State of California?Health and Human Services Agency Kg California Department of Public Health .) on PH RON CHAPMAN, MD, MPH EDMUND G.BROWN JR. Director State Health Officer Governor October 23, 2013 Board of Supervisors County of Tulare 2800 West Burrel Avenue Visalia, CA 93291 LOCAL PRIMACY AGENCY ANNUAL EVALUATION REPORT FISCAL YEAR 2012-2013 Enclosed is the ?Local Primacy Agency Annual Evaluation Report? for the Tulare County Health Human Services Agency. The report covers the period from July 1, 2012 through June 30, 2013. This evaluation and report are required under Section 116330(d) of the California Health and Safety Code. The purpose of the evaluation is to review the status of the small water system program that is being conducted under the Local Primacy Delegation Agreement in effect between your Health Human Services Agency and the California Department of Public Health. Based on the evaluation ?ndings, it has been determined that your Health Human Services Agency is not in compliance with the Department?s local primacy program requirements at this time. The Local Primacy Agency (LPA) has not met the goals and objectives established in the FY 12/13 Workplan. The Department has identi?ed the required items that are necessary to meet the Health and Safety Code. The number of public water systems with ongoing primary MCL violations represents a signi?cant workload for the lead staff assigned to bring these systems into compliance. Lead staff in the LPA program must have detailed knowledge of all aspects of small water systems as well as the laws and regulations governing public water systems. Therefore, it is important that the Tulare County Health Human Services Agency allocates the resources to recruit, develop, retain, promote, and support staff to assure an able, knowledgeable, and motivated workforce is available to run the program effectively. There have been four different lead specialists in the water program over the last 10 which has resulted in a lack of continuity of institutional knowledge, experience and oversight in the water program. To address these concerns, CDPH is planning to assume regulatory jurisdiction of the 61 community water systems in Tulare County. This will allow the County to focus its existing resources on the 76 non-transient non-community and 153 transient water systems in the County. Southern California Drinking Water Field Operations Branch 265 W. Bullard Avenue, Suite 101, Fresno, CA 93704 (559) 447-3300; Fax (559) 447?3304 Internet Address: Tulare County LPA Evaluation FY 12/13 October 22, 2013 Please review the report, we will be can meet with the County to discuss the evaluation once it has been reviewed. If you have any questions, please contact me at (559) 447-3300. Sincerely, Tricia A. Wathen, P.E. Senior Sanitary Engineer SOUTHERN CALIFORNIA BRANCH DRINKING WATER FIELD OPERATIONS Enclosure cc: Jason Britt, Tulare County Health Human Services Agency Nilsa Gonzalez, Tulare County Health Human Services Agency Miguel Herrera, Tulare County Health Human Services Agency Wendy Killou, CDPH SWS Unit Carl Carlucci, CDPH Regional Engineer Local Primacy Agency Annual Evaluation Fiscai Year 201 2201 3 County of Tulare Local Primacy Agency Annual Program Evaluation County of Tulare Fiscal Year 2012?2013 INTRODUCTION On August 6 and 7th, 2013, the California Department of Public Health (CDPH) conducted the annual evaluation of the Tulare County Small Water System Program (SWSP) for the fiscal year (FY) 2012?2013. Tulare County?s Environmental Health Agency has been delegated as a Local Primacy Agency (LPA) and is the County entity responsible for administering the SWSP for public water systems (PWS) of less than 200 service connec?ons. CDPH representatives conducting the evaluation were Ms. Tricia Wathen, Visalia District Engineer; Mr. Carl Carlucci, CDPH Regional Engineer; Ms. Wendy Killou, Small Water Systems Unit Supervisor and Mr. Gene Reade, retired annuitant. Representing the LPA was Ms. Nilsa Gonzalez, Environmental Health Supervisor; Mr. Miguel Herrera, Water Specialist- Register Health Specialist ll; Mr. Yubley Vang, Field Inspector-Registered Health Specialist and Mr. Paul Charpentier, Staff Services Analyst II. This evaluation and report is mandated by California Health and Safety Code (CHSC) Section 116330(d). The purpose of the evaluation is to determine the program status with respect to the objectives set forth in the Tulare County LPA Delegation Work Plan for FY 2012?2013. This report summarizes the findings, recommendations, and directives of the Visalia District, Southern CDPH Drinking Water Field Operations Branch as it relates to LPA program elements as set forth in California Code of Regulations (CCR) Title 22, Sections 64253 through 64260. SUMMARY OF EVALUATION FINDINGS The Tulare County LPA has attempted to initiate and implement compliance with all current requirements of the California Safe Drinking Water Act for the small PWSs located within the county and is working to secure compliance. Tulare County LPA has not met the program objectives that were outlined in the approved FY 2012-2013 work plan and the LPA Program requirements set forth in CCR Title 22, Sections 64253 through 64260. Revised 8/?2/2013 Page i of 63 Local Primacy Agency Annual Evaiuation Fiscal Year 201 22013 County of Tulare DIRECTIVES AND RECOMMENDATIONS CDPH finds that the Tulare County LPA is not achieving general compliance with the LPA requirements for small PWSs and did not meet the goals and objectives established in the FY 2012?2013 work plan. By not meeting the goals and objectives, the public health of public water systems regulated by the LPA is unknown and thus a public health threat and concern. CDPH makes the following directives and recommendations regarding the County?s program: 1 . The LPA must conduct a TMF evaluation of any new public water system or change of ownership. A new water supply permit should not be issued unless all mandatory TMF elements have been provided. The LPA needs to work with the County Planning Department to identify any new proposed public water systems so that the LPA can provide comment on the source of water and/or require the proposed new system to connect to a nearby existing public waters system. The LPA must annually evaluate all the state small water systems to determine if any now meet the definition of a public water system. If the system meets the definition of a public water system, the system should be reclassified, permitted, and regulated as such in a timely manner. The LPA needs to conduct sanitary surveys (inspections) and evaluate all 8 elements of a public water system as required by regulations. The sanitary survey report should clearly identify any deficiencies with an associated deadline for submittal. The continued use of a table for deficient water quality sampling with no associated deadlines is not acceptable. The LPA needs to conduct follow-up on deadlines associated with enforcement actions or permits to ensure the required sampling or reports are conducted and the required information is provided timely. if the required information is not provided, the Revised 8/12/2013 Page 2 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tuiare 10. 11. 12. LPA needs to escalate the enforcement action or issue an appropriate enforcement ac?on. By December 31St of each year, the LPA needs to issue a Citation (addressing action) to any water system that does not have a required distribution system or treatment operator. By February 1, 2014, the LPA should provide the small water system Consumer Confidence Report (CCR) template to their public water systems so the required CCR information is used in the template and provided to the customers. The LPA should be checking for the new template when the Certification is provided to them from the public water system. The County indicated they were going to use the Access database (provided and used by the Visalia District) during the FY 2012?2013 for TCR tracking. The LPA started issuing Citations for TCR MCL violations in January 2013 and needs to continue issuing Citations or Compliance Orders for TCR MCL violations. For any construction projects -- new well or treatment plant, the LPA needs to confirm that CEQA has been completed before a water supply permit is issued. The State Clearinghouse number, date of circulation, and type of CEQA clearance should be identified in the permit. Quarterly, the LPA is recommended to request a Water Quality Monitoring Report from CDPH to ensure that the water systems are collecting samples and requesting that their accredited environmental health lab is successfully transmitting the water quality data electronically to CDPH as stated in CCR Title 22, Section 64469 (0). Requests for these reports can be made to District staff or Small Water Systems staff. The LPA shall correct TCR MCL violations that have a quarterly date range (as highlighted in this report) and update the record in their database of record with the correct begin and end date compliance period) that the water system violated the TCR MCL. The corrected data shall be transmitted to CDPH during the EDT process. Revised 8/12/2013 Page 3 of 63 Locai Primacy Agency Annuai Evaiuation Fiscai Year 2012-2013 County of Tulare 13. By July 1, 2014, the LPA shall require all public water system to update their Emergency Notification Plan using the state formatted form. 14. The LPA shall continue to enter quarterly violations for water systems that are violating the arsenic and nitrate MCL. 15. The LPA shall issue revised water supply permits at least every 10 years or when significant changes are made to PWSs using the state formatted permit including a state approved technical report, permit and certificate. 16. The LPA should utilize the CDPH Lead and Copper Rule database for tracking compliance with monitoring action level exeedances and monitoring and reporting of sampling for lead and copper. Contact Jim Stites to obtain a copy of the database and training on data entry and running the compliance determination reports. The number of public water systems in Tulare County with ongoing primary maximum contaminant level (MCL) violations is high and a large number of systems are out of compliance. This represents a significant workload for the SW8 program staff assigned to bring these systems into compliance. The SWS program staff in the LPA program must have detailed knowledge of all aspects of small water systems as well as the laws and regulations governing public water systems. it is extremely important that Tulare County continues to allocate the resources to recruit, develop, retain, promote, and support staff to assure an able, knowledgeable, and motivated workforce is available to run the water program effectively. Due to significant deficiencies noted in this evaluation and the significant workload of public water systems with nitrate violations and bacteriological problems, the LPA should add positions to this program to ensure the public is receiving water that meets the Safe Drinking Water Act. To address these concerns, CDPH is planning to assume regulatory jurisdiction of the 61 community water systems in Tulare County. This will allow the LPA to focus its existing staffing and resources on the 79 nontransient noncommunity and 164 transient noncommunity water systems in the County. CDPH has concerns with the Revised 3/12/2013 Page 4 of 63 Local Primacy Agency Annual Evaluation County of Tulare Fiscal Year 2012-201 3 public health and oversight of the existing public water systems and the existing staffing within the Tulare County LPA program. CDPH and the Tulare County LPA have been meeting regarding the new Delegation Agreement that needs to be signed by November 30, 2013 to be grant eligible for State Funding to assist LPA provide oversight and bring the LPA regulated systems into compliance with Safe Drinking Water Information System (SDWIS) with is a USEPA required tracking and reporting system. CDPH is working with the existing Tulare County LPA and County Counsel on new Delegation Agreement and program and staffing. CDPH looks fonrvard to our continued partnership as we share the oversight of PWSs in Tulare County. Report Submitted By: Tricia A. Wathen, P.E. Senior Sanitary Engineer, Visalia District CDPH Drinking Water Field Operations Report Prepared By: Lt i '1 {/11 i_ Date: ?3 i 997)! 301?? Wendy Klliou, Sienior Environmental Scientist CDPH Small Water Systems Unit Appendices: Appendix A - LPA Permit Activities Appendix - inventory Maintenance Appendix - Routine Inspections/Sanitary Surveys Appendix - Water Quality Monitoring Activities Appendix Reporting to CDPH Appendix - Enforcement Activities Appendix - Program Management/Work Plans Appendix - LPA Water System Inventory Appendix - CDPH Infrastructure Financing Programs Appendix CDPH Small Water Systems Program Plan Appendix - LPA File Review Appendix Water Systems Exceeding a Primary and Providing Treatment Revised 8/12/2013 Page 5 of 63 Local Primacy Agency Annual Evaluation Fiscai Year 2012-2013 County of Tulare Appendix A: LPA Permit Activities - CCR Title 22, Section 64254 All small PWSs are required to have a Domestic Water Supply Permit that must be accompanied by a technical report. These reports are submitted and reviewed at the time new water systems are proposed or an existing system is modified. The LPA issues new or amended water supply permits following a determination that the technical report is complete and an inspection of the new or modified water system is performed. in addition, the LPA primacy regulations require that all permits be re?evaluated at least once every 10 years to confirm that the permit information is current and that the permits contain conditions appropriate to ensure the proper operation of the water systems. The LPA typically renews a permit with a fee submittal but does not necessarily issue a revised permit in the CDPH format which includes a technical report, permit provisions and certificate every 10 years. The LPA needs to issue revised permits to PWSs at least every 10 years or whenever significant changes are made to PWSs in the CDPH format which includes a technical report, permit provisions and certificate. The LPA issued two water supply permits which was not close to the number of permits (39) identified in the FY 2012-2013 Work Plan. The two permits issued were in the CDPH format including a technical report, permit provisions and certificate. For any construction projects, new well or treatment plant, the County needs to confirm that CEQA has been completed before a water supply permit is issued. The State Clearinghouse number, date of circulation, and type of CEQA clearance should be identified in the permit. During FY 2012-2013, the LPA issued water supply permits in the CDPH format as summarized in Table 1. Revised 3/12/2013 Page 6 of 63 Locai Primacy Agency Annuai Evaluation Fiscal Year 2012-2013 County of Tuiare Table 1: Summary of Permits Issued .