HomeMy WebLinkAbout2019-06-28; Additional Information on the San Diego County Water Authority Twin Oaks; |Gomez, Paz | Quiram, Vicki|To the members of the:
CITY COUNCIL
Date 121 nl¥t CA ✓ cc ✓
CM ~.u(DCM {3)_u
June 28, 2019
Council Memorandum
To: Honorable Mayor Hall and Members of the City Council
From: Paz Gomez, Deputy City Manager, Public Works
{cityof
Carlsbad
Memo ID# 201907 4
Vicki Quiram, General Manager, Carlsbal:Municipal Water District
Via: Elaine Lu key, Chief Operations Officer
Re: Additional Information on the San Dieg County Water Authority Twin Oaks
Water Treatment Plant
This memorandum provides an update to the memorandum sent to the City Council on June 17,
2019, regarding a recent malfunction at the San Diego County Water Authority (Water
Authority) Twin Oaks Water Treatment Plant.
Background/Discussion
The June 17, 2019, memorandum provided an overview of the malfunction at the Twin Oaks
Water Treatment Plant, of the subsequent issuance of a Notice of Violation from the State
Water Quality Control Board Division of Drinking Water, and of the public notification
requirements related to the malfunction. The memorandum is attached for reference.
Based on initial discussions with the Water Authority, staff had informed the City Council via
the prior memorandum that public notices would be mailed to customers on or about July 1,
2019. The Water Authority has recently informed member agencies that public notices will be
delayed to July 8, 2019, or later.
Next Steps
A copy of the public notice and associated press release will be forwarded to the City Council
once these documents have been received.
Attachment: Council Memorandum dated June 17, 2019
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Amanda Guy, Deputy City Attorney
Kristina Ray, Communications Manager
Public Works Branch
Faraday Center 1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2730
. To the members of the:
,JIT'( COUNCIL
Date ~CA ✓-cc ✓
CM -JL:_ COO _ilDCM (3) ✓
June 17, 2019
Council Memorandum
To: Honorable Mayor Hall and Members of the City Council
From: Paz Gomez, Deputy City Manager, Public Works
. {cityof
Carlsbad
Memo ID# 2019014
Vicki Quiram, General Manager, Carlsbi:.~ . unicipal Water District
Via: Elaine Lu key, Chief Operations Officer
Re: Information on the San Diego County ter Authority Twin Oaks Water
Treatment Plant
This memorandum provides information on a recent malfunction at the San Diego County
Water Authority's (Water Authority) Twin Oaks Water Treatment Plant.
Background
Carlsbad Municipal Water District ("CMWD") and multiple other water districts and cities
purchase treated drinking water from the Water Authority. CMWD purchases all of its water
from the Water Authority. Before the water reaches the CMWD water distribution system, the
Water Authority treats the water at the Twin Oaks plant.
Discussion
On April 21, 2019, the Twin Oaks plant experienced a treatment malfunction that was caused
by a valve failure. For 12 hours, the ozone residuals in the plant fell be.low state-mandated
levels. Ozone is used as a disinfectant in water treatment systems and is part of the treatment
process at the Twin Oaks plant. Overall water quality was not compromised and there was no
public health concern.
The water agencies affected by the Twin Oaks plant malfunction include CMWD, Vallecitos
Water District, Valley Center Municipal Water District, Rincon del Diablo Municipal Water
District, Rainbow Municipal Water District, City of Oceanside, Vista Irrigation District, Ramona
Municipal Water District, Padre Dam Municipal Water District, Otay Water District, Helix Water
District and the City of San Diego.
The malfunction at the Twin Oaks plant resulted in a Notice of Violation ("NOV") to the Water
Authority from the State Water Resources Control Board Division of Drinking Water. Although
this malfunction did not pose a public health risk, water users are entitled to know what
happened and what measures were taken to correct the problem.
The Water Authority estimates that it will send required notifications to approximately 300,000
people (see attached map showing Carlsbad Municipal Water District and Vallecitos Water
District boundaries). Olivenhain Municipal Water District customers are not affected. The
Public Works Branch
Faraday Center 1635 Faraday Avenue I Carlsbad, CA 92008 I 760-602-2730
Honorable Mayor Hall and Members of the City Council
June 17, 2019
Page 2
notification will take place on or about July 1, 2019. The NOV is attached and can be found at
the following link:
https:ljwww.waterboards.ca.gov/drinking water/programs/documents/ddwem/dwp%20enfor
cement%20actions/San%20Diego/2019/05 14. 19C 003 3710042 41.pdf
· in addition, Health and Safety Code Section 1164S0(g) requires a secondary notification. This
law requires that large organizations notify people within their organizations. Specifically,
within 10 days of receiving the notice, schools must notify employees, students and parents;
residential rental property owners or managers (including nursing homes and care facilities)
must notify their tenants; and business property owners must notify their employees.
Due to the multiple safeguards in place within the treatment systems, the Water Authority has
· assured the City of Carlsbad that the water quality from the Twin Oaks plant is safe. Specifically,
the Water Authority has represented that it has tested the water from the Twin Oaks plant and
the tests of the water in the distribution system show that the malfunction did not impact
overall water quality, the water quality meets all state and federal standards, and there were
and are no public health concerns.
Next Steps
The Water Authority is finalizing the information that will be provided to the public. Because of
. the regulations involved, getting the final notice prepared takes a little more time than other
types of public notices. The Water Authority is coordinating with its member agency boards and
staff on the release of this information to the public and asking that it be released at the same
time the Water Authority notice is ready to distribute, currently planned no later than July 3.
On or about July 1, 2019, the Water Authority will mail notifications to all customers who
potentially received water from the Twin Oaks plant explaining that treatment requirements
were not met on April 21, 2019. All City of Carlsbad water customers served by CMWD and
Vallecitos Water District will receive notices. City of Carlsbad water customers that are served
by Oliven ha in Municipal Water District will not receive notices since they were not affected.
The Water Authority is prepared to take customer calls and has provided a specific phone
number for this purpose. The city's website will be updated to include a link to the Water
Authority's website which will contain additional information beyond that given in the
notification, including, a fact sheet and a questions and answers document.
CMWD and city customer service providers will also be prepared to handle calls that may come
into the city.
The Water Authority plans to issue a press release no later than July 3, 2019. A copy of the
notice and press release will be forwarded to City Council once these documents have been
received.
Honorable Mayor Hall and Members of the City Council
June 17, 2019
Page 3
If you get questions from residents regarding this issue after they receive the notices, please
feel free to direct them to the Water Authority's Escondido office at 760-480-1991.
Attachments:
1. Map showing Carlsbad Municipal Water District and Vallecitos Water District boundaries
2. State Water Resources Control Board letter dated June 4, 2019, to the Water Authority
3. Key Points distributed by the Water Authority
cc: Scott Chadwick, City Manager
Celia Brewer, City Attorney
Laura Rocha, Deputy City Manager, Administrative Services
Amanda Guy, Deputy City Attorney
Kristina Ray, Communications Manager
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Water Boards
State Water Resources Control Board
Division of Drinking Water
June 4, 2019
_ .system No. 3710042
Ms. Sandra Kerl, Acting General Manager
San Diego County Water Authority
610 W . 5t11 Ave.
Escondido, CA 92025
CITATION NO. 05_14_19C_003
~,
", Gt\VI.~ N,Ews0.1.1
GOVEfmOH
'
N,~ J ARED BLUMENFELD l ~ ~ SECRElARV FOR
,_,. ENVIROHt.lENTAL PROTECTION
TREATMENT TECHNIQUE VIOLATION FOR FAILURE TO MEET DISINFECTION
CONTACT TIME FOR APRIL 2019
Enclosed is Citation No. 05_14_19C_003.(hereinafter •icitation"), issued to San Diego
County Water Authority (hereinafter "SDCWA"). Please note that there are legally
enforceable deadlines associated with this Citation.
