John Simpson, D.ppd, P.E. - 2 - August 22, 2017

Ross Davis Assistant Director, Water Resources Division

MCIWEST-Marine Corps Base (Bldg. 220105T) Box 555013 Camp Pendleton, CA 92055-5013 Erika Marx Drinking Water Section Head, Engineering Branch Environmental Security MCIWEST-Marine Corps Base (Bldg. 22165) Box 555008 Camp Pendleton, CA 92055-5008 Christopher Chen, Enforcement Officer SDWA/FIFRA Enforcement Office U.S. Environmental Protection Agency – Region IX 300 Ala Moana Blvd., #5-152 (ENF-3-3) Honolulu, HI 96850 Phone: (808) 541-2723 E-mail: chen.christopher@epa.gov

Citation No. 05_14_17C_002 1

2

STATE OF CALIFORNIA 3

STATE WATER RESOURCES CONTROL BOARD 4

DIVISION OF DRINKING WATER 5

6

Name of Public Water System: Marine Corps Base Camp Pendleton North 7

Water System 8

Water System No: 3710700 9

10

Attention: John Simpson, D.ppd, P.E. 11

Director, Water Resources Division 12

MCIWEST-Marine Corps Base (Bldg. 220105T) 13

Box 555013 14

Camp Pendleton, CA 92055-5013 15

16

Issued: August 22, 2017 17

18

CITATION FOR NONCOMPLIANCE 19

FAILURE TO COMPLY WITH STATE OPERATOR CERTIFICATION 20

REGULATIONS 21

TITLE 22, CALIFORNIA CODE OF REGULATIONS (CCR), SECTIONS 22

64413.7(a) AND 64413.5(a) 23

24

The California Health and Safety Code (hereinafter “CHSC”), Section 116650 25

authorizes the State Water Resources Control Board (hereinafter “State 26

Board”) to issue a citation to a public water system when the State Board 27

determines that the public water system has violated or is violating the 28

California Safe Drinking Water Act (hereinafter “California SDWA”), (CHSC, 1

Division 104, Part 12, Chapter 4, commencing with Section 116270), or any 2

regulation, standard, permit, or order issued or adopted thereunder. 3

4

The State Board, acting by and through its Division of Drinking Water 5

(hereinafter “Division”) and the Deputy Director for the Division, hereby issues 6

this citation pursuant to Section 116650 of the CHSC to the Marine Corps 7

Base Camp Pendleton North Water System (hereinafter “MCB CamPen 8

NWS”) for violation of Title 22, CCR, Sections 64413.7(a) and 64413.5(a). 9

10

A copy of the applicable statutes and regulations are included in Appendix 1, 11

which is attached hereto and incorporated by reference. 12

13

STATEMENT OF FACTS 14

The MCB CamPen NWS is classified as a Community water system with a 15

population of 15,600, serving 944 connections. 16

17

On May 8, 2017, John Simpson of MCB CamPen e-mailed James Jablonski 18

of the Division regarding the certified operators for the MCB CamPen water 19

systems (both NWS and South Water System, or SWS). Murray Tomlinson 20

was to be designated the Chief Distribution Operator for both systems. From 21

June 26 to June 30, 2017, the United States Environmental Protection Agency 22

(hereinafter “EPA”), Region 9, Enforcement Division, conducted an inspection 23

of the MCB CamPen NWS and SWS, which included interviews with water 24

system operators. During his interview with EPA, Mr. Tomlinson indicated 25

that he was not aware that he was the designated chief distribution operator 26

for the water system; thus, he was not functioning as a chief operator, as 27

defined in Title 22, CCR, Section 63750.25. Art Mendoza, the current 28

Distribution Supervisor for the system, was also interviewed and he indicated 1

that there was no chief distribution operator for the system. Mr. Tomlinson’s 2

and Mr. Mendoza’s interviews are documented in EPA’s Inspection Report of 3

the two systems; a copy of the applicable pages in the report is included in 4

Appendix 3. 5

6

In the aforementioned e-mail, Phillip Sipes was to be designated the Chief 7

Treatment Operator for both systems. EPA also interviewed Mr. Sipes. 8

During that interview, Mr. Sipes indicated that he was a shift operator, not 9

chief operator. Keith Regalado, a shift treatment operator for the system, was 10

