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HomeMy WebLinkAboutItem 7a. Initiation of Annexation to provide Water and Wastewater Services to property at 4320 S. Higuera (ANNX-0662-2024) Item 7a Department: Community Development Cost Center: 4008 For Agenda of: 6/18/2024 Placement: Public Hearing Estimated Time: 30 minutes FROM: Timmi Tway, Community Development Director Aaron Floyd, Utilities Director Prepared By: Hannah Hanh, Associate Planner Mychal Boerman, Utilities Deputy Director - Water SUBJECT: CONSIDERATION OF INITIATION OF AN ANNEXATION WITH PREZONING APPLICATION TO PROVIDE CITY WATER AND WASTEWATER SERVICES TO A THREE-ACRE PARCEL AT 4320 SOUTH HIGUERA STREET (ANNX-0662-2024, RZ-0665-2024) RECOMMENDATION Authorize staff to proceed with processing an Annexation with Prezoning Application for an approximate three-acre parcel located at 4320 South Higuera Street in order for the City to provide water and wastewater services. REPORT-IN-BRIEF On behalf of Ronald Schriner (Property Owner), the Sacramento State Office of Water Programs (Applicant) has applied for an Annexation with Prezoning application for an approximate three-acre parcel located 4320 South Higuera Street (Subject Property) (Attachment A – Project Application). The Subject Property is located within the unincorporated area of San Luis Obispo County (County) and annexation is required for the City of San Luis Obispo (City) to provide water and wastewater services per General Plan Land Use Element (LUE) Policy 1.13.1 (Water and Sewer Service), Water and Wastewater Element (WWE) Policy B 2.2.1 (Service Outside the City Limits), and Municipal Code Chapter 13.04 (Water Service). The Subject Property currently has its own water system consisting of a single well with associated chlorination and distribution systems to serve a total of 30 customers residing in a 24-unit apartment and various, potentially unpermitted structures that include two (2) single-family residences and two (2) trailers. These structures are collectively referred to as the Higuera Apartments. On January 15, 2021, the County of San Luis Obispo Health Agency Public Health Department Environmental Health Services Division (SLOEHS) issued a Compliance Order due to multiple violations dating back to 2017 of nitrate contamination in the Higuera Apartments’ water system (Attachment B – SLOEHS Compliance Order). The Compliance Order requires completion of a Corrective A ction Plan with quarterly reports. Page 151 of 747 Item 7a To address the water contamination issues, the Applicant has identified consolidation of the Subject Property with the City, which includes connecting to the City’s water and wastewater systems and destroying and/or abandoning the existing water system, as the most preferred permanent solution to providing safe and reliable water (Attachment C – Higuera Apartments Water Systems Technical Memorandum). Annexation of the Subject Property would be required for the City to provide water and wastewater services. Amendments to the General Plan and/or City limits require orderly processing consistent with overall goals of the City’s planning program and requirements of California State law as detailed in Municipal Code Chapter 17.130 (General Plan Amendment). Per Section 17.130.020(C) (Early Council Consideration of an Application), these applications may be forwarded by the Community Development Director (Director) to the City Council for early consideration and to determine whether the amendment is consistent with the General Plan. If Council provides direction to move forward, staff will process the application through the standard steps required as described in this report. POLICY CONTEXT Per Section 17.130.010 (Purpose), amendments to the General Plan and/or City limits require orderly processing consistent with overall goals of the City’s planning program and requirements of California State law. Furthermore, Section 17.130.020(C) (Early Council Consideration) states the Director has authority to forward such application to Council for early policy consideration and to determine if it is consistent with overall policy direction in the General Plan. On January 4, 2024, the Applicant submitted an Annexation with Prezoning application for the Subject Property in order for the City to provide water and wastewater services. Staff is seeking direction from Council to proceed forward with processing the application. If Council approves the recommendation to proceed, staff will process the Annexation through the following standard steps, including: 1. Development review by City staff, including preparation of the following: o Environmental review (i.e., assessment of environmental impacts re lated to the required infrastructure improvements to serve the property, etc.); o Plan for Services (i.e., analysis of the annexation area’s impact on overall City services and implementation of the recommendations derived from the analysis); and o Pre-Annexation Agreement (i.e., zoning clarifications, including allowable uses and applicable standards; required public and private infrastructure and utility improvements to be completed; payment of all applicable fees, etc.) 2. Planning Commission public hearing for recommendation 3. City Council hearing for consideration of a resolution of intent 4. Submittal to the San Luis Obispo Local Agency Formation Commission (LAFCO) Page 152 of 747 Item 7a If Council directs staff to not proceed with processing the application, the State Water Board may order mandatory consolidation of the water and wastewater systems to provide safe drinking water in accordance with Sections 116680-116686 of the California Health and Safety Code. If the City proceeds forward on a voluntary basis to complete the annexation and provide water and wastewater services to the Subject Property, the City may be eligible for certain financial incentives from the State Water Board (e.g., loans for infrastructure improvements, refinancing of existing loans, etc.) as a voluntary participant. These financial incentives are updated on an annual basis in the Drinking Water State Revolving Fund (DWSRF) Intended Use Plan (IUP). DISCUSSION Background Location The Subject Property is an approximate three-acre parcel at 4320 South Higuera Street that is located in the County and immediately adjacent to the City limits. As shown in the City’s Land Use Map, the property is located within the City’s sphere of influence and urban reserve line (URL), and is eligible for annexation upon approval of the Council and LAFCO. Site Data Location 4320 South Higuera Parcel Size Three (3) acres Land Use Category Outside of City limits in unincorporated area of the County; Residential Multi-Family (RMF) Site Condition Developed, relatively flat Surrounding Uses North: Residential South: County East: Commercial, Industrial West: Residential Existing Structures The Subject Property includes an existing 24-unit apartment and other potentially unpermitted structures, including two (2) detached single-family residences, two (2) trailers, and various accessory structures (e.g., sheds, storage containers, ground- mounted solar panel system, etc.). Preliminary research confirms permit records for the 24-unit apartment. However, permit records for the other structures have not been identified. Further research and inspection, in coordination with the County, would be required to verify the status of all onsite s tructures as part of the annexation process. Upon annexation of the subject property, any unpermitted structures shall be addressed through either obtaining permits to remove or bring the structures into compliance. Page 153 of 747 Item 7a Existing Water System and Contamination Issues The Subject Property has its own water system consisting of a single well with associated chlorination and distribution systems to serve 30 customers, which have been identified as a disadvantaged community in accordance with Section 79505.5(a) of the Water Code. Due to multiple violations dating back to 2017 of nitrate contamination in the water source well, the SLOEHS issued a Compliance Order on January 15, 2021, which requires completion of a Corrective Action Plan with quarterly reports. The Property Owner has been providing bottled water to the residents since the water con tamination issues were identified. Following issuance of the Compliance Order by SLOEHS, the Applicant began assessing different options to correct the issue and connection to the City’s water and wastewater systems has been identified as the most preferre d permanent solution to providing safe and reliable water to the Subject Property. State Water Board Assistance For the Subject Property to connect to the City’s water and wastewater systems, the State Water Board is providing technical and financial assistance to the Property Owner. The Applicant is assisting in implementing and funding efforts related to the Annexation with Prezoning application review, environmental review, design plans, project management, and payment of impact fees for the water and wastewater connection. The Property Owner would be responsible for other requirements resulting from the annexation such as the permitting and/or removal of any unpermitted structures, implementing street frontage and site improvements, and ongoing payment for annual building inspections and monthly water and wastewater services. Project Description In order for the City to provide water and wastewater services, the Applicant has applied for an Annexation with Prezoning application for the approximate three-acre parcel located at 4320 South Higuera Street. As proposed, the City limits would be revised to include the Subject Property. Consistency with the Major City Goals and General Plan Staff has provided a preliminary consistency analysis of the proposed annexation with the Major City Goals and General Plan. If the Council provides direction to move forward with processing the application, additional detailed analysis and consideration would be included as part of a full project analysis. 