Callahan Final Order

IN THE
COMMONWEALTH OF VIRGINIA
BOARD FOR WATERWORKS AND WASTEWATER WORKS OPERATORS
AND ONSITE SEWAGE SYSTEM PROFESSIONALS
Re: Edward M. Callahan, Jr.

Rustburg, VA 24588
File Number 2016-01793

License Number 1955003670
FINAL OPINION AND ORDER
On March 21, 2017, the Summary of the Informal Fact-Finding Conference ("the
Summary") and notification of the Board for W ate rworks and Wastewater Works t
I
Operators and Onsite Sewage System Professionals ("the Board") April 20, 2017
meeting was sent, via United Parcel Service ("UPS"), to Edward M. Callahan , Jr.
("Callahan") at the address of record . The package was delivered.
On April 20, 2017, the Board met and reviewed the record, which consisted of
the investigative file , the transcript, and exhibits from the Informal Fact-Finding
Conference ("IFF"), and the Summary. Callahan did not appear at the Board
meeting in person , by counsel , or by any other qualified representative.
The Board adopts the Report of Findings, which contains the facts regarding the
regulatory and/or statutory issues in this matter, and adopts the Summary. The
Report of Findings and Summary are incorporated as part of this Order.
The Board finds substantial evidence that Callahan violated the following :
(Effective July 1, 2009)

Count 1: 18 VAC 160-20-140.4
Count 2: 18 VAC 160-20-140.7
The Board imposes the following monetary penalties :
Count 1: 18 VAC 160-20-140.4 $ 1,500.00

Count 2: 18 VAC 160-20-140.7 $ 1,000.00
TOTAL $ 2,500.00
The Board also imposes the following sanctions:
For violation of Counts 1 and 2, license revocation is imposed .
THE TOTAL MONETARY PENALTY ASSESSED HEREIN SHALL BE

PAID WITHIN SIXTY (60) DAYS FROM THE DATE OF ENTRY OF
THIS FINAL ORDER. FAILURE TO PAY THE TOTAL MONETARY
PENALTY ASSESSED WITHIN SIXTY (60) DAYS OF THE DATE OF
ENTRY OF THIS FINAL ORDER WILL RESULT IN THE AUTOMATIC
SUSPENSION OF YOUR LICENSE (LICENSE NO. 1955003670)
UNTIL SUCH TIME AS SAID AMOUNT IS PAID IN FULL.
AS PROVIDED BY RULE 2A:2 OF THE SUP REME COURT OF

VIRGINIA, YOU HAVE THIRTY (30) DAYS FROM THE DATE OF
SERVICE (I.E. THE DATE YOU ACTUALLY RECEIVED THIS
DEC ISION OR THE DATE THE DECISION WAS MAILED TO YOU,
WHICHEVER OCCURRED FIRST) WITHIN WHICH TO APPEAL THIS
DECISION BY FILING A NOTICE OF APPEAL, SIGNED BY EITHER
YOU OR YOUR COUNSEL, W ITH JAY W . DEBOER, SECRETARY
OF THE BOARD FOR WATERWORKS AND WASTEWATER WORKS
OPERATORS AND ONSITE SEWAGE SYSTEM PROFESSIONALS.
IN THE EVENT THAT THE DECISION WAS SERVED ON YOU BY
MAIL, THREE (3) DAYS SHALL BE ADDED TO THE THIRTY (30)
DAY PERIOD.
IF A PETITION FOR APPEAL IS FILE D WITH THE CLERK OF THE

CIRCUIT COURT, AS PROVIDED BY RULE 2A:4 OF THE SUPREME
COURT OF VIRGINIA, THEN THE AUTOMATIC SUSPENSION OF
YOUR LICENSE FOR FAILURE TO PAY THE TOTAL ASSESSED
MONETARY PENALTY WILL BE STAYED PROVIDED THE
FOLLOWING INFORMATION IS RECEIVED BY JAY W . DEBOER,
SECRETARY OF THE BOARD FOR WATERWORKS AND
WASTEWATER WORKS OPERATORS AN D ONSITE SEWAGE
SYSTEM PROFESSIONALS:
1. A SIGNED COPY OF THE NOTICE OF APPEAL; AND

2. A COPY OF THE SURETY AGREEMENT OR A COPY OF THE
RECEIPT FROM THE CLERK OF THE CIRC UIT COURT WHERE THE
APPEAL HAS BEEN FILE D INDICATING THAT A BOND HAS BEEN
POSTED OR CASH PAID INTO THE COURT IN THE AMOUNT OF THE
TOTAL MONETARY PENALTY ASSESSED IN THE FINAL ORDER.
SO ORDERED:
Entered this 20th day of April , 2017 .
BOARD FOR WATERWORKS AND WASTEWATER WOR KS OPERATORS

BY@~
\J\f~r. secretarY
Ja
IN THE
COMMONWEALTH OF VIRGINIA
BOARD FOR WATERWORKS AND WASTEWATERWORKS OPERATORS AND
ONSITE SEWAGE SYSTEM PROFESSIONALS
Re: Edward M. Callahan, Jr.
File Number: 2016-01793

License Number: 1955003670
SUMMARY OF THE INFORMAL FACT-FINDING CONFERENCE
On December 29, 2016, the Notice of Informal Fact-Finding Conference ("Notice) was
sent, by the United Parcel Service ("UPS"), to Edward M. Callahan, Jr. at the address
- - - - -.,...ofnrl'lCierord. The Notice included the-Rep-ort of Finding~ch contained the-f'fa~c...tts...------
regarding the regulatory and/or statutory issues in this matter. The Notice was
delivered.
On February 2, 2017, an Informal Fact-Finding Conference ("IFF") was convened at

the Department of Professional and Occupational Regulation.
The following individuals participated at the IFF: Callahan, Respondent; Alec Kast and
Doug Schroder, Staff Members; and Douglas Perry Greene, Presiding Board Member.
RECOMMENDATION
Based upon the evidence in the record, the following is recommended regarding the
Counts as outlined in the Report of Findings:
Count 1: Board Regulation
Callahan was first licensed as a Waterworks Operator by the Board on November 13,
1987, and has been a Class 1 Waterworks Operator since 2000. Callahan was
employed by the Town of Altavista ("Altavista") at the Altavista Water Treatment Plant
("Altavista WTP") from 1989 until November 17, 2014, when he retired. During the years
prior to his retirement, Callahan was the Plant Superintendent of the Altavista WTP.
The Altavista WTP operates under a permit issued by the Virginia Department of Health
("VDH"), Office of Drinking Water ("ODW'l In accordance with Waterworks Regulations
12 VAC 5-590-370, the Altavista WTP is required to perform sampling to determine the
following , in part:
Turbidity measurements; and
Disinfectant residuals ("chlorine residual") of applied water and finished water. 1
1 Waterworks Regulation 12 VAC 5-590-10 defines the following:
1
During the operation of the Altavista WTP, waterworks operators recorded the following
hourly sampling results on a document titled "NTU, Ph, and Cl2 Hourly Checks" ("Log
Sheet"):
Raw water NTU;2
Raw water Ph;
Applied water NTU;
Applied water Ph;
Applied water chlorine residual levels;
Finished water NTU;
Finished water Ph; and
Finished water chlorine residual levels.
Subsequently, the following daily information was determined or calculated for each of
the above hourly sampling results and recorded at the bottom of each Log Sheet by
Callahan:
----------~~~D~ai~~e~s;_______________________________________________________
Maximum sampling result recorded that day; and

