning environment
 4.  Was there anything that particularly pleased or bothered you about the instructors or the facility:
      fOo	
TSQ 001                          ISA
                                                               (OVER)

-------

10
GOOD
RATING SCALE
987654
ABOVE AVERAGE
AVERAGE

3 2
BELOW
AVERAGE

I
POOR
                  Please answer the following questions using a number from the scale above.

  5.   In your opinion, was the topic matter clearly stated in the agenda you
      received? Please rate by placing a number from the  scale above.
  6.   Please rate how well the topics in the agenda were covered in the actual      .             c\.
      training session.                                                                 	
  7.   Please rate your opportunity to participate in discussions, issues, and/or                    £>
      information  that was relevant to your job.                                       	1—

  8.   Please rate this session as to its overall use to you.                              —
  9.   Please rate the following learning aids if used:
      A. Slide and/or  overhead projections.
      B. Handout material  by instructors.
      C. Rural  Water  Training guides.

 10.   Please rate your instructors in terms of their subject matter knowledge.
      Use  a number from  the  above scale.

      Instructor  _	—	   Rating:
      Instructor  ___	   Rating:
      Instructor  	—   Rating:
      Instructor.  __	   Rating:
   This is my contribution to assuring that quality and effective training will continue to be provided by
 the Rural Water Association in meeting the needs of rural and small water systems in this state and across
 the nation.
                                                                         (Signature)
 Other Comments:
TSQ 001                                 15B

-------
Appendix K

-------
                                                                                                                   Have You
                                                                                                                Attended Other:
Stale Agency
  Training

        No
Yes
  Rural Water
   Training

Yes       No
                                                            WATER SYSTEM
                                                                 FIRM
                                                               AGENCY
'1SR001
                                                                   13A

-------
                                              REGISTRATION
    STATE:
                                  DATE:
TYPE SESSION:
                                                                LOCATION:
            NAME
                                     (Instruction Time)
                                     ADDRESS
                                                       (Factor)
                                                                                 (Credits)
                                                                 WATER SYSTEM
                                                                     FIRM
                                                                    AGENCY
                                                                                         POSITION
                                                                                                                           Have You
                                                                                                                        Attended Other:
                                                                                                              Rural Water
                                                                                                                Training
                                                                                                             Yes
No
          Stale Agency
            Training
Yes

X
                                                                                                                                        No
'IS ROD I
                                                                        13A

-------
Appendix L

-------
                      RURAL WATER TRAINING
                  ASSESSMENT QUESTIONNAIRE
 Date    7*- **     °"	        Location
 1.  Please circle which best describes your position:

   (A) Operator/Manager
    B.  Board Member
    C.  Administrative
    D. State or Federal Representative
    E.  Industry
    F.  Public
 2.  Generally speaking, this training: (Please circle one or more)

   (A) Helped me professionally on how to do a task.
    B.  Helped me professionally by refreshing my memory.
   (C) Helped me professionally by providing needed information.
    D. Was not interesting and/or wasted my time.
 3.  If improvement could be made I would recommend: (Please circle one or more)

    A. Having different instructors.
    B.  More in-depth instruction.
    C. Having more slides and films.
    D. Having less lecture time and more learner participation.
    E  Having a better learning environment
 4.  Was there anything that particularly pleased or bothered you about the instructors or the facility:
          a
TSQ 001                           ISA
                                                               (OVER)

-------
                                         RATING SCALE

                 10      9    fl\     7     6      S     4      3     2	L
              GOOD          "ABOVE           AVERAGE      BELOW      POOR
                              AVERAGE                        AVERAGE
                  Please answer the following questions using a number from the scale above.
 5.  In your opinion, was the topic matter clearly stated in the agenda you
     received?  Please rate by  placing a number from  the scale above.

 6.  Please rate how well the topics in the agenda were covered in the actual
     training session.
 7.  Please rate your opportunity to participate in discussions, issues, and/or                      ,~
     information that was relevant to your job.                                      	^—

 8.  Please rate  this  session as  to its overall  use to you.

 9.  Please rate  the following learning aids if used:
     A.  Slide and/or overhead  projections.
     B.  Handout material by instructors.
     C.  Rural Water Training guides.