2023-25 Major City Goals Housing & Homelessness was prioritized as a Major City Goal in the 2023-2025 Financial Plan to support the expansion of housing options and facilitate housing production. As proposed, annexation of the Subject Property would advance this Major City Goal because the focused objective of this application is to facilitate the continuance of existing residences for a disadvantaged community by connecting to the City’s water and wastewater systems for the provision of safe and reliable water. Page 154 of 747 Item 7a General Plan and Municipal Code The Applicant has applied for an Annexation with Prezoning application for the Subject Property because annexation is required for the City to provide water and wastewater services per LUE Policy 1.13.1 (Water and Sewer Service), WWE Policy B 2.2.1 (Service Outside the City Limits), and Municipal Code Chapter 13.04 (Water Service). This application is a unique circumstance and would not facilitate urban sprawl because the proposed annexation would result in a logical extension of the City limits and supporting services within the existing URL as shown on the Land Use Map. The proposed annexation is limited to an approximate three-acre parcel located immediately outside of the City limits along an arterial street (i.e., South Higuera) that is substantially surrounded by other developed parcels in the City. In addition, goals of the Land Use Element include the accommodation of residents within all income groups (Goal No. 19), preservation of existing housing (Goal No. 20), and provision of safe housing (Goal No. 42). The annexation would advance these preceding goals by supporting the continuance of existing housing through the provision of safe and reliable water. Preliminary Analysis of Water and Wastewater Capacity To ensure that there are adequate resources in the City’s water and wastewater systems to meet needs of the Subject Property if annexed into City limits, the City’s Water Resources section has conducted a preliminary assessment of water supply availability and projected water demand. The City has a Primary Water Supply availability of 7,496 acre-feet per year, which is the volume of water for the City’s projected General Plan buildout. The City’s current water use equals approximately 5,000 acre-feet per year, which results in approximately 2,500 acre-feet of water available for community growth through 2035. Using extremely high water demand projections, which are not likely to be met by the Higuera Apartments, staff estimates that the maximum annual water demand for this property would be 2.1 acre-feet per year. At a maximum, the Higuera Apartments are projected to utilize 0.08% of the available 2,500 acre -feet allocated to meet General Plan buildout. Despite significant population growth over the past several years, the City’s water demand has remained constant and is not projected to meet or exceed 7,496 acre - feet of use by 2035. As such, it is anticipated that there would be adequate water supply to meet the projected water demand of the Higuera Apartments. Additionally, the City's Water Resource Recovery Facility (WRRF) is in the process of being upgraded to increase capacity of the facility and improve water quality. The upgraded capacity would be 5.4 million gallons per day (MGD), with current flow equaling approximately 3.0 MGD. Based on projected community expansion and water demand projections for the Subject Property, it is anticipated that the WRRF would have adequate capacity to accommodate increased wastewater flow from the Higuera Apartments. Page 155 of 747 Item 7a Impacts on Adjacent Areas and Shared Resources If Council provides direction to proceed with processing the application, impacts of the Annexation and any associated development on adjacent parcels and shared resources would be analyzed in detail as part of the project. The analysis would evaluate impacts of (a) immediate improvements required for the City to provide services such as connecting to the water and wastewater systems, bringing all unpermitted structures into compliance, and implementing street frontage and site improvements; and (b) the future development potential of the site. As part of the application review, prezoning would also be required to identify the future zone of the Subject Property upon annexation. Next Steps Staff is seeking direction from Council to proceed with processing the Annexation with Prezoning application. This early consideration referral by the Director is an opportunity for the Council to provide input on the application if necessary. If Council approves the recommendation to proceed, staff will process the Annexation through the following standard steps, including: 1. Development review by City staff, including preparation of: o Environmental review (i.e., assessment of environmental impacts related to the required infrastructure improvements to serve the property, etc .); o Plan for Services (i.e., analysis of the annexation area’s impact on overall City services and implementation of the recommendations derived from such analysis); and o Pre-Annexation Agreement (i.e., zoning clarifications, including allowable uses and applicable standards; required public and private infrastructure and utility improvements to be completed; payment of applicable fees, etc.) 2. Planning Commission public hearing for recommendation 3. City Council hearing for consideration of a resolution of intent 4. Submittal to LAFCO Public Engagement The item is on the June 18, 2024 Council Agenda for consideration of the initiation of this application. The public has an opportunity to comment on this item at or before the meeting. If the Council authorizes staff to proceed with processing, additional public hearings and legal notices would be provided for the Planning Commission and City Council meetings as part of the process for consideration of the Annexation with Prezoning application. CONCURRENCE The Council Agenda Report was reviewed by the Community Development Department, Utilities Department, Finance Department, City Attorney, and City Administration for concurrence. If the Council directs staff to proceed with the application, relevant departments and divisions would evaluate the project in detail as part of the application review. Page 156 of 747 Item 7a ENVIRONMENTAL REVIEW The California Environmental Quality Act (CEQA) does not apply to the recommended action in this report because Council’s action does not constitute a “Project” under Section 15378 (Project) of the CEQA Guidelines nor does the action commit the agency to a definite course of action in regard to a project as described in Section 15352 (Approval) of the CEQA Guidelines. If the annexation application moves forward, the project would be subject to the appropriate environmental review as required per CEQA , which will be presented at the public hearings. FISCAL IMPACT Budgeted: No Budget Year: 2023-25 Funding Identified: Applicant funded Fiscal Analysis: Funding Sources Total Budget Available Current Funding Request Remaining Balance Annual Ongoing Cost General Fund $0 $0 $0 $0 State Federal Fees Other: Total $0 $0 $0 $0 There will be no net fiscal impact related to considering the initiation of the proposed annexation. If Council directs staff to proceed, the applicant will be required to fund the review and processing of the application and associated analysis. The Annexation with Prezoning application is paid on a deposit basis and City staff and consultants log hours required to process the applications, including any future City limit modification through LAFCO. While not currently quantifiable at this time for the initiation, there would be fiscal impacts related to the provision of municipal services to the Subject Property that would be evaluated in detail as part of the Annexation with Prezoning application. It should is also noted that if the City proceeds forward on a voluntary basis to complete the annexation and provide water and wastewater services to the subject property, the City may be eligible for certain financial incentives from the State Water Board (e.g., loans for infrastructure improvements, refinancing of existing loans, etc.), identified in the annual DWSRF IUP, as a voluntary participant. Page 157 of 747 Item 7a ALTERNATIVES 1. Direct staff to move forward with processing the Annexation with Prezoning application, but with direction to staff and the Applicant on any desired revisions to the application. 2. Direct staff to not move forward with processing the Annexation with Prezoning application with the understanding that mandatory consolidation of the Subject Property with the City’s water and wastewater systems may be required by the State Water Board. ATTACHMENTS A - Project Application B - SLOEHS Compliance Order, dated January 15, 2021 C - Higuera Apartments Water System Technical Memorandum, dated June 20, 2023 Page 158 of 747 Weber, Hayes & Associates Hydrogeology and Environmental Engineering 120 Westgate Drive, Watsonville, CA 95076 (831) 722-3580 // www.weber-hayes.com October 27, 2023 City of San Luis Obispo Community Development Department 919 Palm Street San Luis Obispo, CA 93401 Subject: Annexation Application Subject Site: 4320 S Higuera Street, San Luis Obispo, CA 93401 On behalf of Sacramento State Office of Water Programs/University Enterprises Inc., we are providing the attached Annexation Application for Higuera Apartments located at 4320 S. Higuera Street. Higuera Apartments has its own water system. The source well for Higuera Apartments contains nitrates at levels above the State Drinking Water Maximum Contaminant Level (MCL) and is out of compliance with State and Local standards. The State Water Board’s preferred solution is consolidation with the City of San Luis Obispo Water System. Annexation of Higuera Apartments into the City is required for consolidation to allow the City to serve the site with water and sewer services. Please refer to the attached Work Plan for additional details. If you have any questions or comments, or need additional information, please call me at our office at 831.722-3580 or email me at Rich@weber-hayes.com. Sincerely yours, Weber, Hayes and Associates By: Richard V. Peterson, EIT Project Engineer Attachments: City of San Luis Obispo Planning Application Annexation Map Exhibit Technical Assistance (TA) Work Plan ATTACHMENT A Page 159 of 747 ATTACHMENT A Page 160 of 747 ATTACHMENT A Urban Reserve Line. City Boundary will be extended to the URL Area to be annexed - 4320 S. Higuera