Minimum sampling result recorded that day.
The daily information was then recorded on an ODW Report of Operations ("Report") by
Chester Franklin Cofflin ("Cofflin"), the Altavista WTP Plant Manager. At the end of each
month, the following monthly information was determined or calculated for the above
daily sampling results and reported by Cofflin to the ODW in a Report of Operations in
accordance with Waterworks Regulation 12 VAC 5-590-530:
Maximum daily sampling result recorded during the month.
Minimum daily sampling result recorded during the month.
Monthly averages of daily averages recorded during the month.
Each month between January 2014 and September 2014, Cofflin completed and signed
a Report and submitted it to the ODW. On these Reports, Cofflin indicated that the
minimum applied chlorine residual obtained by operating staff of the Altavista WTP was
.6 256 times , out of a total of 273 listed readings.
On August 25, 2014, Christopher Brumfield ("Brumfield") was hired by Altavista as an

operator-in-training at the Altavista WTP. On October 7, 2014, Brumfield contacted
David Garrett ("Garrett"), Director of Public Works for Altavista , and indicated that
operators at the Altavista WTP were falsifying records. Specifically, Brumfield stated
that Cofflin and Callahan had established preferred ranges for the tests performed by
"Disinfectant" means any oxidant (including chlorine) that is added to water in any part of the
treatment or distribution process for the purpose of killing or deactivating pathogenic organisms.
"Applied water" means water that is ready for filtration.
"Finished water'' means water that Is introduced into the distribution system of a waterworks and
is intended for distribution and consumption without further treatment, except as treatment
necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition
of corrosion control chemicals). (Exh. 1-24)
2 Turbidity is abbreviated as "NTu. "NTU" stands for Nephelometric Turbidity Unit.
2
waterworks operators on applied water and finished water. According to Brumfield, if the
test results were outside of the preferred ranges, waterworks operators would record a
reading within the preferred range instead of the actual reading.
Between October 7, 2014 and November 17, 2014, Waverly Coggsdale ("Coggsdale"),
the Town Manager for Altavista, and Garrett conducted an investigation into Brumfield's
allegations. Following the investigation, Cofflin and Callahan were asked to retire from
the Altavista WTP.
Over the course of the investigation, Coggsdale and Garrett received 21 notebooks
from John Jacobs ("Jacobs"), an employee of the Altavista WTP. The notebooks
contained log sheet entries for between July 15, 2009 and October 16, 2014, which
included the following entries documenting false information in log sheets, in part:
Sampling Date Sampling Sampling Type False Result True Result

Time Reported on Recorded in
Log Sheet Notebook
"' Gembef-29 "" o4 ., A~O-""~n'\~ A"'"'fied-GJ:IIE>FiRe- .6 .5
January 5 2014 8:00a.m. Applied Chlorine .6 .4
9:00a.m. Applied Chlorine .6 .5
January 9, 2014 4:00p.m. Applied Chlorine .6 .5
6:00p.m. Applied Chlorine .6 .4
January 10 2014 10:00 p.m. Applied Chlorine .6 .4
11 :00 p.m. Applied Chlorine .6 .4
January 14, 2014 3:00p.m. Applied Chlorine .. 6 .5
January 17 2014 3:00p.m. Applied Chlorine .6 .5
4:00p.m. ApQiied Chlorine .6 .2
10:00 p.m. Applied Chlorine .6 .4
January 26, 2014 8:00a.m. Applied Chlorine .6 .5
January 30, 2014 8:00p.m. Ap_plied Chlorine .6 .5
3
11 :00 p.m. Applied Chlorine .6 .5
January 31 , 2014 3:00p.m. Applied Chlorine .7 .5
February 5 2014 7:00p.m. Applied Chlorine 1 1.1
Jacobs' notebooks also contained the following entry, which was dated January 2,
2014:
Came in at 2:30pm and [Callahan] called me [Jacobs] into his office and
jumped on me about a Applied Turbidity reading on 12-29-13 at 9 :00am and
blessed me out and everything else I did and the way I do it and when I told
him that I do things the way the book calls for he told me that if I don't start
_ __ _ __..,davo.ing-tbings...tba.w.ay.Jle_wants._tbem_done.lhaUw.o.uld_suffer foLiLW.b"""en...._._
l ______ __
asked even if that meant [lying] on the paperwork by that time Gary David had
come in and he told the both of (us] that if it meant [lying] then lie but do not
write anything he didn't like down. What next.
On October 7, 2015, in an interview with Investigator Kevin Hansen ("Investigator

Hansen"), the Board 's Agent, Jacobs admitted he has falsely recorded water quality test
results on log sheets. Additionally, Jacobs stated:
Callahan and Cofflin had told Jacobs "not to write below .6 for the applied test or
above 1.0";
Jacobs did not like recording a false test result because he "was lying";
Jacobs "didn't want to make Cofflin and Callahan mad" so, on occasion, Jacobs
recorded false test results on the log sheets; and
Jacobs maintained records of the actual test results in notebooks.
Additionally, on October 10, 2014, Brumfield's notes indicate the following false entries
were recorded on log sheets:
Time Type False Result True Result

8:00a.m. ~_Qi ied Chlorine .6 .49
9:00a.m. Applied Chlorine .6 .52
3:00p.m. Applied Chlorine 1.0 1.17
4:00p.m. Applied Chlorine 1.0 1.46
4:00p.m. Finished Chlorine 2.0 2.16
On October 27, 2015, in an interview with Investigator Hansen, Pauline Brown