also interviewed and he indicated that there was no chief treatment operator 11

for the system. Mr. Sipes’s and Mr. Regalado’s interviews are also 12

documented in EPA’s Inspection Report of the NWS and SWS; a copy of the 13

applicable pages in the report is included in Appendix 3. 14

15

Operator staffing – including the adequacy of it - was discussed on several 16

occasions during EPA’s inspection (see Appendix 3). 17

18

EPA’s inspection confirmed that the MCB CamPen NWS does not have a 19

centralized Supervisory Control and Data Acquisition (SCADA) system (see 20

Appendix 3). 21

22

EPA’s inspection revealed that the MCB CamPen NWS does not have an 23

Asset Management Plan and Capital Improvement Plan (see Appendix 3). 24

25

A water system operations and maintenance plan - as described in Title 22, 26

CCR, Section 64600 - includes elements pertaining to operators, including the 27

workforce survey to determine the qualifications and training of required 28

operators (Section 64600(a)(11)). An Asset Management Plan and Capital 1

Improvement Plan aids in the planning and scheduling of repairs identified 2

from a regular reservoir inspection program (Section 64600(a)(4)). The 3

improvement to the SCADA system aids in the overall operations of the water 4

system, including groundwater sources and unit processes (Section 5

64600(a)(2)). 6

7

DETERMINATION 8

1. Title 22, CCR, Section 64413.7(a) requires a water system to 9

designate at least one chief operator for each distribution system 10

utilized by the water system. Since Mr. Tomlinson was not functioning 11

as a chief operator, the Division has determined that the MCB CamPen 12

NWS is in violation of Section 64413.7(a). 13

2. Title 22, CCR, Section 64413.5(a) requires a water system to 14

designate at least one chief operator for each water treatment facility 15

utilized by the water system. Since Mr. Sipes indicated that he was a 16

shift operator and not chief operator, the Division has determined that 17

the MCB CamPen NWS is in violation of Section 64413.5(a). 18

19

DIRECTIVES 20

The MCB CamPen NWS is hereby directed to take the following actions: 21

22

1. Within 45 days of receiving this citation, the MCB CamPen NWS shall 23

certify in writing to the Division that chief treatment and distribution 24

operators have been designated for the system. The certification shall 25

include the name and grade level of the operator, and a statement 26

confirming that the operator has the responsibility defined in Title 22, 27

CCR, Section 63750.25. 28

2. On or before April 1, 2018, the MCB CamPen NWS shall comply with 1

Title 22, CCR, Section 64413.7(a) and Title 22, CCR, Section 2

64413.5(a), utilizing appropriately certified chief distribution and 3

treatment operators. 4

3. Within 120 days of receiving this citation, the MCB CamPen NWS shall 5

complete a workforce analysis to determine how many operators are 6

needed to operate the system. 7

4. Within two years of receiving this citation, the MCB CamPen NWS shall 8

install a centralized control system, such as a Supervisory Control and 9

Data Acquisition (“SCADA”) system, for management of the system. 10

5. Within 180 days of receiving this citation, the MCB CamPen NWS shall 11

develop an Asset Management Plan and Capital Improvement Plan 12

that identifies regular maintenance and upgrade needs, costs, capital 13

projects, and timelines for planned upgrades. 14

15

All submittals required by this citation shall be electronically submitted to the 16

Division at the following address. The subject line for all electronic submittals 17

corresponding to this citation shall include the following information: Water 18

System name and number, citation number and title of the document being 19

submitted. 20

21

Oliver Pacifico, P.E., District Engineer, Santa Ana District 22

Dwpdist08@waterboards.ca.gov 23

24

The State Board reserves the right to make such modifications to this citation 25

as it may deem necessary to protect public health and safety. Such 26

modifications may be issued as amendments to this citation and shall be 27

effective upon issuance. 28

1

Nothing in this citation relieves the MCB CamPen NWS of its obligation to 2

meet the requirements of the California SDWA (CHSC, Division 104, Part 12, 3

Chapter 4, commencing with Section 116270), or any regulation, standard, 4

permit or order issued or adopted thereunder. 5

6

PARTIES BOUND 7

This citation shall apply to and be binding upon the MCB CamPen NWS, its 8

owners, shareholders, officers, directors, agents, employees, contractors, 9

successors, and assignees. 10

11

SEVERABILITY 12

The directives of this citation are severable, and the MCB CamPen NWS 13

shall comply with each and every provision thereof notwithstanding the 14

effectiveness of any provision. 15

16

FURTHER ENFORCEMENT ACTION 17

The California SDWA authorizes the State Board to issue a citation or order 18

with assessment of administrative penalties to a public water system for 19

violation or continued violation of the requirements of the California SDWA or 20

any regulation, permit, standard, citation, or order issued or adopted 21

thereunder including, but not limited to, failure to correct a violation identified 22

in a citation or compliance order. The California SDWA also authorizes the 23

State Board to take action to suspend or revoke a permit that has been issued 24

to a public water system if the public water system has violated applicable law 25

or regulations or has failed to comply with an order of the State Board, and to 26

petition the superior court to take various enforcement measures against a 27

public water system that has failed to comply with an order of the State Board. 28

APPENDIX 1 FOR

CITATION NO. 05_14_17C_002: APPLICABLE STATUTES AND REGULATIONS

NOTE: The following language is provided for the convenience of the recipient, and cannot be relied upon as the State of California’s representation of the law. The published codes are the only official representation of the law. Regulations related to drinking water are in Titles 22 and 17 of the California Code of Regulations. Statutes related to drinking water are in the Health & Safety Code, the Water Code, and other codes. California Health and Safety Code (CHSC): Section 116271 states in relevant part: (a) The State Water Resources Control Board succeeds to and is vested with all of the authority, duties, powers, purposes, functions, responsibilities, and jurisdiction of the State Department of Public Health, its predecessors, and its director for purposes of all of the following:

(1) The Environmental Laboratory Accreditation Act (Article 3 (commencing with Section 100825) of Chapter 4 of Part 1 of Division 101). (2) Article 3 (commencing with Section 106875) of Chapter 4 of Part 1. (3) Article 1 (commencing with Section 115825) of Chapter 5 of Part 10. (4) This chapter and the Safe Drinking Water State Revolving Fund Law of 1997 (Chapter 4.5 (commencing with Section 116760)). (5) Article 2 (commencing with Section 116800), Article 3 (commencing with Section 116825), and Article 4 (commencing with Section 116875) of Chapter 5. (6) Chapter 7 (commencing with Section 116975). (7) The Safe Drinking Water, Water Quality and Supply, Flood Control, River and Coastal Protection Bond Act of 2006 (Division 43 (commencing with Section 75001) of the Public Resources Code). (8) The Water Recycling Law (Chapter 7 (commencing with Section 13500) of Division 7 of the Water Code). (9) Chapter 7.3 (commencing with Section 13560) of Division 7 of the Water Code. (10) The California Safe Drinking Water Bond Law of 1976 (Chapter 10.5 (commencing with Section 13850) of Division 7 of the Water Code). (11) Wholesale Regional Water System Security and Reliability Act (Division 20.5 (commencing with Section 73500) of the Water Code). (12) Water Security, Clean Drinking Water, Coastal and Beach Protection Act of 2002 (Division 26.5 (commencing with Section 79500) of the Water Code).