Street Page 161 of 747 TECHNICAL ASSISTANCE (TA) WORK PLAN UNIVERSITY ENTERPRISES, INC. (UEI) AND CALIFORNIA STATE WATER RESOURCES CONTROL BOARD SAFE AND AFFORDABLE FUNDING FOR EQUITY AND RESILIENCE (SAFER) DRINKING WATER PROGRAM TECHNICAL ASSISTANCE (PROJECT) AGREEMENT NUMBER (NO.) D19-17008 TA WORK PLAN NO. 6319-A TA START DATE: JUNE 30, 2021 AMOUNT: $97,096 Whereas through the passage of various bond acts, including Proposition 1 in November 2014 and Senate Bill 200 in July 2019, the State Water Resources Control Board (State Water Board) is authorized to make available certain general obligation bond proceeds (GO Bond Proceeds) and Safe and Affordable Drinking Water Funds (SADW Funds) for projects meeting certain criteria; and Whereas the State Water Board has determined that this Project is eligible for certain GO Bond Proceeds and/or SADW Funds; Therefore, the parties hereby amend the Agreement, originally executed on April 14, 2021, and incorporated herein, to add: TA WORK PLAN NO. 6319-A (5 pages attached) ** ** Entire Exhibit Added All other terms and conditions shall remain the same. RECIPIENT: By: Name: Monica F. Kauppinen Title: Director, Sponsored Programs Administration Date: STATE WATER RESOURCES CONTROL BOARD: By: Name: Joe Karkoski Title: Deputy Director, Division of Financial Assistance Date: ATTACHMENT A Page 162 of 747 Work Plan No. 6319-A Page 1 of 4 Rev. 03/24/21 Technical Assistance (TA) Work Plan TA Type: ☒ Drinking Water ☐ Wastewater ☐ Storm Water ☐ Groundwater Grant Agreement No. D19-17008 TA Start Date: June 30, 2021 TA Recipient(s): Higuera Apartments PWSID No. CA4000563 Community/System Information: Population Served: 30 (Drinking Water Watch Site 2021) Number of Connections: 24 (Drinking Water Watch Site 2021) Median Household Income (MHI): $46,256 (Source: 2015-2019 American Community Survey) Community/System Contact(s): Ronald Schriner, Owner, Higuera Apartments, rschriner@hotmail.com, (805) 541- 6882 Additional Community/ System Contact: Work Plan No.: 6319-A Work Plan Title: Drinking Water State Revolving Fund (DWSRF) Construction Financing Application Assistance Work Plan Submittal Date: February 24, 2022 A. Technical Assistance Details Water System Description: The Higuera Apartments Water System, Water System No. CA4000563, is located at 4320 S. Higuera St. The water system is on a parcel of land just outside the City of San Luis Obispo city limits. Per the CA Drinking Water Watch website, the system serves 30 customers through 24 connections. The water system consists of a single well, with associated chlorination and distribution systems. The well also serves several other customers in addition to the apartments on the parcel, currently estimated as 2 homes and possibly some trailers. Current and Past Compliance Issues: The water system is on the human right to water list for nitrate exceedance , with several recent violations of the nitrate Maximum Contaminant Level (MCL) recorded in 2020 and 2021. The system may have also had issues with high readings for perfluorooctane sulfonate (PFOS). On January 15, 2021, the County of San Luis Obispo issued Compliance Order No. 04_70_21R_001 to Higuera Apartments due to the nitrate MCL exceedances. This Order requires the completion of a Corrective Action Plan and Quarterly Reports. ATTACHMENT A Page 163 of 747 Work Plan No. 6319-A Page 2 of 4 Rev. 03/24/21 Need for Technical Assistance: The water system does not have adequate resources to address their compliance issues, and there is potential for consolidation with the City of San Luis Obispo. An “Ability to Pay Analysis” has been completed by the system and provided to the State Water Board. The scope of the assistance consists of the following two tasks: • Technical Memorandum – Preparation of a Technical Memorandum, per the State Water Board Division of Financial Assistance (DFA) guidelines. An alternatives analysis of potential solutions, i.e., well rehabilitation or replacement, is not needed . Consolidation with the City of San Luis Obispo will be assumed. The technical work will include an evaluation of the existing well to determine whether it should be abandoned or repurposed for irrigation. The engineering work will also include non-drinking water-related infrastructure related to meeting City annexation requirements. • Compliance Order Support – Provide support related to the Compliance Order, including completion of a Corrective Action Plan and Quarterly Reports. Other TA Providers: No other TA providers are currently involved in TA efforts for this system. However, a separate TA Request No. 6601, is being conducted by Sacramento State in parallel with this TA request to consolidate the system’s wastewater connection to the City. B. Summary of Proposed Deliverables and Activities No. Task Notes and Details Regarding Related Activities Lead TA Provider staff/consultant(s) Deliverable & Due Date Budget1 1 Needs Assessment and Work Plan ▪ Hold kickoff meeting and prepare meeting notes ▪ Identify scope, deliverables, schedule, and budget; solicit and review proposals from team members. ▪ Prepare work plan Sacramento State Office of Water Programs (OWP): Randy Marx Completed $ 6,439 2 DWSRF Construction Financing Application: General Package General Package ▪ Prepare General Package. Weber Hayes: Craig Drizin General Package: 08/19/2022 $ 6,609 ATTACHMENT A Page 164 of 747 Work Plan No. 6319-A Page 3 of 4 Rev. 03/24/21 No. Task Notes and Details Regarding Related Activities Lead TA Provider staff/consultant(s) Deliverable & Due Date Budget1 3 DWSRF Construction Financing Application: Technical Package Technical Memorandum ▪ Prepare draft and final Technical Memorandum (TM), per DFA guidelines. Weber Hayes: Craig Drizin Technical Memorandum: Draft- 10/14/2022 Final- 12/16/2022 $ 56,749 4 Compliance Order Support ▪ Prepare Corrective Action Plan ▪ Prepare Quarterly Reports Weber Hayes: Craig Drizin Corrective Action Plan: 09/16/2022 Quarterly Reports: Quarterly $ 6,709 5 Project Management ▪ Provide project management services o Oversight of TA team o Coordinate conference calls and meetings o Ensure quality of deliverables o Upload materials to FAAST as needed o Execute Work Plan o Serve as primary point of contact ▪ Monitor project scope, schedule, & budget OWP: Randy Marx 03/15/2023 $ 20,590 1 Budget may be shifted between tasks upon written approval from the State Water Board Project Manager. ATTACHMENT A Page 165 of 747 Work Plan No. 6319-A Page 4 of 4 Rev. 03/24/21 C. Total Budget (direct costs, including fringe)1 Budget Category Total Amount Requested Personnel $ 27,029 Expenses and Supplies $ 0 Equipment (>$5,000) $ 0 Travel $ 0 Professional and Consultant Services $ 70,067 Contingency2 (10%) $ 0 Total Costs $ 97,096 1 Costs may be shifted between line items upon written approval from the State Water Board Project Manager. Any costs exceeding the total amount requested will require an amendment to this work plan . 2 Use of contingency budget will require written approval from the State Water Board Supervising Engineer. D. California Environmental Quality Act (CEQA) Certification Please indicate if all the work you will implement in connection with this work plan is c onsistent with one of the following CEQA exemptions: ☒ Feasibility and planning studies with no ground disturbing activities (Cal. Code Regs., Tit. 14, § 15262) ☐ Includes information collection via pilot studies, test wells, boreholes, etc. (Cal. Code Regs., Tit. 14, § 15306) If proposed work includes ground disturbing activities in an area(s) with a potential for environmental impacts, including ri parian habitat, wetland, endangered species habitat or sensitive cultural resources areas, you must n otify your State Water Board Project Manager of the nature and scope of such work and receive approval prior to commencing ground disturbing activities. ATTACHMENT A Page 166 of 747 COUNTY OF SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT Michael Hill Health Agency Director Penny Borenstein, MD, MPH Health Officer/Public Health Director Environmental Health Services 2156 Sierra Way, Suite B | San Luis Obispo, CA 93401 | (P) 805-781-5544 | (F) 805-781-4211 www.slopublichealth.org/ehs January 15, 2021 System No. 4000563 Ronald Schriner Higuera Apartments 1749 San Luis Drive San Luis Obispo, CA 93401 COMPLIANCE ORDER NO. 04_70_21R_001 NITRATE MAXIMUM CONTAMINANT LEVEL VIOLATION FOR THE 2017 CALENDAR YEAR Enclosed is Compliance Order No. 04_70_21R_001 (hereinafter “Order”), issued to Higuera Apartments (hereinafter “System”) public water system. Please note that there are legally enforceable deadlines associated with this Order. Higuera Apartments will be billed at the County of San Luis Obispo Health Agency Public Health Department Environmental Health Services (hereinafter “SLOEHS”) hourly rate for the time spent on issuing this Order. California Health and Safety Code (hereinafter “CHSC”) Section 116577 provides that a public water system must reimburse the SLOEHS for actual costs incurred by the SLOEHS for specified enforcement actions, including preparing, issuing, and monitoring compliance with an order. At this time, the SLOEHS has spent approximately 0.5 hours on enforcement activities associated with this violation. The System will receive a bill sent from the SLOEHS in August of the next fiscal year. This bill will contain fees for any enforcement time spent on the Higuera Apartments for the current fiscal year. Any person who is aggrieved by a citation, order or decision issued under authority delegated to an officer or employee of the SLOEHS under Article 8 (commencing with CHSC, Section 116625) or Article 9 (commencing with CHSC, Section 116650), of the Safe Drinking Water Act (CHSC, Division 104, Part 12, Chapter 4), may file a petition with the State Water Board for reconsideration of the citation, order or decision. Petitions must be received by the State Water Board within 30 days of the issuance of the citation, order or decision by the officer or employee of the State Water Board. The date of issuance is the date when the SLOEHS mails a copy of the citation, order or decision. If the 30th day falls on a Saturday, Sunday, or state holiday, the petition is due the following business day by 5:00 p.m. ATTACHMENT B Page 167 of 747 Compliance Order