SDCWA will be billed at tlie State Water Resources Control Board's (hereinafter "State
Water Board") hourly rate for the time spent on issuing this Citation. California Health
and Safety Code (hereinafter "CHSC"), Section 116577, provides that a public water
sy$tem must rei111burse the State Water Board for actual costs incurred by the State
Water Board for specified enforcement actions including, but not limited to, preparing,
issuing and monitoring compliance with a citation.
SDCWA will receive an enforcement invoice from the State Water Board around August
2019. The invoice will contain fees for any enforcement time spent on SDCWA for the
previous fiscal year.
A public water system may file a petition with the State Water Board for reconsideration
of a citation, order or decision made under authority delegated to an officer or employee
of the State Water Board. Petitions must be received by the State Water Board within
30 calendar days of the issuance of the citation, order, or decision ..
The date of issuance is the date when the Division mails or serves a copy of the
citation, order.or decision, whichever occurs first. If the 30th day falls on a Saturday,
Sunday, or state holiday, the petition is due the following business day by 5:00 p.m.
E . J OAQUIN EsaUIVEL, CHAIR I EILEE!s SOBECK, EXECUTIVE .DIRECTOR
1350 Frohl Street, R'oom 20~0, San Diego, CA 92101 I www.walerboards.ca.gov
C.> RECYCLEO PAPf:'il
Ms. Sandra Kerl
June 4, 2019
Information regarding filing petitions may be found at:
San Diego County Water Authority
System No. 3710042
http://www. waterboards. ca.gov/drinking water/prog ra ms/petitions/index. shtml
If you have any questions regarding this matter, please contact Tuba Ertas or me at
(619) 525-4159.
Sincerely,
Sean Sterchi, P.E.
District Engineer
Enclosures: Citation No. 05_14_19C_003
· Certified Mail No. 7018 1130 0001 7617 3091
cc: Lars ·seifert, Chief, San Diego Department of Environmental Health (via e-mail)
Jim Fisher, Director of O & M (via e-mail)
Brian MacDonald, Chief Operator (via e-mail)
Ashley Dummer, District Engineer, Santa Ana Office (via e-mail)
Impacted Agencies:
Matt Vespi, Interim Pub. Utility Director, City of San Diego (via e-mail)
lsaam Hireish, Deputy Director WS Ops., City of San Diego (via e-mail)
Glenn Pruim, General Manager, Vallecitos Water District (via e-mail)·
Shawn Askine, Water System Supervisor, Vallecitos Water District (via e-mail)
Gary Arant, General Manager, Valley Center Municipal .Water District (via e-mail)
Greg Hoyle, Director of Operations, Valley Center MWD (via e-mail)
Clint Baze, Director of Oper., Rincon Del Diablo MWD (ID-A & ID-1) (via e-mail)
Tom Kennedy, General Manager, Rainbow Municipal WO (via e-mail)
Marc Walker, Water Ops. Superint., Rainbow Municipa WO (via e-mail)
Ronald Lutge, Chief Plant Operator, City of Oceanside (via e-mail)
Frank Wolinski, Operations Manager, Vista Irrigation District (via e-mail)
Eric Sanders, Utility Supervisor Water Operations, Carlsbad MWD (vici e-mail)
Troy Henry, System Supervisor, Ramona Municipal WO (via e-mail)
Paul Clarke, Director of Operations, Padre Dam MWD (via e-mail)
Mark Watton, General Manager, Otay Water District (via e-mail)
Jake Vaclavek, System Operations Manager, Otay Water District (via e-mail)
Carlos Lugo, General Manager, Helix Water District (via e-mail)
Larry Lyford, Water Treatment Plant Manager, Helix Water District (via e-mail)
Page 2 of 2
Citation No. 05-14-19C-003
2
3
4
5
STATE OF CALIFORNIA
6
STATE WATER RE.SOURCES CONTROL BOARD
DIVISION OF DRINKING WATER
7 Name of Public Water System: San Diego County Water Authority
8 Water System No: 3710042
9
10 Attention: Sandra Kerl, Acting General Manager
11 San Diego County Water Authority
12 610 W. 5th Ave.
13 Escondido, CA 92025
14
15 Issued: June 4, 2019
16
17
18 CITATION FOR NONCOMPLIANCE
19
20
21
CALIFORNIA CODE OF REGULATIONS, TITLE 22
SECTIONS 64652(a), 64654 (a), 64661 (a), Section 64463.4(a)(1 )(b)
22 TREATMENT TECHNIQUE VIOLATION
23 FOR FAILURE iO MEET DISINFECTION CONTACT TIME
24
25 The California Health and Safety Code (hereinafter "CHSC"), Section 116650
26 authorizes the State Water Resources Control Board (hereinafter "State Water
27 Board") to issue a citation to a public water system when the State Water Board
28 determines that the public water system has violated or is violating the California
29 Safe Drinking Water Act (hereinafter "California SOWA"), (CHSC, Division 104,·
30 Part 12, Chapter 4, commencing with Section 116270 ), or any regulation,
31 standard, permit, or order issued or adopted thereunder.
Page 1 of 9
Citation No. 05m14-19C~003
The State Water Board, acting by and through its Division of Drinking Water
2 (hereinafter "Division") and the Deputy Director for the Division, hereby issues .
3 · Citation No. 05_ 14_ 19C_003 (hereinafter "Citation") pursuant to Section 116650
4 of the CHSC to San Diego County Water Authority (hereinafter, "SDCWA"), for
s I violation of the California Code of Regulations (hereinafter, "CCR"), Title 22,
6 I Sections 64652(a). ·
7 A copy of the applicable statutes and regulations are included in Appendix 1,
8 which is attached hereto and incorporated by reference.
9 STATEMENT OF FACTS
10 SDCWA is a regional water wholesaler and presently provides 75 to 95 percent
11 of the water used in its service area. SDCWA purchases the substantial majority
12 of its water (both untreated and treated) from the Metropolitan Water District of
13 Southern California (MWD), delivering that water to its 24 member agencies
14 through two aqueducts comprised of a total of five north-south pipelines. This
15 network of large transmission lines currently consists of approximately 300 miles
16 . of pipeline varying in diameter from 22 to 108 inches. Treated and untreated
11 water flows by gravity from MWD's Skinner Filtration Plant into San Diego
1s County. SDCWA then delivers the water to its member agencies through 106
19 metered flow control facilities.
20 SDCWA owns one treatment plant: Twin Oaks Valley Water Treatment Plant
21 (TOVWTP) in San Marcos. TOVWTP uses submerged membrane filtration
22 followed by ozonation, biologically activated carbon and chlorination and is rated
23 at 100 MGD. The TOVWTP processes are summarized in the following table.
24 Treatment Process Summarv .
· ·· Treatment:, \ · Unit ;_ .. ·
. ... ;,
... , ··'··
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·' ..
. ·-' .
. '•. ,,. __
.. ,-..
Untreated
Water Gravity
Feed
Untreated water is gravity fed from the 96-inch Pipeline 5 to a 78-inch line that
splits into two 42-inch lines upstream of the Untreated Water Flow Control
Facility (UWFCF).