- PWS :5 i i 5402050 MILK Issued 6/7/2013- SPECIALTIES Change of Ownership GLOBAL 5403147 EXETER Issued 6/3/2013-New KINGDOM Water System HALL *C=Community P=Non-transient Non-community N=Transient Non-community TMF Capacity Evaluation Implementation The 1996 federal Safe Drinking Water Act amendments specified that new PWSs must have technical, managerial, and financial (TMF) capacity before they are permitted to operate by primacy agencies. A new PWS must demonstrate through its financial resources, technical resources, organizational structure, and personnel that it has the capability to comply with all applicable drinking water standards and regulations on an ongoing basis. As a condition of granting CDPH primacy to conduct the PWS regulatory program in California, the United States Environmental Protection Agency (USEPA) requires that CDPH have a mechanism in place to prevent the formation of new PWSs that do not have adequate TMF capacity. CDPH has chosen to incorporate the TMF requirements into its permitting process. In addition, under CHSC Section 116540(b) all PWSs that undergo a change of ownership after January 1, 1998, must demonstrate adequate TMF capacity before being granted a new permit. CDPH has developed criteria to be used in assessing the TMF capacity of PWSs. All LPAs are responsible for ensuring that new PWSs, PWSs undergoing a change of ownership, and funding program applicants have adequate TMF capacity or can acquire it in a specific time period. As such, permits issued by an LPA in all of these cases must contain provisions that require compliance with TMF capacity requirements as applicable. The County has incorporated the TMF capacity requirements into its permit process for new water systems and systems changing ownership. During the planning process and as part of the TMF evaluation, any proposed new public water system should be required to evaluate the cost of connecting to another public water Revised 3/12/2013 Page 7 of 63 Locai Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare system so that small public water systems are not formed. Where feasible, any proposed new public water system should be required to connect to another public water system. This hopefully reduces the formation of small water systems that may have TMF issues in the future and be out of compliance with water quality issues in the future. The LPA needs to work with the County Planning Department to identify any new proposed public water systems so that the LPA can provide comment on the source of water and/or require the proposed new system to connect to a nearby existing public waters system. THE LPA IS IN COMPLIANCE WITH APPENDIX A REQUIREMENTS: El YES NO The LPA was deficient with CCR Title 22, Section 64254 because the number of water supply permits that were identified in the FY 2011?2012 work plan was not completed. In addition, the permits issued did not include CEQA clearance information. The LPA has not been issuing a revised 10-year permit in a CDPH format with a detailed report and permit provisions as identified above. Appendix B: Inventory Maintenance - CCR Title 22, Section 64255 The PWS inventory in Tulare County consists of 304 water systems including: 61 community, 79 nontransient noncommunity, and 164 transient noncommunity PWSs as summarized in Table 2. Changes in the inventory during FY 2012?2013 are listed in Table 3. A detailed list of Tulare County small PWSs are found in Appendix H. The LPA maintains the following minimum required information for all PWSs in their Decade EnvisionConnect database. 0 Water system name . Water system identification number . Mailing address . Type of water system Revised 8/12/2013 Page 8 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare . Name, address, and phone number of the responsible party a Type of ownership 0 Type of water source 0 Type of treatment if any . Dates of operation for seasonally operated systems 0 Number of service connections 0 Population served Table 2: Current Water System Inventory Type 1 . FY2012201 3 -. -. -- FY2011201 2 Community 61 50 Nontransient Noncommunity 79 73 Transient Noncommunity 164 147 .-_To_tat' - Revised 8/12/2013 Page 9 of 63 Local Primacy Agency Annuai Evaluation Fiscal Year 2012-2013 County of Tuiare Table 3: Water System Inventory Changes (Based on what was provided by the LPA and not all inventory changes are noted below) PWS SystemName PWS Ciassufication Comments .- :Number__ Current .. Prior - - - 5400580 ALTA VISTA MHP Reclassrfication Community State Reclassrfication upon Sma? LPA review and water system feedback. 5400570 Reclassification Community State Reclassification upon STREET APTS. Small LPA review and water system feedback. 5403148 COURAGE TO Reclassification NTNC State Reclassification upon CHANGE Small LPA review and water system feedback. 5400744 EAST THREE Reclassification Community State Reclassification upon MUTUAL Small LPA review and water system feedback. 5403158 EAST VANDALIA Reclassification Community State Reclassification upon WC-WEST Small LPA review and water system feedback. 5400769 APTS. Reclassification Community State Reclassification upon Small LPA review and water system feedback. 5400759 Reclassification Community State Reclassification upon 1&2 Small LPA review and water system feedback. 5403089 GRUMPY BEARS Reclassification TNC State Reclassification upon Small LPA review and wate:r system feedback. 5400750 KAWEAH PARK Reclassification TNC State Reclassification Upon RESORT Smaii LPA review and water system feedback. 5403088 KENNEDY Reclassification TNC State Reclassification upon MEADOWS Small LPA review and water GENERAL STORE system feedback. 54030756 LAZY RANCH Reclassification TNC State Reclassification upon MOTEL Small LPA review and water system feedback. 5400887 PARK WATER Reclassification TNC State SYSTEM Small LPA review and water system feedback. 5403149 RANCHO LOPEZ Reciassification Community State Reclassification upon Small LPA review and water system feedback. 5400743 MOTEL Reclassification TNC State Reclassification upon 1 8x 2 Small LPA review and water system feedback. 5400964 SIERRA Reclassification Community State Reclassification upon ASSN Small LPA review and water system feedback. Revised 8/12l2013 Page 10 of 63 Local Primacy Agency Annuai Evaluation Fiscal Year 2012?2013 County of Tulare . PWSF -. .7 Activity-i P-WS-?Classificatien? - 5403073 SLATE MTN Reclassification TNC State Reclassification upon HOMEOWNERS Small LPA review and water system feedback. 5403038 SPRINGVILLE Reclassification Community State Reclassification upon WATER CO Small LPA review and water system feedback. 5400538 TCOVE Reclassification TNC State Reclassification upon Sma? LPA review and water system feedback. State Small Water System Inventory The LPA retains oversight of the state small water systems within the County, which serve between 5 and 14 service connections. During FY 2011~2012, the County identified 64 state small water systems. However, during the review of this inventory, CDPH noted that the LPA did not classify all of the systems correctly and it appeared that there may be a significant number of these state small water systems that are actually public water systems. A public water system is defined as ?a system for the provision of water for human consumption that has 15 or more service connections or regularly serves at least 25 individuals daily at least 60 days out of the year.? Based on a review of the State Small Water Systems in the County, approximately 35 new public water systems were identified. This is the reason for the large increase in public water systems during this last fiscal year. The LPA needs to review the state small system inventory annually and determine which systems meet the definition of a public water system and classify the system correctly as either a state small water system or a public water system (community, nontransient noncommunity or transient water system). If the system is classified as a public water system, the LPA needs to issue the public water system a permit and begin regulating the public water system in a timely manner. THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: YES CI NO Revised 8/12/2013 Page 11 of 63 Local Primacy Agency Annual Evaluation County of Tulare Fiscal Year 2012-2013 Appendix C: Routine Inspections/Sanitary Surveys - CCR Title 22, Section 64255 Routine inspection and sanitary survey frequencies are based on the type of water system, source type, and any required treatment. The frequencies are as follows, along with the CDPH performance requirements: Community Surface Water Treated Every 1 years Every 2 years Every 3 years Non-community Surface Water Treated Every 1 years Every 2 years Every 5 years Community Groundwater Treated Every 2 years Every 2 years Every 3 years Non-community Groundwater Treated Every 2 years Every 2 years Every 5 years Community Groundwater Untreated Every 3 years Every 5 years Every 3 years Non?community Groundwater Untreated Every 3 years Every 5 years Every 5 years A sanitary survey consists of a review of the water system permit and files as well as an onsite inspection of 8 elements in order to evaluate the water system?s ability to produce and distribute safe and reliable drinking water. The components of a sanitary survey are: 1. source(s) treatment distribution system finished water storage pumps, pump facilities, and controls monitoring, reporting, and data verification system management and operation operator compliance with State requirements The LPA does not consistently record or follow-up with water system deficiencies found during routine inspections or sanitary surveys to ensure corrective actions are conducted. Revised 8/12/2013 Page 12 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare Enforcement actions are typically not issued when a water system fails to correct the noted deficiencies in a timely manner. The County?s FY 2012-2013 work plan specifies the sanitary surveys will be conducted at the following frequencies base on District areas in the County: . Small PWSs using surface water or systems treating to meet a primary drinking water standard: once every 2 years. . Small community PWSs using groundwater without treatment: once every 3 years. 0 Small noncommunity PWSs using groundwater without treatment: once every 5 years. The FY 2012-2013 work plan identified 67 water systems that would receive routine inspections/sanitary surveys. LPA staff conducted 11 scheduled routine inspections/sanitary surveys which is only 30% of the projected routine inspections/sanitary surveys in the FY 2012-2013 work plan and 3.6% of the PWS inventory. A total of 9 unscheduled inspections/sanitary surveys were also conducted. A summary of the routine inspections/sanitary surveys conducted are shown in Tables 4 through 11. Table 4: Community Public Water Systems using Surface Water Meets CDPH PWS . . PerfmmaEce? Rbnaheginspeqtionslsanaiarv Surveys Not Applicable Unscheduled Inspections/Sanita Surveys Not Applicable *lnspections inciude all 8 elements of a sanitary survey. Revised 8/12/2013 Page 13 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 20122013 County of Tulare Table 5: Non-community Public Water Systems using Surface Water - . marine rement? (?very 5- years) Unscheduled lnspectionslSamtary Surveys - g- Not Applicable *lnspections include all 8 elements of a sanitary survey. Table 6: Community Water Systems using Treated Groundwater to Comply with a Primary Drinking Water Standard(s) - Mee't's'C'DP'l-l - . . -- Performance e'qulrement?? nispectionlSamtary ryey Completed" None completed *lnspections include all 8 elements of a sanitary survey. Table 7: Non-community Water Systems using Treated Groundwater to Comply with a Primary Drinking Water Standard(s) CDPH :jfigf?Performance ailRequrrement? j-j .?(Every5years) 3 '3'lnspectionlSamtarya away Completed* InelnspectzonslSamtary Survey -- None completed - None completed *lnspections include all 8 elements of a sanitary survey. Revised 8l12/2013 Page 14 of 63 LocaE Primacy Agency Annuai Evaluation Fiscal Year 2012-2013 County of Tulare Table 8: Community Water Systems using Untreated Groundwater 5400728 GRIER MUTUAL WATER CO 06/27/2013 5400631 LINNELL FARM LABOR CENTER 06/18/2013 5403134 RIVER RETREAT MUTUAL 12/05/2012 5400880 THE LAKES 04/18/2013 5400792 WOODVILLE FARM LABOR 06/20/2013 CENTER 5400647 YOKOHL MUTUAL WATER CO 06/03/2013 5401003 EAST OROSI CSD 07/16/2012 5400616 LEMON COVE WATER CO 03/27/2013 *lnspections include ail 8 eiements of a sanitary survey. Table 9: Non-community Water Systems using Untreated Groundwater 5400696 ARMY CORPS 02/05/2013 CAMP 4?2 5400695 ARMY CORPS 02/05/2013 CAMP 3-1 5400778 SCICON 06/04/2013 5400704 THREE RIVERS SCHOOL 01/22/2013 5403145 WAWONA PACKING COMPANY 02/21/2013 LLC 5403144 ALI WATER CO 09/27/2 12 5403062 COMFORT INN SUITES 09/27/2012 5402025 LAKESIDE MINNIT MART 11/27/2012 5402050 MILK SPECIALTIES GLOBAL 06/12/2013 5402050 MILK SPECIALTIES GLOBAL 02/05/2013 5403140 MONARCH NUT CO 07/17/2012 5400774 PIXLEY PARK 10/02/2012 *lnspections include all 8 elements of a sanitary survey. Revised 8/12/2013 Page 15 of 63 Fiscal Year 2012-2013 Locai Primacy Agency Annuai EvaEuation County of Tulare Table 10: Unscheduled Inspection Activities PWS "System Name Reason for Inspection . . .. .. 5400810 AKAL TRAVEL PLAZA 01/09/2013 FIELD 5401085 FANCHER CREEK PACKING INC 03/28/2013 FIELD 5401033 HORIZON NUT LLC 01/08/2013 FIELD 5403048 JD HEISKELL HOLDINGS LLC 04/23/2013 FIELD 5400537 LINDYS LANDING 03/19/2013 FIELD 5400537 LINDYS LANDING 03/18/2013 FIELD 5403053 NS MINI MART 12/17/2012 FIELD 5403053 NS MINI MART 11/27/2012 FIELD 5402038 PATTERSON TRACT CSD 01/23/2013 FIELD 5400529 SHADY GROVE 03/14/2013 FIELD 5400704 THREE RIVERS SCHOOL 04/04/2013 FIELD Table 11: Scheduled Water Systems That Were Not inspected PWS Prc' ?cted -- . Reason for? No Number . .. Name 35:35}? InspectIon 5401038 AKIN WATER CO Jun. ?.Dec 2012 5400757 ARMY CORPS ENG-HORSE Jun?Dec. 2012 CREEK 5400815 BEDEL MUTUAL WATER CO Jun?Dec. 2012 54010074 BOB WILEY DETENTION Jan-Jul. 2013 FACILITY 5400985 TINY MART Jan-Jul. 2013 5400894 CAMP SAN JOAQUIN Jun-Dec. 2012 5401010 CAMP WHITSETT Jun?Dec. 2012 5401049 CAMP WILDERNESS Jam-Dec. 2012 5400555 CENTRAL MUTUAL WATER CO Jun-Dec. 2012 5400582 CENTRAL WATER CO Jun.