No. 04_70_21R_001 2 Information regarding filing petitions may be found at: http://www.waterboards.ca.gov/drinking_water/programs/petitions/index.shtml If you have any questions regarding this matter, please contact me at (805) 781-5553. Sincerely, Leslie Terry Supervising Environmental Health Specialist County of San Luis Obispo Health Agency Public Health Department Environmental Health Services 2156 Sierra Way, Suite B San Luis Obispo, CA 93401 Mail: PO Box 1489 San Luis Obispo, CA 93406 Enclosures Certified Mail No. 0926 5269 1000 0600 0207 cc: Jeff Densmore, District Engineer Santa Barbara District Division of Drinking Water State Water Resources Control Board ATTACHMENT B Page 168 of 747 COUNTY OF SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT Michael Hill Health Agency Director Penny Borenstein, MD, MPH Health Officer/Public Health Director Compliance Order No. 04_70_21R_001 1 2 County of San Luis Obispo Health Agency 3 Department of Public Health 4 Environmental Health Services 5 6 Name of Public Water System: Higuera Apartments 7 Water System No: 4000563 8 9 Attention: Ronald Schriner 10 1749 San Luis Drive 11 San Luis Obispo, CA 93401 12 13 Issued: January 15, 2020 14 15 COMPLIANCE ORDER FOR NONCOMPLIANCE 16 CALIFORNIA HEALTH AND SAFETY CODE, SECTION 116555, 17 CALIFORNIA CODE OF REGULATIONS, TITLE 22, SECTION 64431 18 19 NITRATE MAXIMUM CONTAMINANT LEVEL VIOLATION 20 FOR THE 2017 CALENDER YEAR 21 22 The California Health and Safety Code (hereinafter “CHSC”), Section 116655 authorizes 23 the County of San Luis Obispo Health Agency Public Health Department Environmental 24 ATTACHMENT B Page 169 of 747 Compliance Order No. 04_70_21R_001 2 Health Services (hereinafter “SLOEHS”), to issue a Compliance Order to a public water 1 system when the SLOEHS determines that the public water system has violated or is 2 violating the California Safe Drinking Water Act (hereinafter “California SDWA”), (CHSC, 3 Division 104, Part 12, Chapter 4, commencing with Section 116270), or any regulation, 4 standard, permit, or order issued or adopted thereunder. 5 6 The SLOEHS, acting by and through its primacy delegation from the State Water 7 Resources Control Board, hereby issues Compliance Order No. 04_70_21R_001 8 (hereinafter “Order”), pursuant to Section 116655 of the CHSC to Higuera Apartments 9 (hereinafter “System”), for violation of CHSC, Section 116555(a)(1) and the California 10 Code of Regulations (hereinafter “CCR”), Title 22, Section 64431. 11 12 STATEMENT OF FACTS 13 The CHSC, Section 116555(a)(1) and the CCR, Section 64431 requires all public water 14 systems to comply with primary drinking water standards. Primary drinking water 15 standards include maximum levels of contaminants and the monitoring and reporting 16 requirements as specified in regulation adopted by the State Water Board that pertain to 17 contaminant levels. 18 19 The SLOEHS has received water quality laboratory results for Well No. 1 that have 20 elevated levels of nitrate. The nitrate maximum contaminant level (hereinafter “MCL”) is 21 10 milligrams per liter (hereinafter “mg/L”) as nitrogen, as stated in the CCR, Section 22 64431. A summary of the System’s nitrate monitoring results is presented in Table 1 23 below. 24 Table 1. Well No. 1 Results Nitrate Results 25 26 Sample Date Result (mg/L) 6/29/2017 13 4/22/2019 6.1 ATTACHMENT B Page 170 of 747 Compliance Order No. 04_70_21R_001 3 1 2 3 DETERMINATION 4 The SLOEHS has determined that System has failed to comply with primary drinking water 5 standards pursuant to the CHSC, Section 116555(a)(1) and CCR, Title 22, Section 64431 6 in that the has exceeded the nitrate MCL. 7 8 DIRECTIVES 9 The System is hereby directed to take the following actions: 10 1. By September 1, 2023, comply with CHSC, Section 116555(a)(1) and CCR, Title 11 22, Section 64431. 12 13 2. By January 31, 2021, notify all persons served by the System of the violation of 14 CCR, Title 22, Section 64432.1(a) and Section 64469(a) and (c), in conformance 15 with 64 Sections 64463.4(b) and (c), and 64465. Public notification to the persons 16 served by the System must continue every 3 months until the SLOEHS determines 17 that the nitrate MCL violation is resolved. Appendix 1: Notification Template must 18 be used to fulfill this directive, unless otherwise approved by the SLOEHS. The 19 contents of the public notice must be approved by the SLOEHS prior to issuance. 20 The System must edit the wording of the public notice as necessary. The 21 public notice must be completed in accordance with the following: 22 23 • By mail or direct delivery of the public notice to each customer served by the 24 water system and; 25 26 • By one of the following secondary methods to reach persons not likely to be 27 reached by mail or direct delivery; 28 ATTACHMENT B Page 171 of 747 Compliance Order No. 04_70_21R_001 4 1 2 ➢ By publication in a local newspaper, by delivery to community organizations 3 or by posting in conspicuous public places served by the water system or 4 on the internet. If the water system opts to issue the notice via internet 5 website, the public notice must remain posted for a minimum of seven (7) 6 consecutive days. 7 8 The System must determine which option will be used to con duct the secondary 9 distribution of the notice and notify the SLOEHS of their decision no later than 10 January 31, 2021. 11 12 3. By February 29, 2021, complete Appendix 2: Certification of Completion of Public 13 Notification Form. Submit it together with a copy of the public notice required by 14 Directive 2 to the SLOEHS within 10 days following each public notification. 15 16 4. Prepare for SLOEHS approval, a Corrective Action Plan, identifying improvements 17 to the water system designed to correct the water quality problems identified and 18 ensure that the System delivers water to consumers that meets drinking water 19 standards. The plan must include a time schedule for completion of each of the 20 phases of the project such as design, construction, and startup, and a date that 21 shows when the System will be in compliance. The date must be no later than 22 September 1, 2023. 23 24 5. By February 28, 2021, submit and present the Corrective Action Plan required 25 under Directive No. 4 above, to the SLOEHS office located at 2156 Sierra Way, 26 Unit B, San Luis Obispo, CA 93401 or mailed to PO Box 1489, San Luis Obispo, 27 CA 93406. 28 ATTACHMENT B Page 172 of 747 Compliance Order No. 04_70_21R_001 5 1 6. Perform the actions outlined in the SLOEHS approved Corrective Action Plan, and 2 each and every element of said plan, according to the time schedule set forth 3 therein. 4 5 7. By March 31, 2021, and every three months thereafter, submit a report to the 6 SLOEHS in the form provided as Appendix 3, showing actions taken during the 7 previous quarter (calendar three months) to comply with the Corrective Action 8 Plan. 9 10 8. By January 31, 2021 complete and return to the SLOEHS the “Notification of 11 Receipt” form attached to this Order as Appendix 4. Completion of this fo rm 12 confirms that the System has received this Order and understands that it contains 13 legally enforceable directives(s) with due dates. 14 15 All submittals required by this Order, unless otherwise specified in the directives above, 16 must be electronically submitted to the SLOEHS at the following address. The subject line 17 for all electronic submittals corresponding to this Order must include the following 18 information: Water System name and number, compliance order number, and title of the 19 document being submitted. 20 Leslie Terry 21 lterry@co.slo.ca.us 22 The SLOEHS reserves the right to make modifications to this Order as it may deem 23 necessary to protect public health and safety. Such modifications may be issued as 24 amendments to this Order and shall be effective upon issuance. 25 26 ATTACHMENT B Page 173 of 747 Compliance Order No. 04_70_21R_001 6 Nothing in this Order relieves the System of its obligation to meet the requirements of the 1 California SDWA (CHSC, Division 104, Part 12, Chapter 4, commencing with Section 2 116270), or any regulation, standard, permit or order issued or adopted thereunder. 3 4 PARTIES BOUND 5 This Order shall apply to and be binding upon the System, its owners, shareholders, 6 officers, directors, agents, employees, contractors, successors, and assignees. 7 8 SEVERABILITY 9 The directives of this Order are severable, and the System shall comply with each and 10 every provision thereof notwithstanding the effectiveness of any provision. 11 12 FURTHER ENFORCEMENT ACTION 13 The California SDWA authorizes the SLOEHS to: issue a citation or order with assessment 14 of administrative penalties to a public water system for violation or continued violation of 15 the requirements of the California SDWA or any regulation, permit, standard , citation, or 16 order issued or adopted thereunder including, but not limited to, failure to correct a 17 violation identified in a citation or compliance order. The California SDWA also authorizes 18 the SLOEHS to take action to suspend or revoke a permit that has been issued to a public 19 water system if the public water system has violated applicable law or regulations or has 20 failed to comply with an order of the SLOEHS and to petition the superior court to take 21 various enforcement measures against a public water system that has failed to comply 22 with an order of the SLOEHS. The SLOEHS does not waive any further enforcement action 23 by issuance of this Order. 