California Department of Health: City of Livingston 2013 Water System Inspection Report

LIVINGSTON CA / May, 2013 —

MP900309235Note from TheGardeningSnail: I have just received the complete report from the State. The items requiring action which were noted during the inspection and subsequent file review are as follows:

  1. The permitted active sources for the City are wells nos. 8, 9, 11B, 12, 13, 14, 15, and 16. The Merced District Office of the Drinking Water Field Operations Branch (DWFOB) must permit all other sources before they can be used in the water system. The city must immediately notify the Department in writing of any changes in the operating status of any source.

  2. Wells Nos. 7 and 10 are designated as abandoned sources. The city is currently conducting a Feasibility Study to determine the fate of those two wells. If the city is not going to improve the wells, the City must destroy them in accordance with the Merced County Water Well Ordinance by December 31, 2013. Copies of the destruction logs must be provided to the Department.

  3. The city must comply with the attached water quality monitoring schedule for all of the active sources. All water quality monitoring results obtained in a calendar month must be submitted to the Department via electronic data transfer (EDT) by the 10th day of the following month.

  4. The City shall prepare and submit a 5-year Budget Projection with a Capital Improvement Plan by June 1, 2013. A template is provided in Appendix G.

  5. The City must submit copies of all plans and specifications for any water system improvement projects to the Department for review and approval prior to any work being done on the system.

  6. A copy of the final Feasibility Report must be provided to the Department for review.

  7. The City must complete the electronic Annual report to the Drinking Water Program by April 30, 2013.

  8. All backflow devices are required to be tested on an annual basis. Copies of the testing records must be kept on file for a minimum of 3 years.

  9. The City must provide monthly well production records to the Department by the 10th day of the following month.

  10. The City must implement stringent water conservation measures until further notice to prevent water outages.

  11. The city must record all low pressure customer complaints and provide the Department with a monthly summary of the complaints by the 10th day of the following month.

  12. Well No. 13 must be monitored on a quarterly basis for arsenic. The Results must be submitted to the Department via EDT by the 10th day of the following month.

  13. Wells No 9, 11B, 14, and 15 must be sampled for VOCs by December 2013.

  14. Well No. 14 must be sampled on a quarterly basis for DBCP.

  15. The City must collect 30 lead and copper tap samples from the distribution system by September 30, 2013.

  16. The City must provide the status of what the City plans to do about the manganese exceedance for Well No. 15. the Department sent an email to the City with information on how to conduct a survey to obtain a 9-year monitoring waiver for the exceedance. the city needs to provide an update to the Department on what it plans to do by April 30, 2013.

  17. With the exception of well no 16, all of the City’s wells must be sampled for SOCs in 2013.

  18. Wells nos. 8, 9, 12, 14, and 15 must be sampled for general mineral, general physical, and inorganic chemicals by December 31, 2013.

  19. The City must submit an updated Operations Plan for the arsenic treatment removal system at Well No. 16.

  20. The City must provide a plan and timeline for addressing the recommendations in the 2013 tank inspection report by April 30, 2013 .

Note From TheGardingSnail: The following was created by taking the Report in PDF, and running it through a program that converts Image to Text then bouncing that file through the Bloging Software. When in Doubt, check with the 2013 Annual Inspection on PDF.

Mr. Jose Antonio Ramirez, City Manager City of Livingston

1416 C Street Livingston, CA 95334

RE: 2013 Annual Inspection of City of Livingston

On March 14, 2013, Maria Wieczorek of my staff met with Tony Avina and Humberto Molina to review the City of Livingston (City) water system and its operation. The purpose of this letter is to inform you of the following items requiring action which were noted during the inspection and a subsequent file review:

1. The permitted active sources for the City are Wells Nos. 8, 9, 11B, 12, 13, 14, 15 and 16. The Merced District Office of the Drinking Water Field Operations Branch (DWFOB) must permit all other sources before they can be used in the water system. The City must immediately notify the Department in writing of any changes in the operating status of any source.

2. Wells Nos. 7 and 10 are designated as abandoned sources . The City is currently conducting a Feasibility Study to determine the fate of these two wells. If the City is not going to improve the wells, the City must destroy them in accordance with the Merced County Water Well Ordinance by December 31, 2013. Copies of the destruction logs must be provided to the Department.

3. The City must comply with the attached water quality monitoring schedule for all of the active sources. All water quality monitoring results obtained in a calendar month must be submitted to the Department via electronic data transfer (EDT) by the 1oth day of the following month.

4. The City shall prepare and submit a 5-year Budget Projection with a Capital Improvement Plan by June 1, 2013. A template is provided in Appendix G.

Southern California Drinking Water Field Operations Branch

265 W. Bullard Avenue, Suite 101, Fresno, CA 93704

(559) 447-3300 (559) 447-3304 Fax

Internet Address : http://www.cdph.ca .gov/programs/Pages/DDWEM.aspx

5.The City must submit copies of all plans and specifications for any water system improvement projects to the Department for review and approval prior to any work being done on the system.

6. A copy of the final Feasibility Report must be provided to the Department for review.

7. The City must complete the electronic Annual Report to the Drinking Water Program by April 30, 2013.

8. All backflow devices are required to be tested on an annual basis. Copies of the testing records must be kept on file for a minimum of 3 years.

9. The City must provide monthly well production records to the Department by the 10th day of the following month.

10. The City must implement stringent water conservation measures until further notice to prevent water outages.

11.The City must record all low pressure customer complaints and provide the Department with a monthly summary of the complaints by the 1oth day of the following month.

12. Well No. 13 must be monitored on a quarterly basis for arsenic. The results must be submitted to the Department via EDT by the 10th day of the following month.

13. Wells Nos. 9, 11B, 14, and 15 must be sampled for VOCs by December 2013.

14. Well No. 14 must be sampled on a quarterly basis for DBCP.

15. The City must collect 30 lead and copper tap samples from the distribution system by September 30, 2013.

16. The City must provide the status of what the City plans to do about the manganese exceedance for Well No. 15. The Department sent an email to the City with information on how to conduct a survey to obtain a 9-year monitoring waiver for the exceedance. The City needs to provide an update to the Department on what it plans to do by April 30, 2013.

17. With the exception of Well No. 16, all of the City’s active wells must be sampled for SOCs in 2013.

Page 2

18. Wells Nos. 8, 9, 12, 14, and 15 must be sampled for general mineral, general physical and inorganic chemicals by December 31, 2013 .

19. The City must submit an updated Operations Plan for the arsenic treatment removal system at Well No. 16.

20. The City must provide a plan and timeline for addressing the recommendations in the 2013 tank inspection report by April 30, 2013.

Please provide a written response to this letter by April 30, 2013. Please review the report and provide any comments or clarifications you have to Kassy Chauhan.

Sincerely,

clip_image002[4]

Carl L. Carlucci, P.E. Supervising Sanitary Engineer Central California Section

SOUTHERN CALIFORNIA BRANCH DRINKING WATER FIELD OPERATIONS

cc: Merced County Division of Environmental Health

Humberto Molina, Public Works Director, City of Livingston (same address) Tony Avina, Water Operator, City of Livingston (same address)

Nanda Gottiparthy, SNG Associates (5776 Stoneridge Mall Road, Suite 370, Pleasanton, CA 94588)

CLC/mrw/2410004/2013 Annual

 

California Department of Public Health

Page 3

MEMORANDUM

DATE:   April 15, 2013

TO CarlL. Carlucci, P.E.

Merced District

Drinking Water Field Operations Branch

FROM

Maria R. Wieczorek Merced District

Drinking Water Field Operations Branch   :

SUBJECT:  Annual Inspection City of Livingston System No. 2410004 MERCED COUNTY

clip_image003

I. INTRODUCTION

On March 14, 2013, I conducted an inspection of the City of Livingston’s water system and reviewed its operations . During this inspection, I met with Tony Avina and Humberto Molina. The water system was previously inspected by Kassy Chauhan, P.E. in May 2011.