~Dec. 2012 5400890 CLM-FIR COVE GROUP Jun?Dec. 2012 CAMPGROUNOS 5400889 CLM-STONEY CREEK Jun?Dec. 2012 CAMPGROUND 5401025 DEER MEADOW MUTUAL Jam?Jul. 2013 5400895 FAR HORIZON CAMP Jun?Dec. 2012 5400557 HESTER SCHOOL Jun-Dec. 2012 5401033 HORIZON GROWERS Jan-Jul. 2013 5403090 IN 8 OUT FOOD MART 2013 5400599 KAWEAH HIGH SCHOOL Jun-Dec. 2012 5400515 LEMON COVE WATER CO Jun-Dec. 2012 5403001 LOWER SPRINGS WATER CO Jun-Dec. 2012 5400898 MONTECITO-SEQUIOA CAMP Jun?Dec. 2012 Revised 8/12/2013 Page 16 of 63 Fiscal Year 2012-2013 Local Primacy Agency Annual Evaluation County of Tulare PWS Projected Reason for No Number ys em ame Months/Year Inspection 5400951 MOONEY GROVE PARK Jan-Jul. 2013 5400819 MOUNTAIN VIEW MHP Jun-Dec. 2012 5403128 MOZZARELLA FRESCA Jun?Dec. 2012 5400724 PANORAMA PARK FIRE PRO CO Jun-Dec. 2012 5403081 PETERS FRUIT FAMS, INC Jun?Dec. 2012 5400732 PIERPOINT SPRINGS WATER Jun-Dec. 2012 CO 54 00934 PONDEROSA CSD Jun?Dec. 2012 5400895 PYTHIAN YOUTH CAMP Jun-Dec. 2012 5401001 SEQUOIA CIDER MILL Jan-Jul. 2013 5400701 SEQUOIA CREST WATER CO Jan-Jul. 2013 5400527 SHILOH WATER CO Jan?Jul. 2013 5400940 SIERRA KING HOMEOWNERS Jun?Dec. 2012 ASSN 5400924 SIERRA LAKES Jun?Dec. 2012 5400916 SIERRA MASONIC WATER CO Jun-Dec. 2012 5400552 STONEY CREEK- Restaurant Jun-Dec. 2012 Store 5401004 STYROTEK Jan-Jul. 2013 5400714 SUNDALE UNION SCHOOL Jun?Dec. 2012 5401022 THREE RIVERS GOLF COURSE Jun-Dec. 2012 5400920 TIPTON ELEM SCHOOL Jan-Jul. 2013 5400903 TRACT 92 CSD Jun?Dec. 2012 5400670 TRIPLE MUTUAL WATER CO Jan-Jul. 2013 5400797 TULARE CO CORRECTIONAL Jan?Jul. 2013 CENTER 5401039 TULARE COUNTY CIVIC Jan-Jul. 2013 CENTER 5403050 TULARE COUNTY RECYCLING Jun-Dec. 2012 5402027 TULARE COUNTY ROAD YARD Jun?Dec. 2012 #2 5400820 USFS-BLACKROCK STATION Jun-Dec. 2012 5403020 USFS-HORSE MEADOW CAMP Jun-Dec. 2012 5403034 USFS-JERKEY MEADOW Jun-Dec. 2012 TRAILHEAD 5400827 USFS-KENNEDY CAMPGROUND Jun-Dec. 2012 5400783 USFS-LOWER PEPPERMINT Jun-Dec. 2012 5400957 WEST GOSHEN MUT WATER CO Jun-Dec. 2012 5400718 WILLIAMS MUTUAL WATER CO Jun-Dec. 2012 5403043 YETTEM WATER Jan-Jul. 2013 Revised 8/12/2013 Page 17 of 63 Local Primacy Agency Annuai Evaluation Fiscai Year 2012-2013 County of Tulare THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: El YES NO The LPA was deficient with CCR Title 22, Section 64255 because the LPA did not conduct the water system inspections that were identified in their work plan. In addition, they did not adequately review the eight elements of a sanitary survey. Follow-up on past due water quality monitoring or required reports and plans was not consistent. In FY 2012-2013, two water system files were reviewed (East Orosi and Citrus South Tule School). For one system file reviewed, the inspection report showed the system was delinquent in all source water quality sampling (actually 6 years past due 2 monitoring cycles), lead and copper monitoring 2 years past due and inadequate follow-up on a lead sample that exceeded the action level (AL). Both the Emergency Notification Plan (ENP) and Bacteriological Sample Siting Plan (BSSP) were over 10 years old. By regulations, a BSSP is required to be updated as needed or a minimum of once every 10 years. The ENP is required to be updated annually as required; however, a new required format for State Office of Emergency Services and CDPH contact numbers required were obsolete (over 5 years old) or were not provided. The Consumer Confidence Report provided to the customers did not include the required updated format and several required tables of information and data were not provided. The system exceeded the Total Coliform Rule (TCR) for several months of the year and the public notification provided to the customers was for a TCR monitoring and reporting violation instead of a TCR violation. No proof of public notification was provided in the system file. However, this system was inspected in both 2011 and 2012, but no follow-up for the system?s deficiencies was completed. East Orosi?s - system file was reviewed again during this evaluation and the same deficiencies were noted although the system was inspected in July 2012 before the FY 2011-2012 evaluation. During the FY 2012-2013 evaluation it was noted that the LPA started to use a new inspection report with a checklist format. The intent of the new template is to streamline the Revised 8/12/2013 Page 18 of 63 Local Primacy Agency Annuai Evaluation Fiscai Year 2012-2013 County of Tulare inspection report so that more inspections could be completed efficiently. The Department reviewed and approved the new template for inspections as long as a complete list of water quality requirements, sampling frequency, last sample result and next due report is attached to the inspection form. In addition, any past due monitoring must be identified with a date required for collecting the past due monitoring. The LPA needs to follow-up with any past due monitoring identified that was not collected by the date required in the inspection report. The new inspection checklist format is not approved to be used for a technical report that accompanies a water supply permit. The technical report format should include a detailed description of the 8 elements of a sanitary survey, CEQA clearance and mandatory TMF elements. While CDPH understands the need for a new checklist inspection format, we want to stress the importance of reviewing all the information provided in the previous inspection when the next inspection is conducted. The intent of the inspection is not just to inspect the system but also review all the water quality data collected (or missing) and required reports and to determine compliance. Any past due water quality monitoring or operational requirements should be clearly identified and a deadline for submittal provided to the system. If the LPA does not follow~up on the missed water quality monitoring the system will continue to ignore and a monitoring and reporting violation continues. Monitoring and reporting violations for public water systems that have chemical monitoring requires a lot of oversight, tracking and if necessary enforcement to ensure compliance. This lack of follow-up on monitoring and reporting violations is a significant public health concern. Revised 8/12/2013 Page 19 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare Appendix D: Water Quality Monitoring Activities - CCR Title 22, Section 64256 Total Coliform Rule Monitoring Those water systems identified during this evaluation that failed to monitor and report for the Total Coliform Rule in accordance with CCR Title 22, Section 64256 are listed below in Table 12, including any enforcement action issued by the LPA to the water system informing them of the violation(s). To effectively manage monitoring and reporting requirements, the LPA tracks the water system monitoring and reporting deficiencies by utilizing the Access database provided by CDPH and takes the appropriate corrective action by issuing the proper enforcement actions. There are two types of Enforcement Actions - state actions (lA) or Citations/Compliance Orders (FL). The more formal enforcement action is a Citation or Compliance Order which puts the system on a path to compliance. Citations are for a non-continuing violation and Compliance Orders are for a continuing violation. A less formal state action or enforcement action is typically a Notice of Violation (NOV) or enforcement letter (EL) which cites a violation occurred, usually for a monitoring and reporting violation. The LPA issues a Notice of Violation (NOV) for Total Coliform Rule monitoring and reporting violations. During the FY 2011-2012 evaluation, CDPH discussed the use of the Access database for TCR tracking for MCL violations and monitoring and reporting violations. The LPA had the program but was not familiar with running the various reports. CDPH provided staff assistance with the Access database. The LPA indicated they were going to use the Access database (provided and used by the Visalia District) during the FY 2012-2013 for TCR tracking. The LPA had been using the database but not using the reports for the enforcement tracking. The Department has provided additional technical assistance since the evaluation to insure the LPA understands how in enter the data and run reports for both monitoring and reporting violations and MCL violations. As the LPA uses this database the bacteriological tracking and enforcement workload should improve. Revised 8/1212013 Page 20 of 63 Local Primacy Agency Annual Evaluation County of Tulare Fiscal Year 2012?20'] 3 Table 12: Total Coliform Rule Monitoring and Reporting Violations YMomtorIng. LPenod foircement Enforcement Action . ssue .. .12. . .. .. Date 5400708 ALPINE VILLAGE 4*h OTR 2012 IA 01/10/2013 WATER CO. 5400985 BOB TINY 1st OTR 2013 IA 04/10/2013 MART 5400985 BOB TINY 3rd OTR 2012 IA 10/10/2012 MART 5401049 CAMP 3rd QTR 2012 IA 10/10/2012 WILDERNESS 5403027 3rd OTR 2012 IA 10/10/2012 CAMPGROUND 5400655 CENTRAL JULY 2012 IA 08/10/2012 MUTUAL WATER CO 5400602 EAGLE NEST 4th OTR 2012 IA 01/10/2013 RESORT 5401003 EAST OROSI MARCH 2013 IA 04/10/2013 CSD 5403143 ELDERWOOD 3rd QTR 2012 IA 10/10/2012 MARKET 5403130 ELEANOR AUGUST IA 09/10/2012 ROOSEVELT 2012 COMM LEARNING CTR 5403051 FRIENDS RV NOVEMBER IA 12/10/2012 PARK 2012 5401080 LAKE EXPRESS 4th OTR 2012 IA 01/10/2013 MARKET 5402025 LAKESIDE 1st QTR 2013 IA 04/10/2013 MART 5402025 LAKESIDE OTR 2012 F0 01/10/2013 MIN 4T MA 5402025 LAKESIDE 3? OTR 2012 IA 10/10/2012 MINNIT MART 5400598 MCNALLY 4th OTR 2012 IA 01/10/2013 PAIRVIEW LODGE 5403120 PANADERIA LA NOVEMBER IA 12/10/2012 CABANA 2012 5400509 PANORAMA DECEMBER IA 01/10/2013 HEIGHTS PROP 2012 OWNERS 5400934 PONDEROSA NOVEMBER IA 12/10/2012 CSD 2012 Revised 8/12/2013 Page 21 of 63 Local Primacy Agency Annual Evaiuation Fiscal Year 2012-2013 County of Tulare at number-:2 assi?etiiq ri??df? -. ActiongI ps3; Acrion ?56 -. - a 1 3 Date -. 5402036 R- ANCH IN THE 2012 IA 10/10/2012 SEQUOIAS 5400550 SEVILLE WATER DECEMBER IA 01/10/2013 CO 2012 5400550 SEVILLE WATER SEPTEMBER IA 10/10/2012 CO 2012 5400737 ST ANTHONY 3rd QTR 2012 IA 10/10/2012 RETREAT 5400984 SUCCESS 3rd QTR 2012 IA 10/10/2012 MARKET 5403009 SUPER STOP 4th QTR 2012 IA 01/10/2013 5401039 TULARE OCTOBER IA 11/10/2012 COUNTY 2012 CENTER 5401010 USFS-CAMP 3rd QTR 2012 IA 10/10/2012 WHITSETT 5403145 WAWONA AUGUST IA 09/10/2012 PACKING 2012 COMPANY LLC 5400907 WHITE HORSE 3rd QTR 2012 IA 10/10/2012 INN 1-C=Community, P=Non-transient Non-community, or N=Transient Non-community 2?IA=Notice of Violation(s) or FL=C?tation or Compiiance Order FO=Citation with Penalty Chemical/Radiological Monitoring The LPA notifies water systems of the monitoring and reporting requirements by providing a water quality monitoring schedule to the water system Operator annually or by including the schedule with other correspondence to the water system during the year. However, there is no follow-up by LPA staff with past due monitoring for water systems. Chemical data submitted by water systems are received and reviewed by the program specialist to ensure compliance with the chemical constituents? monitoring and reporting requirements and to advise the water system of any follow-up sampling requirements. Hard copies of all chemical monitoring results are maintained in the water system file. All transient noncommunity systems have conducted required analyses at least once when the water sources were initially placed into service. However, this sampling data may have been collected before the Department?s electronic data transfer (EDT) was operational. Revised 8/12/2013 Page 22 of 63 Locai Primacy Agency Annuai Evaluation Fiscal Year 20122013 County of Tulare Therefore, this data is only available as a hard copy and is not in the CDPH Water Quality inquiry (WQI) database which shows the system delinquent for water quality monitoring. While this missing electronic water quality data may not seem important, this data is merged with the required monitoring schedule and available on website, which is available to the water system, water system operator and the public. The system will appear to be out of compliance for sampling until a new sample is collected or the old data is transferred electronically. The LPA should work with the transient noncommunity water systems to get this one time data into the database or have them collect another water quality sample for the required constituents so the data is transferred electronically and update to date information is also available. Table 13 summarizes the monitoring and reporting violations of small PWSs for general minerals (GM), inorganic chemicals organic chemicals (OC), radiological constituents (Rad), lead and copper (LCR), and disinfection byproducts (DBP). Based on a review of this data, it appears there were no LCR, DBP or Rad monitoring and reporting violations violations for the 304 public water systems the LPA regulates. Based on a query of the CDPH water quality database or Radiological monitoring only, this appears to be inaccurate. it appears the LPA is not reviewing the LCR, DBP or Radiological monitoring completely or correctly as the violations are not identified or entered into the database. The LPA needs to review the LCR, DBP and Radiological monitoring annually and issue enforcement to public water systems with violations. During the sanitary survey evaluation all water quality monitoring should be reviewed. Any past due monitoring should be clearly identified and a deadline provided for submittai. CDPH recommends that the LPA start using the CDPH database for the compliance tracking for chemical monitoring instead of using the current spreadsheet with data entered in manually by the LPA. The LPA now has access to WQI through a remote access and the PWSs have access to the most recent water quality sampling data and sampling frequencies on the CDPH website for Water Quality Monitoring Schedules. Revised 8/12/2013 Page 23 of 63 Local Primacy Agency Annuai Evaluation Fiscai Year 2012?2013 County of Tuiare The Department?s website is updated