 10.  Please rate your instructors in terms of their subject matter knowledge.
     Use a number from the above  scale.

     Instructor		Rating:
     Instructor	
      Instructor  _	•	   R*ring:   	
      Instructor  _	—	   Raring:   	

   This is my contribution to assuring that quality and effective training will continue to be provided by
 the Rural Water Association in meeting the needs of rural and small water systems in this state and across
 the nation.
                                                                      (Signature)

 Other Comments:
TSQ 001                                15B

-------
Appendix M

-------
                    MHP COMPLIANCE IMPROVEMENT PROJECT





                       TECHNICAL ASSISTANCE REPORT
DATE:
                         ARRIVAL TIME:
SYSTEM THAT  TA  WAS  PERFORMED ON:
PERSON CONTACTED:
                                 *//*
SPECIFIC PROBLEM ENCOUNTERED:




                          /-Csas^
                                                 DEPARTURE TIME
                                                      /r>y
                                       /
                                                         srs
EDUCATIONAL MATERIALS PROVIDED:

-------
Appendix N

-------
' SEXAS  MAMUFACTOESEID HOUSING ASSOCIATION
                      P.O. BOX 14428 • AUSTIN, TEXAS 78761
                              July 22, 1988
     TO:       Texas Mobile Home Parks With Public Water Systems

     FROM:     Texas Manufactured Housing Association
                   (In cooperation with:
                    Texas Health Department
                    Texas Rural Water Association
                    National Rural Water Association
                    U. S. Environmental Protection Agency)


              Enclosed with this letter is a very important brochure.
     PLEASE TAKE TEE TIME TO READ IT!!  Four reasons why follow:

              1.   State and federal law  requires  all  drinking water
     for  public  use  to be free  from harmful bacteria.   Furthermore,
     such drinking  water  has to  comply  with  purity  standards
     established  by  the  Texas  Department  of Health  and the U.  S.
     Environmental Protection Agency.  The law further states that the
     owner or manager of every water  supply system shall submit to the
     Texas Department of Health  at least one (1)  sample of water taken
     from the supply  for the  purposes of bacteriological analysis
     during  each month  that the service  operates  — and  that  the
     person  taking  these samples and  operating the  system must  be
     certified by the Texas Health Department.

       HAVE YOU BEEN TAXING SAMPLES AND ARE YOU OR YOUR AUTHORIZED
             REPRESENTATIVE A CERTIFIED WATERWORKS OPERATOR?

              2.   The  penalties for not abiding by the above noted
     law  include fines of between $10 and $1,000 per violation per day
     and/or confinement in jail  for up to 30 days.

                     CAN YOU AFFORD THESE PENALTIES?

              3.   In all likelihood  your insurance will  not cover
     you  if a lawsuit is filed because  of  contaminated water that has
     not been checked by your or your authorized representative.

        CAN YOU AFFORD TO BE DROPPED BY YOUR INSURANCE  COMPANY —
     OR NOT BACKED BY YOUR INSURANCE COMPANY —  IN CASE  OF VIOLATION?
                                                  —  over, please —



                  2215 EAST ANDERSON LANE • AUSTIN, TEXAS • 512/459-1221

-------
Ltr. to Parks on Private Water Systems
July 22, 1988
Page 2
          4.     Equally serious,  as  far  as  your  business  is
concerned,  is  that word  of any  complaints  or  actual lawsuits
concerning contaminated water  might  "get around"  and  your till
rate and profits would seriously decrease.

              NOTHING TRAVELS FASTER  THAN BAD NEWS
                   SPREAD  BY YOUR RESIDENTS!!

          It is  to  your benefit to  read carefully the enclosed
brochure — and then be sure you comply with the  law.

     YOUR POCXETBOOX AS WELL AS YOUR  REPUTATION IS  AT STAKE!
          Representatives of  Texas  Rural Water  Association,  in
cooperation with the Texas Health Department, will be contacting
you, as owner — or your authorized  representative  — to schedule
on-site technical assistance.   Please cooperate with them.  They
will be there to help.

          Additional  information can  be obtained by  calling
Charlotte Zimmerman; Texas Manufactured Housing Association;
Austin, Texas, 512/459-1221.

enclosure

-------
Appendix 0

-------
                   MHP COMPLIANCE  IMPROVEMENT PROJECT



                      TECHNICAL ASSISTANCE REPORT
3ATE:    9.
                         ARRIVAL TIME:
SYSTEM THAT TA WAS PERFORMED ON:  fl'


PERSON CONTACTED:    flirt**  J^ fcAj


SPECIFIC  PROBLEM ENCOUNTERED:   ThL


              987  - Klavl  C£~pLi»»>Cr
                                                DEPARTURE  TIME:



                                                  Mr1.fi.-
    /"/    0
    *- fm Z  i*
HOW  PROBLEM WAS ADDRESSED:
                                        /T /V/W. Js>tf*iSo*J
                                           ++,. la*
OUTCOME
                                       *J ^~» <=-s &~-&.  *h
                                                              <   ^ °°ne Of>
                  1	r
EDUCATIONAL MATERIALS PROVIDED:
                                                                      .-1-J.J

-------