24 25 _______________________________ January 15, 2021 _____ 26 Leslie Terry Date 27 County of San Luis Obispo Health Agency 28 ATTACHMENT B Page 174 of 747 Compliance Order No. 04_70_21R_001 7 Public Health Department 1 Environmental Health Services 2 3 4 Appendices (4): 5 6 1. Notification Template 7 2. Certification of Completion of Public Notification 8 3. Quarterly Progress Report Template 9 4. Notification of Receipt Form 10 11 Certified Mail No. 0926 5269 1000 0600 020712 ATTACHMENT B Page 175 of 747 Compliance Order No. 04_70_21R_001 APPENDIX 1. NOTIFICATION TEMPLATE IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER Este informe contiene información muy importante sobre su agua potable. Tradúzcalo o hable con alguien que lo entienda bien. DRINKING WATER WARNING Higuera Apartments water has high levels of nitrate DO NOT GIVE THE WATER TO INFANTS UNDER 6 MONTHS OLD OR PREGNANT WOMEN OR USE IT TO MAKE INFANT FORMULA Water sample results received April 22, 2019 showed nitrate levels of 6.1 milligrams per liter. This is above the nitrate standard, or maximum contaminant level (MCL), of 10 milligrams per liter. Nitrate in drinking water is a serious health concern for infants less than six months old. What should I do? • DO NOT GIVE THE WATER TO INFANTS. Infants below the age of six months who drink water containing nitrate in excess of the MCL may quickly become seriously ill and, if untreated, may die because high nitrate levels can interfere with the capacity of the infant’s blood to carry oxygen. Symptoms include shortness of breath and blueness of the skin. Symptoms in infants can develop rapidly, with health deteriorating over a period of days. If symptoms occur, seek medical attention immediately. • PREGNANT WOMEN SHOULD NOT CONSUME THE WATER. High nitrate levels may also affect the oxygen-carrying ability of the blood of pregnant women. • Water, juice, and formula for children under six months of age should not be prepared with tap water. Bottled water or other water low in nitrates should be used for infants until further notice. • DO NOT BOIL THE WATER. Boiling, freezing, filtering, or letting water stand does not reduce the nitrate level. Excessive boiling can make the nitrates more concentrated because nitrates remain behind when the water evaporates. • If you have other health issues concerning the consumption of this water, you may wish to consult your doctor. What happened? What is being done? Nitrate in drinking water can come from natural, industrial, or agricultural sources (including septic systems, storm water run-off, and fertilizers). Levels of nitrate in drinking ATTACHMENT B Page 176 of 747 Compliance Order No. 04_70_21R_001 water can vary throughout the year. We will let you know if the amount of n itrate is again below the limit. We are working with the State Water Resources Control Board – Division of Drinking Water to evaluate the water supply and researching options to correct the problem. We anticipate resolving the problem within three years. For more information, please contact Leslie Terry at (805) 781-5553 or lterry@co.slo.ca.us. Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this public notice in a public place or distributing copies by hand or mail. Secondary Notification Requirements Upon receipt of notification from a person operating a public water system, the following notification must be given within 10 days [Health and Safety Code Section 116450(g)]: • SCHOOLS: Must notify school employees, students, and parents (if the students are minors). • RESIDENTIAL RENTAL PROPERTY OWNERS OR MANAGERS (including nursing homes and care facilities): Must notify tenants. • BUSINESS PROPERTY OWNERS, MANAGERS, OR OPERATORS: Must notify employees of businesses located on the property. This notice is being sent to you by Higuera Apartments. State Water System ID#: 4000563 Date distributed: [Insert date the notice is distributed]. ATTACHMENT B Page 177 of 747 Compliance Order No. 04_70_21R_001 INFORMACIÓN IMPORTANTE SOBRE SU AGUA POTABLE Este aviso contiene información muy importante sobre su agua potable. Tradúzcalo o hable con alguien que lo entienda bien. ADVERTENCIA SOBRE EL AGUA POTABLE El agua de Higuera Apartments tiene altos niveles de nitratos NO DE ÉSTA AGUA A BEBÉS MENORES DE 6 MESES O A MUJERES EMBARAZADAS. TAMPOCO USE ÉSTA AGUA PARA PREPAPAR FORMULA INFANTIL Los resultados de las pruebas del agua recibidas el April 22, 2019 mostraron niveles de nitrato de 6.1 milígramos por litro. Estos niveles exceden el estándar o nivel máximo de contaminante (MCL) de 10 milígramos por litro. Los nitratos en el agua potable son una preocupación seria en bebés menores de seis meses. ¿Qué debe hacer? • NO DE ÉSTA AGUA A BEBÉS MENORES DE 6 MESES. Los bebés menores de 6 meses que toman agua con nitrato en exceso del nivel máximo de contaminante (MCL), se pueden enfermar seriamente y rápidamente. Y si los bebés no reciben atención médica, pueden morir debido a que los altos niveles de nitratos pueden interferir con la capacidad de la sangre de los bebés para transportar oxígeno. Los síntomas incluyen falta de aire y coloración azulada de la piel. Los síntomas en los bebés se pueden desarrollar rápidamente y la salud se deteriora en cuestión de días. Si hay síntomas de intoxicación por altos niveles de nitratos, busque atención médica de inmediato. • LAS MUJERES EMBARAZADAS NO DEBEN CONSUMIR AGUA CON ALTOS NIVELES DE NITRATOS. Los altos niveles de nitrato también pueden afectar la capacidad de la sangre de mujeres embarazadas para transportar oxígeno. • No use agua de la llave para preparar jugo, agua, y formula para bebés menores de 6 meses. Use agua embotellada u otra agua baja en nitratos para los bebés menores de 6 meses hasta nuevo aviso. • NO HIERVA EL AGUA. Hervir, congelar, filtrar, o dejar reposar el agua, no reduce el nivel de nitratos. Hervir el agua en exceso puede causar que los nitratos se concentren más, porque los nitratos se quedan cuando el agua se evapora. • Si tiene otros problemas de salud por el consumo de ésta agua, usted debería consultar con su doctor. ATTACHMENT B Page 178 of 747 Compliance Order No. 04_70_21R_001 ¿Qué sucedió? ¿Qué se está haciendo al respecto? El nitrato en el agua potable puede originar de fuentes naturales, industriales, o agriculturales (incluyendo sistemas sépticos, escorrentía de agua de lluvia, y fertilizantes). Los niveles de nitrato en el agua potable pueden variar a través del año. Le informaremos si el nivel de nitratos vuelve a estar debajo del límite. Para más información, por favor contacte a Leslie Terry al (805) 781-5553 o lterry@co.slo.ca.us. Por favor comparta esta información con todas las demás personas que tomen de esta agua, especialmente aquellos que no hayan recibido éste aviso directamente (por ejemplo, las personas en apartamentos, asilos, escuelas, y negocios). Puede hacerlo poniendo este aviso en un lugar público o distribuyendo copias en persona o por correo. Requisitos de Notificación Secundaria Al recibir la notificación de alguien que opere un sistema de agua público, se debe dar la siguiente notificación dentro de 10 días conforme a la Sección 116450(g) del Código de Salud y Seguridad: • ESCUELAS: Deben notificar a los empleados de la escuela, estudiantes, y a los padres (si los estudiantes son menores). • DUEÑOS O GERENTES DE PROPIEDAD PARA ALQUILER RESIDENCIAL (incluyendo asilos e instituciones de cuidado): Deben notificar a sus inquilino s. • DUEÑOS DE PROPIEDAD DE NEGOCIOS, GERENTES, U OPERADORES: Deben notificar a los empleados de los negocios situados en la propiedad. Este aviso es enviado por Higuera Apartments. Núm. de Identificación del Sistema Estatal de Agua: 4000563 Fecha de distribución: [Insert date the notice is distributed]. ATTACHMENT B Page 179 of 747 Compliance Order No. 04_70_21R_001 APPENDIX 2. CERTIFICATION OF COMPLETION OF PUBLIC NOTIFICATION Compliance Order Number: 04_70_21R_001 Name of Water System: Higuera Apartments System Number: 4000563 Attach a copy of the public notice distributed to the water system’s customers. This form, when completed and sent to lterry@co.slo.ca.us for the SLOEHS, certifies that public notification to water users was completed as required by Title 22, California Code of Regulations, Sections 64463-64465. Public notification for failure to comply with the nitrate maximum contaminant level was conducted on: Notification was made on _______________________________________________ (date). For the month, year of _____________________________, ___________. To summarize report delivery used and good-faith efforts taken, please check all items below that apply and fill-in where appropriate: For Community and non-transient non-community public water systems The notice was distributed by mail or direct delivery to each customer on: One or more of the following methods were used to reach persons not likely to be reached by a mailing or direct delivery or persons served by a transient public water system (renters, nursing home patients, prison inmates, etc.): Posted the notice at the following conspicuous locations served by the water system. (If needed, please attach a list of locations). Publication of the notice in a local newspaper or newsletter of general circulation (attach a copy of the published notice, including name of newspaper and date published). Posted the notice on the Internet at www. Other method used to notify customers. I hereby certify that the above information is factual. Certified by: Printed Name Title Signature Date Disclosure: Be advised that the California Health and Safety Code, Sections 116725 and 116730 state that any person who knowingly makes any false statement on any report or document submitted for the purpose of compliance with the Safe Drinking Water Act may be liable for, respectively, a civil penalty not to exceed five thousand dollars ($5,000) for each separate violation or, for continuing violations, for each day that violation continues, or be punished by a fine of not more than $25 ,000 for each day of violation, or by imprisonment in the county jail not to exceed one year, or by both the fine and imprisonment. ATTACHMENT B Page 180 of 747 Compliance Order 04_70_21R_001 APPENDIX 3. QUARTERLY PROGRESS REPORT Water System: Higuera Apartments Water System No: 4000563 Compliance Order No: 04_70_21R_001 Violation: Nitrate Maximum Contaminant Level Calendar Quarter: Date: This form should be prepared and signed by System personnel with appropriate authority to implement the directives of the Compliance Order and the Corrective Action Plan. Please attach additional sheets as necessary. The quarterly progress report must be submitted by the 10th day of each subsequent quarter, to the SLOEHS to the following email address: lterry@co.slo.ca.us titled appropriately. Summary of Compliance Plan: Tasks completed in the reporting quarter: Tasks remaining to complete: Anticipated compliance date: Printed Name Signature Title Date ATTACHMENT B Page 181 of 747 Appendix 4 - Notification of Receipt Compliance Order Number: 04_70_21R_001 Name of Water System: Higuera Apartments System Number: 4000563 Certification I certify that I am an authorized representative of the Higuera Apartments and that Compliance Order No. 04_70_21R_001 was received on ___________________. Further I certify that the Order has been reviewed by the appropriate management staff of the Higuera Apartments and it is clearly understood that Compliance Order No. 04_70_21R_001 contains legally enforceable directives with specific due dates. Signature of Water System Representative Date THIS FORM MUST BE COMPLETED AND RETURNED TO THE SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT ENVIRONMENTAL HEALTH SERVICES, NO LATER THAN JANUARY 31, 2021 Disclosure: Be advised that the California Health and Safety Code, Sections 116725 and 116730 state that any person who knowingly makes any false statement on any report or document submitted for the purpose of compliance with the Safe Drinking Water Act may be liable for, respectively, a civil penalty not to exceed five thousand dollars ($5,000) for each separate violation or, for continuing violations, for each day that violation continues, or be punished by a fine of not more than $25,000 for each day of violation, or by imprisonment in the county jail not to exceed one year, or by both the fine and imprisonment. ATTACHMENT B Page 182 of 747 W EBER, H AYES &ASSOCIATES Hydrogeology and Environmental Engineering (831) 722-3580 www.weber-hayes.com Technical Memorandum Higuera Apartments Water System San Luis Obispo, California June 20, 2023 Prepared for: Higuera Apartments via Technical Assistance from California State Water Resources Control Board; administered by University Enterprises, Inc. (UEI) WHA Project 2T171 ATTACHMENT C Page 183 of 747 Technical Memorandum Higuera Street Apartments i Weber, Hayes & Associates Contents Contents ............................................................................................................................................... i Executive Summary .......................................................................................................................... 1 Background Project Information .................................................................................................... 2 1. Existing Facilities - Description of Water System ....................................................................... 4 2. Analysis of Water System’s Current Water Demand ................................................................ 5 3. Existing Water System Operations and Maintenance (O&M) ................................................. 7 Problem Description ........................................................................................................................ 7 Alternative Analysis – 1 – No Action ............................................................................................... 9 Alternative Analysis – 2 - Consolidation ....................................................................................... 10 1. Description ....................................................................................................................................... 10 2. Design Criteria ................................................................................................................................. 10 a. Option 1 – Connect to Existing Distribution ...................................................................... 11 b. Option 2 – Replace Existing Distribution ........................................................................... 12 3. Environmental Impacts ................................................................................................................. 12 4. Land Requirements ........................................................................................................................ 13 5. Construction and Site Considerations ....................................................................................... 13 6. Cost Estimate ................................................................................................................................... 15 7. Advantages / Disadvantages ........................................................................................................ 16 8. Alternative Evaluation and Selection .......................................................................................... 16 Selected Project .............................................................................................................................. 17 1. Description ....................................................................................................................................... 17 2. Schematic and Map of System’s Proposed Facilities .............................................................. 17 3. Justification....................................................................................................................................... 17 4. Potential O&M Challenges and Solutions ................................................................................. 18 5. Consistency with Local/County Planning .................................................................................. 18 6. Green and Resilient Components ............................................................................................... 18 7. Consolidation Project: Parties Involved / New Structure ....................................................... 18 8. Purchase or Acquisition of Land Necessary to Complete the Project ................................ 19 ATTACHMENT C Page 184 of 747 Technical Memorandum Higuera Street Apartments ii 9. Final Plans, Specifications, and Other Technical Aspects of the Project ............................ 19 10. Water Demand and Capacity Analysis ..................................................................................... 19 11. Estimated Useful Life ................................................................................................................... 20 Detailed Cost Estimate for the Selected Project ......................................................................... 20 Proposed Schedule ........................................................................................................................ 20 Schematic and Map of System’s Proposed Facilities .................................................................. 21 Comprehensive Response to Climate Change ............................................................................ 21 1. Vulnerability ..................................................................................................................................... 21 2. Adaptation ........................................................................................................................................ 23 3. Mitigation ......................................................................................................................................... 25 Limitations ....................................................................................................................................... 27 References ....................................................................................................................................... 28 ATTACHMENT C Page 185 of 747 Technical Memorandum Higuera Street Apartments iii Weber, Hayes & Associates Figures Figure 1 Location Map Figure 2 San Luis Obispo City Limits & Approximate Water System Service Area Map Figure 3 Schematic and Map of Water System – Existing Figure 4 Schematic and Map of Water System – Option 1, Connect to Existing Distribution Figure 5 Schematic and Map of Water System – Option 2, Replace Existing Distribution Tables Table 1: Water Quality Data (Well-01) Table 2: Engineer’s Opinion of Probable Costs for Consolidation (Alternative #2 – Option 1, Connect to Existing Distribution) Table 3: Engineer’s Opinion of Probable Costs for Consolidation (Alternative #2 – Option 2, Replace Existing Distribution) Table 4: Alternative Comparison Summary Appendices Appendix A: County of San Luis Obispo Health Agency Compliance Order No. 04_70_21R_001 ATTACHMENT C Page 186 of 747 Technical Memorandum Higuera Street Apartments 1 Weber, Hayes and Associates Executive Summary This Technical Memorandum (TM) addresses nitrate contamination at Higuera Apartments (Higuera), located at 4320 South Higuera Street, San Luis Obispo, California. See Figure 1 for the project location. Higuera has its own Water System (Higuera WS) (ID No. CA4000563). Weber, Hayes & Associates prepared the TM on behalf of Higuera under a Technical Assistance (TA) Grant from the California State Water Resources Control Board (Water Board) assigned to and administered by University Enterprises, Inc. (UEI). As requested by Water Board staff, the TM evaluates consolidation with the City of San Luis Obispo’s water system against the No Action alternative to address the nitrate contamination issue in the community’s water supply. The intent of this Technical Memorandum (TM) is to: ƒDefine the problems the Higuera WS is facing ƒEvaluate consolidation with the City of San Luis Obispo versus a No Action alternative to provide Higuera residents with safe and reliable drinking water (i.e., resolve the elevated Nitrate issue) ƒIdentify unresolved considerations for stakeholder input to progress planning and design ƒChoose the best alternative to provide Higuera residents with safe and reliable drinking water The best alternative was chosen based on the ability to: x Supply safe and reliable drinking water and to comply with regulatory requirements x Meet the water system’s Operation and Maintenance (O&M) needs x Be financially viable, sustainable, and cost effective x Satisfy public concerns x Satisfy Regulatory concerns x Meet environmental requirements ATTACHMENT C Page 187 of 747 Technical Memorandum Higuera Street Apartments 2 The most sustainable long-term solution is consolidation with the City of San Luis Obispo’s water system. Background Project Information Higuera is located just outside the City of San Luis Obispo city limits, in San Luis Obispo County, which is in the Coast Ranges Geomorphic Province of California (see Figure 1). The Water System’s single existing water supply well, designated Well-01, draws