quarterly with the County?s monitoring schedule and last sample collected for each public water system. This schedule clearly identifies the last sample result, sampling frequencies and next sample due date for each constituent. This is now available for the public water system?s governing board, the water system?s operator and the general public. The LPA should request the water quality monitoring reports for the LPA systems from the CDPH Visalia District Office quarterly. A copy of the monitoring reports should be provided to the LPA system annually. Certified Treatment and Distribution System Operators . CHSC Section 106885 states that any person who operates or supervises the operation of a water treatment plant or a distribution system of a community or nontransient noncommunity water system shall possess a valid and current water treatment and/or distribution operator certificate of the appropriate grade in accordance with the regulations referenced in CHSC Section 106910. The determination of the level of operator certification required for a public water system is defined in CCR Title 22, Sections 63765 for water treatment and 63770 for distribution systems. The LPA has classified all water systems for the appropriate level of water treatment and distribution system operator certification. Each water system has been advised of its system classification for certified treatment or distribution system Operator certification. Table 13 summarizes water systems that are not operating with an operator or with the appropriate level certified operator. There were 4 NOVs issued to public water systems for not having a certified treatment or distribution system operator. Consumer Confidence Reporting Title 22, Section 64480(a) requires each community and nontransient noncommunity public water to issue an annual Consumer Confidence Report (CCR) to customers. All water systems use the standardized reporting format for small public water systems CCRs. The water system is required to distribute the OCR to its customers and provide a copy to the Revised 8/12/2013 Page 24 of 63 Locai Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare County. In addition, the water system is to provide certification that the report has been distributed to its customers and that the information is correct and consistent with the compliance monitoring data submitted to the LPA. Table 13 lists water systems in violation of the OCR requirements for FY 2012?2013. According to the data provided to CDPH, there were no CCR violations in FY 2012-2013 which means all of the CWS and NTNC water systems provided a 2011 CCR to their customers by July 1, 2012 with a copy and certification of delivery to the LPA by October 1, 2012. During the review of the system files, it was noted that some reguired tables were missing in the OCR and an old template was used by the systems. An updated template is developed by CDPH annually to include all required tables or language. A small water system template is also available with very clear directions of what information needs to be provided. By February 1St of each year, the LPA should provide the small water system CCR template to their public water systems to help ensure the required information is provided to the customers. Revised 8/12/2013 Page 25 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 20122013 County of Tulare Table 13: Chemical/Radiological Monitoring and Reporting Violations, OCR, and Certified Operators - -. ,ager??ed,. Ii fatOl? 5 CCR 5400144'nm ALI mam I-.. [j '2012' 5400544 ALLENSWORTH 04/10/2013 2013 5400894 CAMP SAN JOAQUIN 2012 5401053 01/10/2013 5400523 EL MONTE VILLAGE :1 Eitj IX 10/10/2012 3MCITR 2012 5400896 FAR HORIZON CAMP 01/10/2013 2012 5400987 FOUNTAIN SPRINGS EL TAPATIO I 10/10/2012 ydoTR 2012 5403090 IN AND OUT FOOD MART Taking March exam. 5401080 LAKE EXPRESS MARKET 04/10/2013 1st QTR 2013 5401080 LAKE EXPRESS MARKET 01/10/2013 ?hoTR 2012 5402025 LAKESIDE MINNIT MART 04/10/2013 2013 5402025 LAKESIDE MINNIT MART IXI 01/10/2013 2012 5402025 LAKESIDE MINNIT MART 10/10/2012 smoTR 2012 5400628 LEMON COVE- SEQUOIA CAMP 01/10/2013 #hoTR 2012 Revised 8/12/2013 Page 26 of 63 Loca! Primacy Agency Annua! Evaluation County of Tulare Fiscal Year 2012?201 3 leff'f'LCR Operator I . CC i?-Qdf?f?i if?? Acti?n i 5400628 LEMON 00v; SEQUOIA CAMP 10/10/2012 3rd QTR .. .. 2012 5403001 LOWER SPRINGS ED DI 5400898 MONTECITO LAKE RESORT 01/10/2013 2012 5400918 OPEN COUNTRY SWAP MEET 04/10/2013 131 QTR 2013 5400924 SIERRA LAKES MINISTER CAMP 2012 5400805 SOULTS MWC 222220 01/10/2013 5400552 STONEY CREEK RESTAU 01/10/2013 2012 5401004 STYROTEK 04/10/2013 18? QTR 2013 5401004 STYROTEK 10/10/2012 3rd QTR 2012 5400984 SUCCESS MARKET DIXI- EIDD 01/10/2013 2012 5403009 SUPER STOP 01/10/2013 3RU QTR 2012 5403105 THE BARN 01/10/2013 2012 5403071 THREE RIVERS CHEVORN 0.0.2222 01/10/2013 2012 5400704 THREE RIVERS SCHOOL 01/10/2013 2012 5402030 WAU KE NA MARKET EIIXI 01/10/2013 QTR 2012 5402030 WAUKENA MARKET 10/10/2012 3mi QTR 2012 1-C=Community, P=Non~transien2 Non-community, or N=Transient Non-community 2?1A=Notice of Vio!ation(s) or FL=Citation or Compliance Order FO=Citation with Penaity Revised 8/32/2013 Page 27 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tuiare . Surface Water Sources PWSs with a surface water source are required to have a multi-barrier treatment process that includes filtration and disinfection to ensure the removal and/or inactivation of disease- causing viruses, bacteria, and protozoa. The Surface Water Treatment Rule (SWTR), interim Enhanced Surface Water Treatment Rule (IESWTR), Long Term 1 and Long Term 2 Enhanced Surface Water Treatment Rule established standards for approved filtration methods to ensure that these pathogens are reliably removed by the filtration process. The surface water systems in Tulare County were transferred to CDPH, so there are no surface water systems in the regulatory jurisdiction. Table 14: Inventory of Surface Water Systems . aniolatlon 0f . Filtration heSWTRandIor _-?-Number1 - .. -- -- -. (Yes/No) Tulare County does not have any surface water systems in their regulatory jurisdiction. *C=Community. P=Non-transient Non-community, or N=Trans?ent Non-community THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: YES El NO The County was deficient with CCR Title 22, Section 64256 because the County did not issue an enforcement action to systems that had a LCR, DBP and Radiological monitoring and reporting vioiation. As such, with monitoring an? reporting vioiati . and no samples collected the public health impacts associated with those constituents is unknown for the LPA regulated systems. This is a public health threat. In addition, the review of the annual CCR was not adequate for mandatory language and tables that are required to be provided to the customers. Revised 8/12/2013 Page 28 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012-2013 County of Tulare Appendix E: Reporting to CDPH - CCR Title 22, Section 64257 The need for both CDPH and LPAs to develop the capability to transmit PWS program information via electronic data transfer (EDT) is a requirement of the EPA. The information that is required to be reported includes: . A list of all small PWSs that failed in the previous month to comply with drinking water monitoring and reporting regulations. This includes primary drinking water standard violations as well as monitoring and reporting Violations. Information provided should include the system name and number, the type of violation, and the type of enforcement action taken if any. . Quarterly: A list of permits that have been issued, amended, or renewed as well as a list of small PWSs for which a routine inspection or sanitary survey was conducted. 0 Annually: The inventory of small PWSs under the jurisdiction of the LPA. CDPH has requested that these reports be submitted by the LPA. CDPH reviews these files as they are received from the LPA and advises the LPA of any reporting deficiencies associated with transmitting the files. The LPA is expected to review these error reports and correct any data formatting errors accordingly and then resubmit the data along with the data for the following reporting period. The LPA uses Decade EnvisionConnect to comply with the EDT reporting requirements. The LPA submitted the required data in a timely manner for FY 2012?2013. THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: YES NO Revised 8/12/2013 Page 29 of 63 Local Primacy Agency Annual Evaluation Fiscai Year 2012-2013 County of Tulare Appendix F: Enforcement Activities CCR Title 22, Section 64258 The enforcement activities conducted by the LPA are those specified in the primacy agreement and include conducting site visits to the systems to assist in determining the cause of bacteriological contamination, directing corrective actions, requiring notification of the consumer as required, requiring that the water system issue boil water orders or provide bottled water as necessary until water quality deficiencies have been corrected, and issuing addressing enforcement actions. Addressing enforcement actions include the issuance of compliance orders, citations (with or without fines), administrative hearings, or other actions that meet the definition as outlined in the USEPA Enforcement Response Policy dated December 8, 2009. Total Coliform Rule MCL Violations and Enforcement When a small public water system has been determined to have failed the Total Coliform Rule (TCR) MCL, LPA staff may conduct a site inspection of the water system when the cause of the contamination cannot be easily determined by the system operator. If LPA staff is able to determine the cause of the problem, then guidance is provided to the system operator regarding corrective mitigation measures, follow?up monitoring, and public notification requirements. The system then is responsible for implementation of the mitigation measures. Where repeat samples are required, the water system collects 5 routine samples the following month in accordance with requirements of the TCR. However, for the last few years there have been some public water systems with multiple TCR MCL violations in a year so the corrective measures were either not initiated or consistently implemented. The LPA then issues a Citation to notify the water system that they failed the TCR MCL for the month(s) specified which includes various directives for the water system to comply with a specified compliance schedule. These directives may include, but not limited to public notification, repeat sampling requirements, and/or increased monitoring requirements. Listed in Table 15 are the water systems that violated the TCR MCL in FY 2012-2013. Revised 3/12/2013 Page 30 of 63 Local Primacy Agency Annual Evaiuation Fiscai Year 2012-2013 County of Tulare The LPA shall correct TCR MCL violations that have a quarterly date range (as highlighted in Table 15) and update the record in their database of record with the correct begin and end date compliance period) that the water system violated the TCR MCL. During the FY 2011-2012 evaluation, it was noticed that the LPA was issuing a NOV for TCR MCL violations which is not the correct enforcement action for a MCL violation. As such, all the TCR MCL violations in Table 15 below should all be Citations with addressing actions. In addition, if any system has an additional TCR MCL violation the system should be issued a Compliance Order as the violation is continuing. The County was informed during the evaluation FY 201 1-2012 that they need to issue Citations for TCR MCL violations during FY 2012-2013. CDPH has been provided with some Citations that were issued in January 2013 when the LPA started to use Citations correctly for a MCL violation. The LPA needs to continue issuing Citations for TCR MCL violation or a Compliance Order for system with repeat or multiple TCR MCL violations during a 12 month period. Chemical and Radiological Violations and Enforcement Chemical data submitted by the water systems is reviewed by the program specialist to ensure compliance with the MCL requirements. if necessary, the LPA advises the water system of any follow?up sampling requirements. When a system collects a sample for nitrate that is over the MCL, the system is required to collect a confirmation sample and average the two results. If the average of the two samples is above the MCL or the confirmation sample is never collected, then the LPA needs to issue a Compliance Order to the system which requires ongoing monitoring, Tier 1 public notification, proof of public notification and requirement to develop a plan to correct the violation and return to compliance. According to Title 22, Section 64432.1, the nitrate MCL is exceeded with a single sample or average of 2 samples if the repeat is collected within 24 hours. The nitrate MCL is NOT based on the 4 quarter running annual average as it is an acute contaminant. Revised 8/i2l2013 Page 31 of 63 Local Primacy Agency Annual Evaluation Fiscal Year 2012?201 3 County of Tulare Hard copies of all chemical monitoring results are retained as hard copies in the water system file. Listed in Table 16 are the water systems in FY 2012?2013 that exceeded a chemical or radiological MCL along with the associated enforcement action issued. Systems that provide treatment for a primary MCL are listed in Appendix K. Based on a review of this data, it appears there was only one DBP or Rad monitoring MCL violation for the 304 public water systems the LPA regulates. Based on a query of the CDPH water quality database or Radiological monitoring only, this appears to be inaccurate. It appears the LPA is not reviewing the LCR, DBP or Radiological monitoring completely or correctly as the violations are not identified or entered into the database. The LPA needs to review the DBP and Radiological monitoring annually and issue appropriate enforcement actions to public water systems with violations. Revised 8/12/2013 Page 32 of 63 Table 15: Total Coliform Rule MCL Violations and Enforcement c: i Enforcement onType2 . 5931371 Enforcement . .-. .- Actionlssue -- 540001 0 AKALTRAVEL i PLAZA 5400810 AKAL TRAVEL PLAZA 5400810 AKAL TRAVEL PLAZA I NOVEMBER 2012 I 02/10/2013 10/10/2012 FO 12/10/2012 5401038 AKIN WATER CO 5403144 ALI WATER CO 5403144 ALI WATER CO 2 22 5400922 BARTLETT PARK 5400919 BUENA VISTA SCHOOL DECEMBER 2012 NOVEMBER 2012 JANUARY 2013 01/10/2013 10/10/2012 12/10/2012 Kg" 10/10/2012 02/10/2013 5400921 CEDAR SLOPE WATER CO OCTOBER 5400766 CLM-QUAKING ASPEN CAMPGROUND 20. 