1.1 DESCRIPTION OF SYSTEM

The City is located in Merced County and is classified as a community water system (CWS) which serves a permanent population of approximately 13,920 persons through 2,882 service connections, of which 88 are unmetered . The City requires the installation of meters on all new residential construction , remodel residential construction , and on excessive water users. There are 54 commercial connections of which three are unmetered. There are five industrial connections and 17 irrigation connection all of which are metered. The service area is sewered.

The City currently extracts groundwater from its eight active wells, Wells Nos. 8, 9, 11B, 12, 13, 14, 15 and 16. The City has a 1.0 MG welded steel storage tank for water storage. Chlorination is provided at each of the active well sites. Additionally, arsenic removal treatment is provided at the Well No. 16 site. However, Well No. 16 has been offline since September 2011 because the media in the arsenic removal treatment system has been exhausted . Well No. 13 is also offline due to arsenic at elevated levels but below the MCL. The City is currently flushing the well to waste and collecting a bacteriological cycle test and hopes to bring the well online by mid-April if the cycle test results are coliform negative.

City of Livingston Inspection Report April2013

Page 2 of 26

Emergency power is provided at Wells Nos. 8,_ 118, 13, 14, 15, and 16 by diesel­ powered generators located at these sites. The generators are exercised once per month for about 30 minutes. The City services and fuels the generators on the first Wednesday of each month. The generators are capable of operating the wells at these sites during power outages. The diesel storage tanks are located above ground at all six locations.

The City uses a SCADA system to monitor the operation of the City’s wells , water production, and water levels in the storage tank . City water personnel visit all of the active well sites on a daily basis. The operator conducts visual checks of the well site and the chlorination equipment. Chlorine residuals are also recorded during the visit.

1.2 PERMIT COMPLIANCE

The City is currently operating under a domestic water supply permit (No. 03-11-98P- 001), issued on January 6, 1998, a Permit Amendment (No. 03-11-01PA-001) that was issued on January 25, 2001, and a Permit Amendment (No. 03-11-10PA-006) that was issued May 3, 2010. The special permit provisions in the original Water Supply Permit and the 2001 Permit Amendment have been rescinded and the 2010 Permit Amendment contains an all-inclusive list of special permit provisions. The special provisions from the 2010 Permit Amendment are:

1. The City is permitted to use Wells Nos. 8, 9, 118, 12, 13, 14, 15, and 16 as active sources in the water system. No other sources shall be used in the water system without prior written approval from the Merced District Office of the Drinking Water Field Operations Branch (DWFOB).

2. The City does not currently have any sources that are designated as inactive sources. If in the future , the City has sources that are designated as inactive, the City must be aware that inactive sources are not approved as sources of supply and must be locked out or physically disconnected or otherwise isolated so that only an intentional act by an operator , and no automatic response, can place the source in service. Inactive wells can be upgraded to standby status if all monitoring is updated to meet standby requirements and the change in status is approved in writing by the Department. Inactive sources can only be used as a last resort in extreme emergencies after all other active sources of supply have been utilized. Any use of an inactive source is subject to the following restrictions:

a. Emergency notification to the consumers that the water is unsafe for domestic use must be given immediately preceding , and on a continuing basis, during the duration of the emergency use of the source.

b. Initiation of the use of an inactive source must be the result of an intentional manual action by the system operator .

c. The use of an inactive source shall not be initiated without the knowledge and approval of the Department.

d. All monitoring as deemed appropriate by the Department shall be required during or immediately following an emergency use of an inactive source.

Page 3

3. The City does not currently have any standby sources . If in the future any well is designated as standby , the Department must be notified of the change in status. Standby sources may only be used for a maximum of five consecutive days and 15 calendar days per year. The City must notify the Department in writing any time a standby source is used in the water system and submit an incident report that details the events leading up to and during the use of the standby source.

4. Wells Nos. 7 and 10 are designated as abandoned sources. To date, the wells have  not been properly destroyed. The City must submit a plan and time schedule outlining the future of these two wells by June 30, 2010.

5. The City must notify the Department in writing any time the operating status of a source is changed.

6. The City is approved to operate chlorination facilities at all permitted active well sites .

7. The City shall measure and record the chlorine residual levels in the water leaving each well site daily, and in the distribution system at the same time and place that bacteriological samples are collected.

8. The City shall monitor all active sources , before chlorination , monthly for total coliform bacteria and E.coli bacteria if total coliform bacteria are present, using a density analytical method. Results of the coliform tests shall be reported in units of MPN per 100 mi. The raw water monitoring results shall be submitted to the Merced District Office of the DWFOB prior to the 1oth day of the following month.

9. The arsenic removal treatment system at Well No. 16 must be operated in accordance with the approved operations plan for the treatment system . The City must submit a revised operations plan to reflect current operation of the arsenic removal treatment system since changes have been made since the treatment system was originally installed. The revised operations plan must be submitted to the Department for review and approval by June 30 , 2010.

10. The City shall submit an annual report summarizing and assessing the arsenic removal treatment system performance during the previous year to the Department by March 1st of each year . The annual report shall include the following :

Page 4

a. Comprehensive discussion of action taken in the previous year including media change outs, vessel backwashing, treatment unit maintenance , monitoring changes , operational changes and problems and water quality problems .

b. A written summary of monitoring results since the last annual report.

c. An evaluation of the performance of each treatment vessel during the previous year.

11. The City shall submit a summary of operations and monitoring data for the arsenic removal treatment system at Well No. 16 to the Department on a monthly basis including daily system total flow; daily hours of operation ; influent and effluent arsenic concentrations ; backwash duration, volume and dates ; and media change out dates. Reports shall be submitted by the 10th day of the following month.

The City is in compliance with all but Provision No. 4 of the Permit Amendment. The City is conducting a Feasibility Study to determine the fate of Wells Nos. 7 and 10. The City expects to have the Feasibility Study completed by the end of April 2013.

1.3 ENFORCEMENT HISTORY

The City has not received any enforcement actions from the Department since the last inspection was conducted in 2011. However, the City was issued an Enforcement Letter in May 2009 for Well No. 15 exceeding the secondary MCL for manganese . The City has not yet resolved this issue. The City has the option of conducting a survey to determine if its customers are willing to pay for treatment for manganese removal. The City has not yet conducted the survey. A copy of the draft Feasibility Study .was submitted to our office on March 18, 2013. The option of treatment is briefly covered in the Study. The Department provided comments to the City on the draft Feasibility Study on April 5, 2013 .

1.4 AREA SERVED

The City is located about 16 miles north of the City of Merced. The City serves residential, commercial , industrial and irrigation connections . The surrounding land use is primarily agricultural around the City. The major industrial user of the City’s water is the Foster Farms Processing Plant. The Plant uses an average of between 3 and 4 million gallons of water each day for processing .

Page 5

II. INVESTIGATION FINDINGS

2.1 GROUNDWATER SOURCES OF SUPPLY

The domestic water supply is obtained from eight active wells , Wells Nos. 8, 9, 118, 12, 13, 14, 15, and ·16. All of the wells are located adequately away from sewers and other potential hazards . System pressure is maintained between 50 and 65 psi with Mercoid pressure switch controls on all of the wells . A description of each of the active wells follows:

Well No. 8 (Active Raw) PS Code 2410004-008

Well No. 8 was constructed in 1983 in the northern portion of the City. The well is surrounded by orchards , a school, and a stormwater basin. The well is 518 feet deep and has an 18-inch diameter steel casing to a depth of 300 feet. The casing is perforated from 165 to 187 feet, 205 to 215 feet, 225 to 235 feet, 245 to 260 feet, and 270 to 290 feet for a total screened depth of 77 feet. A cement annular seal is provided from 0 to 100 feet and the well is gravel packed from 100 to 300 feet. A 30-inch diameter steel conductor casing is provided to a depth of 100 feet. The well is equipped with a 125-hp electric motor and a water-lubricated DWT pump capable of producing 1,200 gpm.