2 IP :i g e
Untreated
Water
Pump Station
Untreated
Water Flow
.control Facility
Fine Screening
Submerged
Membrane
I Filtration
I
3 j p ,I g C
Citation No. 05-14-19C-003
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The Untreated Water Pump Station (UWPS) draws untreated water from the
Twin Oaks Valley Flow Regulating Structure (TOVFRS) and discharges into a
78-inch line that splits into two 42-inch lihes upstream of the UWFCF. The
UWPS is equipped with four 17,500 gallon per minute (gpm) Weir-Floway
vertical turbine pumps operated in parallel. Each vertical turbine pump is
driven by a constant-speed motor. ·
The UWFCF meters and regulates untreated water flows {flow range of 25 -
11 O MGD) to the Fine Screening. The UWFCF consist of two equally sized
flow trains connected in parallel. Each flow train has a flow range of 25 -55
MGD and is capable of operating separately, or in parallel combination. Each
trair:i consists of an upstream isolation ball valve, an ultrasonic flowmeter,
triple offset butterfly valve for flow control, and a butterfly valve for
downstream isolation. Return flow from the Residuals-Handling Facility is
blended with the influent stream at this facility.
Untreated water passes through three rotating and self-cleaning S.P.Kinney
457-micron screens and then flows to the submerged membrane filtration
facility.
Membrane filtration is provided by a Zenon Zee Weed 1000 V3 and V4 system
(6 V3 trains and 8 V4 trains, all will be V4 upon completion of the phased V3
train membrane change outs). The V3 modules have a Vsys of 600 ft2 for an
individual cassette volume of 1,479.52 gallons and the V4 modules have a
Vsys of 550 ft2 for an individual cassette volume of 1,313.07 gallons:
Screened, untreated water enters the submerged membrane filtration (SMF)
facility and is distributed to the membrane trains through a feedwater channel
and feed piping. The feed channel provides a hydraulic break between the
UWFCF and the membrane trains. Feedwater enters the membrane tanks
through a bottom sump with a baffle plate and'rises through the tank or
permeates through the membranes. A permeate pump draws the water
through the membrane fibers under vacuum pressure and discharges the
filtered water permeate into a common 72-inch permeate header that feeds
the ozone contactor facility.
The SMF facility is comprised of 14 membrane trains (tanks) arranged in
parallel. The tanks are grouped into two banks of seven trains. Each
membrane train contains 6 cassettes housing a maximum of 96 modules, in a
12-foot wide by 17-foot long tank. The cassettes are suspended in the tanks
from stainless steel beams mechanic;ally attached to the tank walls. Each
train has a dedicated permeate pump, associated piping, and support
systems (backwash system, chemical metering systems, chemical cleaning
systems, air scour system, membrane integrity testing (MIT) system, and
instrument air system). The CIP chemicals consist of 12% sodium
hypochlorite, 50% citric acid and 40% hydrochloric acid. A vacuum pump
system (1 duty, 1 standby) operates intermittently during system operation to
keep the permeate piping free of entrained air and to prime the permeate
pumps. The SMF also houses the membrane cleaning chemicals: sodium
hypochlorite solution (12 -15%), citric acid, and hydrochloric acid.
The filtration process operates in deposition mode with a return flow from the
Residuals-Handling system.
Citation No. 05-14-19C-003
. : Tto~Tl~f: :({ •,, ,::; •... ;, . . . ,' · ... ' l)e~¢ri1?ti~n~.' .. ' '',, ', ,. ;. , -\::
, •, ··. ·.<,. ·,.:··:,·· .. , .... ,. ,. ., ... ,.. .... .., :<.•· .. ·./ ..... : ...... ,,, .,,, .,
OzonE:l
Contactor
Facility
Biologically
Active
Carbon
Contactors
Ch~mical
Mixing
Chamber
Clearwells
Treated Water
Flow Control
Facility
Residuals-
Handling
System
4IP nge
An 18,000 gallon submerged membrane backpulse tank was added to supply
the backpulse pumps (1 duty, 1 standby) from .this tanks as opposed to .the
permeate header and reduce flow variations to the ozone contactor.
The permeate pumps transfer filtered water to the ozone contact.facility.
Ozone is injected into the process flow in the front end of the ozone. contactor
using fine bubble diffusion. The water then flows through the contactors to
provide contact time for Giardia and virus inactivation. Two distinct sections
are provided within the ozone contactors. The first section, which consists of
an inlet channel and three cells.configured with over-under baffles, is used for
ozone injec:tion and inactivation contact time. The second section, which is
constructed with five cells using serpentine baffles, provides hydrogen
peroxide injection, contact time for advanced oxidation, and ozone quenching
through sodium bisulfite injection.
The ozonated water flows into the Biologically Active Carbon (BAC) contactor
and is distributed to the BAC beds. The BAC system is comprised of 10
basins arranged in parallel. The BAC beds are grouped into two banks of five
basins. Each bed has 6 feet of activated carbon media and is 24 feet wide by
32 feet long. The beds are similar in design to conventional deep granular
media filters. Each bed has a maximum hydraulic loading rate (HLR) of
approximately 10 gallons per minute per square foot (gpm/ft2) and has been
designed for a nominal empty bed contact time (EBCT) of 5 minutes. Each
bed is monitored for level, flow, headless, and runtime. These values are
used to monitor contactor oerformance and initiate backwash cvcles.
The chemical mix chamber (CMC) is located immediately downstream of the
BAC facility. The CMC is a concrete water-holding basin with two Weir-
Floway vertical turbine pumps to promote mixing and serpentine baffles to
provide detention time for chemical reactions. Chlorine and ammonia are
added at a specific ratio to form chloramines for matching the existing
residual disinfectant within Pipeline 4. Sodium hydrox[de can be added as
necessary to increase the pH of the water in order to reduce corrosivity and
help stabilize the chloramine residual. Fluoride can be added to the flow as
necessary to meet target fluoride levels. A venturi meter is installed
immediately downstream of the CMC basin to monitor treated water flow from
the treatment olant.
Following the CMC, treated water will flow into two circular prestressed
concrete clearwells. Each clearwell has a capacity of 7.5 MG. The clearwells
are hydraulically connected to operate at the same water level and are J.m-
baffied. The primary control of the water surface in the clearvyells is the flow
control valves in the Treated Water Flow Control Facility (TWFCF). The
clearwells have been modified with connections and piping to allow ·
desalinated seawater to mix with the TOVWTP treated surface water prior to
distribution to the TWFCF.
The TWFCF monitors and controls treated water from the TOVWTP
clearwells to Pipeline 4, corresponding to distribution system demand rates of
25 to 174 MGD. The TWFCF consists of one 42-inch diameter and one 54-
inch diameter train operating in parallel. Each train consists of an upstream
isolation ball valve, an ultrasonic flowmeter, a butterfly valve for flow control,
and a butterfly valve for downstream isolation. Each flow train is capable of
ooeratinq separately or in parallel. ·
The Residuals-Handling system receives waste washwater generated by the
various sources in the water treatment process, provides solids/liquid
separation, and returns the treated waste washwater back to the UWFCF.
The Residuals-Handling system consists of the following facilities:
Equalization Basins, Clarifiers, Gravity Thickeners, and Centrifuges. The
' .. ::., TteWri~nt:: .. · ··•µii1r · ... ·
Chemical
Facility A
Chemical
Facility B
Chloramine
Boost Facilities
Citation No, 05-14-19C-003
,· . ~ •. ' . · ... Descriptiom;, :·•· . '.-, . • ... ~ ~: : . ·: ' ' . .-.. • . '
I•:;· :-.•
' ,· ·-· '
. ., ' _..:-·: -,·: :: : ;_. ,.~--
polymer storage and feed systems used for the Residuals-Handling System
are housed in the dewaterinq buildinq.
Chemical Facility A receives, stores, and provides flu6tosilicic acid, aqueous
ammonia, ferric chloride, hydrogen peroxide, sodium bisulfite, and sodium
hydroxide to JOVWTP chemical injection sites.
Chemical Facility B provides the primary storage, generation, and distribution
of the 0.8-percent (as chlorine) sodium hypochlorite solution used at the .
