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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX PACIFIC SOUTHWEST REGION
75 Hawthorne Street
San Francisco, CA 94105-3901
—

OCT 172019
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
70190700000176529817
Mr. Scott Lawson
Oasis Mobile Home Park
Torres Martinez Desert Cahuilla Indian Reservation
88740 Avenue70
Thermal, CA 92274
Subject:

Emergency Administrative Order under Section 1431 SDWA
U.S. EPA Docket No. PWS-AO-2019-6008
Oasis Mobile Home Park Public Water System (090605129)

Dear Mr. Lawson:
The purpose of this letter is to notify you of ongoing violations of the above-referenced emergency order
(“the Order”) that U.S. EPA Region 9 (“EPA”) issued to Oasis Mobile Home Park (“Oasis”) under
Section 1431 of the Safe Drinking Water Act (“SDWA”), 42 U.S.C. § 300i, on August 27, 2019, to
address EPA’s concerns about a potential imminent and substantial endangerment to human health from
high levels of arsenic in Oasis’ public water system (“the System”). The Order also was intended to
bring the System into compliance with SDWA’s maximum contaminant level (“MCL”) for arsenic of 10
parts per billion (“ppb”). In calendar year 2019, arsenic monitoring results taken at the System were
above the arsenic MCL on April 16th, June 6th, and July 15th, at 16 ppb, 89 ppb and 97 ppb, respectively.
Arsenic levels increased more than nine times the MCL. These high levels could result in acute and
chronic health effects.
Oasis has failed to timely comply with the following requirements of the Order:
Alternative Water
Under paragraph 20 of the Order, Oasis must provide an alternative source of water to its customers at
no direct cost to customers until the System comes into compliance with the arsenic MCL running
annual average (“RAA”) or EPA notifies Oasis in writing that it may discontinue supplying alternative
source of water to its customers. Based on a recent inspection and interviews with Oasis’ residents, it
appears that Oasis has failed to meet this requirement because it restricts the time and manner that
alternative water is provided. Specifically, Oasis has limited hours of operation during the weekend (9
am to 12 pm) and only allows the individuals named on the lease to pick up bottled water. Further,
shortly after the Order was issued, Oasis raised the rent by $100. While you assert that the raise in rent
was scheduled prior to the issuance of the Order, the timing of it gives the appearance that Oasis is
attempting to recoup its costs from its customers for providing water. If Oasis is attempting to recoup its
costs of providing alternative water to its customers, this would be a violation of the Order.
Public Notice
Under the public notice requirements at 40 C.F.R. 141.203(a)(1), (b) and (c), the System must provide
public notice of any MCL violation as soon as practical, but no later than 30 days after the system learns
of a violation, and in a form and manner that is reasonably calculated to reach persons served. Oasis was

 in violation of the public notice requirement prior to issuance of the Order, and paragraph 23 of the
Order required that Oasis comply with the provision. However, Oasis continues to violate the
requirement by posting misleading notices (see Attachment A photo) suggesting to the System’s users
that water is now safe to drink. Sampling data still does not establish that Oasis is no longer in violation
of the arsenic MCL. On October 10, 2019, given Oasis’ failure to provide adequate public notice, EPA
inspectors posted public notices in English and Spanish on public property throughout Oasis and these
public notice must not be removed and/or altered.
Technical Review of Arsenic Treatment System
Under paragraph 26 of the Order, Oasis “shall engage a technical provider with sufficient engineering
knowledge and certification regarding the particular treatment system used by Respondents to assess and
identify deficiencies related to the System’s arsenic treatment.” It is unclear whether Oasis has
complied with this requirement, as it has provided the names of four different technical providers and
has not clarified which one it has chosen or whether any of them has the requisite experience with this
particular treatment system. Within 5 business days of receipt of this letter, Oasis shall identify to EPA
Oasis’ technical provider and describe this individual’s experience and background with regard to Oasis’
treatment system.
Disapproval of Work Plan
Finally, under Paragraph 27 of the Order, “Respondents shall develop and submit to EPA for review and
approval the findings of its technical provider’s review, a written work plan (“Work Plan”) to address
any identified deficiencies related to the arsenic treatment system, along with a proposed schedule for
expeditious implementation of any identified measures or work to make the System function in a
manner that ensures compliance,” including reliably and consistently being in compliance with the
arsenic MCL RAA in accordance with SDWA regulations. While Oasis submitted a plan on October 11,
2019, it is lacking in sufficient detail to meet the requirements of the Order, and must be revised and
resubmitted with additional details before it is implemented. Specifically, it appears that the submitted
Work Plan is based off of RCAC’s Technical Review and recommendations, which was completed on
August 23, 2019 prior to the issuance of the Order. Oasis should have its elected technical provider
provide a new Technical Review, which could reference and/or use findings from the RCAC’s
Technical Review, as an attachment to the resubmitted Work Plan. In addition, the resubmitted Work
Plan must better identify and describe each work project in accordance with what was discovered during
the technical review and described in the report, and establish realistic project completion dates with due
dates for each project. We ask that you set up a call with EPA and your technical provider before
October 25 to discuss a revised Work Plan in order to submit it by November 1.
Entry Point to Distribution
Under the inorganic chemical sampling and analytical requirements of the SDWA, 40 C.F.R. § 141.23,
community water systems must conduct arsenic monitoring to determine compliance with the MCL,
including taking one sample at ever entry point to the distribution (“EPTD”) during each compliance
period which is representative of each well after treatment. Based on the System’s submitted arsenic
analytical reports to EPA from Babcock Laboratories, Inc., arsenic sampling is not being consistently
taken at the System’s EPTD. Therefore, EPA is making a determination based on relevant information
and visual confirmation that the System’s EPTD for Well 1 (GWOO 1), will be located at the nearest
sampling tap directly after arsenic treatment. No other sampling location (e.g., Storage Tank) will be an
acceptable location pursuant to the sampling and analytical requirements under SDWA, 40 C.F.R. §
141.23, unless otherwise noted in writing by EPA.

 If you or anyone on your staff have technical questions, please contact Everett Pringle at (415) 9723548 or via email to pringle.everett@epa.gov. Legal questions should be directed to Marcela von
Vacano in our Office of Regional Counsel at (415) 972-3905, or via e-mail to
vonvacano.marcela@epa.gov.
Thank you for your prompt attention to this matter.

Amy C. Miller, Director
Enforcement and Compliance Assurance Division
cc:

The Honorable Thomas Tortez. Torres Martinez Desert Cahuilla Indian Reservation

 Einer~encv Order Oasis Mobile Home Park
U.S. EPA 1)ocket \o.P\\ S-AO-2() I 9-6OO~
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