The concrete pedestal is approximately 3-feet by 3-feet and is approximately 18 inches above finished grade . The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve, a Cia-valve, a pressure gauge, a hose bib with air vacuum breaker, chlorine injection ports, a flow meter, a gate valve and a discharge-to-waste line. The discharge-to -waste line is open to the atmosphere, not connected to the storm drain system.

The well site includes a 125-KW Onan generator that is capable of supplying enough power for the well. The generator is automatically started during a power outage. The generator is cooled by a radiator separate from the water system and is exercised once per month for half an hour before school starts. The generator features an above­ ground diesel storage tank.

The water produced by this source is disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 55-gallon solution tank and a Pulsatron metering pump rated at 24 gallons per day (gpd) at 100 pounds per square inch (psi). The chlorination equipment is enclosed in a block building where the wellhead is located. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

The water produced by Well No. 8 contains 1,2,3-TCP in excess of the Notification Level of 0.005 ug/L. The City was awarded 9 million dollars in a lawsuit against Dow

Page 6

Chemicals for the contamination. A removal treatment system is in process of being designed to treat the contamination. Our office recently reviewed and commented on the draft plans and specification for the proposed GAC treatment system. Construction of the treatment system is expected to begin by the end of summer 2013.

Well No.9 (Active Raw) PS Code 2410004-009

Well No. 9 was constructed in 1985 to a depth of 503 feet. The surrounding area is characterized by residential and commercial development. The well contains an 18- inch diameter steel casing to a depth of 324 feet and is perforated from 167 to 185 feet, 203 to 209 feet , 219 to 233 feet, 251 to 265 feet, 298 to 304 feet, and 309 to 322 feet for a total screened interval of 71 feet. A cement annular seal is provided from 0 to 100 feet and the well is gravel packed from 100 to 324 feet. A 30-inch diameter steel conductor casing was installed to a depth of 100 feet. Well No. 9 is the City’s lead well and it is equipped with a 150-hp electric motor and a water-lubricated DWT pump capable of producing 1,300 gpm.

The concrete pedestal is approximately 3-feet by 3-feet and is approximately 18 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes a Cia-valve , a pressure gauge, a hose bib, chlorine injection ports, a flow meter, a gate valve and a discharge-to-waste line.

The water produced by this source is disinfected using 12.5% sodium hypochlorite . Chlorination equipment consists of a 55-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in a locked, fiberglass enclosure at the well site. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

Well No. 118 (Active Raw) PS Code 2410004-011

Well No. 11B was constructed in 1990 to a depth of 285 feet. The surrounding area is characterized by orchard/agricultural area and the Foster Farms wastewater discharge ponds. The well is also located adjacent to a railroad line and is about 100 feet from a high pressure petroleum pipeline. The well contains a 16-inch diameter steel casing and is screened from 160 to 187 feet, 224 to 240 feet , and 250 to 280 feet for a total screened interval of 73 feet. The well has a 30-inch diameter steel casing with a cement annular seal from 0 to 147 feet. The well is gravel packed from 147 to 285 feet. The well is equipped with a 100-hp electric motor and a water-lubricated DWT capable of producing 800 gpm.

The concrete pedestal is approximately 4-feet by 4-feet and is approximately 18 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve, Cia-valve , a pressure gauge, a

Page 7

hose bib, chlorine injection ports, a gate valve and a discharge-to-waste line. This well is dedicated to serve the Foster Farms Chicken Processing Plant. The discharge line to the Foster Farms plant contains a flow meter. The processing plant uses an average of between 3 and 4 MG of water on a daily basis, which makes them the City’s largest consumer.

The water produced by this source is disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 30-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in a locked metal enclosure at the well site. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

The well site includes a Generac 2000 Series generator that is capable of supplying enough power for the well. The generator is automatically started during a power outage. The generator is cooled by a radiator separate from the water system and is exercised monthly.

Well No. 12 (Active Raw) PS Code 2410004-012

Well No. 12 was constructed in 1989 to a depth of 410 feet. The surrounding land use includes a school site and residential developments. The well contains an 18-inch diameter steel casing with perforations from 165 to 185 feet , 196 to 255 feet, and 267 to 290 feet for a total screened interval of 102 feet. A 36-inch diameter steel conductor casing and cement seal are installed to a depth of 155 feet. The well is gravel packed from 155 to 410 feet. The well is equipped with a 100-hp electric motor and a water­ lubricated DWT pump capable of producing 1,400 gpm.

The concrete pedestal is approximately 4-feet by 4-feet and is approximately 18 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve, Cia-valve , a pressure gauge , a hose bib, chlorine injection ports, a flow meter a gate valve and a discharge-to- waste line.

The water produced by this source is disinfected using 12.5% sodium hypochlorite . Chlorination equipment consists of a 100-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in a locked metal enclosure at the well site. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

Well No. 13 (Active Raw) PS Code 2410004-013

Well No. 13 was constructed in 1993 to a depth of 335 feet. The surrounding area is characterized by open land, agricultural, a stormwater basin and a new residential development. The well contains an 18-inch diameter steel we!l casing with perforations

Page 8

at 162 to 186 feet, 207 to 221 feet, 233 to 248 feet, 294 to 300 feet, and 318 to 331 feet for a total screened interval of 72 feet. A 36-inch diameter steel conductor casing and cement seal are installed to a depth of 155 feet. The well is gravel packed from 155 to 334 feet. The well is equipped with a 150-hp electric motor and an oil-lubricated DWT pump capable of producing 1,100 gpm. The well produces hydrogen sulfide odors which are kept at a minimum with the addition of chlorine.

The concrete pedestal is approximately 3-feet by 3-feet and will be approximately 24 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve , Cia-valve, a pressure gauge, a hose bib, chlorine injection ports, a flow meter, a gate valve and a discharge­ to-waste line. The well has been offline because it produces water with arsenic levels close to the MCL. Currently, the running annual average (RAA) is below the arsenic MCL. The City recently completed a cycle test for the well and was granted permission to bring the well back online.

The water produced by this source will be disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 30-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in the building that houses the wellhead at this well site. The site features an eyewash station inside the well building as well as on the outside of the building.

An emergency power generator is installed at this site and is capable of operating the wellhead and the treatment equipment in the event of a power outage. The generator is exercised on a monthly basis.

Well No. 14 (Active Raw) PS Code 2410004-014

Well No. 14 was constructed in 1993 to a depth of 400 feet. The surrounding land use includes both agricultural and residential developments. The well contains an 18-inch diameter steel casing to a depth of 307 feet with screened sections at 234 to 238 feet and 245 to 305 feet for a total screened interval of 64 feet. The well features a 36-inch diameter steel conductor casing to a depth of 20 feet and a cement annular seal to a depth of 225 feet. The well is gravel packed from 225 to 400 feet. The well is equipped with a 125-hp electric motor and submersible pump capable of producing 1,000 gpm.

The concrete pedestal is approximately 3-feet by 3-feet and approximately 18 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve, Cia-valve, a pressure gauge, a hose bib with an air vacuum breaker, chlorine injection ports, and a flow meter.

The water produced by this source is disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 55-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in a locked,

Page 9

fiberglass enclosure at this well site. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

This site is equipped with a Cummins Onan diesel powered generator. The generator is capable of operating the wellhead and the treatment equipment in the event of a power outage. The generator is exercised on a weekly basis for about 30 minutes.