("Brown"), an employee at the Altavista WTP, stated, in part:
Cofflin and Callahan told waterworks operators not to record an applied chlorine
residual below .6;
If an applied chlorine residual less than .6 were recorded, it would have been
4
erased and changed by Cofftin or Callahan;
Callahan directed her to write down false applied chlorine residuals if the actual
chlorine residuals were found to be not within the preferred range of .6 to 1.0;
Callahan used the data recorded on the NTU, Ph, and CL2 Hourly Check sheets to
obtain daily averages as well as determining the minimum and maximum levels;
and
The daily chlorine residual averages, maximum chlorine residual levels, and
minimum chlorine residual levels were reported to the ODW.
On November 9, 2015, in an interview with Investigator Hansen, Callahan stated, in

part:
Cofflin and Callahan wanted the applied chlorine to be between .6 and 1.0;
The preferred range for the finished chlorine was 1.5 to 2.0;
Cofflin and Callahan would tell the waterworks operators to write .6 for the applied
chlorine residuals, but Callahan did not know where that number came from;
Callahan believed the ODW required minimum applied chlorine residual to be .6;
W....a..t..e~rw~orks_operat.o.m..ays wrota.JtfoLtbe applied chJQrine residual, even if the" ' - - - - -
- -- -- -',.__._
test results were lower;
Water samples collected from filter 5 would be "a worst case" for applied water; and
If the water sample collected at filter 5 resulted in applied chlorine residual of less
than .6, the water at filters 1, 2, 3, and, 4 more than likely would be above .6 if
tested.
At the beginning of the IFF, Callahan claimed that the Altavista WTP had never
provided false readings to the ODW. According to Callahan, although the readings were
reported as between .6 and 1.0, regardless of the result, each reading was accurate
"[b]ecause eventually that's what it was going to be." (Transcript, p. 9) Additionally,
Callahan stated that the range was longstanding practice, and claimed that the readings
would match the log sheets if taken from other locations at the Altavista WTP:
When I first worked there 25 years ago it was a .6 . That's what we were told.
That's what I was told .... [l]f you went outside and took it and did graph
samples on any other five basins you would have had a .6 somewhere out
there, between .6 and a .10. That's where the plant operated at its best is in
those ranges. (Transcript, pp. 10-11)
Callahan also stated that Jacobs should have known that the reading practices were
improper, and taken steps to ensure his log sheets were accurate:
[l]f [Jacobs] had been an operator that he claims to have been he would have
went outside and took samples off of the other basins to see if that reading
was it. Four hours- you have a four-hour delay time before you will actually
get water that you are bringing in for applied water on top of the filters.
(Transcript, pp. 12-13)
5
Later in the proceeding, when confronted with Jacobs' log books, Callahan admitted
that the Altavista WTP had provided false information to the ODW, but refused to take
responsibility for it:
MR. KAST: Mr. Callahan , can I direct your attention to the list of readings
with a sample date of January 23, 2014 towards the bottom of the page. You
can see that there are recorded results from 3 p.m. to 10 p.m. on that day.
And we have a column that's listed, False resu lt recorded on log sheet,
which has .6 for all of the readings for this day. And then we have, True
result recorded in notebook. And you can see that the readings starting at 3
p.m. going all the way through until10 p.m. is significantly less than .6.
You've said repeatedly during th is conference that the information that was
being provided by Filter 5 was not really an issue because it would have
normalized within four hours. This is an example that we have in the file that
indicates that for more than four hours the true result from Filter 5 is not
within the range that was reported to VDH. Can you explain why this
wouldn't be an issue, why this would be okay?
MR. CALLAHAN : No, I cannot. But I can also state that if it wasn't it was
because the operator wasn't feeding enough bleach in the raw water.
MR. KAST: But if it is accurate that the readings on the far column were the
readings that were actually coming through the filter, and the readings that
were reported to VDH were the readings on the column to the left, that
would be false information ; correct?
MR. CALLAHAN: Well, if he took it off of No. 5 Filter only, yes. (Transcript,
pp. 17-19)
As one of the upper management of the Altavista WTP, Callahan was responsible for
the work practices of the operators taking readings. Further, there is no indication that
any operator took addition steps to confirm a read ing of between .6 and 1.0 for App lied
Chlorine when the reading from Filter 5 was out of range .
Callahan's participation in the Altavista WTP practices of providing inaccurate

information to the ODW in connection with monthly reporting requ irements under the
VDH regulations, which was itself a violation of Board Regulation 18 VAC 160-20-140.3,
is a violation of Board Regulation 18 VAC 160-20-140.4.
It appears that Callahan was part of a management scheme that resulted in false log
sheets and false reports to the ODW. When confronted about the reporting on log
sheets during his tenure, Callahan was unable or unwilling to see that log sheets which
were not based on actual readings were inherently unreliable as indicators of plant
operation, and that those inaccurate reports redounded in the data provided on the
monthly reports to the ODW.
6
Moreover, Callahan recognized that the reporting practices he allowed to persist could
easily have given rise to fraudulent reports, as operators had no Incentive to submit log
sheets based on readings they had actually conducted:
MR. SCHRODER: If I know as one of your operators that I have to fill out this
piece of paper and for this specific reading ifs got to be a .6 to 1.0 because
nothing else would be acceptable, it would be erased and changed if I put
something below a .6 or above a 1.0 why would I even bother to take the
reading? Why would I just not sit in the office and then write in .6 without
taking the reading?
MR. CALLAHAN: I'm assuming that they could have done that if they wanted
to. I would hope they wouldn't. (Transcript, p. 25)
Callahan supervised a working environment that required flagrant, extensive, and

egregious violations of the basic duties of a waterworks operator over a period of many
years. Additionally, Callahan continues to believe, despite strong evidence to the
y, thatn~1h'irrgwrong-trne-quirtngwaterwort<s operatorsio--provittec - - - - - - - -
- - - - -=co=n,....tr""'a""'r"T"""'
inaccurate log sheets.
Therefore, I recommend a monetary penalty of $1 ,500.00 and license revocation be