water from the San Luis Obispo Valley Groundwater Basin. The Department of Water Resources (DWR) classifies the Basin as a high-priority groundwater basin based on fluctuating and declining groundwater levels (SGMA 2022). The Higuera WS (CA4000563) currently serves 32 customers through 25 connections. The system consists of a single well with associated chlorination and a distribution system. The Higuera WS has had a known issue with elevated Nitrate concentrations since at least 2017. The Local Primacy Agency with jurisdiction over the Higuera WS is the County of San Luis Obispo Health Agency, Public Health Department, Environmental Health Services (County). In 2020, the County issued Compliance Order No. 04_70_21R_001 (dated January 15, 2020; presented as Appendix A) to the Higuera WS for noncompliance due to Nitrate Maximum Contaminant Level (MCL) violations for the 2017 calendar year. The Compliance Order reported that Nitrate was detected in samples collected from Well-01 on June 29, 2017 and April 22, 2019 at concentrations of 13 and 6.1 milligrams per liter (mg/L), respectively. The Nitrate MCL for drinking water is 10 mg/L. Subsequent analyses indicated persistent detections of Nitrate concentrations above the MCL. These analyses are summarized in Section 3, below. Higuera received Technical Assistance grant funding to evaluate consolidation to bring their water system into regulatory compliance. The Water Board prioritizes the reduction of public water systems with the goal of consolidating small water systems into larger systems when ATTACHMENT C Page 188 of 747 Technical Memorandum Higuera Street Apartments 3 Weber, Hayes and Associates consolidation is determined to be feasible and the most sustainable solution. Consolidation in this case is considered to be the most cost-effective long-term solution. See Figure 2 for a Vicinity Map showing Higuera and the San Luis Obispo city limits and approximate water service area boundary (DWR, 2023). The City of San Luis Obispo has capacity to provide water to Higuera with their existing water system infrastructure, which extends proximate to the site along South Higuera Street. Due to the likely physical ease of consolidation and assurance that consolidation would address the nitrate issue, consolidation with the City of San Luis Obispo was considered the only appropriate alternative to evaluate alongside the No Action alternative. Treatment of the existing source water from Well No. 1 was not considered in this evaluation due to the expense of installing and operating nitrate treatment systems, the likelihood of additional complexity resulting from PFA contamination in the existing well, the general ease of connection and proximity to an existing reliable and safe water system (City of San Luis Obispo), and the Water Board’s preference for consolidation of small water systems. This Technical Memorandum (TM) describes the Higuera WS and problems, then evaluates the Consolidation and No Action alternative solutions to bring the Higuera WS into regulatory compliance. ATTACHMENT C Page 189 of 747 Technical Memorandum Higuera Street Apartments 4 1. Existing Facilities - Description of Water System The Higuera WS utilizes groundwater as its drinking water source. The capacity of their single source well, designated Well-01, is unknown according to the County Domestic Water Supply Permit, (June 26, 2019 (County of San Luis Obispo, 2019). The system currently serves 25 active residential connections and the population served is approximately 32 residents. See Figure 3 (existing) and Figures 4 & 5 (consolidation) for a Schematic and Map of the Water System. Groundwater well specifications per County Water Supply Permit (Well-01: construction date unknown): ƒWell depth: ~96.5 feet ƒ8-inch PVC casing extends to 84 feet ƒ1 ½ hp submersible pump set at 84 feet ƒChem Tech pump injects 12.5% sodium hypochlorite chlorine into the well Recent information from the well contractor indicates the well depth and pump setting may be different from information in the County Permit. The groundwater is pumped from the well via a submersible pump directly to distribution and is pressurized to approximately 60 PSI by two 85- gallon pressure tanks. The Higuera WS distribution system consists of 1½-inch, 1-inch, and ¾- inch galvanized steel and PVC piping for domestic and irrigation purposes. The Higuera WS does not have a potable water storage tank or a backup power supply. This means if the well pump loses power or fails, Higuera and the residents lose their water source, and may also lose water pressure, leaving the system vulnerable to contamination. Well-01 was reported by the property owner to have been installed in the 1920’s and is located about 300-yards Northeast of the property, across S. Higuera Street near the PG&E service yard. The 1 ½” PVC supply line that delivers water from Well-01 to the property was replaced approximately 15-years ago as was the 1” galvanized and ¾” PVC lines that frame the apartment building. The 1 ½” PVC distribution line that delivers water from the property line to the ATTACHMENT C Page 190 of 747 Technical Memorandum Higuera Street Apartments 5 Weber, Hayes and Associates apartment building was replaced approximately 8 years ago. Distribution branches connecting each dwelling unit are updated / replaced as needed by the property owner. Nitrates are present in Well-01 at concentrations above the drinking water MCL. Due to the Nitrate MCL exceedance, the County issued Compliance Order No. 04_70_21R_001 (January 15, 2020) to Higuera WS. The Compliance Order required Point of Use (POU) treatment for each building /dwelling unit. POU treatment has not been installed. Bottled water is provided to residents, and public notices have been posted to inform residents of water quality issues. 2. Analysis of Water System’s Current Water Demand No water meters are in use at Higuera. Total water demand at Higuera includes both domestic and irrigation water. To determine the water demand, we used the average residential water use per capita per day for San Luis Obispo from 2014 – present of approximately 57 gallons (CSWRCB 2023)1. As Higuera is currently not part of San Luis Obispo, we also calculated a more conservative water demand, using the current population and 100 gallons per person, per day2. The average irrigation water demand was assumed to be 360 gallons per day. The corresponding average daily demand ranges from 2,184 to 3,560 gallons per day (gpd). x Average Daily Demand = 57 gpd/person x 32 people + 360 gpd = 2,184-gpd (ADD)1 x Average Daily Demand = 100 gpd/person x 32 people + 360 gpd = 3,560-gpd (ADD)2 To determine Maximum Daily Demand (MDD), we multiply the Average Daily Demand by 1.66. x Maximum Daily Demand = 2,184-gpd x 1.66 = 3,625-gpd (MDD)1 x Maximum Daily Demand = 3,560-gpd x 1.66 = 5,910-gpd (MDD)2 Separately we calculated the water demand using the Maximum Allowable Density (MAD) population for the property along with the San Luis Obispo average of 57 gallons per person, per ATTACHMENT C Page 191 of 747 Technical Memorandum Higuera Street Apartments 6 day and the average irrigation demand estimate of 360 gallons per day. Maximum allowable density is based on the City’s General Plan Land Use Element (City of San Luis Obispo 2022) and can be considered a reasonable amount of population growth expected to occur over a 20-year period. The MAD demand can be viewed as the future water demand resultant from growth. Higuera’s Land Use Designation is Medium Density Residential, which permits a MAD of 36 dwelling units for the property. At an estimated occupancy rate of 1.5 people/unit (above the current 1.28 people/unit) the MAD population is 54 people. MAD Average Daily Demand = 57-gpd/person x 54 people + 360 gpd = 3,438-gpd (MAD-ADD) MAD Maximum Daily Demand = 3,438-gpd x 1.66 = 5,707-gpd (MAD-MDD) We believe that the City of San Luis Obispo water system can easily supply both the existing MDD and future estimated MAD-MDD at Higuera. ATTACHMENT C Page 192 of 747 Technical Memorandum Higuera Street Apartments 7 Weber, Hayes and Associates 3. Existing Water System Operations and Maintenance (O&M) Higuera WS is classified as a Community Water System. The existing water system operations and maintenance (O&M) is performed by Dave Woods and Farm Supply Company. O&M tasks generally include maintaining the water well, pressure tanks, water lines, and associated appurtenances. Ron Schriner, the property owner, collects water samples for analytical testing. The water system does not meter total production or water usage by residents and does not collect separate payment for water usage. Water is included in the rental of each dwelling unit. Distribution branches serving individual apartments are replaced on an as-needed basis. Problem Description The primary problem with Higuera’s water system is that the source water (from Well-01) contains nitrate at concentrations that exceed the MCL of 10 milligrams per liter (mg/L), and therefore pose an immediate health risk. The County issued Compliance Order No. 04_70_21R_001 (January 15, 2020; presented as Appendix A) to Higuera for noncompliance due to Nitrate Maximum Contaminant Level violations for the 2017 calendar year. A summary of Nitrate concentrations to date are presented below. 