5400942 CLM-REDWOOD MEADOW CAMPGROUND 5403062 COMFORT INN SUITES Revised 8/12/2013 2012 41:] DEBBIE 11/10/2012 10/10/2012 CI 10/10/2012 FO 10/10/2012 Page 33 of 63 System; Name PWS CIassnf?catuon MC Enforcement 5 IACtloniTyipe Penod Action ssue nfo rcement I 5.5311 II I .. - . 5403130 ROOSEVELT COMM LEARNING CTR 5400762 GIUMARRA VINEYARDS 3 8: 4 5400763 GIUMARRA VINEYARDS 5 6 5402047 GLEANINGS FOR THE HUNGRY 2012 I3 IXI FO 10/10/2012 FO 10/10/2012 El FO 10/10/2012 5402047 GLEANINGS FOR THE HUNGRY 2200 OCTOBER 2012 F0 11/10/2012 5401 076 GOLDEN STATE VINTNERS CL JULY 2012 08/10/2012 5401076 GOLDEN STATE VI NTNERS SEPTEMBER 2012 El CI 10/10/2012 5403141 HELLWIG PRODUCTS CO INC JANUARY 2013 02/1 012013 5403141 HELLWIG PRODUCTS CO INC FEBRUARY 2013 K4 03/10/2013 5403083 JODY FRESH COOLING CO - PWS 5400537 LINDYS LANDING 5400951 MOONEY GROVE PARK Revised 8/12/2013 OCTOBER 2012 11/10/2012 01/10/2013 10/10/2012 Page 34 of 63 .PvV?fsgra aon 5401040 WALLACE - RR DONNELLEY 2012 . Enforcement ACtIOnType Enforcement I Date 5401040 MOORE WALLACE - RR DONNELLEY NOVEMBER 2012 El 12/10/2012 54031 02 NEW LEAF COLD STORAGE Cl. 5403053 NS MINI MART 5403053 NS MINI MART 5400918 OPEN COUNTRY SWAP MEET 22 5400519 PALO VERDE SCHOOL DECEMBER 01/10/2013 FO 10/10/2012 FO 12/10/2012 10/10/2012 JANUARY 2013 02/10/2013 5402038 PATTERSON TRACT CSD JANUARY 201 3 51 F0 02/10/2013 5402038 PATTERSON TRACT CSD FEBRUARY 2013 FO 04/10/2013 5402038 PATTERSON TRACT CSD OCTOBER 2012 11/10/2012 5402038 PATTERSON TRACT CSD NOVEMBER 2012 FO 12/10/2012 5402038 PATTERSON TRACT CSD 0,00000 DECEMBER 2012 FO 01/10/2013 5400774 PIXLEY PARK JANUARY 201 3 El 02/10/2013 5400774 PIXLEY PARK FEBRUARY 2013 FO 03/10/2013 Revised 8/12/2013 Page 35 of 63 54007f4" 5402031 PREET MARKET 5400556 RIVER RETREAT MUTUAL Actonlssue '1'0/1'0'1261'3'2' .. 10/10/2012 10/10/2012 5400556 RIVER RETREAT MUTUAL OCTOBER 2012 11/10/2012 5400556 RIVER RETREAT MUTUAL - 3:352 0 NOVEMBER 2012 12/10/2012 5400709 SEQUOIA UNIO SCHOOL 0. NOVEMBER 2012 12/10/2012 540071 1 SIERRA VIEW ACADEMY 0. NOVEMBER 2012 12/1 012012 7131515] [j 5400754 SO KAWEAH MUTUAL WATER CO AUGUST 2012 FO 09/10/2012 5400754 SO KAWEAH MUTUAL WATER CO SEPTEMBER 2012 F0 10/10/2012 5403040 SUHOW WATE SYSTEM FEBRUARY 2013 F0 03/10/2013 5400751 THREE RIVERS HIDEAWAY FEBRUARY 2013 5400751 THREE RIVERS HIDEAWAY 5400751 THREE RIVERS HIDEAWAY 5400567 TOOLEVILLE WATER COMPANY FO 03/10/2013 FO 10/10/2012 FO 01/10/2013 FO 10/10/2012 Revised 8/12/2013 Page 36 of 63 vuwn'ber: vcui?'sii? ??tidon ""54?02022" 'rnAvERanL FARMS - PWS 540301 1 USA PETRO SUPER STOP 5403046 VISALIA CITRUS ORANGE COVE 2012 Actronlssue 01/10/2013 10/10/2012 5403046 VISALIA CITRUS PACKING- ORANGE COVE OCTOBER 2012 gs FO 11/10/2012 1-CxCommunity, P=Non-transient Non-community, or N=Transient Non-community 2-EAeNotice of Violation(s) or FL=Citation or Compliance Order or For-Citation with Penalty 3~Under the Enforcement Response Policy and Enforcement Targeting Tool (ERP-ETT), water systems? violations are evaluated using a weighed points system. Each violation is assigned a number of points based on the assigned threat to public health, where priority is given to acute health based violations. (Acute health?based vioiations are worth 10 points, other health-based violations and Total Cotiform Rule repeat monitoring violations are worth 5 points, nitrate monitoring and reporting violations are worth 5 points, and other monitoring and reporting and any other violations are worth 1 point.) Systems that are checked above have greater than or equal to 11 points, are designated as ?priority systems", and have appeared on the ETF during the ?scal year. Revised 8/12/2013 Page 37 of 63 Table 16: Chemical Radiological MCL Violations and Enforcement Number SystemName I . .. Enforcement Action 5400810- mm." PLAZA ?ff-ate .. FL .. 07/28/2010 Itst QTR 2013 5400810 TRAVEL PLAZA Nitrate FL 07/28/2010 3rd QTR 2012 5400810 AKAL TRAVEL PLAZA Nitrate FL 07/28/2010 4th QTR 2012 5400544 ALLENSWORTH Arsenic FL 12/21/2010 3rd QTR 2012 5400544 ALLENSWORTH Arsenic 0.010 mg/L FL 12/21/2010 4th QTR 2012 5400544 ALLENSWORTH Arsenic 0.010 mg/L FL 12/21/2010 4th QTR 2012 5403022 APTCO LLC Nitrate 45 mg/L FL 03/23/201 1 1st QTR 2013 5400651 BEVERLY GRAND MUTUAL WATER Nitrate 45 mg/L FL 05/24/201 1 1st QTR 2013 5400651 BEVERLY GRAND MUTUAL WATER Nitrate 45 mg/L FL 05/24/201 1 3rd QTR 2012 5400651 BEVERLY GRAND MUTUAL WATER Nitrate 45 mg/L FL 05/24/201 1 4th QTR 2012 5400919 BUENA VISTA SCHOOL Nitrate 45 mg/L FL 07/28/2010 ist QTR 2013 5400919 BUENA VISTA SCHOOL Nitrate 45 mg/L FL 07/28/2010 4th QTR 2012 5401053 CHARLIE Nitrate 45 mg/L FL 09/14/2010 1st QTR 2013 5401053 CHARLIE Nitrate 45 mg/i. FL 09/14/2010 3rd QTR 2012 5401053 CHARLIE Nitrate 45 mg/L FL 09/14/2010 4th QTR 2012 5400555 SOUTH TULE SCHOOL Nitrate 45 mg/L FL 09/14/2010 1st QTR 2013 5400555 CITRUS SOUTH TULE SCHOOL Nitrate 45 mg/L FL 09/14/2010 4th QTR 2012 5403030 DRY CREEK DELI Nitrate 45 mg/L FL 10/01 /2007 1st QTR 2013 5403030 DRY CREEK DELI Nitrate 45 mg/L FL 10/01/2007 4th QTR 2012 5403007 THARP INC Nitrate 45 mg/L FL 10/03/2012 3rd QTR 2012 5403007 THARP INC Nitrate 45 mg/L FL 06/06/2007 El 1:1 Cl E3 IXI El 3rd QTR 2012 Revised 8/12/2013 rage 38 0163 PWS Contaminant MCL rcement Enforcement - - Comments - . Date PWS 3 SYStemName Numm? -- 5401603 EAST O'Rog'sieSDT I I 58.80- 04/15/2010 5400523 EL MONTE VILLAGE Nitrate 55.90 05/24/201 1 1st QTR 2013 5400523 EL MONTE VILLAGE Nitrate 47.80 05/24/201 1 4th QTR 2012 5400987 FOUNTAIN SPRINGS EL TAPATIO Nitrate 67.00 45 mg/L 09/14/2010 1st QTR 2013 5400987 FOUNTAIN SPRINGS EL TAPATIO Nitrate 65.00 45 mg/L FL 09/14/2010 4th QTR 2012 5400763 GIUMARRA VINEYARDS 5 6 Nitrate 48.0 45 mg/L FL 10/3/2012 2012 Annual 5400548 KINGS INN MOTEL Nitrate 70.00 45 mg/L FL 07/28/2010 1st QTR 2013 5400548 KINGS INN MOTEL Nitrate 73.00 45 mg/L FL 07/28/2010 3rd QTR 2012 5400548 KINGS INN MOTEL Nitrate 67.00 45 mg/L FL 07/28/201 0 4th QTR 2012 5402024 KINGS RIVER MARKET Nitrate 53.20 45 mg/L FL 09/14/2010 1st QTR 2013 5402024 KINGS RIVER MARKET Nitrate 53.20 45 mg/L FL 09/14/2010 3rd QTR 2012 5402024 KINGS RIVER MARKET Nitrate 45.80 45 mg/L FL 09/14/2010 4th QTR 2012 5400660 LAKE SUCCESS MOBILE LODGE Nitrate 84.00 45 mg/L FL 09/14/2010 1st QTR 2013 5400616 LEMON COVE WATER CO Nitrate 60.00 45 mg/L FL 09/14/2010 1st QTR 2013 5400616 LEMON COVE WATER CO Nitrate 60.00 45 mg/L FL 09/14/2010 3rd QTR 2012 5400616 LEMON COVE WATER CO Nitrate 60.00 45 mg/L FL 09/14/2010 CI EIEJD 4th QTR 2012 5400628 LEMON CAMP Nitrate 57.00 45 mg/L FL 01 /28/2000 >13, 1st QTR 2013 5400628 LEMON CAMP Nitrate 57.00 45 mg/L FL 01/28/2000 )2 1st QTR 2013 54031 06 L0 BUE BROS EARLIBEST Nitrate 81.00 45 mg/L FL 08/30/2010 1st QTR 2013 5403106 LO BUE BROS EARLIBEST Nitrate 59.00 45 mg/L FL 08/30/2010 4th QTR 2012 5403140 MONARCH NUT CO Nitrate 84.10 45 mg/L FL 10/08/2012 1st QTR 2013 5403140 MONARCH NUT CO Nitrate 83.60 45 mg/L FL 10/08/2012 3rd QTR 2012 5403140 MONARCH NUT CO Nitrate 87.90 45 mg/L FL 10/08/2012 3rd QTR 2012 5403140 MONARCH NUT CO 2 2222220 0002 2 n. o. 0.9.3.12. Nitrate 87.90 45 mg/L FL 09/01/2011 4th QTR 2012 Revised 8/12/2013 Page 39 of 63 P-WS "ti? ?Ei?ccement Date.. 5402043 MONSON MARKET Nitrate 45 mg/L 07/28/2010 3rd QTR 2012 5402043 MONSON MARKET Nitrate 45 mg/L 07/28/2010 4th QTR 2012 5403128 MOZZARELLA FRESCA Nitrate 45 mg/L 3/21/2013 2012 Annual 5400713 OAK VALLEY SCHOOL Arsenic 0.010 mg/L 08/22/201 1 1st QTR 2013 540071 3 OAK VALLEY SCHOOL Arsenic 0.010 mgli. 08/22/201 1 3rd QTR 2012 5400713 OAK VALLEY SCHOOL Arsenic 0.010 mg/L 08/22/2011 4th QTR 2012 5400918 OPEN COUNTRY SWAP MEET Nitrate 45 mg/L 01/09/2012 Iilg- EIDEJCID 3rd QTR 2012 5400918 OPEN COUNTRY SWAP MEET Nitrate 45 mg/L 01/09/2012 4th QTR 2012 5400541 PARAMOUNT CITRUS Nitrate 45 mg/i. 09/14/2010 181 QTR 2013 5400541 PARAMOUNT CITRUS Nitrate 45 mg/L 09/14/2010 4th QTR 2012 5402056 PEOPLES GROCERY Nitrate 45 07/28/2010 1st QTR 2013 5402056 PEOPLES GROCERY Nitrate 45 mg/L 07/28/201 0 3rd QTR 2012 5402056 PEOPLES GROCERY Nitrate 45 mg/L 07/28/2010 4th QTR 2012 5403054 PFFJ, LLC Arsenic 0.010 mg/L 05/24/201 1 1st QTR 2013 5403054 PFFJ, LLC Arsenic 0.010 mg/L 05/24/201 1 4th QTR 2012 5403054 PFFJ, LLC Arsenic 0.010 mg/L FL 05/24/201 1 4th QTR 2012 5403013 MART Nitrate 45 mg/L FL 04/27/2010 1st QTR 2013 5403013 PRINCE MART Nitrate 45 mg/L FL 04/27/2010 3rd QTR 2012 540301 3 PRINCE MART Nitrate 45 mg/L FL 04/27/2010 4th QTR 2012 5400735 RODRIGUEZ LABOR Nitrate 45 mg/L. FL 04/27/2010 1st QTR 2013 5400735 RODRIGUEZ LABOR CAMP Nitrate 45 mg/L FL 04/27/201 0 3rd QTR 2012 5400735 RODRIGUEZ LABOR CAMP Nitrate 45 mg/L FL 04/27/2010 4th QTR 2012 5400558 SAUCELITO ELEM SCHOOL 2220.0. 0. 0.22 0.0.2220. 0.. 0. 2220000. Nitrate 45 mg/L FL 09/14/2010 I3 El DECIDED 1st QTR 2013 Revised 8/ 1 21201 3 Page 40 of 63 ;+vas: Date 2 Comments #5400558 SAUCELITO ELEM SCHOOL IDBCP 09/14/2010 "?151" CTR 2011 3 5400558 SAUCELITO ELEM SCHOOL Nitrate 09/14/2010 4th QTR 2012 5400558 SAUCELITO ELEM SCHOOL DBCP 09/14/2010 4th QTR 2012 5400709 SEQUOIA UNION SCHOOL Nitrate 09/14/2010 1st QTR 2013 5400709 UNION SCHOOL Nitrate 09/14/2010 4th QTR 2012 5400709 SEQUOIA UNION SCHOOL Nitrate 09/14/2010 4th QTR 2012 5403110 SIERRA MUTUAL WATER CO Nitrate 09/14/2010 QTR 2013 5403110 SIERRA MUTUAL WATER CO Nitrate 09/14/2010 3rd QTR 2012 5403110 SIERRA MUTUAL WATER CO Nitrate 09/14/2010 3rd QTR 2012 5403110 SIERRA MUTUAL WATER CO Nitrate 09/14/2010 4th QTR 2012 5403110 SIERRA MUTUAL WATER CO Nitrate 09/14/2010 4th QTR 2012 5400711 SIERRA VIEW JR ACADEMY Nitrate 09/14/2010 4th QTR 2012 5400754 SO KAWEAH MUTUAL WATER CO Arsenic .0110 04/23/2012 1st QTR 2013 5400754 SO KAWEAH MUTUAL WATER CO Arsenic .0110 04/23/2012 4th QTR 2012 5400805 SOULTS MUTUAL WATER CO Nitrate 70.20 09/28/2010 1st QTR 2013 5400805 SOULTS MUTUAL WATER CO Nitrate 70.20 07/28/2010 DUDDCIEICIEICIBIEIXIE 3rd QTR 2012 5400805 SOULTS MUTUAL WATER CO Nitrate 70.20 07/28/2010 4th QTR 2012 5402013 SUN PACIFIC SHIPPERS LP .. EXETER Nitrate 63.00 01/09/2012 1st QTR 2013 5402013 SUN PACIFIC SHIPPERS LP EXETER Nitrate 63.00 01/09/2012 CID 4th QTR 2012 Revised 8/12/2013 Page 41 of 63 - - :13} greemen; PWS Ct 3'3531 Result 1 "'546'1'665? HIT-HARP REAL .. 3 PROPERTIES Nitrate 87.70 0911312011 3rd 5400670 TRIPLE MUTUAL WATER CO Nitrate 60.00 10/25/201 1 1st QTR 2013 5400670 TRIPLE MUTUAL WATER CO Nitrate 84.00 10/25/201 1 3rd QTR 2012 5400670 TRIPLE MUTUAL CO Nitrate 64.00 10/25/201 1 3rd QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 55.00 10/25/201 1 3rd QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 48.00 45 mg/L 10/25/201 1 3rd QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 50.00 45 mg/L 10/25/2011 3rd QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 51.00 45 mg/L 10/25/2011 3rd QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 84.00 45 mg/L 10/25/2011 4th QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 64.00 45 mg/L 10/25/2011 4th QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 62.00 45 mg/L 10/25/201 1 4th QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 51.00 45 mg/L 10/25/201 1 4th QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 53.00 45 mg/L 10/25/201 1 4th QTR 2012 5400670 TRIPLE MUTUAL WATER CO Nitrate 51.00 45 mg/L 10/25/2011 4th QTR 2012 5400507 VESALIA FRESNO SOUTH KOA Nitrate 92.50 45 mg/L 09/14/2010 1st QTR 2013 5400507 VISALIA FRESNO SOUTH KOA Nitrate 92.50 45 mg/L FL 09/14/2010 3rd QTR 2012 5400507 FRESNO SOUTH KOA Nitrate 65.00 45 mg/L FL 09/14/2010 4th QTR 2012 5403010 CITRUS PAC Nitrate 55.00 45 mg/L FL 09/14/2010 1st QTR 2013 Revised 8/1 212013 Page 42 of 63 PWS Number System Name Class1 Contaminant MCL Result MCL Enforcement Action Type2 Enforcement Action Issue Date ETT3 Comments 5403010 VISALIA CITRUS PAC DLAKE Nitrate 55.00 45 mg/L FL 09/14/2010 4th QTR 2012 5403046 VISALIA CITRUS COVE Nitrate 130.0 45 mg/L FL 07/28/2010 1st QTR 2013 5403046 VISALIA CITRUS PACKING-ORANGE COVE Nitrate 130.0 45 mg/L FL 07/28/2010 4th QTR 2012 5400795 WAUKENA ELEMENTARY SCHOOL Uranium 40.00 20 piC/L FL 10/21/2010 1st QTR 2013 5400795 WAUKENA ELEMENTARY SCHOOL Nitrate 74.00 45 mg/L FL 10/21/2010 1st QTR 2013 5400795 WAUKENA ELEMENTARY SCHOOL Uranium 42.00 20 piC/L FL 10/21/2010 3rd QTR 2012 5400795 WAUKENA ELEMENTARY SCHOOL Nitrate 74.00 45 mg/L FL 10/21/2010 4th QTR 2012 5400795 WAU KENA ELEMENTARY SCHOOL Uranium 41.00 20 piC/L FL 10/21/2010 4th QTR 2012 5402030 WAU KENA MARKET 0.0.10.2 Nitrate 95.00 45 mg/L FL 07/28/2010 1st QTR 2013 5400957 WEST GOSHEN MUTAL WATER CO Nitrate 51.00 45 mg/L FL 10/2/2012 2012 Annual 1-C=Community, P=Non?transient Non-community, or N=Transient Non-community 2-lA=Notice of Violation(s) or FL=Citation or Compliance Order 3-Under the EPA's Enforcement Response Policy and Enforcement Targeting Tool water systems? violations are evaIuated using a weighed points system. Each violation is assigned a number of points based on the assigned threat to public health, where priority is given to acute health based violations. (Acute health-based violations are worth 10 points, other health-based violations and Total Coliforrn Rule repeat monitoring violations are worth 5 points, nitrate monitoring and reporting violations are worth 5 points, and other monitoring and reporting and any other violations are worth 1 point.) Systems that are checked above have greater than or equal to 11 points, are designated as "priority systems", and have appeared on the EFT during the fiscal year. Revised 8/12/2013 Page 43 of 63 THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: YES NO The LPA was deficient with CCR Title 22, Section 64258 because they did not issue the Citations for TCR MCL violations or continuous TCR MCL violations until half way through the year. During the first six months, the LPA issued a NOV for a TCR MCL violation, after the evaluation, the County started issuing a Citation to any system with a TCR MCL violation. In addition, after two or more TCR MCL violations the system should be issued 3 Compliance Order to evaluate the problem and to find a solution to the bacteriological problem. The LPA did not issue enforcement actions for DBP or Radiological MCL violations. It appears from a print out from that there were some Radiological MCL violations that were not identified or Compliance Orders issued. Revised 3/12/2013 Page 44 of 63 Appendix G: Program Management/Work Plans - CCR Title 22, Section 64259 though 64260 The LPA is under