(b) The State Water Resources Control Board shall maintain a drinking water program and carry out the duties, responsibilities, and functions described in this section. Statutory reference to “department,” “state department,” or “director” regarding a function transferred to the State Water Resources Control Board shall refer to the State Water Resources Control Board. This section does not impair the authority of a local health officer to enforce this chapter or a county’s election not to enforce this chapter, as provided in Section 116500... (k) (1) The State Water Resources Control Board shall appoint a deputy director who reports to the executive

director to oversee the issuance and enforcement of public water system permits and other duties as appropriate. The deputy director shall have public health expertise. (2) The deputy director is delegated the State Water Resources Control Board’s authority to provide notice, approve notice content, approve emergency notification plans, and take other action pursuant to Article 5 (commencing with Section 116450), to issue, renew, reissue, revise, amend, or deny any public water system permits pursuant to Article 7 (commencing with Section 116525), to suspend or revoke any public water system permit pursuant to Article 8 (commencing with Section 116625), and to issue citations, assess penalties, or issue orders pursuant to Article 9 (commencing with Section 116650). Decisions and actions of the deputy director taken pursuant to Article 5 (commencing with Section 116450) or Article 7 (commencing with Section 116525) are deemed decisions and actions taken, but are not subject to reconsideration, by the State Water Resources Control Board. Decisions and actions of the deputy director taken pursuant to Article 8 (commencing with Section 116625) and Article 9 (commencing with Section 116650) are deemed decisions and actions taken by the State Water Resources Control Board, but any aggrieved person may petition the State Water Resources Control Board for reconsideration of the decision or action. This subdivision is not a limitation on the State Water Resources Control Board’s authority to delegate any other powers and duties.

Section 116555 states in relevant part: (a) Any person who owns a public water system shall ensure that the system does all of the following:

(1) Complies with primary and secondary drinking water standards. (2) Will not be subject to backflow under normal operating conditions. (3) Provides a reliable and adequate supply of pure, wholesome, healthful, and potable water.

Section 116650 states in relevant part: (a) If the state board determines that a public water system is in violation of this chapter or any regulation, permit, standard, citation, or order issued or adopted thereunder, the state board may issue a citation to the public water system. The citation shall be served upon the public water system personally or by certified mail. Service shall be deemed effective as of the date of personal service or the date of receipt of the certified mail. If a person to whom a citation is directed refuses to accept delivery of the certified mail, the date of service shall be deemed to be the date of mailing. (b) Each citation shall be in writing and shall describe the nature of the violation or violations, including a reference to the statutory provision, standard, order, citation, permit, or regulation alleged to have been violated. (c) A citation may specify a date for elimination or correction of the condition constituting the violation. (d) A citation may include the assessment of a penalty as specified in subdivision (e). (e) The state board may assess a penalty in an amount not to exceed one thousand dollars ($1,000) per day for each day that a violation occurred, and for each day that a violation continues to occur. A separate penalty may be assessed for each violation and shall be in addition to any liability or penalty imposed under any other law. Title 22, California Code of Regulations (CCR): §63750.25. Chief Operator. “Chief operator” means the person who has overall responsibility for the day-to-day, hands-on, operation of a water treatment facility or the person who has overall responsibility for the day-to-day, hands-on, operation of a distribution system. §63765. Water Treatment Facility Staff Certification Requirements. (a) Except as provided in (c), chief and shift operators shall possess valid operator certificates pursuant to Table 63765-A.

Table 63765-A Minimum Certification Requirements for Chief and Shift Operators

Treatment Facility Classification

Minimum Certification of Chief Operator

Minimum Certification of Shift Operator

T1 T1 T1 T2 T2 T1 T3 T3 T2 T4 T4 T3 T5 T5 T3

§63770. Distribution System Staff Certification Requirements. (a) Chief and shift operators shall possess valid operator certificates pursuant to Table 63770-A.

Table 63770-A Minimum Certification Requirements for Chief and Shift Operators

Distribution System Classification

Minimum Certification of Chief Operator

Minimum Certification of Shift Operator

D1 D1 D1 D2 D2 D1 D3 D3 D2 D4 D4 D3 D5 D5 D3

§64413.5. Treatment Facility Staff Certification Requirements. (a) Each water supplier shall designate at least one chief operator that meets the requirements specified in §63765 for each water treatment facility utilized by the water system. §64413.7. Distribution System Staff Certification Requirements. (a) Each water supplier shall designate at least one chief operator that meets the requirements specified in §63770 for each distribution system utilized by the water system.