imposed.
Count 2: Board Regulation
After Callahan resigned from the Altavista WTP, numerous issues were discovered
relating to the maintenance of the plant, including:
As of November 14, 2014, at the pump station for the Staunton River, the primary
water source for the Altavista WTP, both surface water pumps were inoperable, a
replacement pump which had been acquired had not been installed, and the
primary intake inlet was clogged with silt;
As of November 14, 2014, at the pump station for Reed Creek, a secondary water
source for the Altavista WTP, the check dam was obstructed by sediment, requiring
the installation of an emergency pump system;
As of December 10, 2014, the mixers for the solids holding tank were inoperable,
with the result that four feet of sediment had accumulated in the holding tank,
which, according to a proposal from W.E.L. Incorporated to Altavista, would require
between 100 and 120 hours of labor, at a cost of between $67,900.00 and
$81,480.00, to remove; 3
As of December 10, 2014, six of the 10 flocculation mixers at the Altavista WTP
were inoperable, including both mixers in one of the basins;
As of July 1, 2015, all flocculation mixers were inoperable, all sluice gates for the
flocculation basins were wedged in place, rather than properly installed, and
numerous valves and chemical feed facilities were in need of repair or upgrade;
and
3 Ultimately, as a cost-savings measure, the sediment was removed by the Public Wor1<:s Department for
Altavista.
7
As of July 22, 2015, the poor repair practices contributed to the damage suffered
when a transient water surge, or "water hammer," caused extensive damage to the
Altavista wrP, in part due to failure of a surge relief valve during the water hammer
event.
Additionally, according to Brown, operators at the Altavista WTP did not have access to
the tool room, as it was kept locked by Cofflin and Callahan.
During the IFF, Callahan disputed that the tool room was locked: "I noticed that
somebody stated that the tool room was locked, and they couldn't get the parts. Well,
that's a bunch of bull. The tool room was open." (Transcript, p. 33)
Regarding the maintenance generally, Callahan stated that the Altavista WTP was well-
maintained, but that big maintenance projects could only be done when water demands
in Altavista were low:
We did most of our maintenance when our hardest water user was down for
the1r ma1ntenance. Arid~tmrforz~~. Oofng-'tttrn:same----
way. Otherwise, we did maintenance on a daily basis on things that we could
do that we wouldn't shut down and disrupt water usage .. .. We averaged 19 to
22 hours a day run time. You don't have a whole lot of time to do
maintenance. (Transcript, pp. 34, 35)
Regarding the Staunton River issues, Callahan claimed that the pumps were scheduled
to be replaced in November, but that the process was more involved because the pump
design had changed between the new and old version. Additionally, Callahan claimed
that the river intake was not in use because of lower flow of the river, and the intake
would have "eventually" (Transcript, p. 37) been cleaned out. However, Callahan
admitted that the intake could have been cleaned out while the Altavista WTP was in
operation.
Regarding the Reed Creek issues, Callahan stated that the intake was scheduled to be
cleaned in 2015 and was on a four year cleaning schedule. Callahan provided evidence
of this cleaning schedule at the IFF. (Callahan Exh. 1, p. 4) It appears that between
November 8, 2014, when the Reed Creek intake was photographed by Brown, and
March 23, 2016, when it was photographed by Investigator Hansen, the scheduled
cleaning occurred.
Regarding the solids holding tank, Callahan did not appear to understand why the four
feet of sediment in the bottom of the tank was a problem: "I don't really know what the
problem would be with having 4 foot of solids in a solids tank because that's what it's
designed to do, to hold solids." (Transcipt, p. 43) Additionally, it does not appear that
Callahan understood the purpose of the mixers in the tank, or had any involvement in
maintenance of the tank:
8
MR. KAST: So if somebody had come up to you while you were working at the
Altavista [WTP] and asked you what the condition of the solids holding tank
was you would have had to say you didn't know?
MR. CALLAHAN: True.
Further, Callahan offered in defense that he had intended to do rudimentary

assessment of the tank during a future maintenance period: however, it is unclear why,
if Callahan had not been asked to retired from his position, he would have found time to
assess the solids holding tank after not assessing it for decades.
Regarding the water hammer incident, Callahan admitted that the surge relief valve
should have reduced the scope of the damage if it had been operational, but denied
knowledge that there were any issues with the valve during his tenure:
MR. KAST: If the surge relief valve had been completely operational do you
think that the result of the mistake would have been different?
-------- .. -------- ---------- ------- ----------- ---- --------------- --- - -----------
MR. CALLAHAN: Definitely.
MR. KAST: Definitely?
MR. CALLAHAN: Yeah. But I'm sure -- as far as I know the relief valve was
operational.
MR. KAST: And was that based on an inspection that you had done or-
MR. CALLAHAN: It had not been long. It had not been probably four or five
years that we had replaced the old one and had installed a new one. So I'm
assuming that it was operational. It was set at a certain pressure to relieve.
And I'm sure that- as far as I know it was operational. (Transcript, pp. 53-54)
Callahan also claimed that maintenance at the plant was good based on its history prior
to his retirement: "But like I said, we never had a mechanical failure of any kind to shut
the plant down in the 25 years I was there." (Transcript, p. 58) However, I believe this
statement misses the point: it appears that the Altavista WTP, over the course of
Callahan's career, had numerous deficiencies that were insufficiently addressed in the
years following his retirement. To the extent that Callahan's management practices
caused precedent conditions that subsequent management failed to redress, Callahan
bears a share of culpability for what happened next.
Callahan's apparent pattern of negligent plant maintenance is a violation of 18 VAC

160-20-140.7.
I note in particular that Callahan did not appear to understand the purpose of mixers in
the solids holding tank and did not understand the importance of routine assessment
and maintenance of the mixers. As a result of his negligence in this area, Callahan cost
Altavista labor that a third party would have billed up to $82,000.00 to complete.
9
Additionally, Callahan did not appear to recognize that maintenance of the surge relief
valve should have been a regular occurrence as well. Rather than making maintenance
of the surge relief valve a component of the major maintenance the plant was able to
conduct on a yearly basis, it appears that Callahan felt it was appropriate to let the
surge relief valve remain untested, and assume that the time frame since its
replacement was a proper basis for its reliability.
Due, in part, to Callahan's improper maintenance practices here, the water hammer
event caused massive damage to the plant which required extensive and costly repairs .
Altavista also was forced to buy water from a nearby locality for an extended period, at
substantial cost, as the plant was out of operation in the ensuing days.
In short, Callahan's management of plant maintenance gave rise to egregious,

expensive, and disastrous plant conditions after his forced retirement. Therefore, I
recommend a monetary penalty of $1,000.00 and license revocation be imposed.
By: ~rry~- ~-D~te:-~oli------------

Presiding Board Member
BOARD FOR WATERWORKS AND WASTEWATER WORKS OPERATORS

10
VIRGINIA DEPARTMENT OF PROFESSIONAL
AND OCCUPATIONAL REGULATION
9960 MAYLAND DRIVE, SUITE 400
RICHMOND, VA 23233
REPORT OF FINDINGS
BOARD: Board for Waterworks and Wastewater Works Operators

and Onsite Sewage System Professionals
DATE: April20, 2016 (Revised July 6, 2016 -AST; October 7,
2016 -ADJ)
FILE NUMBER: 2016-01793

RESPONDENT: Edward M. Callahan Jr.
LICENSE NUMBER: 1955003670
- - EXPIRATION: - - - February 28,-2017 -- ------
SUBMITTED BY: Kevin Hansen

APPROVED BY: Ann Tackett
COMMENTS:
Companion to files 2016-00456, 2016-00725, 2016-01790, and 2016-01791.
****'*****
Edward M. Callahan Jr. ("Callahan") was at all times material to this matter subject to the
Board's regulation as an applicant for licensure and/or a licensed Waterworks Operator in
Virginia (No. 1955003670).
Based on the analysis and/or investigation of this matter, there is probable cause to
believe the respondent has committed the following violation(s) of the Code of Virginia
and/or Board's regulation(s):
BACKGROUND:
On August 20, 2015, the Department of Professional and Occupational Regulation (''the
Department") received a written complaint from David Garrett ("Garrett"), Director of
Public Works for the Town of Altavista, Virginia regarding Pauline Brown ("Brown"). 4 In
a supplemental letter received with the complaint, Garrett made the additional
allegations:
Chester "Chuck Franklin Cofflin ("Cofflin"), Plant Manager of the Altavista Water
Treatment Plant ("Altavista WTP"), and Callahan, Plant Superintendent of the
Altavista WTP, established a range of "acceptable" test results for each water
4 Garrett's complaint against Brown was docketed as File Number 2016-00456.