Well No. 15 (Active Raw) PS Code 2410004-015

Well No. 15 was constructed in 1998 to a depth of 284 feet. The surrounding land use includes open field and a commercial development. The well contains a 32-inch diameter steel conductor casing from 0 to 20 feet, a 16-inch diameter copper bearing blank casing from 0 to 190 feet and 16-inch diameter steel blank casing from 190 to 210 feet. Perforations are provided from 210 to 244 feet and from 256 to 270 feet for a total screened interval of 48 feet. The well has a cement annular seal from 0 to 200 feet and is gravel packed from 200 to 284 feet.

The well is equipped with a 100-hp electric motor and a DWT water-lubricated pump capable of producing 900 gpm. The entire well site is enclosed by a chain-link fence enclosure. The concrete pedestal is approximately 4-feet by 4-feet and approximately 12 inches above finished grade. A portion of the discharge line is enclosed within a wooden enclosure. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve, Cia-valve , a pressure gauge , a hose bib, chlorine injection ports, a flow meter, a gate valve and a discharge-to-waste line.

The water produced by this source is disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 25-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is enclosed in a locked enclosure that has an alarm to alert the City of any intruders. The chlorine residual is monitored in the distribution system at the same time and location as the collection of the bacteriological samples.

Emergency power is provided by a GENERAC diesel engine that is exercised once per month. The generator is capable of operating the wellhead and the treatment equipment in the event of a power outage.

The water produced by Well No. 15 has levels of manganese in excess of the secondary MCL, elevated levels of arsenic near the MCL, and 1,2,3-trichloropropane (1,2.3-TCP) at levels in excess of the Department’s Notification Level. The City minimizes the use of Well No. 15 because of the quality of the water.

Page 10

Well No. 16 Kishi Well (Active Raw) PS Code 2410004-025 OFFLINE

Well No. 16 was constructed in 2006 to a depth of 477 feet. The surrounding land use includes open field and a residential development. The well contains a 16-inch diameter steel blank casing from 0 to 236 feet. Perforations are provided from 236 to 246 feet, from 254 to 274 feet, from 294 to 304 feet, from 334 to 344 feet, and from 422 to 462 feet for a total screened interval of 90 feet. The well has a cement annular seal from 0 to 85 feet and is gravel packed from 85 to 477 feet.

The well is equipped with a 150-hp electric motor and a DWT water-lubricated pump capable of producing 1,200 gpm . The wellhead is located in a locked building along with the chlorination equipment and the emergency power generator. The entire well site is enclosed by a concrete block fence enclosure. The area surrounding the well is paved. The concrete pedestal is approximately 3-feet by 3-feet and approximately 24 inches above finished grade. The pedestal has a casing vent and a gravel chute mounted on it. The discharge piping includes an air relief valve , check valve , a pressure gauge, chlorine injection ports, a Krohne magnetic flow meter, and a gate valve for the discharge-to-waste line. The well discharges to waste automatically for two minutes at start-up and for an additional two minutes at shut-down. The flow that discharges to waste goes to the storm drain system.

The water produced by this source will be disinfected using 12.5% sodium hypochlorite. Chlorination equipment consists of a 55-gallon solution tank and a Pulsatron metering pump rated at 24 gpd at 100 psi. The chlorination equipment is located in the same building as the wellhead . The chlorine residual will be continuously monitored by a Hach CL17 online chlorine residual analyzer. There is an eyewash station and shower located near the chlorination equipment.

The water produced by this well has been determined to contain arsenic at concentrations that exceed the maximum contaminant level (MCL) for arsenic , 10 ug/L. Therefore , all of the water produced by Well No. 16 is treated using an adsorptive arsenic removal treatment system. Well No. 16 has been offline since September 2011 because the media in the arsenic removal treatment system has been exhausted . It is expected that a media change out will occur in the near future and Well No. 16 will be put back online by summer 2013 .

2.1 TREATMENT

Chlorination

Chlorination equipment for all of the active wells consists of Pulsatron electronic metering pumps and various sizes of sodium hypochlorite solution tanks . The City purchases ANSI/NSF standard 60 certified 12.5% solution of sodium hypochlorite manufactured by Bremtag to disinfect the water produced by the wells. The sodium

Page 11

hypochlorite is dosed to produce a chlorine residual of 0.7 mg/L in the distribution system. The chlorination equipment at most of the City’s wells is located in either locked, metal enclosures or inside the building that houses the wellhead. Each of the well sites is equipped with an eyewash and shower station for use by the operators when needed.

A review of the City’s files revealed that the City submitted a chlorination operations plan dated February 2008. The chlorination operations plan contains information on the equipment used by the City, the sodium hypochlorite used by the City and the monitoring procedures and operator certification requirements . The plan was approved by the Department on February 14, 2008. The City must continue to operate their chlorination systems as indicated in the approved operations plan.

Arsenic Removal Treatment System (OFFLINE)

The arsenic removal treatment system at Well No. 16 consists of chlorination followed by pressure filtration through vessels containing DOW Adsorbsia GTO for arsenic removal. The City has selected a new adsorptive media (Filtronics NXT-2) for the arsenic treatment system. In an effort to improve the performance of the media, the City is also adding pH adjustment equipment to the arsenic treatment system. The City must provide a copy of the plans and specifications for the treatment plant upgrades. In addition, the City will be required to update the Operations Plan for the Well No. 16 arsenic treatment system and submit a Permit Amendment application. The existing treatment system is described below.

Chlorination

The City provides pre-chlorination to oxidize arsenite [As (Ill)] to arsenate [As(V)] to facilitate adsorption and provide a chlorine residual in the distribution system . The chlorination system consists of a 300-gallon chlorine solution tank and a Premia 75 Micro metering pump rated at 10 gallons per hour (gph) at 35 psi. There are two metering pumps in duty/stand-by configuration that are used to inject the sodium hypochlorite solution into the raw water prior to entering the arsenic removal treatment system . The chlorine solution tank and metering pumps are located in the wellhead building and are not exposed to direct sunlight. The design dosage of sodium hypochlorite is a maximum of 5.0 mg/L, with a target residual leaving the treatment system of 1.0 mg/L. The chlorine residual leaving the treatment system is continuously monitored by a HACH CL-17 online chlorine residual analyzer. The chlorine residual levels are monitored every 2.5 minutes, 24 hours per day.

Arsenic Removal Treatment System

The chlorinated water pumps directly to three arsenic adsorption vessels arranged in parallel for arsenic removal. The vessels are 90 inches in diameter with DOW

Page 12

Adsorbsia GTO, each with an available surface area of 44.2 square feet. As mentioned, the media utilized for the arsenic removal is granular titanium oxide (GTO) , manufactured by DOW Chemical. The GTO media is NSF/ANSI-certified.

Each vessel has a GTO bed depth of 44 inches, providing a GTO volume of approximately 165 cubic feet. Each vessel also contains a 3-inch barrier sand filter bed and a 6-inch layer of support gravel to support the GTO media. Well production is limited to 1,200 gpm with the flow split equally to the three filters for a maximum surface loading rate of approximately 9.0 gpm/ff through the arsenic adsorption vessels.

The empty bed contact time (EBCT) for the three arsenic adsorption vessels in parallel operation at 400 gpm each is approximately 3.0 minutes.

Effluent from the arsenic treatment plant flows directly to the distribution system. The chlorine residual of the effluent is monitored with the online chlorine analyzer described in the section regarding chlorination.