APPENDIX 2 FOR CITATION NO. 05_14_17C_002: MAY 8, 2017 E-MAIL FROM MCB CAMPEN TO DIVISION REGARDING CERTIFIED OPERATORS

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Jablonski, James@Waterboards

From: Simpson CIV John O <john.o.simpson@usmc.mil>Sent: Monday, May 08, 2017 5:49 PMTo: Jablonski, James@WaterboardsCc: Davis CIV Ross L; Marx CIV Erika; Bonsavage CIV Mark J; Pacifico, Oliver@WaterboardsSubject: RE: CPEN Chief Operator Inquiry

Jim, Erika will provide you with our more formal submission, but I wanted to get back to you as quickly as possible on this. Phillip Sipes (T3) will be designated our Chief Treatment Operator for both the Southern and Northern Systems. Murry Tomlinson (D4) will be designated our Chief Distribution Operator for both the Southern and Northern Systems. As you know, even though the Systems are permitted separately, "operationally" we operate them as one system for distribution with the distribution operator(s) [one operator at night and two or more during the day and evening] covering the entire base and for treatment, we have a southern shift operator on with a the northern system a combination of treatment and distribution. Treatment Shift Operators: Keith Regalado (T3) Loui Andiorio (T3) Anthony Buccellato (T2) Distribution Shift Operators: Bruce Kilgore (D3) Craig Daskalakis (D3) Brian Spencer (D4) Respectfully, John Simpson, DPP, PE Director, Water Resources Division Camp Pendleton, CA (O) 760-725-1059 (C) 760-846-2273 john.o.simpson@usmc.mil -----Original Message----- From: Jablonski, James@Waterboards [mailto:James.Jablonski@waterboards.ca.gov] Sent: Thursday, May 04, 2017 2:19 PM To: Simpson CIV John O Cc: Davis CIV Ross L; Marx CIV Erika; Bonsavage CIV Mark J; Pacifico, Oliver@Waterboards Subject: [Non-DoD Source] CPEN Chief Operator Inquiry

APPENDIX 3 FOR CITATION NO. 05_14_17C_002: EXCERPT OF EPA’S INSPECTION REPORT OF THE MCB CAMPEN NWS & SWS

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U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

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Mr. Simpson stated that WRD is modeled after a standard water district and explained variousobstacles for operating the Systems. One of the main obstacles is the lag in funding. If aconstruction project is $1M or more, then it will take a minimum of six years before they canobtain the funds from Congress and begin construction. He added that maintaining staff levelsis difficult because WRD can only hire operators at approximately $20,000 less than nearbywater districts and offers less desirable retirement plans. The systems do not currently have anoperational SCADA system. WRD has struggled to install a new system due to cybersecurityissues discussed in more detail below. WRD plans to install a comprehensive SCADA system inapproximately 1.5 years, with a total cost of ideally less than $3M. This is being funded using aportion of the budget that does not require congressional approval. Mr. Simpson explained thattheir more immediate solution is to purchase and install sensors so that the reservoir levels canbe determined remotely. Until that time, operators must drive back and forth betweenreservoirs and booster stations in order to maintain reservoir levels.

Mr. Entingh described EnvSec akin to a Department of Environmental Resources. He explainedthat EnvSec currently does not have the expertise to evaluate the integrity of reservoirs, wells,and other drinking water apparatuses.

Mr. Simpson stated that operators can be working up to 12-hour shifts. Contractors are nothelpful because the Systems do not have SCADA, unlike most other public water systems in theregion. As a result, contractors do not understand how the Systems work. Mr. Simpson alsostated that there are hurtles to hiring contract operators due to federal restrictions, and thatcontract operators are mainly used during emergency situations. He added that it is 1.87 timesmore expensive to temporarily hire a state operator, and that hiring state operators also fostersdissatisfied employees because of their higher pay and benefits.

Mr. Simpson and Mr. Davis described further operational issues. One operator manages bothSystems at night. Due to lack of SCADA, an operator must visit every reservoir to check whetherit needs filling and check every well to operate the pumps. As a result, a reservoir may be filledlonger than needed, leading to overflow. Another issue may be two wells actively pumping,potentially leading to backflow concerns. During the day, a distribution operator monitors thereservoirs and wells, and records all important data in a logbook. This logbook is handed over tothe next operator when a shift ends. I asked about who oversees the logbooks. Mr. Simpsonstated that this was Mr. Art Mendoza, distribution system operator and D2 certified.

The Systems previously had partial SCADA capabilities but fell into disrepair for the followingreasons: lack of maintenance; wildfires; and most importantly, the loss of accreditation by

U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

5

military cybersecurity personnel. This SCADA formerly served up to ¾ of the South System. Mr.Simpson stated that the new, planned SCADA will have proper accreditation and that WRD willdo everything to ensure it does not lose cybersecurity accreditation.

All sampling is handled by an outside contractor (CB&I Labs) and third party laboratories. Mr.Simpson estimated that $1.2M goes towards drinking water sample collection and laboratoryanalysis. Some laboratory analyses are further subcontracted to a couple of other laboratories.WRD occasionally collects random samples to confirm the validity of sampling and analyses bythe contractors.

Mr. Simpson informed us that the Southern Advanced Water Treatment Plant (“SouthernAWT”), which has reverse osmosis treatment and granular activated carbon treatment for hightotal dissolved solids (“TDS”), is currently down. He estimated that this treatment plant willhopefully be functional again by mid-July. In the meantime, all the water goes through an ironand manganese removal plant (“I&M Plant”). The I&M plant connected to the Southern AWT isalso currently not operating due to filtering issues and lack of funds to spend on mediareplacement.