TOVWTP,
The Chloramine Boost Facilities provide for the mixing and injection of sodium
hypochlorite and aqueous ammonia to desalinated water or to combined
Clearwell effluent for the purpbSe of boosting chloramine residual. Facilities
also include water quality monitoring. 1.========'========'=========="===========~===:dJ
2 TOVWTP is fully automated with automatic shutdowns based on a series of
3 water quality parameters identified in the Operations Plan. Operators alerted of
4 aJarm conditions can view conditions and trends, and take appropriate actions
s remotely through the plant SCADA system.
6 The Zenon ZeeWeed 1000 V4 series membranes were granted conditional log
7 removal credit (LRC) for 4-log Cryptosporidium, 4-log Giardia, and 3.5-log virus
s · removal via the Division's Alternative Filtration Technology (AFT} demonstration
9 process. The demonstration was performed with a maximum recovery of 95
10 percent, a maximum TMP of 12 psig, a maximum flux of 55 gfd, and membrane
11 . integrity demonstrated by daily pressure decay test (PDT). The TOVWTP
12 operates in deposition mode with a recovery rate goal of less than or equal to 97
n percent, a maximum instantaneous flux of 42 gfd, a maximum TMP of 13 psig,
14 and will perform daily PDT for direct integrity testing.
15 In order to gain approval to operate with a lower LRC or 3-log Giardia and
16 Cryptosporidium, GE/Zenon performed additional demonstration studies on the
17 ZeeWeed 1000 V3 & V4 membranes that verified a minimum of 3-log
18 Cryptosporidium and Giardia and minimum of 2-log virus reduction could be
19 achieved provided the level of care of the membranes resulted in a calculated
20 LRV of 3.2 log or greater. Additionally, the TOVWTP primary disinfection system
21 is operated to meet a minimum of 0.5-log Giardia and 2-log virus inactivation to
22 provide multi barrier treatment and achieve the minimum virus inactivation ·
23 requirements. Consequently, TOVWTP must be operated with a UCL of no less
S I Pa1;c
Citation No. 05-14-19C-003
than 3.2 to ensure Giardia multi-barrier and overall virus reduction requirements
2 of the surface water treatment rule are met.
3 The ozone system has been sized to provide the required ozone capacity for
4 inactivation of 0.5-log Giardia and 2-log virus at all times, as well as taste. and
5 odor control when needed for a flow rate of 100 MGD. The Ozone Contactor
6 Facility consists of two parallel trains, including two Liquid Oxygen (LOX)
7 storage tanks, two vaporizers, two ozone generators, and a 2-train contactor.
8 Each ozone generator has a maximum production capacity of 1,800 lb/day, but if
9 both generators are required to be in operation at the same time, a maximum of
10 2,400 lb/day is deliverable through the ozone piping. The two 15,000-gallon LOX
11 storage tanks and the two vaporizers are located on a pad adjacent to the ozone
12 contactor. The LOX storage is sufficient for 30 days at average daily demand.
13 CCR, Title 22 Section 64652 (a) requires that a supplier using an approved
14 surface water shall provide multibarrier treatment that meets the requirements of
15 Chapter 17 13nd reliably ensures at least, between a point where the raw water is
16 not subject to recontamination by surface water runoff and a point downstream
17 before or at the first customer:
18 ( 1) A total of 99.9 percent reduction of Giardia lamblia cysts through filtration and
19 disinfection;
20 (2) A total of 99.99 percent reduction of viruses through filtration and
21 disinfection; and
22 (3) A total of 99 percent removal of Cryptosporidium through filtration.
23 CCR, Title 22, Section 64654 (a) requires that all approved surface water utilized
24 by a supplier shall be provided with continuous disinfection treatment sufficient
25 to insure that the total treatment process provides inactivation of Giardia lamblia
26 cysts and viruses, in conjunction with the removals obtained through filtration, to
27 meet the reduction requirements specified in section 64652(a).
28 CCR, Title 22, Section 64661 (a) requires that a supplier shall operate each
29 treatment plant in accordance with an operations plan that has been approved
30 by the State Board.
611'::ige
I
Citation No. 05-1 4-19C-003
CCR, Title 22 Section 64463.4(a)(1 )(b) requires a water system to give public
2 notice pursuant to this section if any of the following occurs:
3 ( 1) Any violation of the MCL, MRDL, and t~eatment technique requirements.
4 On April 21, 2019: A second ozone contactor was placed into operation at 8.30
5 pm due to an increase in water treatment demand from 54-MGD to 68-MGD. •
6 I Prior to the flow increase, only one ozone contactor was in operation. The
7 influent valve to the second contactor failed to fully open and as a result the
8 majority of the flow was sent to only one contactor.
9
10
11
12
13
14
15
16
17
18
19
20 .
21
22
23
The incident was discovered at 12.50 pm on April 22 , 2019 and measures were
taken to correct the plant's operations .. During the incident, the total plant flow
was as high as 75 MGD, with only 8 to 10 MGD going to the second contactor,
and the lowest calculated inactivation for the first contactor was 0.17-Log Giardia
and 1.35-Log virus. The minimum inactivation requirements for the ozone
system are 0.5-log Giardia and 2-log virus.
On April 22, 2019: The Division was contacted by treatment plant staff and had a
conference call meeting with the chief operator and SDCWA. The Division
considered the membrane filtration removal credits of 3-log Giardia and 2-log
virus, and calculated CT for other segments of the treatment plant, including raw
water free chlorine disjnfection; Chemical Mix Chamber free chlorine
disinfection, and downstream total chloramine disinfection. The Division
determined that the overall minimum pathogen reduction requirements of the
Surface Water Tre.atment Rule were likely met; therefore, a Tier 1 Public
Notification was not warranted for the April 21/22, 2019 Treatment Technique
24 . · violation.
25 On April 25, 2019: The chief operator submitted an incident report (in Appendix
26 · 2) along with procedures to prevent reoccurrence of this failure to the Division.
21 On April 30, 2019: The chief operator provided additional water treatment plant
28 programming actions (hereinafter PLC upgrades) to be taken to prevent a similar ·
29 incident via email. An excerpt of that email is copied below:
71 P. u g e
Citation No. 05-14-19C-003
/. Creating and normalizing the ratio.
2 1. The target ratio will be ozone gas flow which is fed t9ward one contactor
3 divided by resid,ual ozone concentration at location C1 or C-~nd at same
4 contactor; Units are [SCFM]l[mg/L].
s 2. Maximum ozone gas flow can be 300 SCFM. To convert in %, SDCWA will
6 multiply measured value by [100/300].
1 3. Maximum ozone concentration at location C1 can be 3.0 mg/L. To convert in
8 % SDCWA will multiply measured value by [100/3].
9 4. After conversion the ratio [Ozone Gas Flow]/[Ozone Cone] in one contactor
10 will be in units of[%]/[%] or unitless.
11 //. Creating alarm
12 1. Take ratio from Contactor 1 and divide by same ratio from Contactor 2.
13 2. When both Contactors are running, if the result is in the range 0.8-1.2 mg/L,
14 SDCWA will have acceptable conditions for disinfection.
15 3. When both Contactors are running, and result is outside the range 0.8-1.2
16 mg/L, SDCWA will create alarm.
11 Ill. Corrective actions
18 1. Check position of inlet and outlet gates for both contactors.
19 2. Check position of manual isolation valves for ozone flow toward all diffuser
20 headers. Ensure equal position between both contactors.
21 3. Check last calibration date for ozone sensors at location C1 for both
22 contactors. Consider re-calibration.
23
24
Sj Pa~e
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6
7
8
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10
11
12
13
14
I 15
16
17
18
19
20
21
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Citation No. 05-14-19C-003
DETERMINATIONS
Based on the above Statement of Facts, the Division has determined thatSDCWA
is in violation of CCR, Title 22, Sections 64654 (a), 64652 (a), 64463.4 (a)(1 )(b)
and 64661.