11
quality test performed by the following waterworks operators:
o Brown;
o John Russell Jacobs ("Jacobs");
o Gary Anthony David; and
o Marvin Samuel Jones Jr.
Cofflin and Callahan instructed the operators and trainees to record test results
within the established ranges, regardless of the actual results.
Cofflin and Callahan erased actual test results and replaced them with another
result that was within their "established" range.
Cofflin and Callahan "were negligent in their duties to ensure that preventive
maintenance was performed at the Town's raw water intakes and at the water
plant". (Exh. C-1b)
On September 17, 2015, the Department received a written complaint from Misty
Johnson ("Johnson"), Superintendent of the Altavista WTP, regarding Brumfield.
Johnson was employed by the Town of Altavista as the Superintendent of the Altavista
WTP.s (Exhs. C-1c and 1-16)
On January 25, 2016, during a review of the documents in File Number 2016-00456 and
File Number 2016-00725, it was discovered that Callahan may have violated the the
Board' s regulations . A request was made to docket a new file regarding Callahan.
(Exh. C-1a)
The Altavista WTP operates under Virginia Department of Health, Office of Drinking
Water ("ODW") Operations Permit number 5031050. (Exh. W-3a)
On November 13, 1987, Callahan was issued a Waterworks Operator license.

Callahan's current license rank (No. 1955003670) is Class 1. Callahan was employed
at the Altavista WTP from 1989 to November 17, 2014 (Exhs. 1-1 and 1-14)
On November 15, 1980, Cofflin was issued a Waterworks Operator license. Cofflin's
current license rank (No. 1955003895) is Class 1. On November 17, 2014, Cofflin
retired from Altavista WTP. (Exhs. C-1b-1 and 1-2)
On August 31 , 2009, Brown was issued a Waterworks Operator license. Brown's

current license rank (No. 1955006393) is Class 2. Brown has been employed at
Altavista WTP since 2008. (Exhs. 1-3 and 1-14)
On July 1, 2009, Jacobs was issued a Waterworks Operator license (No. 1955006359).
Jacobs' current license rank is Class 2. Jacobs was employed at the Altavista WTP
from 2007 to around November 2015. (Exhs. 1-4 and 1-13)
On August 25, 2014, Christopher Brumfield ("Brumfield") was employed by the Town of
Altavista as an operator-in-training for the Altavista WTP. Brown was assigned to train
s Johnson's complaint against Brumfield was docketed as File Number 2016-00725.

12
Brumfield on the operational, water sampling, water monitoring, and reporting tasks
performed by operating staff of the Altavista WTP. (Exh. C-1b, 1-14, and 1-17)
On May 23, 2015, Brumfield was issued a Waterworks operator license. Brumfield's
current license rank (No. 1955007070) is Class 3. (Exh. 1-5)
*********
1. Board Regulation
18 VAC 160-20-140. Discipline.
The board has the power to discipline and fine any licensee, interim licensee, or
provisional licensee and to suspend or revoke or refuse to renew or reinstate any
license, interim license, or provisional license as well as the power to deny any
application for a license, interim license, or provisional license under the
provisions of Chapter 23 ( 54.1-2300 et seq.) of Title 54.1 of the Code of
Virginia and this chapter for any of the following:
4. Violating or inducing another person to violate any provisions of

Chapter 1, 2, 3 or 23 of Title 54.1 of the Code of Virginia , the
provisions of any other relevant Virginia or federal regulation, or of
any provision of this chapter;
Historical Notes
Derived from Virginia Register Volume 17, Issue 9, eff. February 15, 2001; amended, Virginia Register
Volume 23, Issue 1, eff. December 1, 2006; Volume 25, Issue 19, eff. July 1, 2009.
Print Date: July 1, 2009
FACTS:
Board Regulation 18 VAC 160-20-140 specifies, in part:
license, interim license, or provisional license a.s well as the power to deny any
provisions of Chapter 23 ( 54.1-2300 et seq.) of Trtle 54.1 of the Code of
3. Not demonstrating reasonable care, judgment, or application of the

required knowledge, skill and ability in the performance of the licensee's or
interim licensee's duties;
In accordance with Waterworks Regulations 12 VAC 5-590-370, the Altavista WTP is

required to perform sampling to determine the following, in part:
Turbidity measurements.
13
Disinfectant residuals ("chlorine residual") of applied water and finished water.6
During the operation of the Altavista WTP, waterworks operators recorded the following
hourly sampling results on a document titled "NTU, Ph, and CL2 Hourly Checks" ("Log
Sheet"):
Raw water NTU. 7
Raw water Ph.
Applied water NTU.
Applied water Ph.
Applied water chlorine residual levels.
Finished water NTU.
Finished water Ph.
Finished water chlorine residual levels. (Exh. 1-15)
Subsequently, the following daily information was determined or calculated for each of
the above hourly sampling results and recorded at the bottom of each Log Sheet by
Callahan:
Daily averages.
Maximum sampling result recorded that day.
Minimum sampling result recorded that day. (Exh. 1-15)
The above daily information was then recorded by date on an ODW Report of
Operations by Cofflin. At the end of each month, the following monthly information was
determined or calculated for the above daily sampling results and reported by Cofflin to
the ODW in a Report of Operations in accordance with Waterworks Regulation 12 VAC
5-590-530:
Maximum daily sampling result recorded during the month.
Minimum daily sampling result recorded during the month.
Monthly averages of daily averages recorded during the month. (Exh. 1-15)
Each month between January 2014 and September 2014, Cofflin completed and signed
a Report of Operation and submitted them to the ODW. On each Report of Operation,
Cofflin reported that the minimum applied chlorine residual obtained by operating staff
of the Altavista WTP was .6 on 256 of the 273 listed readings. (Exh. C-1 b-11)
On October 7, 2014, Brumfield informed Garrett that "operators were willfully falsifying
records". Brumfield told Garrett that Cofflin and Callahan had established "preferred
s Waterworks Regulation 12 VAC 5-590-10 defines the following:

"Disinfectant" means any oxidant (including chlorine) that is added to water in any part of the
treatment or distribution process for the purpose of killing or deactivating pathogenic organisms.
"Applied water" means water that is ready for filtration.
"Finished water" means water that is introduced into the distribution system of a waterworks and
is intended for distribution and consumption without further treatment, except as treatment
necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition
of corrosion control chemicals). (Exh. 1-24)
7 Turbidity is abbreviated as "NTU". "NTU" stands for Nephelometric Turbidity Unit