Drive to Reservoir RowAfter the opening conference, Mr. Ryan Thresher, Ms. Erika Marx, and Mr. Reginald Holman,drove us to the top of “Reservoir Row”, where a series of reservoirs are located along hilltops.This assisted EPA and DDW staff to understand the layout of the Santa Margarita Basin andwhere reservoirs, wells, and other important landmarks are located. I asked about basicinformation such as population served and number of connections. Ms. Marx stated that theinformation has not changed since the DDW sanitary survey conducted in March 2017. Seepage 6.

Mr. Holman explained that the first two digits on a building number for any building in CampPendleton indicates the area. The base is separated into numbered zones. Ms. Marx stated thatlogbooks are kept for each well and reservoir. She explained that someone is always managingthe treatment plant in the South System, although it may have to close at night if not enoughoperators are available.

1.3 Facility/Site DescriptionThe Systems, located just north of Oceanside in San Diego County, are owned and operated bythe United States Marine Corps. Per the presentation provided by WRD, Camp Pendleton’s twoSystems combined include: seven watersheds, 4 aquifers, 22 wells, 34 reservoirs, two advanced

U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

7

SECTION II – DAY 2 OBSERVATIONS (JUNE 27, 2017)On Tuesday, June 27, 2017, EPA and DDW staff met EnvSec staff at 8:00 AM at the CampPendleton Main Gate parking lot. EnvSec drove us to the Facilities Maintenance Department(FMD) building to discuss the plans for each day and answer any questions before starting fieldvisits. EPA, DDW, and Camp Pendleton staff followed this exact same procedure every day of theinspections.

At the FMD building, we met Art Mendoza and Allen Hollander. Mr. Entingh, Mr. Thresher, andMs. Marx were also present the entire day. I asked Mr. Mendoza to explain the South System’schlorination treatment, and to explain the map and diagram provided the first day. The SouthSystem map indicated a couple of secondary chlorination stations. Mr. Mendoza explained thatthese stations were built to trigger if the chlorine residual was detected below 1.4 parts permillion (ppm). They are no longer used because there were problems with over chlorination. Mr.Mendoza explained that pressure drops led to the chlorine analyzer pulling in air, which triggeredfalse chlorine residual readings. This would trigger chlorination when it was not appropriate.These secondary stations have not been used for at least two years. The Las Pulgas side of theSystem has primary chlorination in the Las Flores area.

Mr. Mendoza stated that there are three entry points into the distribution system. Pressure istypically around 80-115 psi after treatment and that the goal is to maintain approximately 100psi within the distribution system. One operator makes the rounds to each reservoir, boosterpump, and well for the Santa Margarita portion of the South System. Another operator handlesthe North System and the Las Pulgas portion of the South System.

Mr. Hollander stated that all the required Title 22 drinking water monitoring is collected at theentry points and at the wells.

Mr. Mendoza stated that Reservoir 33710 is out of service. The goal for the steel tanks in Area31 is to convert them to firefighting purposes only.

I asked Mr. Mendoza about his length of employment. He responded that he has worked for WRDfor 9 years. His title is water distribution operator supervisor although he is not the “chiefdistribution operator”, a position required by the DDW permit. Mr. Mendoza stated that there iscurrently no chief distribution operator.

I asked Mr. Mendoza to explain the logbook system for managing the Systems. He explained thateach operator has a 10-hour shift. The first shift is from 0600 to 1600. The next shift is 1800 to0400. There is technically a two-hour interval between each shift. Logbooks are passed from each

U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

8

operator. If an operator is not able to physically hand over the logbook to the next operator, thenthe operator will write down notes for the next operator. On Wednesdays, there are twooperators working during the day. The operator that is not out doing the routine run will go outto conduct inspections of each reservoir and well. Wells and booster stations have independentlymaintained logbooks. Reservoirs logbooks are not maintained.

2.1 Unity RoomThe Unity Room is located within the FMD building. It monitors what remains of the oldSCADA. It only monitors a couple of wells and reservoirs at this point. It cannotcommunicate with the treatment plants anymore.

The Southern AWT keeps a record of which wells are on and off. Mr. Mendoza stated thatit is not possible or very difficult to detect chlorine events, reservoir overflows, or othersimilar issues due to the current method of operating the Systems.

2.2 Steel Tank 2491 and Booster Pump 2492Mr. Mendoza explained that this storage tank’s primary purpose is to feed BoosterStation 2492 to help send water up into Reservoir Row. It has a capacity of 150,000gallons. I was unable to observe the overflow because the overgrown brush obscured itslocation and limited access.

Booster Pump 2492 was rebuilt last year and is actively pumping 2-3 times per week. Itis typically on for only a short period.

2.3 Reservoir 13154I observed that the 5MG reservoir’s vent screens did not appear tightened, formingsmall gaps that may allow pest intrusion into the reservoir. This was also identified inthe March 2017 sanitary survey. Due to the nature of the roofing, rain water pondingwas evident because of dried puddles of dirt. Mr. Mendoza explained that they inspectfor water intrusion every three years due to ponding on the roof, but nothing is done inbetween. Mr. Mendoza was unable to locate the location of the overflow at the time ofthe inspection. The hatch door and the opening had a sanitary seal and did not have anynoticeable issues.

2.4 Reservoir 13151This reservoir has a capacity of 1.7 MG. The hatch door and opening appeared to be ingood condition. The terminal point of the overflow was too far downhill from thereservoir to access. Mr. Mendoza stated that all the overflow endpoints have a flapper

U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

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2.10 Interview: Murray TomlinsonAt the Southern AWT, we interviewed Murray Tomlinson, distribution operator. Mr.Tomlinson has been working for Camp Pendleton for 1.5 years, focusing on the SouthSystem. He works 10-hour shifts for four days a week. His shift is Sunday throughWednesday. He is a D4/T3 certified operator with 35 years of experience and reports toMr. Mendoza.