SDCWA is in violation of CCR, Title 22 Section 64652 ( a), in that the water system
has failed to provide multi barrier treatment that meets the requirements of Chapter
17.
SDCWA is in violation of CCR, Title 22 Section 64654 (a), in that the water system
has failed to provide continuous disinfection treatment sufficient to insure that the
total treatment process provided inactivation of Giardia and viruses, in conjunction
with the removals obtained through filtration, to meet the reduction requirements
specified in section 64652(a) at the compliance points for the plant.
SDCWA is in violation of CCR, Title 22 Section 64661, in that the water system
has failed to operate the treatment plant in accordance with the operations plan
that has been approved by the State Water Board and also failed to comply with
permit provision #16 of Permit No. 05-14-15P-009, issued on October 9, 2015.
DIRECTIVES
SDCWA is hereby directed to take the following actions:
1. Within 60 days of the date of this citation, SDCWA must submit to the Division
a revised Operations Plan that includes system and operational procedure
upgrades that will ensure a similar incident as described in this citation will not
occur again. The revised Operations Plan must include the PLC upgrades for
the implementation of a CT ratio parameter proposed by the chief operator and
summarized in the Statement of Facts above.
2. Within 30 days of issuance of this Citation, SDCWA must implement the PLC
upgrades as summarized in the Statement of Facts section above.
3. Within 30 days of issuance of this Citation, SDCWA must give public
notification of the Treatment Technique violation to all customers who received
or may have received water produced by TOVWTP from April 21, 2019 at 8:30
9jP a ge
:
. '
Citation No. 05-14-19C-003
1 r, pm to April 22, 2019 at 12:50 PM in accordance with CCR, Title 22, Section I;
2 I 64463.4 and the Spanish language public notification requirements of CCR, Title
3 22 Section 64465(c)(2). Public notice must be via, as a minimum, one6f the
4 . following forms:
5 (A) Mail or direct deiivery to each customer receiving a bill, including those that
6 provide their drinking water to others (e.g., schools or school systems,
7 apartment building owners, or large private employers), and other service
8 connections fa which water is delivered by the water system; and
9 (B) Use of one or more of the following methods to reach persons not likely to be
I
10 I reached by a mailing or direct delivery (renters, university students, nursing
11 home patients, prison inmates, etc.):
12 , 1. Publication in a local newspaper;
13 I The required public notification may be done by SDCWA or a combined effort of
14 the SDCWA and effected member agencies. A public notification plan and draft
15 notification(s) must be submitted to the Division for review and approval prior to
16 conducting public notification.
17 4. In accordance with CCR, Title 22, Section 64469 (d), within 10 days of
18 1 conducting public notification, SDCWA must provide to the Division certification
19 of public notification using the enclosed form (Appendix 3).
20 5. SDCWA must complete and return to the State Water Board the "Notification
21
1
of Receipt" form (Appendix 4) within 7 days of issuance of this Citation.
22 Completion of this form confirms that SDCWA has received this Citation and
23 understands that it contains legally enforceable directive(s) with due dates.
24 6. By July 1, 2020,SDCWA and effected member agencies must report the
25 Treatment Technique violation in the SDCWA's and each effected member
,26 agencies' 2019 Consumer Confidence Report (CCR). Draft CCR's must receive
27 written Division approval prior to distribution.
28
29
IOI P age
Citation No. 05-14-19C-003
All submittals required by this Citation must be electronically submitted to the
2 Division at the following address. The subject line for all electronic submittals
3 corresponding to this Citation must include the following information: San Diego
4 County Water Authority, 92025, Citation No. 05-14-19C-003 and title of the
. 5 document being submitted.
6 Sean Sterchi
7 DDWSanDiego@Waterboards.ca.gov
8 The State Board reserves the right to make such modifications to this Citation as
9 it may deem necessary to protect public health and safety. Such modifications
10 may be issued as amendments to this Citation and must be effective upon
11 issuance.
12 Nothing in this Citation relieves SDCWA of its obligation to meet the_
13 requirements of the California SOWA (CHSC, Division 104, Part 12, Chapter 4,
14 commencing with Section 116270), or any regulation, standard, permit or order
15 issued or adopted thereunder.
16 PARTIES BOUND
11 This Citation must apply to and be binding upon SOCWA, its owners,
18 shareholders, officers, directors, agents, employees, contractors, successors,
19 and assignees.
20 SEVERABILITY
21 The requirements of this Citation are severable, and SOCWA must comply with
22 each and every provision thereof notwithstanding the effectiveness of any
23 pro,~v=is=ia=□~s _____________ _
24 FURTHER ENFORCEMENT ACTION
25 1 The California SOWA authorizes the State Water Board to: issue a citation or
26 order with assessment of administrative penalties to a public water system for
21 violation or continued violation of the requirements of the California SOWA or
28 any regulation, permit, standard, citation, or order issued or adopted thereunder
lllPugc
Citation No. 05-14-19C-003
including, but not limited to, failure to correct a violation identified in a citation or
2 compliance order. The California SOWA also authorizes the State Water Board
3 to take action to suspend or revoke a permit that has been issued to a public
4 water system if the public water system has violated applicable law or
s . regulations or has failed to comply with an order of the State Water Board, and
6 to petition the superior court to take various enforcement measures against a
7 public water system that has failed to comply with an order of the State Water
8 Board. The State Water Board does not waive any further enforcement action by
9 issuance of this Citation .
IO
. ;J Sl1 . ------, _____ :-;}--------------------------------6 J Y I 1 1 ________ _
11 Sean Sterchi, P.E. Date
12 District Engineer
.13 San Diego District
14 State Water Resources Control Board -Division of Drinking Water
15
16
17 cc: Lars Seifert, Chief, San Diego Department of Environmental Health
18 (via e-mail)
19
20 APPENDICES: ·
21 1) Applicable Statutes and Regulations
22 2) Incident Report ·
23 3) Proof of Notification
24 4) Notification of Receipt
25
26
27 CERTIFIED MAIL NO. 7018 1130 0001 7617 .3091
28
12 j pa g c
APPENDIX 1. APPLICABLE STATUTES AND-REGULATIONS FOR
CITATION NO. 05-14-19C-003
NOTE: The following language is provided for the convenience of the recipient, and cannot
·be _relied upon as the State of California's representation of the law. _The published codes
are the only official representation of the la_w. Regulations related to drinking water are in
Titles 22 and 17 of the Califo,:nia Code of Regulations. Statutes related to drinking water .
are in the Health & Safety Code, the Water-Code, and other codes.
California Health and Safety Code (CHSC):
§Sectio·n 116271 states in relevant part:
(a) The· State Water Resources Cor:itrol Board succ_eeds to and is \rested with all of the
authority, duties, ·powers, purposes, functions, responsibilities, and jurisdiction of the
s·tate Department of Public Health, its predecessors, and its director.for purposes of all of
the following: .
'(1) The Environmental Laboratory Accreditation A.ct (Article 3 (commencing with Section
100825) of Chapter 4 of Part 1 of Division 101 ). ·
. (2) Article 3 ( commencing with Section 106875) of Ch?Pter 4 of Part 1.
(3) Article 1 (commencing with Section 115825) of Chapter 5 of Part 1 o.
( 4) This chapter and the Safe Drinking Water State Revolving Fund Law of 1997 (Chapter
4.5 (commencing with-Section 116760)). .
(5) Article 2 (commencing with Section 116800), Article 3 ( commencing with Section
116825), and Article 4 ( commencing with Section 116875) of Chapter 5.
(6) Chapter 7 ( commencing with Secti_on 116975). ·
(7) The Safe Drinking Water, Water Quality and Supply, Flood Control1 River and Coastal
Protection Bond Act of 2006 (Divisio·n 43 (commencing with Section 75001) of the Public
Resources Code.).