14
ranges" for certain tests performed by waterworks operators on applied water and
finished water. Brumfield reported that if the test results were found to be outside of the
"preferred ranges", waterworks operators would record a reading within the range
established by the plant management instead of the actual reading. (Exh. C-1 b)
Between October 7, 2014 and November 17, 2014, Waverly Coggsdale ("Coggsdale"),
Town Manager for the Town of Altavista, and Garrett conducted an investigation into
Brumfield's allegations. Following an investigation by Coggsdale and Garrett, Cofflin
and Callahan retired from the Altavista WTP. (Exhs. C-1 b-1 and 1-11)
Jacobs
During the investigation conducted by Coggsdale and Garrett, Garrett received twenty-
one steno notebooks from Jacobs in which Jacobs recorded results of water quality
tests that he performed while working at the Altavista WTP. Garrett told Investigator
Kevin Hansen ("Investigator Hansen") that a comparison of the recordings in the
notebooks with the recordings on the Log Sheets showed inaccuracies. Garrett stated
that for any false test results provided by Jacobs on the Log Sheet, Jacobs
contemporaneously recorded the actual test results in the notebooks using red or blue
pencil. (Exh. 1-6, 1-7, and 1-1 1)
During a review of Jacobs' notebooks, Investigator Hansen made the following

observations:
The notes were dated between July 15, 2009 and October 16, 2014. 8
Each notebook contained handwritten sampling results similar to the type recorded
on the Log Sheets.
Most of the sampling results were recorded in gray pencil; however, some sampling
results were found to be recorded in blue or red pencil.
Jacobs periodically recorded personal observations of activities that occurred at the
Altavista WTP. (Exh. 1-7)
On December 29, 2013, Jacobs recorded the following , in part, in a notebook dated
between December 27, 2013 and February 6, 2014:
At 8:00a.m., the applied chlorine residual was .5. The applied chlorine residual
was recorded with blue pencil.
At 9:00a.m ., the applied turbidity (recorded in the notebooks as Apl NTU) was 1.2.
(Exh. C-1b-2)
The Log Sheet dated December 29, 2013, includes the following, in part:
The 8:00 a.m. applied chlorine residual was recorded as .6.
The 9:00a.m. applied turbidity (recorded as Applied NTU) was recorded as .9.
The minimum applied chlorine residual recorded on that date was .6.
The maximum applied turbidity recorded on that date was .9. (Exh. C-1b-4)
On January 2 , 2014, Jacobs made the following entry in the notebook:
8 The notebooks were found to exclude intermittent periods of time w ithin the date range provided.
15
"Came in at 2:30pm and [Callahan] called me [Jacobs] into his office and jumped
on me about a Applied Turbidity reading on 12-29-13 at 9:00am and blessed me
out and everything else I did and the way I do it and when I told him that I do
things the way the book calls for he told me that if I don't start doing things the
way he wants them done that I would suffer for it. When I asked even if that
meant [lying] on the paperwork by that time Gary David had come in and he told
the both of [us) that if it meant [lying] then lie but do not write anything he didn't
like down. What next." (Exh. C-1b-6)
The sampling results most often reported falsely on the Log Sheets were the applied
chlorine residuals. In the notebook with sampling results dated between December 27,
2013 and February 6, 2014, Jacobs falsely reported the following:
Sampling Date sampling Sampling Type False Result True Result

Time Reported on Recorded in
Loo Sheet Notebook
December 29, 2013 8:00a.m. Applied Chlorine .6 .5
Januarv 5, 2014 8:00a.m. APPlied Chlorine .6 .. .4
9:00a.m. AoPiied Chlorine .6 .5
January 9, 2014 4 :00p.m. Applied Chlorine .6 .5
6:00 o.m. Aoolied Chlorine .6 .4
January 10 2014 10:00 p.m. Applied Chlorine .6 .4
11:00 p.m. APPlied Chlorine .6 .4
January 14. 2014 3:00p.m. Aoolied Chlorine .6 .5
8:00p.m . Applied Chlorine .6 .5
4 :00p.m . Applied Chlorine .6 .5
6:00P.m. APPlied Chlorine .6 .5
4 :00p.m. Applied Chlorine .6 .5
January 23, 2014 3:00p.m . Applied Chlorine .6 .2
4:00 o.m . APPlied Chlorine .6 .2
10:00 p.m. Applied Chlorine .6 .4
January 26 2014 8:00a.m. Applied Chlorine .6 .5
8:00 o.m. APPlied Chlorine .6 .4
January 30 2014 8:00p.m . Applied Chlorine .6 .5
16
11:00 p.m. Ap_plied Chlorine .6 .5
February 5 2014 7:00p.m. Applied Chlorine 1 1.1
(Exhs. C-1b-3 and C-1b-5)
On October 7, 2015, during an interview with Investigator Hansen, Jacobs admitted that
he had falsely recorded water quality test results on the Log Sheets. Jacobs stated the
following:
Callahan and Cofflin had told Jacobs "not to write below .6 for the applied test or
above 1.0."
Jacobs did not like recording a false test result because he "was lying."
Jacobs "didn't want to make Cofflin and Callahan mad"; so, on occasion, Jacobs
recorded false test results on the Log Sheets.
Jacobs maintained records of the actual test results in notebooks. (Exh. 1-13)
Concerning the notebook entry dated "9/10/13", Jacobs stated the following:
Jacobs used colored pencils to record actual test results that were "out of limits".
"Redn markings indicated actual test results that were "too high".
"Blue" markings indicated actual test results that were "too low".
On September 10, 2013, Jacobs recorded an applied chlorine test result taken at
3:00 a.m. as ".5".
The record in blue indicated that the actual test result was below the preferred
range of .6 to 1.0.
On the same date, Jacobs recorded an applied chlorine test result taken at 4:00
a.m . as ".5"
The 4:00 a.m. test result was also recorded in blue indicating that the test result
was too low. (Exhs. C-1b-7, 1-8, and 1-13)
Upon review of the Log Sheet for September 10, 2013, Jacobs stated the following:
The applied chlorine test result for 3:00a.m. indicated ".6".
The applied chlorine test result for 4:00a.m. indicated ".6".
"I admit that I wrote .6" on the daily record.
Some of the information for the applied chlorine on the Log Sheet is "false". (Exhs.
C-1b-8 and 1-13)
Brown
On October 10, 2014, in his personal notes, Brumfield recorded the following applied
chlorine residuals obtained while working with Brown:
.49 at 8:00a.m .;
.52 at 9:00a.m.;
1.17 at3:00 p .m.; and
17
1.46 at4:00 p.m.9 (Exh. W-1a)
On October 10, 2014, rather than record the actual applied chlorine residuals noted by
Brumfield, Brown recorded the following false applied chlorine residuals on a Log Sheet:
.6 at 8:00 a.m.
.6 at 9:00 a.m.
1.0 at 3:00 p.m.
1.0 at 4:00p.m. (Exhs. C-1b-9 and 1-12)
On October 10, 2014, at approximately 4 :00 p.m., Brumfield observed that the Hach CL-
17 chlorine analyzer ("Hach CL-17") displayed the finished chlorine residual as 2.1 6.
Brumfield observed Brown record the 4:00 p.m. finished chlorine residual as "2.0" on the
Log Sheet dated October 10, 2014. Brumfield photographed the Log Sheet and display
of the Hach CL-17. (Exhs. C-1b-9, 1-12, W-1b~ and W-1c)
On or about October 10, 2014, using the information recorded on the Log Sheet,
Callahan determined the following , in part:
The average for the applied chlorine residuals recorded for the day was .9.
The minimum recorded applied chlorine residual was .6.
The maximum recorded applied chlorine residual was 1.0.
The maximum recorded finished chlorine residual was 2.0.
The above data was recorded at the bottom of the Log Sheet. (Exhs. C-1 b-9 and 1-15)
On October 27, 2015, during an interview with Investigator Hansen, Brown stated the
following, in part:
Coffiin and Callahan told waterworks operators not to record an applied chlorine
residual below .6.
If an applied chlorine residual less than .6 were recorded , it would have been
erased and changed by Coftlin or Callahan.
Callahan directed her to write down false applied chlorine residuals if the actual
chlorine residuals were found to be not within the preferred range of .6 to 1.0.
Callahan used the data recorded on the NTU, Ph, and CL2 Hourly Check sheets to
obtain daily averages as well as determining the minimum and maximum levels.
The daily chlorine residual averages, maximum chlorine residual levels, and
minimum chlorine residual levels were reported to the ODW. (Exh. 1-14)
On November 9, 2015, during an interview with Investigator Hansen, Callahan stated