The arsenic adsorption vessels are backwashed periodically to prevent compaction of the media bed and remove captured particulates. Backwash is initiated manually when the pressure differential through the arsenic adsorption vessels exceeds 10 psi, as measured by differential pressure sensors installed on the vessels. Backwash is performed at a rate of approximately 9.0 gpm/ff . During the backwash, one vessel is taken offline , and raw water from the well provides the 400 gpm that is required to meet the 9.0 gpm/ff backwash rate. The other vessels are out of service during the backwash period. After all filters have been backwashed , the units are rinsed prior to being returned to service. Backwash water is discharged to a 20,000-gallon bolted steel backwash tank located onsite. The tank is approximately 16-ft in height and 15-ft in diameter . The tank serves as a storage facility for backwash water and rinse water produced by the arsenic removal treatment system . The backwash and rinse water in the backwash tank water discharge to the City’s sewer system . None of the backwash water is recycled.

GTO is not regenerated when the adsorption capacity is exhausted . Rather, spent GTO media is disposed of and new GTO media is installed. To determine when the arsenic adsorption capacity of the GTO is nearing exhaustion, arsenic monitoring is conducted on a monthly basis at the combined filter effluent. The laboratory turnaround time for these samples is typically 7 to 10 days . When the arsenic concentration at the combined effluent of an arsenic adsorption vessel reaches 0.005 mg/L, arsenic monitoring is conducted on a weekly basis at the combined effluent. When the arsenic concentration at the combined effluent reaches 0.008 mg/L (80% of the MCL), media change out will be scheduled for the vessels . The City anticipates that the vessels will reach an arsenic level of 0.008 mg/L at approximately the same time and, therefore , all media will be changed out at once. Prior to returning the treatment plant to service , each vessel with new media must be sampled for bacteriological quality. A vessel will

Page 13

be returned to service only when bacteriological analysis results show the vessel has been properly disinfected and is free from total coliform bacteria .

As mentioned, the media in the vessels has been exhausted and the City is in the process of replacing the media. The City has selected a new adsorptive media (Filtronics NXT-2) and will be starting the media change out in the near future. Well No. 16 and the arsenic treatment plant have been offline since September 2011.

2.3 ADEQUACY OF SUPPLY

The City uses Wells Nos. 8, 9, 11B, 12, 13, 14, and 15 to regularly meet system demand. Well No. 16 has been offline since September 2011. The total source capacity for the system is 8,900 gpm. The City produced a total of 2,380 MG during 2012. Based on prior production records submitted to the Department, the maximum month usage occurred during July when 251 MG of water was used. The estimated maximum day demand (MOD) is calculated by applying a peaking factor of 1.5 to the average day demand during the maximum month. The estimated MOD is 8,434 gpm

gpm/service connection) . However, revised production reports were submitted to the Department in March 2013. The actual maximum day demand occurred on July 13, 2012 when 10,275,000 gallons were used. This is a MOD of 7,135 gpm (2.5

gpm/service connection). Peak hour demand (PHD) is calculated by multiplying the maximum day by a peaking factor of 1.5. Therefore , the PHD is 10,703 gpm (3.7 gpm/service connection). The City’s combined well capacities are listed below:

Well No.

Source

Capacity (gpm)

8

1,200

9

1,300

11B

800

12

1,400

13

1,100

14

1,000

15

900

16* offline

1,200*

Total

combined capacity:

7,700 gpm

* Not mcluded m total

Page 14

Storage can be used to meet PHD. · The City has 1 MG of storage. California Waterworks Standards (CWS) require water systems with more than 1,000 service connections to have at least 4 hours of storage capacity during peak demand periods. The City has exactly 4 hours (4.06) of storage available for use during peak hour demand periods.

With the addition of Well No. 13, the City’s combined source capacity is increased to 7,700 gpm, which is enough source capacity to meet the actual MOD. The Department notified the City in an email dated March 15, 2013, of these deficiencies and requested that the City provide the following items:

• A plan and time schedule for bringing Wells Nos. 13 and 16 back online by April 5, 2013.

• A plan and time schedule for increasing the City’s source capacity by April 5, 2013.

• Provide accurate production reports based on actual usage by the 1oth day of the following month.

• Implement water conservation measures immediately and through the peak demand season.

• Provide a report documenting all customer complaints for low water pressure by the 1oth day of the following month.

• Provide missing production records for November and December 2011 by April 5, 2013.

• Provide the single highest day of production (maximum day) from the SCADA data for 2011 and 2012 by April 5, 2013.

• Provide monthly water consumption data for Foster Farms Processing Plant.

In a meeting with the City on March 27, 2013, the City indicated their willingness to cooperate and provide the items requested. The City has provided the missing production reports, the Foster Farms consumption data, the maximum day production data, more detailed production reports, and a log of any customer complaints related to low pressure. The City is working on implementing water conservation measures. Also, the City is working with Kennedy Jenks and AECOM to bring Wells Nos. 13 and 16 back online as well as for increasing the City’s source capacity. Well No. 13 was brought back o nline on April 12, 2013.

During the inspection , it was noted that the City’s largest consumer of water is the Foster Farms Processing Plant. It was estimated that the Processing Plant uses an average of between 3 and 4 MG of water from the City on a daily basis.

It was also noted during the inspection that the City’s water rates are not sufficient. The City currently charges residential customers $9.90 per 47 hcf (hundred cubic feet) with no penalty fee for exceeding that amount. The City charges even less ($8.70 per 47 hcf) for commercial customers and $0.30 per 1,000 gallons for exceeding the 47 hcf. In

Page 15

a letter dated September 15, 2010 , the Department expressed concern to the City about having sufficient water rates to generate enough revenue to cover all of the water system’s expenses including operation , maintenance and capital improvements . It appears that the City may not have enough staff under the Water Division to keep up with the operation of the system. The Water Division currently employs 3 certified operators who are responsible for all of the operation and maintenance of the well sites, investigating customer complaints , and providing any repairs to the system.

The City is currently conducting a Feasibility Study to examine adding additional source capacity, adding additional storage capacity , and adding localized or centralized treatment to provide water that complies with all primary and secondary drinking water standards. Several of the City’s wells produce water with 1,2,3-TCP above the Notification Level. Many of the same wells produce water with arsenic approaching the MCL (Well No. 12), at the MCL (Wells Nos. 13 & 15), and over the MCL (Well No. 16). Thirdly , Well No. 15 produces water with excessive manganese levels. The City has opted to provide treatment for the latter rather than applying for a waiver from the Department. The Feasibility Study is expected to be completed by the end of April 2013.

The Department is requiring the City to complete a 5-year Budget Projection with a CIP (Capital Improvement Plan). Our office is concerned that the City does not have adequate financial capability to provide for the ongoing operation. maintenance . and upgrading of the system.

2.3 STORAGE

The City has a 1.0 MG welded steel storage tank in the southeast section of the City that was built in 1999. The tank is 32 feet high and 75 feet in diameter and receives water from the distribution system through a one-way check valve . The tank is a bottom-fill tank. A flow meter is present. Three 50-hp, 1,000 gpm centrifugal pumps draw water from the tank and discharge it into the distribution system . Only one pump operates at a time and each month the lead pump is rotated by the operator . The pumps operate on system pressure to maintain 50 to 60 psi in the system.

The tank is primarily filled by Well No. 12 which is dedicated to fill the tank from 8:30 p.m. to 11:30 p.m., each evening. The operation of Well No. 12 is controlled by a SCADA system . If the water level in the tank is low at 8:30 p.m., the SCADA system will initiate a start of Well No. 12 to begin filling the tank . The fill line is equipped with an air relief valve, a pressure gauge, a one-way check valve and a second pressure gauge. The tank also features an overflow drain that has a screened flap on the end to minimize the chance of small animals/debris from entering the tank. The tank is equipped with a water level indicator and an access ladder that is inaccessible on the bottom half. The operator indicated that one of the City’s operators climbs the tank at least once a month to inspect the top of the tank , the access hatch and the vent. There

Page 16

are water quality monitoring ports at three levels in the tank . The City can use these water quality monitoring ports to determine chlorine residuals and other water quality parameters at various levels in the tank.