(8) The Water Recycling Law (Chapter 7 ( commencing with Section 13500) of Division 7
of the Water Code). · · · ·
(9) Chapter 7.3 (commencing with Section 13560) of Division 7 of the Water Code.
(10) The California Safe Drinking Water Bond Law of 1976 (Chapter 10.5 (commencing
with Section 13850) of Division 7 of the Water Code).
(11) Wholesale Regipnal Water System Security and Reliability Act (Division 20.5
(commencing with Section 73500) of the Water ~ode).
(12) Water Security, Clean Drinking Water, Coastal and Beach Protection Act of 2002
(Division 26.5 (commencing with Section 79500) of _the Water Cpde).
(b) The State Water Resournes Control Board shall maintain a drinking water program
atid carry out the duties, responsibilities,· and functions described in this section. Statutory
reference to "department," "state department," or "director" regarding a functio·n
transferred to the State Water Resources Control Board shall refer to the State Water .
Resources Control Board. This section does not impair the authority of a local health
officer to enforce this chapter or a county's election not to enforce this chapter, as ·
provided in Section 116500. .
(k)(1) The State Water R~sources Control Board shall appoint a deputy director who
·reports to the executive director to oversee the issuance and enforcement of public water
· system permits and other duties· as appropriate. The deputy director shall have public
health expertise. · · · ·
I
I I . I
Citation No. os-14.19c.;003
(2) The deputy director is deiegated the State Water Resources Control Board's-authority
to provid~ notice, approve notice content, approve emergency notification plans, and take
other action pursuant to Article 5 ( commencing with Section 116450), to issue, renew,
reissue, revise, -amend, or deny any public water system permits pursuant to Article 7
( commencing with Section 116525), to suspend or revoke any public water system permit
pursuant to Article 8 ( commencing with Section ·116625), and to issue citations, assess
penalties, or issue orders pursuant to Article 9 ( commencing with Section 116650).
Decisions arid actions of the deputy director taken pursuant to Article 5 ( commencing with .
Section 116450) or Article 7 (commencing with Section 116525) are deenied decisions
and actions taken, but are not subjectto reconsideration, by the State Water Resources
· Control Board. Decisions and actions of the deputy director taken pursuant to Article 8
(com'ri1encing with Section 116625) and'Article 9 (commencing with Section 116650) are
. deemed decisions and ·actions tal<en by the State Water Resources Control Board, but
any aggrieved person may-petition the. State Water Resources Contro·1 Board for
reconsideration of the decision or action. This subdivision is not a limitation on tlie State
Water Resources Control Efoard's authority to delegate any other powers and duties.
§Section 116650 states in relevant part: .
(a) If the State Water Boar:d determines that a public w~ter system is in violation of this
chapter or any regulation, permit, standard, citation, or order issued or adopted
thereunder, the State Water Board may issue a.citation to the public water-system. The
citation shall be served upon the public water system personally or by certified mail.
Service shall be deemed effective as of the date of personal service or the date of receipt
of the certified mail. If a person to whom a citation is directed refuses to-accept delivery of
the certified mail, the date of service shall be deemed to be the date of mailing. .
(b) Each citation shall be in writing and shall describe the nature of the violation or
violations, inqluding a reference· to the statutory provision, standard, order1 citation,
permit, or regu·lation alleged to have been violated. . ·
( c) A citation may specify a date for elimination or correction of the condition constituting
the violation. · ·
· (d) A citation may include the assessment of a penalty as specified in subdivision (e).
(e) The State Water Board may assess a penalty in an amount not to exceed one .
thousand dollars ($1,000) p.er day for each day that a violation occurred, and for each day
that a viola_tion continues to occur.A separate pen·atty may be assessed for each violation
and shall be in addition to any liability or penalty imposed under any other law.
21Page
Citation No. 05-14-19C-003
§64652. Treatment Technique Requirements and Compliance Options.
· (a) A supplier using an approved surface water shall provide multibarrier treatment that
·meets the requirements of this chapter and reliably ensures at least, between a point
where the.raw water is not subject to recontamination by·surface water runoff and a point
. downstream before or at the .first customer: · . . ·
( 1) A total of 99.9 percent reduction of Giardia lamblia cysts through _filtration and
disinfection: · ·
(2) A tota1 of 99.99 percent reduction of viruses through filtration and disinfection; and
(3) A total of 99 percent removal of Cryptospor1dium through filtration.
§64654. Disinfection. · .
(a) All approved surface water utilized by a supplier shall be provided with continuous
disinfection treatment sufficient to insure . that the total treatment· process provides
inactivation of Giardia lainblia cysts and viruses, in conjunction with the removals obtained
through filtration, to meet the.reduction requirements specified in section 64652(a).
§64661. Operations Plan. . .
(a) A supplier shall operate each treatm~nt plant in ·accordance with an operations plan
that has been approved by the State Water Board. With a permit application for a n~w
· . treatment plant. or modification to an existing treatment plant, th.e suppiier shall submit for
State Water Board review the operations plan to determine if it includes those items
required in subsection (b). The State Water Board shall review the operations plan to:
determine if it includes those items required in subsection (b ). The operations plan shall
· b_e designed to produce the optimal water quality from the treatment process. The
supplier shall operate its treatment plant in accqrdance with the approved plan. .
(b) The operations plan shall consist of a description of the utility's treatment plant .
performance monitoring program, unit process equipment maintenance program, filter
. media inspection ·program, operating personnel, including numbers of staff, certification
levels and .responsibilities; how and when each unit process :i$ operated; labor~tory
·. procedures; procedures used to determine chemical dose rates; records; response to
plant and watershed emergencies; and reliability features .
.. . .
31Page
i i I
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! I
Citation No. 05-14-19~-003
§64463.4. Tier 2 Public Notice.
(a) A water system shall give public notice pursuant to thi.s section if any of the
following occurs:
(1) Any violation of the MCL, MRDL, and treatment technique requirements, except:
. (A) Where a Tier 1 public notice is required under section 64463.1: or
(B) Where the State Board determines that a Tier 1 public notice is required, based on
potential health impacts and persistence of the violations;
(b) A water system shall give the notice as soon as possible within 30 days after it learns
of a violation or occurrence specified in subsection ( a),' except that the water system may
request an extension of Lip to 60 days for providing the notice. This extension would be
subject to the State Board's written approval based on the violation or occurrence having .
been resolved and the State Board's determination that public ·healtl'J and welfare would
in no way be adversely affected. In addition, the water system shall:
(1) Maintain posted notices in place for.as long as the violation or occurrence .
,continues, but in no case less than seven days;
· (2) Repeat the notice every three months· as long as the violation or occurrence
continues. Subject to the State Board's written approval based on its determination
tha.t public health would in no way be· adversely affected, the water system may be
allowed· to notice less frequently but in no case less than once per year, No
allowance for reduced frequency of notice shaU be given in the case of a total .
coliform MCL violation or v.iolation of a Chapter 17 treatment technique
requirement; and · .
· (3) For turbidity violations pursuant to sections 64652.5(c)(2) and 64653(c), (d)
and (f); as applicable, a water system shall consult with the State· Board as soon .
as possible within 24 hours after the water system learns· of the violation to
determine Whether a Tier 1 .public notice is required. If consultation do·es not take
piace within 24 hours, the water system shall give Tier 1' public notice within 48 ·
hours after learning of the violation, ·
(c) A water system shalr deliver the notice, tn a manner designed to reach
persons served, within the required time perio<:f as follows:
(1) Unless otherwise directed by the State Board in writing based· on its
assessment of the· violat.ion or occurrence and the potential for adverse effects on
public health and welfare, community water systems shall give public notice by;
· (A) Mail or direct delivery ta. each customer receiving a bfll including those that
provide their drinking water to others (e.g., schools or school systems, apartment
building owners, or large private employers), and other service connectio·ns to
which water is delivered by the water system; and
(B) Use of one or more of the following methods to reach persons not likely to be
reached by a mailing or direct delivery (renters, university students, nursing home
patients, prison inmates, et?):
1. Publication in a local newspaper;
2. Posting in conspicuous public places served by the water system, ~r on the Internet; or
3. Del!very to community organizations;
.....