the Tulare County Health and Human Services Agency and is responsible for the management of the County?s small public water system regulatory program. The SWSP is administered by the interim Director of Environmental Health, Mr. Jason Britt; Ms. Nilsa Gonzalez, Environmental Health Supervisor; Mr. Miguel Herrera, REHS and Mr. Paul Charpentier, Staff Services Analyst II. The County?s SWSP is funded by water system annual operating permit and enforcement fees. Table 17 lists the various fees that Tulare County Environmental Health charges to the PWSs. The current program has 2.5 full time PYs in the water program for oversight of the 304 public water systems. Table 17: Tulare County SWSP Fees for FY 2012-2013 urrentFee Water System annual fee CWS 15?24 Sen/ice Connections $357 Water System annual fee CWS 25-99 Service Connections $578 Water System annual fee CWS 100?199 Service Connections $725 Water System annual fee Transient Noncommunity $504 Water System annual fee Nontransient Noncommunity $504 Water System annual fee State Small 5-14 Service conn $263 Water System enforcement action hourly $105 Water System New TMF application CWS $725 Water System New TMF Nontransient $436 Water System TMF change of ownership $221 Well Permit - Public $231 Well Permit Permit to Destroy $116 File Maintenance CCR Title 22, Section 64259 states that each LPA shall establish and maintain an individual file for each small PWS which includes the following information: . Current water supply permit and technical report. . Permit applications, permit technical reports, and all technical reports supporting the water supply permits for a minimum of 10 years. I . Current plans and specifications pertaining to source information, treatment information, storage facilities, distribution plans, water quality plans, total coliform sample siting plans, and emergency plans. Revised 8/12/2013 Page 45 of 63 . Copies of bacteriological water quality analyses for a minimum of 5 years. . Copies of water quality monitoring data for a minimum of 10 years. . Correspondence, memoranda, and other written records pertaining to the water system issued or written within the past 3 years. 0 Copies of all compliance orders, citations, court actions, and other enforcement documentation issued. Tulare County maintains their files by hard-copy. Refer to the file review form(s) and deficiencies in Appendix L. Work Plans CCR Title 22, Section 64260 requires LPAs to submit proposed annual work plans to CDPH no later than May 1 of each year for the fiscal year commencing July 1 of that year. The work plan outlines the proposed activities that include the following: . Listing goals and objectives . Maintaining water system inventory and files . Issuing water supply permits . Conducting inspections/sanitary surveys . Monitoring water quality data . Submitting various reports to CDPH . Issuing enforcement actions . Maintaining and submitting data to CDPH The LPA submitted a work plan for FY 2012-2013, dated April 26, 2012. It was approved by CDPH on June 1,2012. THE LPA IS IN COMPLIANCE WITH APPENDIX REQUIREMENTS: YES NO Revised 8/1 212013 Page 46 of 63 Appendix H: LPA Water System Inventory Community Water Systems PWS Number Water System Name Population Number of Service Connections 5400504 A A MHP 60 200 5401038 AKIN WATER CO 22 50 5403144 ALI WATER CO 13 50 5400544 ALLENSWORTH 110 400 5400580 ALTA VISTA 10 29 5400710 BADGER HILL ESTATES 77 300 5400816 BEDEL MUTUAL WATER CO. 66 155 5400651 BEVERLY GRAND MUTUAL WATER 28 108 5400655 CENTRAL MUTUAL WATER CO 23 115 5400570 CHINOWTH STREET APARTMENTS 10 30 5401026 DEER MEADOW MUTUAL 22 75 5403023 DELFT COLONY WATER 99 400 5400542 DUCOR CSD 125 850 5401003 EAST OROSI CSD 106 700 5400744 EAST THREE RIVERS MUTUAL 14 28 10002648 EAST VAN DALIA WC - WEST 13 20 5400523 EL MONTE VILLAGE 49 100 5403084 FAIRWAY MUTUAL WATER CO 20 53 5400769 FOOTHILL APARTMENTS 14 40 5400759 GIUMARRA VINEYARDS 1 2 8 60 5402047 GLEANINGS FOR THE HUNGRY 12 31 5400600 GOLDEN KEY APARTMENTS 16 48 5400728 GRIER MUTUAL WATER CO 89 190 5400536 KINGS RIVER ESTATES 35 100 5400660 LAKE SUCCESS MOBILE LODGE 18 40 5400616 LEMON COVE WATER CO 50 200 5400631 LINNELL FARM LABOR CENTER 190 896 5400604 MOUNTAIN VIEW DUPLEXES 27 108 5400819 MOUNTAIN VIEW 24 44 5402038 PATTERSON TRACT CSD 114 550 5400732 PIERPOINT SPRINGS WATER CO. 78 165 5400934 PONDEROSA CSD 116 232 5403149 RANCHO LOPEZ 14 42 5400556 RIVER RETREAT MUTUAL 21 100 5400735 RODRIGUEZ LABOR CAMP 35 110 5400701 SEQUOIA CREST WATER CO 93 70 5400550 SEVILLE WATER CO 77 400 5400529 SHADY GROVE 40 137 5400527 SHILOH WATER CO. 20 75 5400940 SIERRA KING HOMEOWNERS ASSN 40 120 5403110 SIERRA MUTUAL WATER CO 15 39 5400964 SIERRA VISTA ASSN 13 44 5400754 80 KAWEAH MUTUAL WATER CO 105 300 5400805 SOULTS MUTUAL WATER CO 36 100 SOUTH FORK ESTATES MUTUAL WATER 5403113 CO 19 76 Revised 8/12/2013 Page 47 of 63 5403038 5400824 5400881 5400641 5400880 5400567 5400903 5400553 5400670 5400875 5400957 5400966 5400718 5400792 5403043 5400647 Revised 8/12/2013 SPRINGVILLE WATER CO SULTANA SUNRISE MUTUAL WATER CO. THELAKES TOOLEVILLE WATER COMPANY TRACT 92 TRAVER WATER LLC TRIPLE MUTUAL WATER CO VHLAGEAPARTMENTS WESTLAKE VILLAGE WILLTAMS MUTUAL WATER CO WOODVILLE FARM LABOR CENTER YETTEM WATER SYSTEM YOKOHL MUTUAL WATER CO Total Number of Communi Water 3 tems Page 48 of 63 Nontransient Noncommunity Water Systems Population Number of PWS Number Water System Name Service Connections 5403022 APTCO LLC 6 150 5401074 BOB WILEY DETENTION FACILITY 5 1130 5403138 BRANDT FARMS, INC 2 100 5400919 BU ENA VISTA SCHOOL 4 130 5403132 CALGREN RENEWABLE FUELS 5 70 5403042 CALIFORNIA DAIRIES INC 2 100 5400873 CHARTER ALTERNATIVES ACADEMY 8 345 5400555 CITRUS SOUTH TULE SCHOOL 1 50 5400886 COLUMBINE SCHOOL 2 160 5402040 EAST UNION SCHOOL 5 0 5400844 ELBOW CREEK SCHOOL 1 365 5400846 ELBOW SCHOOL 1 103 ELEANOR ROOSEVELT COMM LEARNING 5403130 CTR 5 100 5403147 EXETER KINGDOM HALL 1 100 5403126 FAMILY EDUCATION CENTER 1 50 5403080 FRUIT PATCH INC 1 125 5402046 GNI WATERMAN LLC 1 225 5401076 GOLDEN STATE VINTNERS 10 50 5400620 GRAND VIEW SCHOOL 11 200 5403065 HAVEN PACKING 2 150 5403141 HELLWIG PRODUCTS CO INC 2 29 5400657 HESTER SCHOOL 8 498 5400994 HOPE ELEMENTARY SCHOOL 1 100 5401033 HORIZON NUT LLC 3 150 5402008 HOT SPRINGS SCHOOL 1 42 5403121 INTERNATIONAL PAPER EXETER BULK 1 130 5403048 JD HEISKELL HOLDINGS LLC 4 33 5403083 JODY FRESH COOLING CO PWS 2 110 5400699 KAWEAH HIGH SCHOOL 1 150 5400624 KINGS RIVER ELEM SCHOOL 10 600 5403146 LIBERTY SCHOOL 1+ 400 5403106 LO BUE BROS - EARLIBEST 1 99 5402050 MILK SPECIALTIES GLOBAL 40 225 5403140 MONARCH NUT CO 6 25 5403032 MONROVIA NURSERY - NURSERY 2 400 5403055 MONROVIA NURSERY - OFFICE 1 50 5403127 MONROVIA VENICE HILLS NURSERY 5 30 5401040 MOORE WALLACE - RR DONNELLEY 1 160 5403152 MOUNTAIN VIEW COLD STORAGE 1+ 25+ 5403128 MOZZARELLA FRESCA 2 150 5403102 NEW LEAF COLD STORAGE 2 50 5400713 OAK VALLEY SCHOOL 7 300 5400636 OROSI HIGH SCHOOL 14 900 5400972 OUTSIDE CREEK SCHOOL 2 125 5400850 PACKWOOD SCHOOL 3 60 5400519 PALO VERDE SCHOOL 26 500 5400541 PARAMOUNT CITRUS 5 100 Revised 8/12/2013 Page 49 of 63 5400 9 PENNISULA PACKAGING CO 1 200 5403054 PFFJ, LLC 11 87 5400882 PLEASANT VIEW WEST 9 527 5400884 ROCKFORD SCHOOL 4 240 5403118 SAPUTO DAIRY FOOD USA 1 65 5400558 SAUCELITO ELEM SCHOOL 3 75 5400709 SEQUOIA UNION SCHOOL 1 400 5400638 SIERRA SCHOOL 1 40 5400711 SIERRA VIEW JR ACADEMY 6 160 5401004 STYROTEK 1 36 5403133 SUMMITT CHARTER ACADEMY 6 250 5402013 SUN PACIFIC SHIPPERS LP - EXETER 2 200 5403031 SUN PACIFIC-TULARE 2 250 5400714 SUNDALE UNION SCHOOL 11 450 5403131 SUNNY ACRES WATER SYSTEM 2 80 5400704 THREE RIVERS SCHOOL 1 300 5403114 TRAVER FEEDMILL PWS 3 40 5400639 TRAVER SCHOOL 8 300 5403139 TREEHOUSE CALIFORNIA ALMONDS LLC 4 100 5400797 TULARE CO CORRECTIONAL CTR RD CAMP 19 500 5401039 TULARE COUNTY CIVIC CENTER 5 300 5403050 TULARE COUNTY RECYCLING 2 40 5402027 TULARE COUNTY ROAD YARD #2 PWS 4 60 5401082 VENTURA COASTAL CORP 5 35 5403119 VENTURA COASTAL, LLC 6 75 5403010 VISALIA PACKERS-WOODLAKE 7 100 5403046 VISALIA CTTRUS PACKING-ORANGE COVE 7 70 5400795 WAUKENA ELEMENTARY SCHOOL 5 230 5403145 WAWONA PACKING COMPANY LLC 1 400 5400864 ACADEMY 13 300 5400526 WES PAK, INC 4 50 5403154 WILLITS EQUIPMENT CO 25+ Total Number of Nontransient Noncommunity Water Systems 79 Revised 3/12/2013 Page 50 of 63 Transient Noncommunity Water Systems Population Number of PWS Number Water System Name Service Connections 5401053 ACID 1 150 5400810 AKAL TRAVEL PLAZA 3 200 5400708 ALPINE VILLAGE WATER CO. 45 90 5403151 ARCO AM PM - PIXLEY 1 1000 5400757 ARMY CORPS ENG-HORSE CREEK 30 100 5400755 ARMY CORPS ENG-REC AREA 2 200 5403137 ARMY CORPS ENG-SLICK ROCK 1 100 5400696 ARMY CORPS ENGS-NORTH CAMP 4-2 4 25 5400695 ARMY CORPS CAMP 3-1 4 100 5401084 BADGER MTN HOUSE INC 1 25 5400823 BALCH PARK 45 100 5400922 BARTLETT PARK 60 66000 5402019 BLANCA MARKET DELI 3 25 5400985 TINY MART 3 25 5400513 CAL HOT SPRINGS RESORT 59 50 5400894 CAMP SAN JOAQUIN 9 80 5401049 CAMP WILDERNESS 3 40 5403047 CASILLAS WATER SYSTEM 6 30 5403026 CDF-FRAISER MILL CAMPGROUND 19 300 5403049 CDF-HEDRICK POND CAMPGROUND 7 70 5403025 FALLS CAMPGROUND 8 90 5403027 CDF-SHAKE CAMPGROUND 14 50 5400921 CEDAR SLOPE WATER CO 59 25 5403076 CENTRAL CAL TRISTEZA ERAD 5 25 5403153 CIRCLE - SCICON 1+ 1000 5400760 CLM-BELKNAP CAMPGROUND 4 30 5400863 CLM-CAMP 3 CAMPGROUND 10 104 5403109 CLM-COFFEE CAMP UPPER DAY USE 6 36 5400945 CLM-COY FLAT CAMPGROUND 5 25 5401089 CLM-ESHOM CAMPGROUND 15 63 5400868 CLM-FAIRVIEW CAMPGROUND 1 125 5400890 GROUP CAMPGROUNDS 4 75 5402017 LEDGE CAMPGROUND 13 74 5400848 CLM-HEADQUARTERS CAMPGROUND 12 88 5402016 FLAT CAMP GROUND 11 80 5400743 CLM-LOWER COFFEE CAMP 1+ 1000 5400766 CLM-QUAKING ASPEN CAMPGROUND 15 112 5400942 CLM-REDWOOD MEADOW CAMPGROUND 4 30 5400889 CREEK CAMPGROUND 20 133 5400811 CLM-WHITE RIVER CAMPGROUND 4 25 5400738 CLM-WISHON CAMPGROUND 10 56 5400549 CLUB ROYAL OAK 3 700 5403062 COMFORT INN 8 SUITES 1 125 5403116 CORRAL CREEK 2 104 5403148 COURAGE TO CHANGE 7 40 5400583 CUTLER PARK 10 300 5402057 DEER CREEK RV PARK 78 76 5401093 DOYLE SPRINGS ASSN 51 300 Revised 8/12/2013 Page 51 of 63 540 030 DRY CREEK DELI 1 50 5403007 THARP INC 4 65 5400602 NEST RESORT 2 200 5403143 ELDERWOOD MARKET 1+ 1000 5403041 FAMILY TREE FARMS 3 25 5400896 FAR HORIZON CAMP 12 60 5403142 RANCH MARKET 1+ 1000 5403143 FERRY FARMS LLC 2 80 5400987 FOUNTAIN SPRINGS EL TAPATIO 2 25 5403051 FRIENDS RV PARK 44 24 5400692 GARDEN INN 1 40 5403082 GIUMARRA BROS FRUIT CO 1 40 5400762 GIUMARRA VINEYARDS 3 4 7 125 5400763 GIUMARRA VINEYARDS 5 6 2 150 5403089 GRUMPY BEARS 1 52 5403150 MARKET 1+ 1000 5400505 HARTLAND CHRISTIAN CAMP 4 140 5403135 HARTLAND HOMEOWNERS ASSN 36 20 5403157 BREAKFAST 1+ 1000 5403090 IN OUT FOODMART 1 75 5400750 KAWEAH PARK RESORT 45 500 5403088 KENNEDY MEADOWS GENERAL STORE 3 300 5400548 KINGS INN MOTEL 1 130 5401048 KINGS RIVER GOLF COURSE 1 500 5402024 KINGS RIVER MARKET 2 25 5401025 KENGSBURG GUN CLUB 3 150 5400761 LAKE ELOWIN RESORT 12 40 5401080 LAKE EXPRESS MARKET 4 25 5402025 LAKESIDE MINNIT MART 1 25 5400518 LAKESIDE TRAILER PARK 91 500 5400756 LAZY RANCH MOTEL 25 12 5400628 LEMON CAMP 55 100 5400537 LINDYS LANDING 2 500 5401079 LIVESTOCK SALES YARD 2 60 5403001 LOWER SPRINGS WATER CO 3 50 5403086 MARTELLA LIVESTOCK AUCTION 2 50 5400598 FAIRVIEW LODGE 19 35 5402043 MONSON MARKET 2 25 5400898 MONTECITO LAKE RESORT 10 3925 5400951 MOONEY GROVE PARK 12 200 5400679 MOTEL 99 4 60 5403053 NS MINI MART 2 140 5400918 OPEN COUNTRY SWAP MEET 5 300 5403122 FOOD MART 1 500 5403156 PAN AMERICAN BALLROOM 1+ 1000 5403120 PANADERIA LA CABANA 1 155 5400509 PANORAMA HEIGHTS PROP OWNERS 109 100 5400724 PANORAMA PARK FIRE PRO CO 58 90 5400887 PARK WATER SYSTEM 7 20 Revised 8/1212013 Page 52 of 63 ranSIentNoncommu Ice: - If} .. nectio 5403 5 DISPOSAL INC 1000 5402056 PEOPLES GROCERY 25 5403081 PETERS FRUIT FARMS, INC 125 5400774 PIXLEY PARK 50 5400611 PORTERVILLE TRAILER PARK 80 5400511 POSO PARK ASSN 52 5402031 PREET MARKET 1 300 5403013 PRINCE MART 2 25 5400895 PYTHIAN YOUTH CAMP 13 275 5400703 QUAIL VALLEY REC VILLAGE 100 2500 5400961 QUAKER MEADOW CAMP 11 200 5400929 RIVERLAND RESORT 7 100 5401094 TRAVEL CENTER 1 103 5400959 RM PYLES BOYS CAMP 5 110 5403072 ROGERS CAMP HOMEOWNERS ASSN 9 25 5402036 R-RANCH IN THE SEQUOIAS 115 500 5400778 SCICON 15 21 5402055 SEQUOIA HEIGHTS CAMPGROUND 7 110 5400743 SEQUOIA MOTEL 1 2 9 47 5400629 SEQUOIA RV RANCH 21 19 5403100 SEVEN CIRCLES RETREAT 3 30 5402039 SEVILLE MARKET 2 100 5400917 SHOP GO 1 25 5401099 SIERRA CHRISTIAN CAMP 6 150 5401092 SIERRA GLEN STORE 1 25 5400924 SIERRA LAKES MINISTER CAMP 30 62 5400916 SIERRA MASONIC WATER CO 24 45 5403073 SLATE MTN HOMEOWNERS ASSOCIATION 41 60 5400581 SPEAR CREEK CABIN OWNERS ASSOC 26 52 5400737 ST RETREAT 3 130 5400552 STONEY CREEK 4 42 5400984 SUCCESS MARKET 4 25 5400722 SUGARLOAF MUTUAL WATER CO 30 25 5400543 SUGARLOAF VILLAGE MUTUAL 25 70 5403040 SUHOVY WATER SYSTEM 2 25 5403009 SUPER STOP 1 95 5400538 TCOVE 5 26 5403039 TEA POT DOME WATER CO 4 25 5401063 THARP REAL PROPERTIES 3 35 5403105 THE BARN 2 200 5400975 THE SEAFOOD CAFE 1 50 5403071 THREE RIVERS CHEVRON 1 50 5401022 THREE RIVERS GOLF COURSE 1 100 5400751 THREE RIVERS HEDEAWAY 14 50 5402037 THREE RIVERS LIBRARY 1 80 5403014 THREE RIVERS LIONS CLUB 3 100 5400838 THREE RIVERS 9 25 5402022 TRAVER VALLEY FARMS - PWS 3 25 5403011 USA PETRO SUPER STOP 2 25 Revised 8/12/2013 Page 53 of 63 5400820 5403085 5401010 5400826 5403020 5400772 5403034 5403021 5400827 5400783 5400765 5402026 5403125 5400507 5400928 5402030 5400623 5400907 Revised 8112/2013 STATION TRAILHEAD USES-CAMP WHITSETT USPS-FISH CREEK CAMPGROUND USES-HORSE MEADOW CAMPGROUND SPRINGS RANGER STATION USFS-JERKEY MEADOW TRAILHEAD USFSKENNEDYCAMPGROUND USFS-LOWER PEPPERMINT MEADOW CAM PGROUND VICTORIAN GARDENS VISALIA - FRESNO SOUTH KOA VISALIA SALES YARD WAUKENA MARKET WESTERN - HOLIDAY LODGE WHITE HORSE INN Total Number of Transient Noncommun Water 8 tems Page 54 of 63 Appendix I: CDPH Infrastructure Financing Programs CDPH has several funding programs to assist small PWSs with improvements to bring the systems into compliance with State and federal regulations. The LPA forwards information related to the State funding programs to all water systems that have significant deficiencies. The information includes a pre?application for funding and the deadline for its submittal to the State. The LPA assists CDPH in evaluating proposed projects for the systems requesting funding under the various programs. Table 18 lists water systems under the Tulare County LPA regulatory jurisdiction that currently have active executed funding projects (construction or planning feasibility), are in the process of receiving a funding agreement, or have received a funding agreement for funding in one of 3 funding programs: Proposition 50, Proposition 84, and the State Revolving Fund (SRF) in FY 2012?2013. The California Rural Water Association (CRWA) and/or Self?Help Enterprises (SHE) are continuing to provide technical assistance to the small PWSs in Tulare County to complete the Drinking Water SRF applications and the mandatory elements of TMF. CRWA also provides technical assistance for completion of TMF capacity criteria for water systems changing ownership or those needing help or training on specific operational issues. Revised 8/12/2013 Page 55 of 63 Table 18: Water Systems Currently Seeking CDPH Funding the City of Exeter. Funding . . . System Name Program Preject No. Problem PrOJect Status TRACT 403 . . . . Unfiltered Surface Consolidating With North Kaweah, Prop 50 5403129001 Water Construction FA Executed on 4/11/13 Prop 84 Planning Study with Richgrove RODRIGUEZ Consolidation with complete, invited to submit LABOR CAMP Prop 84 5400735002 Richgrove CSD construction application. Construction application submitted on 7/12/13 SEQUOIA UNION SRF 5400709-001 Nitrate compliance Construction FA Executed on 5/3/13 SCHOOL . Planning Study FA Executed on Svi?EPEco Prop 84 5400550-007 swig?? water 11/27/12- in progress. FA amended on 9 9/9/13 to expand scope/budget Excess nitrate Planning Study FA Executed on AKIN WATER . . 