Mr. Tomlinson drives from reservoir to reservoir to determine whether water must beadded via the wells. He stated that he also monitors chlorine residuals when conductingsite visits. Mr. Tomlinson typically starts in the Area 28, moves to Reservoir Road, andthen to Areas 20, 32, and 33. He prioritizes visiting all wells that are actively pumpingduring his shift. He attempts to visit each reservoir every day although this may notalways happen due to time constraints.

Mr. Tomlinson makes all his notes in the operator logbook. After his shift, the logbook ishanded over to the next operator. Because of short staff, Mr. Tomlinson statedoperators cannot focus on all job duties as well as they should. For example, operatorsare not always able to read pumping levels. He stated that there were five operatoropenings right now and it will soon be six because an operator is retiring very soon. Headded that every operator on staff is at minimum D2/T2 certified.

I asked Mr. Tomlinson if he was chief distribution operator. He stated that he did nothold this position. I informed him that an email from WRD in DDW’s sanitary surveyindicated that he was chief distribution operator of the South and North System. Hereplied that this is first time he has heard he held this position.

2.11 Interview: Keith RegaladoAfter Mr. Tomlinson, we interviewed Mr. Regalado. Mr. Regalado is a shift treatmentoperator who began working for WRD in 2011. On a normal day of work, he said hewould check the SCADA, walk through the treatment plants and check that everything isfunctioning correctly. He added that this is currently not his normal day as thetreatment operators are focused on getting the treatment plants up and running first.He explained that the SCADA for the treatment plants still function because it does notrequire the cybersecurity accreditation that a system-wide SCADA would require.

Twice per day, Mr. Regalado completes an electronic “Go Form”, located on a e-tablet,which evaluates various aspects of the treatment plant. He stated that the SouthernAWT is usually staffed with two operators during the day, maybe three. At night, there is

U.S. Marine Corps / Camp Pendleton South and North Public Water SystemsInspection Dates: June 26, 2017 – June 30, 2017

12

one operator. There are two treatment shift operators and three treatment operators.The treatment plant is manned all hours of the day between six operators.

I asked Mr. Regalado about whether there was a chief treatment operator. He statedthat there are currently no chief treatment operators and no treatment supervisors.

2.12 Sampling and AnalysisDuring conversations in the vehicle driving to the various locations, Mr. Allen Hollanderstated that a contractor by the name of CB&I Federal Services collects all the drinkingwater samples. CB&I has been collecting samples on Camp Pendleton since 2005. CB&Ihas subcontracted laboratory analyses to EMAX. EMAX subsequently subcontractsanalyses primarily to Eurofins, which analyzes approximately 95% of the samples. BSKanalyzes perfluorinated compounds. Fruit Growers Laboratory analyzes radiochemicalcontaminants. All samples collected on weekends are sent to Enviro-Matrix.

For a short period, operators collected coliform samples. This practice was halted due tolack of operators available. Operators do not accompany the contractors during theprocess of collecting samples.

2.13 SecuritySecurity for all sites visited during the inspections appeared satisfactory regardingvandals and intruders. I observed that locked fences surrounded all the water facilities.All buildings were locked.

SECTION III – DAY 3 OBSERVATIONS (JUNE 28, 2017)Mr. McCarthy joined Ms. Watanabe and myself on Day 3. Mr. Pacifico had to return to theoffice to attend to other business.

3.1 ComplaintsAt the FMD building, I asked about the complaint system for the two Systems. Mr.Hollander stated that customer complaints go to Mr. Hollander, who then puts theminto the monthly report to DDW. He estimated that 80% of the complaints are requestsfor bottled drinking water. WRD only provides bottled water if a certain area is notserviced by one of the two Systems. Most of the requests are denied.

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Mr. Hollander stated that there was one incident of a customer falling ill. The militaryhospital investigated and conducted tests. The hospital concluded that the drinkingwater did not cause the illness.

Complaints are made to the FMD Customer Service phone line. A program calledMaximo generates work orders based off the complaints. When an operator goes out torespond to a complaint, they always test for chlorine residual, taste, and smell. Mr.Hollander stated that the monthly reports to DDW include complaints, if we areinterested in the record of complaints.

3.2 Incidents/ViolationsI asked about any notable incidents within the five years. Mr. Mendoza explained thatthey started manning the South System with operators 24 hours per day approximatelyfive years ago. The chief operator was on standby all hours of the day. WRD decided tohave staffing 24 hours per day after an over-chlorination incident. A chlorine reader wasfaulty and was chlorinating all night even though water was not being pumped, and thiserror wasn’t discovered until morning. Mr. Mendoza detailed that the chlorine residualwas above 4 ppm at the far end of the South System. They had to flush from over 100hydrants and partially dumped the finished water reservoirs.

Mr. Hollander stated that there were three total coliform detects in 2016. One in Marchat the South System, and two at the North System in July and September. WRD andDDW conducted L1 and L2 assessments, respectively, as required by the Revised TotalColiform Rule, but were unable to determine the source of the coliform detects at theNorth System.