The tank was last inspected in January 2013 by Liquid Engineering Corporation. The inspection brought the following items to the City’s attention :

• The interior coating (walls, floor , and interior support column) is in overall poor condition. There is a large amount of blistering, cracking, and pinholes in the coating. It is recommended to blast and recoat the interior of the tank .

• The tank hatch is not equipped with a security hatch locking device.

• The tank vent is not equipped with a security shroud.

The Department reviewed the tank inspection on March 21. 2013 . In an email to the City, dated March 21. 2013. the Department requested that the City provide a plan and timeline for addressing the inspection items by April 15. 2013.

2.3 DISTRIBUTION SYSTEM

Water Mains

The distribution system is within a single pressure zone. The distribution mains range in size from 6 to 12-inches in diameter and are constructed of C900 PVC, asbestos­ cement and ductile iron. All new construction involves the installation of C900 PVC pipeline. The majority of the new water mains are 12-inches in diameter. The City maintains the minimum sewer and water line separation requirements .

Main Repairs

In the event of a main break, the City responds immediately. Small breaks are usually repaired under pressure with a repair clamp. For larger repairs that require the section to be replaced, and for installation of new mains, the section is first swabbed , then dry powdered chlorine is placed in the pipe and the section is recharged with water . Depending on the chlorine residual concentration, the water may be held in the section for up to 24 hours. This water is then flushed out, and a bacteriological sample is collected from the repaired section prior to it being placed back into service.

2.4 OPERATION AND MAINTENANCE

The City Manager is Jose Ramirez. The primary person responsible for oversight of the water system is Humberto Molina, Public Works Director. Based on the Department’s Operator Certification requirements, the City is classified as a T2 water system. The City employs three certified treatment plant operators: one T2 (Humberto Molina) and two T1 certified treatment plant operators (Tony Avina and Shawn Hess). The City is

Page 17

required to have a chief treatment plant operator certified as a T2, minimum, and a shift treatment plant operator certified as a T1, minimum. The City meets these requirements.

The City’s distribution system is classified as a D3 system. The City employs three certified distribution system operators: one D3 (Tony Avina) and three D1 certified distribution system operators (Shawn Hess, Jeff Arnold and Jesus Chavez, Jr.). The City is required to have a chief distribution system operator certified as a D3, minimum , and a shift distribution system operator as a D2, minimum. The City meets these requirements.

An operator visits each of the well sites on a daily basis, seven days per week. During the daily site visits, the operators read the hour meter, the flow meter and the pressure gauge. In addition , the operator collects a chlorine residual reading (twice per week). During the visit , the operator also visually inspects the well sites and performs routine maintenance on the wells.

The storage tank is visually inspected on a daily basis. During the inspections, the operator monitors the chlorine residual in the tank at three different levels in the tank, in addition to ensuring the site is secure. The City has installed a SCADA system that remotely monitors each of the well sites and the storage tank. The City does not anticipate a reduction in the daily well visits to a lesser frequency and relying more on the SCADA because they want to maintain the current level of service .

2.6.1 Cross-Connection Control Program

The City has a cross-connection control program by authority of City Ordinance Title 9, Chapter 5, Sections 53 to 70. The City has a total of 209 backflow prevention devices. All backflow devices must be tested on an annual basis.

During the inspection, the cross-connection control program was reviewed . The City appears to be in full compliance with the cross-connection control regulations. The City has a certified cross-connection control specialist on staff (Tony Avina) , has certified backflow prevention device testers on staff and uses the TOKAY software to assist with the operation of the cross-connection control program. The City has been using the TOKAY software since 2008 to help manage the cross-connection control program. The Water Division works closely with the Planning and Building Departments to ensure that all changes to the City’s users are properly inspected and adequate backflow protection is in place. The last system-wide cross-connection control survey was completed in 2006. The City does not anticipate conducting another system-wide cross-connection control survey because of the system that is in place to ensure that all new services or changes in service are reviewed and inspected by the cross-connection control specialist.

Page 18

2.6.2 Treatment Operations Plan

The City has an approved Chlorination Operations Plan and an Arsen ic Treatment Removal Facility Operations Plan on file with the Department. A revised Arsenic Treatment System Operations Plan will be required to incorporate pending changes to the treatment system. The City is required to update any of the Operations Plan when changes occur.

2.6.3 Emergency Notification Plan

The City has an Emergency Notification Plan, dated May 1, 2012, on file with the Department. The Plan lists Jose Ramirez, Tony Avina, and Jim Rightsell as the primary, secondary , and tertiary contacts in the event of a water quality emergency. The notification methods that will be used by the City include: radio, television , door-to­ door, and telephone (Code Red). The Department has requested an updated ENP because of the addition of Humberto Molina as the new Public Works Director.

2.6.4 Consumer Confidence Report (CCR)

The City is required to submit a CCR to each customer in this water system by July 151 of each year . A copy of the CCR and certification letter must be submitted to the Department by October 1st of each year. The document must be prepared in accordance with the proposed regulations. The 2011 CCR and signed certification form were submitted to the Department on September 11, 2012.

2.6.5 Vulnerability Assessment for Sources

Source water assessments were completed for the City’s wells by the Department in 2002. The City’s sources are considered most vulnerable to the following activities associated with contaminants detected in the water supply:

• Parks

• Chemical/petroleum pipelines

• Lagoons/liquid wastes

• Machine shops

• Wastewater treatment plants

• Hardware/lumber/parts stores

• Crops, irrigated [Berries, hops, mint, orchards , sod, greenhouses]

• Fertilizer/Pesticide/Herbicide Application

• Housing- high density [>1 house/0.5 acres]

• Septic systems- high density [>1/acre]

• Apartments and condominiums

Crops, nonirrigated [e.g., Christmas trees, grains, grass seeds, hay]

Page 19

• Sewer collection systems

• Automobile – Body shops

• Automobile – Repair shops

• Fleet/truck/bus terminals

• RV/mini storage

• Schools

The sources are also considered most vulnerable to the following activities not associated with any detected contaminants:

• Automobile – Gas stations

• Historic gas stations

• Dry cleaners

• Injection wells/dry wells/ sumps

• Septic systems- low density [<1/acre]

• Wells – Agricultural! Irrigation

• Agricultural drainage

The City is required to report this information each year to their customers in the annual Consumer Confidence Report (CCR).

2.7 WATER QUALITY AND MONITORING

2.7.1 General Mineral, General Physical and Inorganic Chemicals

Based on the Water Quality Monitoring Schedule, the City is required to test its active sources once every three years for general mineral, general physical and inorganic chemicals. A summary of the water quality analyses dates from the wells is provided below:

Well No.

GP/GM/10

Nitrate

Rads

Perchlorate

VOCs

SOCs

8

3/2010

2/2013

9/2011

1/2012

2/2012

3/2010

9

5/2010

2/2013

9/2011

1/2012

11/2009

5/2010

11B

3/2011

4/2012

10/2005

1/2012

11/2009

3/2010

12

3/2010

3/2012

6/2011

1/2012

9/2012

3/2010

13

(offline)

2/2012

2/2013

6/2005

2/2012

9/2012

11/2010

14

3/2010

2/2013

9/2005

4/2012

11/2009

3/2010

15

3/2010

2/2013

9/2005

2/2012

11/2009

3/2010

16

(offline)

9/2011

9/2011

9/2008

2/2012

9/2011

9/2011

Page 20

Arsenic Monitoring

The City is required to conduct arsenic monitoring as part of the inorganic chemical monitoring once every 3 years. Wells Nos. 8, 9, 11B, 12, 13, 14 and 16 were sampled for arsenic between 2010 and 2012. The results range between 5.2 ug/L and 9 ug/L. Well No. 15 is sampled quarterly for arsenic. The last sample was collected in December 2012 and was 8.97 ug/L. Well No. 13 is also supposed to be sampled on a quarterly basis for arsenic. The City lapsed in its quarterly sampling of Well No. 13 and will resume the monitoring during first week of April 2013. Well No. 16 is offline and also produces water with arsenic above the MCL. The last sample was collected in October 2011 and the result was 28.0 ug/L. A list of sample collection dates is provided in a “Last Sample/Next Due” report (Appendix B).