6/17/11- the max.18 months is CO Prop 84 5401038001 consolidation complete. Issuing 2nd Planning FA to complete scope of work P84 Planning study FA executed on OAK VALLEY . 6/17/11. Planning Project complete. SCHOOL Pr?p 84 5400713001 Amen": invited for construction, SRF construction app received on 10/2/13 Planning/Feasibility Study to evaluate . Co-funded Planning Study FA 23d Executed on 1/5/12- in progress. Ducor CSD . . Project near completion and will soon obtain and maintaln . . . . be anIted to submit a construction clean, affordable, a Iication and adequate water pp supplies. Planning/Feasibility . Beverly Grand Study for water Planning Study FA Executed Mutual Water Prop 84 5400651-001 system that 1114/12 the mam months '5 Com an exceeds the nitrate complete. Issuing 2nd Planning FA to complete scope of work MCL. Planning Study FA Executed on Buena Vista 6/21/11. Planning Project complete, School Prop 84 5400919001 212286233; nitrate invited for construction, SRF MCL construction app received on 10/2/13 Planning/Feasibility Study for water . East Orosi cso Prop 34 5401003-003 system that P'ann'?9 StUdy FA Execmed 0? . 11/16/12- in progress exceeds the nitrate MCL. LEMON COVE Compliance with Submitted planning application- FA WATER CO SRF 5400616001 nitrate standard expected to be issued by June 2014 WOODVILLE . . . . . . Submitted planning application- FA FARM LABOR Prop 84 54007'92-003 Nitrate compliance expected to be issued by June 2014 CENTER Submitted planning application- in Nitrate- pipeline. Project has since been DEL ORO Consolidation with switched to a combined construction RIVER ISLAND SRF 5402048?001 Del Oro River Island project with the Del Oro River Island SERV TERR #2 Terr #1 Terr #1 SWTP project. Combined Construction FA for both projects expected to be issued by June 2014 Planning/Feasibility Tooleville Study for water . Mutual Water Prop 84 5400567-001 system to drill new FA ExeCUted 0" 6/26/13- in progress Co. well or connect to Revised 8/12/2013 Page 56 of 63 F'I?Iannlrig Feast ility Study for water Waukena - system that Submitted planning application- FA Prop 84 5400795 001 exceeds the gross expected to be issued by June 2014 alpha, uranium. and nitrate MCLs. Planning/Feasibility Study for water . . . . Soults Mutual Submitted planning application- FA Water Company PFOP 84 5400805004 zizzegs?i?g nitrate expected to be issued by June 2014 MCL. Allensworth . Planning Study FA Executed on SRF 5400544-001 Arsenic 4,291,13_ in progress Bacterioiogicat . . . . . . - Submitted planning application- FA Tract 92 SRF 5400903 002 Eggtj?mnatton new expected to be issued by June 2014 Fate Verde failed to submit a planning application by 4/5/13. Project was g?hggERDE SRF 5400519001 Arsenic invited again and the schooi responded that they woutd submit a SRF construction application by 12/20/13 EL MONTE . . . . VILLAGE SRF 5400523-003 Nitrate compliance gamed Wallinmg app'mam? M.H.P. - tn pipe tne GLEANINGS . . . . FOR THE SRF 5402047001 Nitrate compliance app"ca"?? 0? HUNGRY 0 - :n pipe me KINGS INN MOTEL . Spring 2013 SRF Invite? nonresponsive (Americas Best SRF 54005484301 Nitrate to invitation Value Inn) . . . SOUTH TULE SRF 5400555-001 Nitrate 391'?? 2913 SRF SCHOOL to imitation TRAILER ISLE . . . PARK (Sequoia SRF 5400629-001 Arsenic 39??9 201 3 SRF Emma" ??8590an RV Ranch) to invitation Insufficient water . . . . TEVISTON . Submitted planning application on SRF 5400641~003 335:5:- water 4 [5,11% in pipeline WATERT - . . . GRANDVIIEETN SRF 5400666-001 Nitrate Spring 2013 SRF EnVIte- nonresponswe GARDENS to invitation CENTRAL . Submitted planning application on WATER co. SRF 5400683002 N't?ate 9/20/13? in pipeline agm?EAH SRF 5400754_002 Arsenic Spring 2013 SRF nonresponsive WATER CO to invitation WEST GOSHEN . Construction FA Issued on 10/1 1/13 to MUTUAL SRF 5400957'005 Nitrate consolidate with Cal Water? in progress WATER CO. WESTLAKE . Spring 2013 SRF Invite- nonresponsive VILLAGE SRF 5400966002 ?mate to invitation HOPE ELEM . Spring 2013 SRF invite? nonresponsive SCHOOL SRF 5400994-001 Nitrate to invitation UC . Spring 2013 SRF invite- nonresponsive SCHOOL SRF 5401006?003 Nitrate to invitation Maggi??327 SRF 5403103001 Arsenic Spring 2013 SRF invite? nonresponsive WATER CO to invitation SIERRA Spring 2013 SRF lnvite- water system MUTUAL SRF 5403110?001 Nitrate requested to be Bypassed for funding WATER CO consideration Revised 8/12/2013 Page 57 of 63 Project not listed on SRF PPL, P84 CAL HOT Bypassed project on 7l25/1? due to SPRINGS SRF 5400513-001 Arsenic failure to meet application deadlines. RESORT Water System must submit a SRF Universal Pre~App Con oiidated with TRACT Prop 84 5400663-001 Po Project Complete MUTUAL Nitrate- consolidate . . Sultana~ . Planning Study FA Issued on 8/63/13? In on so area SRF 5400824-001 monson area With progress Sultana Tipton- North insufficient water . Burnett Road SRF 5403108-001 capacity? water FA Execmed 6/26/13- In progress system outages Revised 8/12/2013 Page 58 of 63 Appendix J: CDPH Small Water System Program Plan CDPH has developed a Small Water System Goal targeted to bring small community systems into sustainable compliance with primary drinking water standards. CDPH has developed an implementation plan that defines specific tasks to achieve the goal as well as measureable results of progress. The implementation plan includes the use of CDPH staff and coordination with LPA drinking water programs, technical assistance providers, and stakeholders to accomplish its goal. This comprehensive approach will address the specific violations and reduce the number of primary drinking water standard violations in California. The Small Water System Program Plan Goal consists of a bringing approximately 63 of these systems back into compliance. Achieving this goal will bring the compliance rate of small water systems in the state from the present 92% to 95%, matching that of large community water systems. CDPH will focus internal efforts and third party provider services toward these listed systems in order to bring them into compliance. The intent is to direct attention and resources to these systems to help them secure funding that will solve their problems and to develop their TMF capacity to a level that will that will ensure sustainability into the future. The Program Plan tracks the progress of 183 community water systems that have between 15 and 999 service connections that are on the list. You can find information below related to the implementation and progress of the Small Water Systems Program Plan. Table 19 lists water systems under the Tulare County LPA regulatory jurisdiction that are on the Program Plan list and what their status is to meet their milestones in returning to compliance with the primary drinking water standards. Revised 8/12/2013 Page 59 of 63 Table 19: Water Systems Listed on the Small Water System Program Plan PWS Water System Name Funding Status Number Program 5401038 Akin Water Company Nitrate P84 P84 planning FA exc 6/16/11 but system will need 2nd planning FA 5400544 Allensworth CSD Arsenic SRF SRF planning FA exc April 2013 5410050 Alpaugh Joint Powers Arsenic P84 P84 Exc FA May 2010 but will Authority need 2nd FA 5400651 Beverly Grand Mutual Nitrate P84 P84 R2- feasibility study (FA Water executed 1/14/2012). Consolidation with City of Porterville. 5400682 Central Water Nitrate Purchased by Plainview MWC Company April 2012. Still need to connect. responded to latest SRF invite - planning app due sept 20th 5400665 Del Oro - River Island Nitrate, SRF SRF application submitted and Service Territory #01 Uranium under 5402048 Del Oro - River Island Nitrate SRF SRF application submitted and Service Territory #02 under 5400542 Ducor CSD Nitrate SRF-P84 SRF-P84 planning cofund executed 5401003 East Orosi CSD Nitrate P84 P84 R3 - feasibility study FA exc 11/16/12 5400523 El Monte Village MHP Nitrate SRF SRF planning application submitted April 2013 - App deemed incomplete, follow-up August 2013 5400663 Fairways Tract Mutual Nitrate P84 Water system consolidated with the City of Porterville on 12?12? 11 5402047 Gleanings For The Nitrate Using POU for years to deliver Hungry clean water 5400660 Lake Success Mobile Nitrate installed Ion-Exchange Lodge treatment 5400616 Lemon Cove Water Nitrate SRF Processing SRF application for Company planning FA 5410052 - El Rancho Surface P84 P84 feasibility (exc 6/28/10) Water completed; P84 construction FA exec April 2013 5410007 LSID - Tonyville Nitrate P84 P84 feasibility study complete but City of Lindsay cannot provide water due to their own issues; awaiting City of Lindsay SRF project 5410009 Pixley PUD Arsenic P84 P84 R3 feasibility study FA executed 8/14/12 5410033 Pratt MWC Arsenic SRF-P84 SRF-Executed (003P), P84- Executed (003P) P84 R1 - feasibility study (complete 5/16/2012) P84 Construction Revised 8/12/2013 Page 60 of 63 FA ass August 2013 5410024 Richgrove CSD Nitrate P84 P84 R2 feasibility study complete - transitioning to P84 construction. Part of Rodriguez Labor Camp Project 5400735 Rodriguez Labor Nitrate P84 P84 R2 feasibility study Camp complete - transitioning to P84 construction. Part of Richgrove CSD consolidation project 5400550 Seville Water Nitrate P84 P84 Exc Emergency FA in Company addition to P84 R3 - feasibility study FA exc 11/28/12. Appiied for P84 interim emergency funding. 5403110 Sierra MWC Nitrate Submitted compliance pian to County but has not made any progress 5400805 Soults MWC Nitrate P84 5400567 Toolevilie Water Nitrate SRF-P84 for nitrate vioiations on Company 9/2010. RAA currently right below for both weiis. SRF Planning FA exec June 2013 5400670 Tripie MWC Nitrate Met with County a year ago, discussed blending, POU, but no progress has been made 5400957 West Goshen MWC Nitrate SRF Applied for P84 emergency funding. SRF application under review 5400966 Westlake Village Nitrate Below nitrate MCL since April MHP 2011. Consolidation with City of Visalia possible - only discussed 5403043 Yettem Nitrate P84 P84 R3 - feasibility study FA exc 11/28/12. Revised 8/12/2013 Page 61 of 63 APPENDIX K: WATER SYSTEMS EXCEEDING A PRIMARY AND PROVIDING TREATMENT PWS System Name umber . .. - 54003009 eupers'tcp' "Careertaracmaria? GAC 5401004 Styrotek DBCP, Nitrate Ion Exchange 5403145 Wawona Packing DBCP GAC Company 5401053 Charlie?s TNC Nitrate Ion Exchange 5403030 Dry Creek Deli TNC Nitrate Ion Exchange 5400987 Fountain Springs El TNC Nitrate Ion Exchange Tapatio 5402047 Gieanings for the Nitrate Ion Exchange Hungry 5400660 Lake Success Mobile Nitrate Ion Exchange Lodge *CmCommunity. P=Non-transient Non?community, or N=Transient Non~community Revised 8/12/2013 Page 62 of 63 Provrded Appendix L: LPA FILE REVIEW Revised 8/12/2013 Page 63 of 63 System Name: West Goshen MWC California.Department of Public Health .- tSmall Water system'unit FiieReview- System Number: 5400957 Population: 400 Service Connections: 84 Water System Classification: .Community DNon-Transient Non-Community [:ITransient Non?Community DOther: System Physical Location Address: 5155 Ave. 308 Operator Certification: @m l:]D2 DD4 DDS [:lT1 Notes: Water permit does not identify operator certification requirement. Water Supply Permit Date ssuedz2l20l2008 Permit Number (if applicable): Groundwater [3 Surface Water GWUDI Other: Number of Sources: 2 Number of Number of Sources: Sources Number of Sources: State Formatted Permit?: Permit >10 Years Old?: Tech. Report Included: Yes El Yes(D) No Yes Notes: Treatment Provided Yes I: No Required Treatment for: SWTR [j MCL?Primary MCL-?Secondary Other: Treatment Type: POU Provided: Yes Kl No For what Constituen?s): Bottled Water Provided: Yes No For what Constituen?s): bottled water. Nitrate -- Prop. 84, interim Notes: Last Updated29/39/2013 Page 1 California Department of Public Health Small Water System Unit LPA F-ile Review Date of Last Sanitary Conducted: 2/20/2008 State Formatted Report?: Yes l:l Do the Sanitary Survey Reports Include all 8 Elements(see below)?: Yeslj Sanitary Survey Elements: Source, Treatment, Distribution. Storage, Pump Facilities. Monitoring/Reporting/Data Verification, Management/Operation, and Operato; Certification. Is a Sanitary Survey Past Due Based on the 3 or 5 year Frequency: IE Yes(D) No Notes: Water quality delinquent. Bacteriological Sample Siting Plan: Date of Last BSSP BacT Monitoring Frequency Yes 7/18/2005 per Mon. Qtr. BSSP is 10 Years Old?: El Yes(D) No BSSP Needs Revisions? IE Yes(D) No Emergency Notificaton Plan: Yes Date of Last Emergency Notificaton Plan: 12/5/1997 Water System Ops Plan?: Yes IE Date of Last Water System Ops Plan: Notes: BSSP list old contacts-needs updating for contacts. ENP had a note with intials noting that the phone number for the water system is not good. ENP needs to be the state format. Bacteriological issues: TCR MCLs [j TCR is the LPA Requiring Water System to Sample Source(Required or Optional (Precautionary): Yes No of MCL Violations in a 12 Month Period (3 or more= cont. is advised): is the LPA Using Last Sample/Next Dee Report Last Sample Date(s) of Req. inorganic Chemicals (IOC): 6/2008 due in June 2011 In Compliance?: Yes Last Sample Date(s) of Req. Volatile Organic Chemicals (VOC): 6/2008 due in June 2014 In Compliance?: Yes Last Sample Date(s) of Req. Organic Chemicals (SOC): CI 4/2001 due in April 2004 In Compliance?: El Yes Last Sample Date(s) of Required Radiological Chemicals: El 6/2008 due in June 2014 In Compliance?: Yes PageIZ Last Updated29/19/2013 California Department Of Public Health Small Water System Unit LPA File Review Last Sample Date(s) of Nitrate/Nitrite Chemlcais quarterly monitoring required. In Compliance?: Yes Last Sample Date(s) for Lead and Copper Rule: 12/1999 In Compliance?: Yes Does the Water System have Unaddressed MCL lssues?: Yes(D) No Notes: Does the Water System have Previous Year CCR on File?: Yes 2011 Does the OCR Meet Reporting Yes Not filled-out correctly. Was the Proof of Notification Verification Form Submitted to LPA and in the File: Yes Do the Enforcement Actions Issued Meet the Addressing EA Criteria Below?: [3 Yes Enforcement actions need to have the foitowing elements to be classified as an ADDRESSING ACTION: . . The Action must describe the specific provision of statue or regulation that has been violated. . The Action must cite the appiicable provision of statue or regulation. 