Mr. Hollander also mentioned that the South System had a total trihalomethane MCLviolation in 2016. A rigorous flushing program was implemented at the site and at otherdead end mains, with auto flushers installed in the problematic areas. This flushingprogram has contained the disinfection byproduct levels. Mr. Hollander stated thatthere was triggered groundwater monitoring violation but this was quickly resolvedafter DDW explained the monitoring requirements.

3.3 MaintenanceMr. Mendoza explained that reservoirs are inspected every month. Drain valves areexercised every quarter. He noted that a couple of drain valves are broken shut. WRDhas a valve equipment truck to do routine valve exercising but not enough operators to

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use the truck. The truck is brand new and has not be used yet. There is no formal valveexercising program.

I asked about whether there is any quality assurance or quality control (“QA/QC”)mechanisms for the System operations. Mr. Mendoza stated that there previously was aQA/QC staffer who would check logbooks and check reservoirs, wells, and pumpingstations. He no longer works at Camp Pendleton and no replacement was hired.

In the event of an emergency, Mr. Mendoza is the person contacted to deal with anysituation that arises and makes operational decisions at that time. Mr. Mendoza statedthat there are eleven distribution operators.

3.4 Reservoir 43610The reservoir is 0.5 MG concrete tank. In the DDW sanitary survey, it was pointed outthat the access road had eroded to the point that the overflow piping was visible. Iobserved that the road was fully repaired. The overflow had a flapper valve andappeared to be in decent condition. The nearby hillside was eroding with dirt gatheringnear the base of the reservoir. The March 2017 sanitary survey identified this deficiency.WRD has not implemented any measures to mitigate the potential effects of erosion asthey were still awaiting funds for this project.

The overflow screen located inside the reservoir had debris located on top of thescreen. Mr. Mendoza stated that most of the large pieces of debris have been removed.After the inspection and upon further review of the photograph of the debris back in theoffice, the unidentified debris appears to be three dead animal carcasses (possiblymice). On July 19, 2017, I emailed Mr. Simpson and Ms. Sahagun about the dead animalsin the reservoir. Mr. Simpson stated on the phone later that day that they had cleanedthe reservoir.

The level gauge and Miltronics are not functional. The operators determine the level byopening the hatch and making approximations. The vent screen was facing upwardswith a coarse mesh.

3.5 Booster Pump Station 43310The pump station housed three pumps. A diesel Kohler power system is used to providepower. The logbook appeared be up to date. The booster pumps appeared to be indecent condition.

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I observed that there was a bee infestation outside of the well house. This poses a safetyrisk to operators who must visit this well house every day. There were also birds nestingunder to well house eaves.

3.9 Chlorination Station 410618We encountered Mr. Reynolds again at the chlorination station. Mr. Reynolds statedthat after turning on Well 41611 he then comes to this chlorination station as it must beactivated manually. The automated chlorine feeder was down at the time of theinspection. Mr. Reynolds explained that he watches the chlorine residual reader until itreaches the desired level of 1.75 – 2 ppm. I observed that the salt used for the brine wasNSF-certified.

Mr. Reynolds stated the water softener at the beginning of the treatment process isalways on. It must be replaced approximately every three weeks. I observed that thechlorine reader displayed a chlorine residual value of 1.70 ppm and pH of 7.32. Iobserved that the brine tank had an opening at the top for the feed line, and that thisopening was simply covered with a towel. When the brine tank’s top was opened, Iobserved a couple of insects ran to hide in the piles of salt.

Mr. Reynolds collected a grab sample for the chlorine residual to check the accuracy ofthe automated chlorine reader. He registered a chlorine residual of 2.07. Mr. Reynoldinformed Ms. Watanabe and I that the grab sample is accurate and that the automatedchlorine reader has been inaccurate lately.

I asked Mr. Reynolds about his work duties. He stated that he has been an employee fortwo years and mostly focuses on the North System. He also covers the Las Pulgasportion of the South System during his shift.

3.10 Interview: Phillip SipesAt the Southern AWT, Ms. Watanabe and I interviewed Mr. Sipes with only Mr.McCarthy present. I asked other Camp Pendleton representatives if they could grant usprivacy during the interview.

Mr. Sipes stated that he was a shift operator and has been working for Camp Pendletonfor 8.5 years. He has been acting treatment supervisor since November 2016 and isgoing to be appointed treatment supervisor very soon. He indicated that even when hebecomes treatment supervisor, this is not the same title as chief treatment operator. As

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there is no chief treatment operator, Mr. Sipes reports to Mr. Davis. In the case of anemergency regarding the treatment plants, Mr. Sipes is the point of contact.

I asked Mr. Sipes about his normal duties. He responded that he delegates a lot of thework so he can focus on monthly reporting, creating purchases orders and requests,certifying payroll, and providing training to staff. Mr. Sipes supervises five operators,two laborers, and two pool operators. Mr. Sipes works with two other treatmentoperators on Monday, Tuesday and every other Wednesday. All the other day typicallyhave 1-2 operators.

Mr. Sipes stated that only one operator works during the day on Friday and Saturday. Iasked Mr. Sipes how many operators the treatment plants should have, in his opinion.He replied that during the day, the South System should have at minimum threetreatment operators and the supervisor. He added that one treatment operator for theNorth System was likely enough.

Mr. Sipes explained that the Southern AWT has had problems since its inception. Thetreatment operators have completed a lot of remediation and troubleshooting so theSouthern AWT and I&M Plants should be running much better in the future. WRD has acontract with Hach to calibrate their equipment annually.