Perchlorate Monitoring

The City is required to conduct perchlorate monitoring as part of the inorganic chemical monitoring once every 3 years. Wells Nos. 8, 9, 11B, 12, 13, 14, 15, and 16 were sampled for perchlorate in 2012 and the results were non-detect (ND). A list of sample collection dates is provided in a “Last Sample/Next Due” report (Appendix B).

Manganese Monitoring

Wells Nos. 15 and 16 produce water with manganese above the secondary MCL. The City was issued Enforcement Letter No. 03-11-09E-048 on May 28, 2009 for Well No. 15. The letter requested a plan and timeline for developing a solution . The City responded to the letter and indicated that they would not be applying for a waiver but would research treatment system to remove the manganese from the water produced by Well No. 15.

The City conducts quarterly monitoring of Well No. 15 for manganese. The last sample was collected in December 2012 and was 69.0 ug/L. The secondary MCL for manganese is 50 ug/L. Well No. 16 is offline. Once Well No. 16 is brought online (post media change out), the filtered effluent will need to be monitored on a monthly basis for manganese.

2.7.2 Nitrate and Nitrite Monitoring

All active wells are required to be sampled for nitrates on an annual basis. However, Wells Nos. 8, 9 and 14 produce water with nitrate levels greater than half the MCL which requires them to be monitored for nitrates on a quarterly basis. Wells Nos. 8, 9, and 14 were last sampled for nitrates in February 2013 and the results were 23.8 mg/L, 7.6 mg/L, and 25.6 mg/L, respectively . However, Well No. 9 is not currently producing water with levels of nitrate greater than half of the MCL. The City may submit a written request to decrease the nitrate monitoring from quarterly to annual monitoring for Well

Page 21

No. 9. Well Nos. 13 and 15 were also sampled in February 2013 and the results were 2.1 mg/L and non-detect (NO), respectively. Well No. 11B was last sampled for nitrate in April 2012 and the result was non-detect (NO). Well No. 12 was last sampled for nitrate in March 2012 and the result was 17.4 mg/L. Well No. 16 was last sampled for nitrate in 2011 and the result was 7.9 mg/L.

All active wells are required to be tested for nitrite every 3 years . Wells Nos. 8, 9, 11B, 12, 13, 14, and 15 were last sampled for nitrite between 2010 and 2012. The results were non-detect (NO). Well No. 16 was last tested for nitrite in 2011 and the result was non-detect (NO). A list of sample collection dates is provided in a “Last Sample/Next Due” report (Appendix B).

2.7.2 Volatile Organic Chemicals (VOCs)

Volatile organic chemical monitoring is required once every 3 years . Wells Nos. 8, 12, and 13 were sampled for VOCs in 2012 and the results were non-detect (NO). Well No. 16 was last sampled for VOCs in 2011 and the results were non-detect (NO). A list of sample collection dates is provided in a “Last Sample/Next Due” report (Appendix B).

Wells Nos. 9, 11B. 14, and 15 were last sampled for VOCs in 2009 are now overdue. Wells Nos. 9, 11B. 14. and 15 must be sampled for VOCs by December 2013.

2.7.3 Synthetic Organic Chemicals (SOCs)

Synthetic organic chemical monitoring (alachlor, atrazine, DBCP, EDB, and simazine) is required once every 3 years. Wells Nos. 8, 9, 11B, 12, 13, 14, and 15 were sampled in 2010 for SOCs. With the exception of Wells Nos. 9 and 14, the results were all non­ detect (NO). Wells Nos. 9 and 14 produce water with detectable levels of DBCP. Well No. 16 was last sampled for SOCs in 2011 and the results were non-detect (NO). A list of sample collection dates is provided in a “Last Sample/Next Due” report (Appendix B).

1,2,3-TCP Monitoring

Several of the City’s wells produce water with detectable amounts of 1,2,3-TCP. The Notification Level for 1,2,3-TCP is 0.005 ug/L. The City conducts quarterly monitoring of Wells Nos. 8, 9, 11B, 12, 14, and 15 for 1,2,3-TCP. The last sample results collected in January 2013 ranged between 0.022 to 0.75 ug/L. The Department recommends that the City remove from service any source which produces 100 times the Notification Level. Due to high demand, the City needs all functioning wells to keep up with demand. The City notifies its customers of the 1,2,3-TCP levels via the annual Consumer Confidence Report (CCR).

The City filed a lawsuit against Dow Chemical claiming Dow Chemical was responsible for the 1,2,3-TCP contamination in the City’s wells. The lawsuit was settled out of court

Page 22

and resulted in monies being awarded to the City to provide treatment for removal of the 1,2,3-TCP. The City is proceeding with the design of treatment facilities for removal of 1,2,3-TCP from the water produced by Well No. 8. The City anticipates using GAC for removal of the 1,2,3-TCP. A maximum contaminant level for 1,2,3-TCP has not been established.

DBCP monitoring

Well No. 9 is monitored monthly for D8CP. The last sample was collected in March 2013 and the result was 0.1 ug/L. Well No. 14 was last sampled for D8CP in 2010 and the result was 0.18 ug/L. Well No. 14 must to be sampled on a quarterly basis for D8CP. Historical results for Well No. 14 show D8CP levels between 0.02 to 0.18 ug/L. Wells Nos. 8, 118, and 12 are sampled on a quarterly basis for D8CP. The last samples were collected in February 2013 and the results were non-detect (ND) for all three of the wells.

2.7.2 Radiological Constituents

The California Radionuclide Rule became effective on June 11, 2006. Initial monitoring requirements under the California Radionuclide Rule must have been satisfied by December 31, 2007. Analysis for uranium is required if the Gross Alpha activity is greater than 5 pCi/L. If the level of uranium detected is greater than 5 pCi/L, a Radium- 226 and a Radium-228 analysis must be completed . The City has satisfied all of the initial monitoring requirements and is in compliance with the MCLs for Wells Nos. 8, 9, 118, 12, 13, 14, 15, and 16. Well No. 8 is on a 3-year monitoring frequency for gross alpha. Well No. 9 is on a 6-year monitoring frequency for gross alpha. Wells Nos. 118, 12, 13, 14, 15, and 16 are on 9-year monitoring frequencies for gross alpha . The overall results and next sample due dates are appended in Appendix C.

2.7.3 Source Bacteriological Monitoring

The City collects monthly bacteriological samples from its active wells. A review of the data since May 2011 has revealed that the City has had one total coliform positive sample . The repeat sample was negative for total coliform bacteria. A summary of the source bacteriological results for the City is appended as Appendix E.

California Ground Water Rule

As per the requirements of the California Ground Water Rule (GWR), public water systems are required to conduct triggered source – monitoring whenever a routine distribution system sample is positive for total coliform bacteria . The City has specified that each active well will be sampled for E.coli when a routine distribution system sample shows the presence of total coliform bacteria.

Page 23

2.8 DISTRIBUTION SYSTEM MONITORING

2.8.1 Bacteriological Water Quality

Based on the number of service connections and population served, the City is required to collect and analyze four bacteriological samples per week from within the distribution system. The City has an approved Bacteriological Sample Siting Plan (BSSP), dated October 15, 2011, on file with the Department. A review of the data since May 2011 revealed that the City has had one coliform positive sample. All repeat samples were negative for coliform bacteria. The chlorine residual maintained in the distribution system is between 0.1 and 1.0 ppm. These results are indicated on the lab analyses. A summary of the distribution bacteriological results for the City since May 2011 is included in Appendix D.