4!Page
Citation No. 05-14-19C-003
. (2)Unless othetwise directed by the State Board in _writing based on its assessment of
the violation or occurrence arid the potential for adverse effects on public health and ·
welfare, noncommunity water systems shall give the public notice by: ·
(A) Posting in conspicuous locations throughout the area served by the water system;
and ·
(B) Using one or more of the following methods to reach persons not_ likely to be reached
by a public posting:
1 .. Publication in a local newspaper or newslett_er distributed to customers;
2. E-mail message to employees or.students;
:3. Posting on the Internet or intranet; or
-4. Direct delivery to each customer. ·
§64465. Public Notice Content and·format.
(a) Each public notice given pursuant to this article, except Tier 3 public notices for
varianc.es and exemptions pursuant to subsection· (b), shall contain the following:
(1) A description of the violation or occurrence, including the contaminant(s) of con·cern,
and (as applicable) th~ contaminant level(s); ·
(2) The date(s) of the violation or occurrence;
(3) Any potential adverse health effects from the violation or occurrence, including the
appropriate standard health effects language. from appendices 64465-A through G;
· (4) The population at risk, including subpopulations particula.rly·.vulnerable. if exposed to ·
the contaminant in drinking water;
(5) Whether alternative water supplies should be -used;.
(6) What actions consumers should tal<e, including when ·they should seek medical help,
if-known· · ' (7) What the water system is doing to correct the violation or occurrence;
(8) When th.e water system expects to return to compliance or resolve the occurrence;
(9) The name, business address, and phone number of the water system owner,
. operator, or designee of the water system as a source of additional information
concerning the public notice; · · ·
( 10) A statement to encourage the public notice recipient to· distribute the public notice to
other persons served, using the following standard language: "Please share this.
information with all the other people who drink this water, especially those who .may not ·
have received this public notice directly (for example, people.in apartments, nursing ·
homes, schools, and business.es). You cari do this by posting this public notice in a public
. place or 'distributing copies by hand or mail."; and .
(11) For a vvater system with a monitoring and testing .procedure violation, this language
shall be included: "We are required to monitor your drinking water for specific
contaminants on a regular basis. Results of regular monitoring are an indicator of whether
or not your drinking water meets health standards. During [compliance period dates], we
['did not monitor or test' or 'did not complete all monitoring or testingJ for [contaminant(s)J,
and_ therefore, cannot be sure of the_ quality of your drinking water during that time." ·
(b) A Tier 3 public notice for a water .system operating under a variance or exemption
shall include the elements in this subsection. ·1f a water system has violated its variance or
exemption cond_itions, the public notice shall also include the elements in subseGtio.n (a).
· (1) An explanation of the reasons for the variance or exemption;
(2) The date on which the variance or exemption was issued;
--5 IP age
1 .,
Citation No. 05-14-19C-003
(3) A brief status report on the steps the water system is tal<ing to install treatment, find
alternative sources of water, or otherwise comply With the terms and schedules of the
variance or exemption; and · · ·
(4) A notice of any opportunity for public input in the review of the variance or exemption.
(c) A public water system providing notice pursuant to. this article shall comply with the
following multilingual-related requirements:
.. ( 1) For a Tier 1 public notice:
(A) The notice shall be provided in English, Spanish, and the language spoken by any
non-English-speaking group exceeding 1 O percent of the persons served by the public .
· water system, .and the notice shall include a telephone number or address where such
individuals may contact the public water system for assistance; and
(B) If any non-English-speaking group exceeds 1,000 persons served by the public water
· system, but does not exceed 1 0 percent served, the notice shall include information in the ·
appropriate language.(s) regarding the importance of the notice, and the telephone ·
number or address where such individuals may contact the public water -system to obtain
a translated copy of.the notice from the public water system or assistance in the
appropriate language;
(2) For a Tier 2 or Tier 3 public notice:
(A) The notice shall contain information in Spanish regarding· the importance of the notice,
or contain a telephone number or address where Spartish.:.speaking residents may ·
contact the public water system to obtain a translated copy of the notice or assistance in ·
Span~h;arid .
(B) When a non-English speaking group other than Spanish-speaking exceeds 1,000
residents or 10 percent of the residents served by the public water system, the notice
shall include: · ·
1. Information in the appropriate language( s) regarding the importance of the notice; or
2. A telephone number or address where such residents may contact the public water
system to obtain a translated copy of-the notice or assistance in t~e appropriate
language; and .
(3) For a public water system subject to the. bymally-Alaforre Bilingual Services Act.,
Chapter 17.5, Division 7, of the Government Code (commencirigwith section 7290),
meeting the requirements of this Article may not ensure compliance with.the Dymally-
Alatorre Bilingual Services Act.
(d) Each public notice given pursuant to this article shall:
· (1} Be displayed such that it catches people's attention when printed or posted -and be
formatted in such a way that the message in the public notice can be understood at the
eighth-grade level; ·
(2) Not contain technical language beyond an eighth-grade level or print smaller than 12
point;-a_nd
(3) Not contain language that minimizes or contradicts the information being given in the
publfc notice. · ·
· §64469. Reporting Requirements.
(c)Within 1.0 days of giving initial or repeat public notice pursuant to Article 18 of this
Chapter, except for notice given-under section 64463.?(d), each water system shall
submit a certification to the State Board that it has done so, along with a representative
copy of_ each. type of public notice given. · ·
"
61Page
Citation No. 05-14-19C-003
.APPENDIX2
. INCIDENT REPORT
· '71Page
April 25, 2019 ·
Mr. Sean Sterchl, P-.E
District Ehgjneer
Twin Oaks Valley Water Treatment Plant
. Tei 76(i-7[:-~. ?3::.r;
t~ea-.~55-344 -C~~4
California State Water Resources Control Board-Division Drinking Water
San Diego Oistr1ct ·
1350 Front Street, Room 2050 ·
San Diego, CA 92101
I Subject: San .Diego CountyWater Authority, PWSID# CA3710042
Twin Oaks Valley Water Treatment Plant
Incident Report-Less Than Required Ozonatlon Inactivation .
Mr. Sterchi,
This correspondence serves as a follow-up incident report for the events of April 21, 2019, during which at
approxlmalely 8:30 p.m, a second ozone contacior was placed into operation due to an increase in water
treatment demand from 54-MGD to 68-MGD. Typically, normal pr.otocol entails placing the second ozone
contactor Into service whenever the treated flow demand is > 55-MGD.
The following are the required steps included In Standard Operating Procedure (SOP) for this proce1:,s:
• Divert all treated water flow from the _clearwells to the SDCWA Raw Water Twin Oaks Valley Flow
Regulating Structure (TOVFRS) by placing all Biolo9lcally Active Carbon Contactlws (BACC's)-offline
resulting in an overflow of entire flow to TOVFRS. . .
• Open the off-line ozone _coritactor influent and effluent valves to allow flow through contactor.
• Initiate ozone ·dosing to coritactor via SC ADA by selecting the off~line contactor to transition on-line.
Onc:e this command is·lnltiated, which ever flow meter measurihg the entire plant flow has be~n
selected .(raw water Influent flow from Facllity-11 or tre.ated water flow from the C_hemical Mix Chamber) .
Is divided 50/50 to both. contactors for ozone dose via flow pacing.