Mr. Sipes explained that all the operator positions at Camp Pendleton are hired astreatment operators. Two years ago, the operators were split into distribution operatorsand treatment operators in terms of job duties. Treatment operators work 12-hourshifts to ensure that the Southern AWT is manned 24 hours a day. Mr. Sipes stated heworks 10-hour shifts. When operators have 8-hour shifts, they commonly end up doing12-hour shifts out of necessity.

I asked about checking chlorine residuals at the treatment plant. Mr. Sipes explainedthat they collect grab samples using a Hach SL1000, which stores all the data collectedand is uploaded into a computer. A residual is collected in the morning and a couple oftimes per shift. In addition, the required chlorine residual monitoring is collected duringeach shift.

I asked Mr. Sipes if he has observed anything unusual during his employment at CampPendleton. He replied that WRD used a former employee’s name and certification to filla required position even though he was no longer employed by WRD for over sixmonths.

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Mr. McCarthy observed the overflow when Ms. Watanabe and I were inspecting thereservoir. He stated that the overflow had a flapper valve and appeared to be in goodcondition.

SECTION 4 – DAY 4 OBSERVATIONS (JUNE 29, 2017)Ms. Watanabe and I met James Jablonski, DDW engineer, at the parking lot before heading tothe FMD office. Mr. McCarthy and Mr. Pacifico did not attend Day 4 as they had to attend toother business. At the office, I explained that we would begin inspecting the North Systemtoday and that Ms. Watanabe would be leading most of the questions. I presented Mr. Entinghmy EPA-issued enforcement credential and issued the Notice of Inspection. Mr. Entingh and Mr.Davis jointly signed the Notice of Inspection. Mr. Mendoza, Ms. Marx, Mr. Thresher, and Mr.Hollander were present for the meeting.

Ms. Watanabe asked about the operator situation for the North System. Mr. Mendoza repliedthat there is no chief distribution or treatment operator, although he still serves as operatorsupervisor. The North System had no shift operator at the time of the inspection. The oneoperator during the day who manages the North System also manages portions of the SouthSystem – the 41 Area and the LCAC (Landing Craft Air Cushion). Mr. Mendoza stated that alloperators that work in the North System hold at least a Distribution 2 (D2) certification and aTreatment 2 (T2) certification. The following operators work on the North System: JohnReynolds and Bruce Kilgore. An additional T2 certified operator – Mike Gill, also worksperiodically in the North System.

Ms. Watanabe asked about standard operating procedures (“SOP”) developed by WRD. Mr.Hollander stated that they are working on new SOPs although they are still in draft form. Hestated that he would provide the currently approved SOPs to EPA. These SOPs cover bothSystems. I asked about an emergency response plan. Mr. Hollander replied that this is includedin the SOP documents. Mr. Mendoza also explained that he is called during any emergency.

Ms. Watanabe asked about the backflow prevention program. Mr. Hollander stated that acontractor called LTS handles the backflow prevention program. The backflow testing isconducted annually. Cross connection tests are conducted every three years. LTS also managesthe hydrant flushing program. According to Mr. Hollander, hydrants are flushed every quarter.Mr. Jablonski asked about hydrant flushing frequency due to the drought. Mr. Hollander statedthat flushing frequency has not been affected by drought conditions.

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Mr. Hollander explained that the annual report to DDW includes reservoir cleaning dates. Hestated that he would also provide a list of reservoir cleaning dates for both Systems to EPA. Ms.Watanabe also asked whether they had a valve exercising program. Mr. Mendoza stated thatthere was no valve exercising program for the North system. He stated that they have a valvetruck, but insufficient personnel to operate it.

Ms. Watanabe asked about how WRD manages its infrastructure assets and improvements. Mr.Hollander and Mr. Entingh replied that in terms of managing assets, Camp Pendleton is draftinga main evaluation which will feed a capital improvement plan in the future. They acknowledgedthat this did not include assets such as reservoirs. WRD and FMD are currently reviewing theplan. Mr. Entingh explained that they are reactive to any fixes required to maintain the Systemsand that there is no comprehensive plan to manage infrastructure maintenance/replacements.He added that it can take approximately two years to replace a well. EnvSec may access aseparate fund from the usual Congressional appropriations to make water system upgrades.These funds take less time to access than the lengthy Congressional process.

Ms. Watanabe asked about SCADA capabilities for the North System. Mr. Mendoza explainedthat a couple of booster stations can sometimes be controlled remotely from the Unity Room.Mr. Jablonski asked about the chlorination and CCT stations. Mr. Mendoza replied that thesestations cannot be controlled via SCADA.

Ms. Watanabe asked for an explanation of the North System’s operations. Mr. Mendoza statethat a northern AWT is currently under construction. When completed, the northern AWT willbe a centralized point for chlorination, CCT, and fluoridation. They hope to have the northernAWT functional by late 2018. The System has two operational wells: 610521 and 610511. Waterfrom these two wells can go in two directions.

All the San Onofre wells have been down for two years. Two of these wells are down due to airentrainment issues causing chlorine residual analysis issues and chlorine feed issues. Two of theold wells were replaced with new wells but still have air entrainment issues that have not beenresolved. A study is currently underway to identify the problems and repair the wells.Otherwise, these wells are out of service an indefinite amount of time. Well 55030 also has highiron levels.

Mr. Mendoza stated that Well 620620 is out of commission due to missing parts and repairshave not been made yet. Well 61531 has been inactivated and is no longer permitted for use.Mr. Mendoza stated that the autodialers in the North System are not operational.