2.8.2 Lead and Copper Rule Monitoring

The City completed initial monitoring requirements and is now allowed to collect the reduced number of 30 triennial samples. The goth percentile for lead should be less than

0.015 mg/L and the goth percentile for copper should be less than 1.3 mg/L. The City

last sampled for lead and copper in 2010. The results were below the respective Action Levels. Lead and copper monitoring is required during the months of June, July , August , or September. The next round of samples is due to be collected in 2013 . A summary of the data on file is included in Appendix F.

2.8.3 Disinfection Byproduct Monitoring (DBP)

Since the water from the wells is continuously chlorinated, the distribution system is required to be monitored for disinfection byproducts including total trihalomethanes (TTHMs) and haloacetic acids (HAA5s). The City submitted a Disinfection Byproducts Rule (DBPR) monitoring plan on December 4, 2003. The DBP plan indicates that the City will collect one sample per quarter from 2335 F Street , which represents the location of maximum residence time in the distribution system. The City has been collecting quarterly of monitoring for TTHM and HAA5 since 2004. The current running annual average (RAA) for the samples last collected in the 1st quarter of 2013 shows TTHMs at 4.1. ug/L and 1.6 ug/L for HAA5s, respectively.

Stage 2 DBPR

The City is considered a Schedule Ill system under the USEPA Stage 2 Disinfectants and Disinfection Byproducts Rule. The City received a 40/30 waiver for the Stage 2 DBPR Initial Distribution System Evaluation (lOSE) requirement. As such, the City is required to continue monitoring as they have done under the Stage 1 DBPR. Monitoring for Stage 2 DBPR will commence on October 1, 2013 . The City submitted a

Page 24

Stage 2 DBPR Plan, dated February 26, 2013, to the Department. The Plan was reviewed and approved on March 5, 2013 . The Plan lists the four locations where TTHM and HAAS samples will be collected every 90 days. The City has will collect the first quarter of Stage 2 monitoring during the second week of November 2013 . The PSCodes for the City’s Stage 2 monitoring sites are as follows:

PSCode

Stage 2 monitoring site

2410004-900

ST2DBP – 2235 F Street

2410004-901

ST2DBP- 1831 Wells Avenue

2410004-902

ST2DBP – 2981 Trigger Lane

2410004-903

ST2DBP – 1230 Olive Avenue

All analytical results from all monitoring conducted at the Stage 2 DBPR compliance monitoring locations must be submitted electronically to the Department’s Water Quality Inquiry (WQI) database via Electronic Data Transfer (EDT) by the tenth day of the following month.

Ill. SYSTEM APPRAISAL

The City of Livingston water system is in good overall condition . However, the City does not meet the Department’s maximum day and peak hour demand criteria. Several of the City’s wells produce water with concentrations of 1,2,3-TCP greater than the Notification Level. Wells Nos. 15 and 16 produce water with concentrations of manganese above the secondary MCL. Wells Nos. 13 and 16 are offline . Well No. 16 produces water with concentratiqns of arsenic above the MCL. An arsenic removal plant was installed and the Well No. 16 site which is no longer in service because the media is exhausted. The City is currently working on a Feasibility Study to evaluate centralized treatment, adding source capacity, and adding additional storage capacity. The City expects that the Feasibility Study to be completed by the end of April 2013. It is unclear as to whether or not the City has adequate financial resources to provide for the ongoing operation, maintenance, and upgrading of the system. The following items need to be addressed by the City:

1. The permitted active sources for the City are Wells Nos. 8, 9, 11B, 12, 13, 14, 15 and 16. The Merced District Office of the Drinking Water Field Operations Branch (DWFOB) must permit all other sources before they can be used in the water system . The City must immediately notify the Department in writing of any changes in the operating status of any source.

2. Wells Nos. 7 and 10 are designated as abandoned sources. The City is currently conducting a Feasibility Study to determine the fate of these two wells. If the City is not going to improve the wells , the City must destroy them in accordance with the

Page 25

Merced County Water Well Ordinance by December 31, 2013. Copies of the destruction logs must be provided to the Department.

3. The City must comply with the attached water quality monitoring schedule for all of the active sources. All water quality monitoring results obtained in a calendar month must be .submitted to the Department via electronic data transfer (EDT) by the 10th day of the following month.

4. The City shall prepare and submit a 5-year Budget Projection with a Capital Improvement Plan by June 1, 2013. A template is provided in Appendix G.

5. The City must submit copies of all plans and specifications for any water system improvement projects to the Department for review and approval prior to any work being done on the system.

6. A copy of the final Feasibility Report must be provided to the Department for review.

7. The City must complete the electronic Annual Report to the Drinking Water Program by April 30, 2013.

8. All backflow devices are required to be tested on an annual basis. Copies of the testing records must be kept on file for a minimum of 3 years .

9. The City must provide monthly well production records to the Department by the 10th day of the following month.

10. The City must implement stringent water conservation measures until further notice to prevent water outages.

11. The City must record all low pressure customer complaints and provide the Department with a monthly summary of the complaints by the 10th day of the following month.

12.Well No. 13 must be monitored on a quarterly basis for arsenic. The results must be submitted to the Department via EDT by the 10th day of the following month.

13.Wells Nos. 9, 11B, 14, and 15 must be sampled for VOCs by December 2013.

14.Well No. 14 must be sampled on a quarterly basis for DBCP.

15. The City must collect 30 lead and copper tap samples from the distribution system by September 30, 2013.

Page 26

16. The City must provide the status of what the City plans to do about the manganese exceedance for Well No. 15. The Department sent an email to the City with information on how to conduct a survey to obtain a 9-year monitoring waiver for the exceedance . The City needs to provide an update to the Department on what it plans to do by April 30, 2013.

17. With the exception of Well No. 16, all of the City’s active wells must be sampled for SOCs in 2013.

18.W IIs Nos. 8, 9, 12, 14, and 15 must be sampled for general mineral, general physical and inorganic chemicals by December 31, 2013.

19. The City must submit an updated Operations Plan for the arsenic treatment removal system at Well No. 16.

20. The City must provide a plan and timeline for addressing the recommendations in the 2013 tank inspection report by April 15, 2013.

Appendices

Appendix A: Water Quality Monitoring Schedule (CLGA)

Appendix B: Last/Next Due Monitoring Schedule

Appendix C: Summary of Radiological Monitoring Results and Monitoring Frequencies

Appendix D: Bacteriological Distribution Monitoring Report Appendix E: Source Monitoring Report

Appendix F: Lead/Copper Tap Monitoring Results Appendix G: 5-year Budget Projection w/CIP

CLC/mrw/2410004/lnspection Report.doc

Advertisements

4 thoughts on “California Department of Health: City of Livingston 2013 Water System Inspection Report

  1. Pingback: A Contract to Demolish The Court Theater, A Feasibility Analysis for a Sustainable Water Treatment, and a City Council Agenda | Thegardeningsnail's Weblog (because not every critter is hiding under a rock...)

  2. Pingback: Cockroaches, Arsenic, and TCP; A Requiem for the Court Theater and a Planning Commission Agenda | Thegardeningsnail's Weblog (because not every critter is hiding under a rock...)

  3. Pingback: Watering Days, Fireworks Booths, Arsenic, Sand and “Broken” Wells: plus a City Council Agenda | Thegardeningsnail's Weblog (because not every critter is hiding under a rock...)

  4. Pingback: Arsenic and Lawsuits, Workshops and Hearings; A Clean Up/Abatement Order from the Water Board, and a City Council Agenda | Thegardeningsnail's Weblog (because not every critter is hiding under a rock...)

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s