the following, in part:
Coffiin and Callahan wanted the applied chlorine residuals to be between .6 and
1.0.
The preferred range for the finished chlorine residuals was 1.5 to 2.0.
Coftlin and Callahan would tell the waterworks operators to write .6 for the applied
chlorine residuals; however, Callahan did not know where that number came from.
Callahan believed the ODW required the minimum applied chlorine residual to be
e The data recorded represents mg/L or parts per million.

18
.6.
Waterworks operators always wrote .6 for the applied chlorine residual, even if the
test results were lower.
The water sample collected from filter 5 would be "a worst case" for the applied
water.
If the water sample collected at filter 5 resulted in an applied chlorine residual tess
than .6, the water at filters 1, 2, 3, and, 4 more than likely would be above .6 if
tested. (Exh. 1-15)
Callahan induced operating staff of the Altavista WTP to fail to demonstrate reasonable
care and judgment by falsely recording water sampling results on records maintained by
the Altavista WTP and of which were reported to the ODW.
2. Board Regulation
18 VAC 160-20-140. Discipline.
license, interim license, or provisional license as well as the power to deny any
provisions of Chapter 23 ( 54.1-2300 et seq.) of Title 54.1 of the Code of
7. Negligence, or a continued pattern of incompetence, in the practice

of a licensee or interim licensee; or
Historical Notes
Derived from Virginia Register Volume 17, Issue 9, eff. February 15, 2001; amended, Virginia Register
Volume 23, Issue 1, eff. December 1, 2006; Volume 25, Issue 19, eff. July 1, 2009.
Print Date: July 1, 2009
FACTS:
Staunton River Water Pumps
Waterworks Regulation 12 VAC 5-590-1040.1 specifies that the Altavista WTP shall have
at its pump station "at least two pumping units" which shall, in part:
1. Have ample capacity to supply the peak demand without overloading; and,
2. Have maintenance parts and tools readily available.
The Altavista WTP obtains raw water from the Staunton River, its primary surface water
source. (Exhs. C-1b and 1-14)
On November 14, 2014, the Altavista WfP experienced a failure of the surface water
pumps used to pump water from the Staunton River. As a result of the disruption in the
production of finished water by the Altavista WTP, the Campbell County Utilities and
Service Authority ("Campbell County") temporarily supplied water to the Town of Altavista.
Following the disruption, Garrett determined the following:
19
Both surface water pumps were found to be inoperable.
One of the pumps had been inoperable for approximately one year.
A replacement pump for the inoperable pump had been acquired by Cofflin and/or
Callahan; however, it was never installed.
The primary intake inlet on the Staunton River was found to be clogged with silt.
Only the low water level intake structure in the middle of the Staunton River was
functional. (Exhs. C-1 b and 1-22)
Reed Creek Water Source

In the event the Altavista WTP cannot pump raw water from the Staunton River, raw water
can be pumped from Reed Creek, a secondary surface water source. (Exhs. C-1b and 1-
14)
On November 14, 2014, upon request from Garrett, Thomas Fore ("Fore"), Superintendent
of the Town of Amherst Water Treatment Plant, responded to the Altavista WTP to provide
assistance with the failure of the surface water pumps used to pump water from the

Staunton River.1 Fore suggested that the Altavista WTP pump surface water from Reed
Creek; however, Fore was told that the Altavista wrP experienced trouble when attempts
were made to pump water from Reed Creek. Subsequently, Fore determined that the
check dam was obstructed by sediment. Fore then assisted with the installation of an
emergency pump system for the Altavista WTP. (Exh. 1-21)
On December 8, 2014, Brown photographed the Reed Creek inlet which had become
obstructed by silt. (Exh. W-2)
On March 23, 2016, Investigator Hansen photographed the Reed Creek inlet after the silt
had been removed by the Town of Altavista Department of Public Works. (Exh. 1-9)
Solids Holding Tank

The Altavista WTP utilizes a holding tank into which backwash water is deposited and held
until being further processed by the Town of Altavista Wastewater Treatment Plant. The
holding tank is equipped with two motorized mixers which circulate the backwash water to
prevent the settling of sediment. (Exhs. C-1 b and 1-23)
Following the trouble with the surface water pumps, Garrett and Fore determined that the
mixers in the solids holding tank were not operating. An inspection revealed that the
motors for the mixers were inoperable. Due to the mixers being inoperable for a
prolonged period, sediment accumulated at a depth of four feet in the holding tank. (Exhs.
C-1b, 1-10, and 1-21)
On or about December 10, 2014, W.E.L. Incorporated provided the Town of Altavista with
a proposal to remove the sediment from the holding tank. The proposal specified a cost of
1o Fore is a licensed Waterworks Operator Class 1.
20
$6,790.00 per 10 hour day and estimated that the project duration would be 10 to 12
days. 11 (Exh. C-1 b-1 0)
According to Brown, one of the holding tank mixers had been inoperable since sometime
in the year 2008 and the other stopped working sometime in the year 2011. (Exh. 1-23)
Flocculation Mixers
In addition to the above, Fore also observed that half of the mixers in the mixing chambers
where the flocculation process occurs were not operational. Fore stated that the
flocculation process is "an integral part of the water purification process". (Exh. 1-21)
Regarding the flocculation mixers, Brown stated the following:

The Altavista WTP is equipped with ten flocculation mixers; two per basin.
At one time, four of the ten flocculation mixers were inoperable.
Both flocculation mixers for basin number one were inoperable.
Basin two and three each had one inoperable flocculation mixer.
Cofflin and Callahan were aware that the flocculation mixers were inoperable.
Cofflin and Callahan had included the repair of the flocculation mixers on a list of
repairs to complete during a scheduled shutdown of Abbot Laboratories in October
2014. (Exh. 1-23)
ODW Inspection
On July 1, 2015, Bernard Proctor ("Proctor"), P .E., District Engineer for the ODW,
performed an inspection of the Altavista WTP. Proctor identified the following problems
found during an inspection performed on May 29, 2014:
"The fence around McMinnis spring was overgrown with vegetation. The
vegetation should be removed and the fence repaired."
The continuous pH units need to be calibrated.
The Melinda and Clarion finished water storage tanks need to be painted. Also, the
last professional tank survey was performed in 2008. All tanks should be inspected
inside and outside and the Town should implement any recommendations made.
(Exh. W-3b)
Proctor also identified the following conditions found during the July 1, 2015 inspection
of the Altavista WTP:
All flocculation mixers were not found to be operational.
The two sluice gates in each of the five flocculation basins were found to have been
wedged in place. None of the gates have been repaired and returned to service.
Sluice gates/operation needs to be restored .
One of the two inlet mud valves for sedimentation basin #3 needs repair.
Sedimentation basin drain valve in basin #1 needs repair.
Automatic valve in rate of flow line for filter #5 needs to be repaired.
Filter surface wash valve #5 filter is leaking. Manually operated currently.
The physical condition of chemical feed facilities needs attention. The
11 Ultimately, as a cost-savings measure, the Public Works Department for the Town of Altavista cleaned
the solids from the holding tank.
21
fluoridationlhydrofluosilicic acid feed system needs upgrade.
It is difficult to maintain uniform concentrations or feed rate of fluoride acid.
(Exh. W-3b)
Water Hammer
On July 22, 2015, at approximately 1:30 a.m., the Altavista WTP stopped producing
finished water after sustaining damage resultant of a transient water surge ("water
hammer"). The water hammer udamaged the combined discharge piping for the
finished water pumps located in the control portion of the plant's clear well" which
resulted in a loss of pressure in the distribution system. Campbell County temporarily
provided water to the Town of Altavista following the water hammer. (Exhs. C-1 c, C-1 c-1,
1-16, 1-17, 1-18, 1-19, and W-3c)
On July 31, 2015, after performing an investigation of the water hammer incident,
Christopher Tabor P.E., Senior Associate with Hazen and Sawyer, reported, in part:
"The failed tie rods were found to be in an extremely corroded condition."
"The condition of much of the ferrous metals within the clear well also exhibited
corrosion and severe tuberculation."
"Both pump headers include surge relief valves to prevent damage due to transient
surges. However, based on visual observations and lack of maintenance records, it
is unclear whether these valves were adequately operational." (Exh. C-1c-1)
Callahan and Cofflin were responsible for performing and/or the assignment of
maintenance tasks for the Altavista WTP. (Exhs. 1-11 and 1-19)
According to Brown, Cofflin and Callahan did not allow operating staff to perform
maintenance on the Altavista WTP. Brown stated the Cofflin and Callahan "kept the
maintenance tools locked up in their office". (Exh. 1-18)
Callahan, as a Waterworks Operator Class 1, was negligent in his duties and

responsibilities by failing to maintain the Altavista WTP in a condition which ensured the
continual production of finished water.
22

Callahan Final Order

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Callahan Final Order

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IN THE

BOARD FOR WATERWORKS AND WASTEWATER WORKS OPERATORS

AND ONSITE SEWAGE SYSTEM PROFESSIONALS

Re: Edward M. Callahan, Jr.

File Number 2016-01793

FINAL OPINION AND ORDER

(Effective July 1, 2009)

Count 1: 18 VAC 160-20-140.4 $ 1,500.00

The Board also imposes the following sanctions:

For violation of Counts 1 and 2, license revocation is imposed .

THE TOTAL MONETARY PENALTY ASSESSED HEREIN SHALL BE

AS PROVIDED BY RULE 2A:2 OF THE SUP REME COURT OF

IF A PETITION FOR APPEAL IS FILE D WITH THE CLERK OF THE

1. A SIGNED COPY OF THE NOTICE OF APPEAL; AND

Entered this 20th day of April , 2017 .

BOARD FOR WATERWORKS AND WASTEWATER WOR KS OPERATORS

BOARD FOR WATERWORKS AND WASTEWATERWORKS OPERATORS AND

ONSITE SEWAGE SYSTEM PROFESSIONALS

Re: Edward M. Callahan, Jr.

File Number: 2016-01793

SUMMARY OF THE INFORMAL FACT-FINDING CONFERENCE

On February 2, 2017, an Informal Fact-Finding Conference ("IFF") was convened at

Count 1: Board Regulation

Maximum sampling result recorded that day; and

On August 25, 2014, Christopher Brumfield ("Brumfield") was hired by Altavista as an

Sampling Date Sampling Sampling Type False Result True Result

On October 7, 2015, in an interview with Investigator Kevin Hansen ("Investigator

Time Type False Result True Result

On October 27, 2015, in an interview with Investigator Hansen, Pauline Brown

On November 9, 2015, in an interview with Investigator Hansen, Callahan stated, in

Callahan's participation in the Altavista WTP practices of providing inaccurate

Callahan supervised a working environment that required flagrant, extensive, and

Therefore, I recommend a monetary penalty of $1 ,500.00 and license revocation be

Count 2: Board Regulation

MR. CALLAHAN: True.

Further, Callahan offered in defense that he had intended to do rudimentary

MR. KAST: Definitely?

Callahan's apparent pattern of negligent plant maintenance is a violation of 18 VAC

In short, Callahan's management of plant maintenance gave rise to egregious,

By: ~rry~- ~-D~te:-~oli------------

BOARD FOR WATERWORKS AND WASTEWATER WORKS OPERATORS

BOARD: Board for Waterworks and Wastewater Works Operators

FILE NUMBER: 2016-01793

SUBMITTED BY: Kevin Hansen

Companion to files 2016-00456, 2016-00725, 2016-01790, and 2016-01791.

4 Garrett's complaint against Brown was docketed as File Number 2016-00456.

On November 13, 1987, Callahan was issued a Waterworks Operator license.

On August 31 , 2009, Brown was issued a Waterworks Operator license. Brown's

s Johnson's complaint against Brumfield was docketed as File Number 2016-00725.

18 VAC 160-20-140. Discipline.

4. Violating or inducing another person to violate any provisions of

Print Date: July 1, 2009

3. Not demonstrating reasonable care, judgment, or application of the

In accordance with Waterworks Regulations 12 VAC 5-590-370, the Altavista WTP is

s Waterworks Regulation 12 VAC 5-590-10 defines the following:

7 Turbidity is abbreviated as "NTU". "NTU" stands for Nephelometric Turbidity Unit

During a review of Jacobs' notebooks, Investigator Hansen made the following

On January 2 , 2014, Jacobs made the following entry in the notebook:

Sampling Date sampling Sampling Type False Result True Result

On November 9, 2015, during an interview with Investigator Hansen, Callahan stated

e The data recorded represents mg/L or parts per million.

18 VAC 160-20-140. Discipline.

7. Negligence, or a continued pattern of incompetence, in the practice

Print Date: July 1, 2009