0 The Action must describe specific actions to be performed by the water system to return to compliance directives). . The Action must inctude a compliance schedule. . The Action must inform the water system that fatture to comply with the Action is, in and of itself, an enforceable action (Le. Civil Penalty Clause). Does the LPA Need to Work on Issuing Addressing Enforcement Actions?: El Yes(D) No ls the Public Notification Included in the Enforcement Action. lssuect (Tier tlTier Yes Is the LPA Using the Correct Public Notification Notices?: [1 Yes Notes: LCR reported from the well for the OCR. Nitrates incorrect 2011 results should be provided. Page 3 Last Updated29/19/2013 California Department _of Public Health Small Water System Unit LPA- File. Review Water Systems Only the Water System Submitting SWTR Monitoring Reports Including CT reports? Yes [1 If Yes, Are they the State Formatted Reports? I: Yes For Conventiona I urfaee Is the Water System Submitting Quarterly TOC Monitoring Reports?: El Yes lf Yes, Are they the State Formatted Reports? Yes No( D) Is the water system Monltorlng for [j Yes Does the Water System have a DBP Monitoring Plan on File?: CI Yes Notes: Pagel4 Last Updated:9/19/2013 California Department of Public Health Small Water System Unit LPA File Review COUNTY NAME: Tulare A. WATER SYSTEM INFORMATION System Name: Dry Creek Deli System Number: 5403030 Population: Service Connections: Water System Classification: l:lCommunity EINon?Transient Non-Community IXITransient Non-Community DOther: System Physical Location Address: 33454 Sierra Drive, Lemon Cove 93244 Operator Certification: Em D02 [304 Dos EH DTs DT4 Notes: PWS was formerly Foothill Fruit Co. B. PERMIT INFORMATION Water Supply Permit Date ssued:5l31l2012 Permit Number (if applicable): State Formatted Permit?: Permit >10 Years Old?: Tech. Report Included: Yes Yes(D) No Yes I:l Notes: Permit provision missing-T1 operator, treated water samples required. PN still required, but permitted for treatment-Culligan RESIN Tech c. INFORMATION . Groundwater Surface Water GWUDI Other. Treatment Provided: I:l No Number of Number of Number of . Number of Sources: Sources. 1 Sources. Sources Required Treatment for: SWTR MCL-Primary El MCL?Secondary CI2 I:l Other: Treatment Type: IX treatment installed POU Provided: Yes I: No For what Constituent(s): Bottled Water Provided: l:l Yes No For what Constituent(s): Notes: TMF packet included. Page 1 Last Updated19/19/2013 California-Department of=Public Health Small Water System Unit LPA File Review Date of Last Sanitary Conducted: 5/24/2012 State Formatted Report?: Yes Do the Sanitary Survey Reports Include all 8 Elements(see below)?: Yesg Sanitary Survey Elements: Source, Treatment, Distribution, Storage, Pump Facilities, Monitoring/Reporting/Data Verification, Management/Operation, and Operator Certification. Is a Sanitary Survey Past Due Based on the 3 or 5 year Frequency: Yes(D) No Notes: Required treatement operator tevel not identified. The owner was listed, but unknown if he has a T1 license or what is required. il/I&R for treated water not (used quarterly). BSSP lists a (T2102 Bob Protzman). Bacteriological Sample Siting Plan: Date of Last BSSP: BacT Monitoring Frequency: Yes Cl 11/20/2012 1 per Mon. El Qtr. BSSP is 10 Years Old?: Yes(D) No BSSP Needs Revisions? IE Yes(D) No Emergency Notificaton Plan: Yes Date of Last Emergency Notificaton Plan: 11/20/2012 Water System Ops Plan?: Yes Date of Last Water System Ops Plan: none available Notes: No emergency operations plan for the ion exchange treatement plant. BSSP needs a distribution map with sample site locations noted. ENPs need to be on state forms with State DEs phone numbers. Bacteriological Issues: of MCL Violations in a 12 Month Period (3 Is Required or Optional TCR MCLs or more= cont. Cl; is advised): (Precautionary): Yes No TCR Is the LPA Requiring Water System to Sample Source(s) for Yes Is the LPA Using WQI Last Sample/Next Due Reports?: Yes Last Sample Date(s) of Req. Inorganic Chemicals (IOC): Nitrate treatment requires monthiy treated; quarterly raw. Not In Compliance?: Yes conducting as required Last Sample Date(s) of Req. Volatile Organic Chemicals (VOC): one sample required for TNC not in database. In Compliance?: [3 Yes Last Sample Date(s) of Req. Organic Chemicals (SOC): one sample required for TNC not in database. In Compliance?: Yes Last Sample Date(s) of Required Radiological Chemicals: one sample required for TNC -- not in database. In Compliance?: (3 Yes c: i 2 Last Updated:9/19/2013 California Department of Public Health Small Water System Unit LPA File Review G. WATER QUALITY MONITORING (CONTINUED) Last Sample Date(s) of Nitrate/Nitrite Chemicals Nitrate treatment requires treated; quarterly raw. Not In Compliance?: Yes conducting as required Last Sample Date(s) for Lead and Copper Rule: Not required for a TNC In Compliance?: Yes Does the Water System have Unaddressed MCL Issues?: Yes(D) I: No Notes: Need to change this water nitrate monitoring to montly due to the new permit that was issued 5/2012 for ion exchange treatement. H. CONSUMER CONFIDENCE REPORTS (CCR) NIA Does the Water System have Previous Year CCR on File?: Yes - Not required for a TNC Does the CCR Meet Reporting Yes NIA - Not required for a TNC Was the Proof of Notification Verification Form Submitted to LPA and in the File: Yes I: l. ENFORCEMENT ACTIONS Do the Enforcement Actions Issued Meet the Addressing EA Criteria Below?: Yes El Enforcement actions need to have the following elements to be classified as an ADDRESSING ACTION: . The Action must describe the specific provision of statue or regulation that has been violated. - The Action must cite the applicable provision of statue or regulation. 0 The Action must describe specific actions to be performed by the water system to return to compliance (is. directives). . The Action must include a compliance schedule. 0 The Action must inform the water system that failure to comply with the Action is, in and of itself, an enforceable action (Le. Civil Penalty Clause). Does the LPA Need to Work on Issuing Addressing Enforcement Actions?: Yes(D) I: No Is the Public Notification Included in the Enforcement Action Issued (Tier 1/Tier Yes I: Is the LPA Using the Correct Public Notification Notices?: Yes Notes: Permit was issued for ion exchange, but the water system is still providing PN for nitrate violations and actually had a fine for not providing PM for 102013. Letter signed 5/25/2013 saying no modifications, doesn?t say for what is? Is it for ion exchange treatement? Page 3 Last Updated:9/19/2013 c-aliforniaa'epartment ofPuinc Health small Water Syste_m5Unit LPA File Review Pagel4 Lasi Updated:9/19/2013 Californiaoepiartment of Public Health Small Water System Unit . . File-Review, is the Water System Submitting SWTR Monitoring Reports, including CT reports?: No it Yes, Are they the State Formatted Reports? [1 Yes is the Water System Submitting Quarterly TOC Monitoring Reports?: Yes if Yes, Are they the State Formatted Reports? Yes is the Water System Monitoring for Yes Does the Water System have a DBP Monitoring Plan on File?: Yes Notes: Permit issued for IX treatment May 12, 2012, however the system still providing PM for N03 violation and they actually had a fine for not providing PN in the ?ist quarter of 2013. If they have approved IX treatment then PM is not required. This system provides treatment for a primary MCL and should be inspected once every 2 years. Page 5 Last Updatedzgn 9/2013 ?California Department-pf; Health Small Water-System-Uhit - LPA File Rev'ie'w'. System Name: East Orosi System Number: 5401003 Population: 700 Service Connections: 130 Water System Classification: IXCommunity DNon?Transient Non?Community DTransient Non-Community [:IOther: System Physical Location Address: Lone Ave Road 136, Orosi Operator Certification: DDS D05 [:lT2 DT4 Notes: D1 Required? Water Supply Permit Date Issued: 4/6/2006 Permit Number (if applicable): State Formatted Permit?: Permit >10 Years Old?: Tech. Report Included: Yes Yes(D) No (2006) IE Yes I: Notes: Groundwater Surface Water GWUDI Other: Treatment Provided: Number of Number of Number of . Yes No Sources: 2 Sources: Sources Number Of Sources. Required Treatment for: [j SWTR MCL-Primary MCL-Secondary 012 Other: Treatment Type: POU Provided: Yes No For what Constituent(s): Bottled Water Provided: Yes No For what Constituent(s): Notes: Water System exceeds nitrate MCL, apptied for bottled water. Page 1 Last Updated29/19/2013 California Department of Public Health Small Water System Unit LPA File Review D. SANITARY SURVEY Date of Last Sanitary Conducted: State Formatted Report?: Yes Do the Sanitary Survey Reports Include all 8 Elements(see below)?: Yesg Sanitary Survey Elements: Source, Treatment, Distribution, Storage, Pump Facilities, Monitoring/Reporting/Data Verification, Management/Operation, and Operator Certification. Is a Sanitary Survey Past Due Based on the 3 or 5 year Frequency: Yes(D) No Notes: 6/2012 inspection to investigate source coliform contamination. E. OPERATIONAL PLANS Bacteriological Sample Siting Plan: . BacT Monitoring Frequency: IE Yes Date of Last BSSP. 11/99. 1 per Mon. El Qtr. BSSP is 10 Years Old?: Yes(D) No BSSP Needs Revisions? Yes(D) I: No Emergency Notificaton Plan: Yes Date of Last Emergency Notificaton Plan: Water System Ops Plan?: Yes Date of Last Water System Ops Plan: Notes: ENP- needs update new form and very old. BSSP is over 10 years old. Required to be updated every 10 years. Need updated form. F. WATER QUALITY MONITORING Bacteriological Issues: of Violations in a 12 Month Period (3 Is Required or Optional TCR MCLs or more= cont. Clzis advised): (Precautionarythe LPA Requiring Water System to Sample Source(s) for Yes Is the LPA Using WQI Last Sample/Next Due Reports?: Yes Last Sample Date(s) of Req. Inorganic Chemicals (IOC): El In Compliance?: Yes Last Sample Date(s) of Req. Volatile Organic Chemicals (VOC): In Compliance?: Yes El Last Sample Date(s) of Req. Organic Chemicals (SOC): In Compliance?: Yes I: Last Sample Date(s) of Required Radiological Chemicals: In Compliance?: Yes Page 2 Last Updated:9/19/2013 California Department ofPublic Health Small Water-System Unit LPA File Review Last Sample {)ate(s) of Nitrate/Nitrite Chemicals [3 In Compliance?: Yes [2 Last Sample Date(s) for Lead and Copper Rule: In Compliance?: Yes Does the Water System have Unaddressed MCL lssues?: Yes(D) No Notes: They have unadressed nitrate MCL issues. W.Q. out of date past due on monitoring. Does the Water System have Previous Year CCR on File?: Yes Year 2011 Does the CCR Meet Reporting Yes shows lead at 16.05 MCL Was the Proof of Notification Verification Form Submitted to LPA and in the File: Yes Do the Enforcement Actions Issued Meet the Addressing EA Criteria Below?: Yes Enforcement actions need to have the following elements to be classified as an ADDRESSING ACTION: . The Action must describe the specific provision of statue or regulation that has been violated. . The Action must cite the applicable provision of statue or regulation. . The Action must describe specific actions to be performed by the water system to return to compliance directives). The Action must include a compiiance schedule. 0 The Action must inform the water system that failure to compiy with the Action is, in and of itself, an enforceable action Civil Penalty Clause). Does the LPA Need to Work on Issuing Addressing Enforcement Actions?: Yes(D) No is the Public Notification included in the Enforcement Action lssued (Tier 11Tier Yes Is the LPA Using the Correct Public Notification Notices?: Yes Notes: They are not issuing the Public Notices at the correct frequencies. Nitrate proof of notification was last submitted to the LPA on 3/14/2012. Page 3 Last Updated:9th/2013 California Department of Public Health Small Water System Unit LPA File Review jFor Surface Water is the water System Submitting SWTR MonItormg Reports including CT reports Yes If Yes, Are they the State Formatted Reports? [3 Yes Is the Water System Submitting Quarterly TOC monitoring Reports?: Yes If Yes, Are they the State Formatted Reports? Yes [1 Water Systems Only (Comm mty' .. Chlo man Is the Water System Monitoring for I:l Yes [1 Does the Water System have a DBP Monitoring Plan on File?: Yes Notes: Even though the system was inspected in both 2011 and 2012, based on a file review during the Evaluation for both years, the system is still missing WQ monitoring, BSSP 10 years old, old ENP that does not have adequate after hours phone numbers for State DES and Visalia District Contacts. Follow- up with deadlines for the above issues has not been addressed. Pagel4 Last Updated:9l19/2013 California Department of Public Health Small Water System Unit LPA File Review L. EXPLAINATION OF DEFICIENCIES (D): Priority 1- Within 30 Days Priority 2- Within 60 Days Priority 3- Within 90 Days Priority 4- Deadline As stated A 10. Reviewer: Date: Page 5 Last Updated19/19/2013