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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 N b A I Feet [==:J Munlclpal Boundar'l CJ CMWD, Service Area [.-_.] City of Oceanside [==:J OMWD CJ San Dleguito wp L.· -]vwo CJ vista ID Riverside Count}'. ' \ \..._CARLSBAQ . _ \" San Diego l?aaifip \ Count''/ 0Gea11·c L\ ATKINS j_.t o,,,;_,.,-s:1R;£ , r. "''(~t-< ... \. i . : .. ,:·.,,. · ENGlJir7TAS · r-__. , z. ... -:·' _:,'·-·,.. . L r: . .._____, ,-': . (~.i. STUDY AREA FlGURE2-1 CMWD ViaterMaster·Pran Novemher 2011 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 ;_ .. · . ... ;, ... , ··'·· ' . ,· ,·, ··, .. < Pe,sc;ripti9ns :· .·.· . ' . : ,· . :· ;; .. ,,. ··,·· . .. " .·.. -·-•--i : . ' : :,;, '. ·,· .,."' ·' .. . ·-' . . '•. ,,. __ .. ,-.. 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 : .·.•,. ;o_esc:r_i~d9,;i~; ., .. · < . · · ·· ' ,d . • .... , :;,· .. ; ,. . . .. :. •'. . . ... . '., : .. : ;i.,, ...... ~,)<' : .. ' ·; .', 5; •·· 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 2 3 4 5 6 7 8 9 10 11 12 13 14 I 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 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 -1 ! 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