• After establishing the required ozone Inactivation for Glardfa and Virus, slowly return treated water flow
to the clearwells by returning the BACC's from Off-line to On-line.
Until the event of April 21, 2019, this procedure had functioned without incldent. The circumstances surrounding
the failure on the evening o! Aprfl 21, 2019 are ldenti~led In the following bullet items: ·
• · The.on -duty operator performing this task did nof visually monitor the opening of the valves ensuring both·
the Influent and effluent valves had fully opened.allowing full flow through the contactor.
• An OPEN command was Initiated to the actuator and the on-duty operator assumed it would fully open
correctly however the actuator only opened approximately 8-inch.es i~stead of the required 53-inches.
e This condition resulted In an estimated flow of between 8 to 10-MGD through the contactor, with the
majority of the 68-MGD flowing through the original in-service ozone contactor. Note: Flow data Indicate
periods of 75-MGD were also experienced during this time. .
., . As a result of this valve failure, the flow value was mathematically split via SCADA 50/50 between the two
contactors which resulted in the contactor receiving the bull< of the flow Incorrectly dosln9 the actual flow.
" · This situation existed from 9:00 SPM April 21, 2019 until the failed actuator was observed by a second
on-duty operator at approximately 12:50 PM April 22, 2019.
· • Total plant t~eated wa.te.rfiow was adjusted to approximately 55-MGD at 9:00 AM April 22, 2019 with a
reduced Treated Water Flow demand.
During this approximately 12-hour time the lowest calculated inactivation was·Giardla 0.17-Log, Virus 1,35~Log
The following tasks and procedurea. will be implemented to prevent reoccurrence of this failure:
• l)pdate Contactor lsoiation SOP to·include operator vlsoal verification that all Isolation valves are either
fully close or fully open as comman9ed,
e, Revlse and discuss SOP revisions with all staff.·
" Add vi.sual reference to valve stem with red and green marks to clear PVC housing fndicating fully open
.and fully closed valve stem positions,
• Pull wire to PLC-45 to provide discreet valve position and fail alarms to $CADA
• In plant SCADA HMJ will generate a warning ·message when both ozone contactors are In service and the
difference between normalized ratfas between contaotors exceed a predetermined selected setpolnt. This
alarm will allow operations to detect notably different conditions in disinfection. Since a.II other p1;1rameters
are meMured and controlled within closed loop controllers, the only parameter l.efUs the flow. The flow
will be the main disturbat11::e which will affecUhe normalized ratio between desire~ and actual dose · ·.
achieved, This warning message will be displayed .on a .pop~up screen with a detailed explanation ofthe
cause and requir.ed aottons to mitigate the flow unbalance,
Please do not hesitate to contact me tf any follow up Information is needed.
Regards,
Brian MacDonald
Jacobs
Plant M.anager'
Twin Oaks Valley WTP
Copies to: Chris Castaing, Operations & Maintenance Manager, San Diego. County Water Authority
Dennis Burrell, Regional Manager, Jacobs Engineering ·
Enter Document No. via Document Properties 2
Citation No. 05-14-19C-003
APPENDIX3
DRINKING WATER NOTIFICATIONS TO CONSUMERS
PROOF OF NOTIFICATION
Nanie of Water System:
Please explain what caused the problem if you have determined what it was and wh9t steps you
have taken to correct it. ·
C.onsumers Notified Yes ----No ----
If not; Explain: ___________ _
Da.te of Notification: ____ _
. . .
On the date of notification set forth above, I served the above referenced document(s) on the
consumers by:
Sending a copy through the U.S. Mail,-first class, postage· prepaid, addressed to each
of the resident(s) a·t the place where the property is situated, pursuant to the Galifornia
Civil Code. Attach copy of Notice.
Newspaper (if the problem has been corrected). Attach a. copy of Notice .
. Personally hand-delivering a copy to each of the consumers. Attach a copy of Notjce .. ·
Posted on a public bulletin board, that will be seen by each of the consumers (for small,
non-community water systems with prior Department approval). Attach copy of Notice.
I hereby declare the forgoing to be true and correct under penalty of perjury.
Date Signature of Person Serving Notice
** Notice: Complete this Proof of Notification and return ft along with a copy of the notification
to the Department within 1 O days of posting the notification.
Disclosure: Be advised that the California Health and Safety Code states that any person who
knowingly makes a false statem_ent on any report or document submitted for the purpose of
compliance with the attached order may be liable for a civil penalty not to exceed five thousand
dollars ($5,000} for each separate violation for each day that violation continues. In addition, the
violatqrs may be prosecuted in c_riminal court and upon conviction, be punished by fine of not more
than twenty-five thousand dollars ($25,000) for each day of violation, or be imprisoned in county jail
not to exceed one year or by both the fine and imprisonment. ·
8IPage
Citation No. 05-14-19C-003
APPENDIX 4 -NOTIFICATION OF RECEIPT
Citation Number: 05-14-19C-003
Name of Water System: San Diego County Water Authority
System Number: 3710042
Certification
I certify that I am an authorized representative of San Diego County Water Authority and that
Citation No. 05-14-:19C-003 was received on ________ . Further I certify that the
Citation has been reviewed by the appropriate management staff of the San Diego County Water
Authority and it is clearly understood that Citation No. 05-14-19C-0Q3 contains legally enforceable
. directives with specific due dates.
Signature of Water System Representative Date
THIS FORM MUST BE COMPLETED AND RETURNED TO THE STATE WATER BOARD,
DIVISION OF DRINKING WATER, NO LATER THAN JUNE 11, 201~.
Disclosure: Be advised that the California Health and Safety Code, Sections 116745 and 116730
state that any person who knowingly makes any false statement on any report or document
submitted for the purpose of compliance with the Safe Drinking Water Act may be liable for,
respectively, a civil penalty not to exceed five thousand dollars ($5,000) for each separate violation
or, for continuing violations, for each day that violation continues, or be punished by a fine of not
more than $25,000 for each day of violation, or by imprisonment in the county jail not to exceed one
year, or by both the fine and imprisonment.
91 Pa~ e
Our Region's Trusted Water Leader
San Diego County Water Authority
Water Quality Notification
June 2019
June 2019
■ A brief treatment process malfunction at the Twin Oaks Valley Water Treatment Plant
on April 21, 2019, resulted in a Notice of Violation from the state Division of Drinking
. Water.
o The malfunction lasted for about twelve hours, when ozone residuals in the plant ·
fell below state-mandated levels.
• Ozone is a widely used disinfectant in water treatment systems, and part of
the treatment process at Twin Oaks.
o This is the first NOV issued at the Twin Oaks plant in more than a decade of
service.
o The failure was the result of a valve failing to fully open.
o A contractor (CH2M Hill/Jacobs) operates the plant, but the NOV is issued to the
Water Authority as the owner/permit holder.
■ Overall water quality was not compromised, and there is no public health concern due
to multiple safeguards in place.
o Residents don't need to boil water or take other precautions.
o Water quality continued to meet all state and federal standards.
o If there had been an emergency, people would have been notified immediately.
o Corrective actions were taken immediately and the lapse was reported to state
regulators.
o The contractor has updated its operational procedures and installed additional
monitoring equipment to prevent future problems.
■ Although this is not an emergency, water users are entitled to know what happened and
what was done to correct the problem.
o The total number of customers affected is still being determined.
o We will be notifying all customers who potentially received water from Twin
Oaks during the failure; we are working with our member agencies to identify
those customers.
o Affected agencies include Valley Center, Vallecitos, Rincon, Rainbow,
Oceanside, Vista, Carlsbad, Ramona, Padre Dam, Otay, Helix and the City of San
Diego.
■ For public inquiries about this situation, please call the Water Authority's Escondido
office at 760-480-1991.
https://sdcwa office365.sharepoint.com/sites/intranet/poc/S itePages/key-points.aspx