1RWDEOH ȱQJ/ FRQFHQWUDWLRQVRIper- and polyfluoroalkyl substances (PFAS) have also been detected in the source water. PFAS are widely used and environmentally persistent chemicals found in water and other mediums, and are still being investigated and understood. As of August 2022, there are no primary drinking water standards (maximum contaminant levels or MCLs) for PFAS in California. The development of standards for PFOA, PFOS, and other PFAS are among the priorities of the Division of Drinking Water (CSWRCB PFAS 2023). A complete list of source well analytical data from CA Drinking Water Watch is presented in Table 1 (CSWRCB 2022). ATTACHMENT C Page 193 of 747 Technical Memorandum Higuera Street Apartments 8 Nitrate Concentrations in Well-01 Analyte Date Concentration (mg/L) MCL (mg/L) Nitrate 6/29/2017 13 10 4/22/2019 6.1 2/2021 12 5/2021 12 12/2021 14.4 The construction date of the Higuera WS well (Well-01) is not known. It is located across the street from Higuera. The Higuera WS utilizes two 85-gallon pressure tanks at the well head connected via a 1 ½-inch distribution line that is sleeved under S. Higuera Street to supply water to the residents. There is no storage or back-up power. The distribution system piping, and other system appurtenances are likely near the end of their useful life span. The Compliance Order requires the water system to meet all primary drinking water standards. ATTACHMENT C Page 194 of 747 Technical Memorandum Higuera Street Apartments 9 Weber, Hayes and Associates Alternative Analysis – 1 – No Action Project Alternative #1 involves taking no corrective actions. This alternative does not address the primary problem of nitrate concentrations above the Maximum Contaminant Level (MCL). The ramifications of not addressing this issue include residents potentially becoming ill and failing to address the regulatory compliance requirements. For these reasons, we do not recommend Alternative #1. ATTACHMENT C Page 195 of 747 Technical Memorandum Higuera Street Apartments 10 Alternative Analysis – 2 - Consolidation 1. Description Project Alternative #2 involves consolidating Higuera WS with the City of San Luis Obispo Water System. Alternative #2 addresses the primary problem of elevated Nitrate concentrations, because the City of San Luis Obispo delivers water that does not contain elevated Nitrate or other contaminants. The Consolidation alternative requires abandonment of the existing well system and annexation of the property into the City of San Luis Obispo, which has concomitant non-water system infrastructure requirements. The City has addressed many of these requirements in the Pre- application Review of Higuera Apartments Water and Wastewater Consolidation, Including Annexation to the City of San Luis Obispo letter to the Water Board, dated February 21, 2023. 2. Design Criteria The design parameters are connecting Higuera to the existing 12-inch PVC San Luis Obispo City water main located along the West side of S. Higuera Street. The static pressure in the existing main is between 65-75 psi at the site. Three metered connections would be provided off the main line: one domestic for the Higuera Apartments complex, one domestic for the single-family home on the project site, and one for irrigation with a backflow preventer (See Figures 4 & 5). Existing fire hydrants are located on the Eastern side of S. Higuera Street near the end of the City’s existing 12-inch water main, and midway between the North and South ends of the property, allowing the main to be periodically flushed. We have assumed that that City’s system has the capacity to provide firefighting capabilities to Higuera. ATTACHMENT C Page 196 of 747 Technical Memorandum Higuera Street Apartments 11 Weber, Hayes and Associates Due to complexities associated with the City (as the potential construction grant recipient) contracting for construction on private property (Higuera), two options are provided for consolidation design. Option 1 utilizes the Higuera WS existing water distribution system wherever possible. Option 2 replaces all distribution lines on site. Due to the age of the existing water system and possible lead service line issues, it would be beneficial to replace the existing distribution lines as part of the project. Options 1 & 2 are discussed below and shown on Figures 4 and 5. Distribution line and meter sizes may be adjusted in the engineering phase as more data is obtained. a. Option 1 – Connect to Existing Distribution A 2-inch diameter domestic water service connection would extend perpendicularly from the existing 12-inch water main toward Higuera, to serve the apartment building (See Figure 4). Directly following the City approved 2-inch water meter the 2-inch domestic line would connect to the existing 1 ½-inch PVC line currently installed but not in use. The apartment building would be disconnected from the current distribution line at the Northwest corner of the apartment building and connected to the formerly installed and unused 1 ½-inch PVC line. A 1-inch diameter service connection with a ¾-inch water meter and a 1-inch domestic water distribution line with would extend perpendicularly from the existing 12-inch water main on the southern side of the property to serve the single-family home. Additionally, a 1-inch diameter irrigation water service connection with a ¾-inch meter would extend perpendicular, adjacent (minimum 18 inches apart per City specifications) to the new 2-inch domestic water line and would connect to the existing 1 ½-inch PVC line that serves the entire property. The domestic distribution system would be disconnected from this line at the Northwest corner of the apartment building leaving only irrigation service. New water meter boxes would be provided for each connection, to which the existing distribution network would tie into. A backflow prevention assembly would be installed on the irrigation line just past the meter. ATTACHMENT C Page 197 of 747 Technical Memorandum Higuera Street Apartments 12 b. Option 2 – Replace Existing Distribution A 2-inch diameter domestic water service connection and meter would extend perpendicularly from the existing 12-inch water main toward Higuera, to serve the apartment building (see Figure 5). The existing 1-inch galvanized and ¾” PVC distribution branches that frame the apartment building and the 1 ½-inch PVC distribution line from the property line would be replaced with a new 2 ½-inch PVC distribution line. The individual dwelling unit distribution lines would be replaced with new ¾” type K hard copper connections. A 1-inch diameter service connection with a ¾-inch water meter and a 1-inch domestic water distribution line with would extend perpendicularly on the southern side of the property to serve the single-family home. Additionally, a 1-inch diameter irrigation water service connection and a ¾-inch meter would extend perpendicular from the 12-inch water main on the North side of the apartment building, adjacent (minimum 18 inches apart per City specifications) to the new 2-inch domestic water line and would connect to the existing 1 ½-inch PVC line that serves the entire property. The domestic distribution system would be disconnected from this line at the Northwest corner of the apartment building leaving only irrigation service. Water meter boxes would be provided for each connection. A backflow prevention assembly would be installed behind the meter on the irrigation line. This option has the advantage of knowing there are no lead service lines at the site. Lead was detected in one of the 2021 service samples, see Table 1. 3. Environmental Impacts Alternative #2 has minor environmental impacts including land disturbance associated with abandonment of the existing well and associated distribution lines, and installation of service and distribution lines and associated appurtenances. Requirements of City annexation (required for water service) may involve vegetation and/or tree removal and site access path construction. Potential contamination from a previous crude oil pipeline in S. Higuera Street would be managed as discussed in Section 5, below. ATTACHMENT C Page 198 of 747 Technical Memorandum Higuera Street Apartments 13 Weber, Hayes and Associates 4. Land Requirements Higuera property is owned by Ron Schriner. The property would be annexed from the County into the City of San Luis Obispo, and as such would be required to meet City standards. City annexation would need to be approved by the City Council and the Local Agency Formation Commission (LAFCO). Requirements include, but are not limited to, frontage improvements and pre-zoning to identify the future zoning designation of the property. Annexation requirements are discussed further in Section 5, below. No land would have to be purchased to implement Alternative 2 (Options 1 or 2). 5. Construction and Site Considerations We anticipate that there is enough room to install the proposed water distribution lines, water meter boxes, backflow prevention assembly, and associated appurtenances. Unless otherwise waived or approved for deferral the City considers frontage improvements a requisite to annexation. This typically includes a curb, gutter, sidewalk, driveways, street lights, and fire hydrants. Roadway improvements, bike lane addition, undergrounding of existing overhead utility lines and drainage improvements as applicable are additional typical requirements. The City has indicated that a portion or all of the standard frontage improvements may be deferred. At this time only an accessible path connecting the existing sidewalk on the North side of the property to the property is required by the City. A Covenant to Install Frontage Improvements or other City approved agreement would be recorded against the parcel listing any deferred improvements. ATTACHMENT C Page 199 of 747 Technical Memorandum Higuera Street Apartments 14 Per a record search of the Water Board’s GeoTracker data base, potential contamination concerns exist from the Former Unocal No. 2 Pipeline located between 4320 and 4325 S. Higuera Street along the public right of way (Geotracker SL0607995940). Unocal historically had an easement for an eight-inch petroleum pipeline (crude oil) along the West side of S. Higuera Street, which was excavated and moved in 1952. In 1998, petroleum hydrocarbons were discovered in the soil beneath S. Higuera Street while PG&E was conducting utility work. Soil and groundwater monitoring wells were installed in the public right of way to monitor Total Petroleum Hydrocarbons (TPH) concentrations and were later properly destroyed. Excavation and proper off-site disposal of TPH-contaminated soil was considered infeasible due to the presence of utilities in the roadway. In 2005, Chevron Environmental Management Company (CEMC) assumed responsibility for the cleanup of this site. The case was closed as of 1/13/2015 on the basis that soil and groundwater contamination had been adequately characterized, the most recent monitoring event showed no detectable pollutants, and no water supply wells existed within 500 feet (CCRWQCB 2015). CEMC developed a Site Soil and Groundwater Management Plan (SGMP) to ensure proper handling of site soils and groundwater should they be exposed during future activities in the roadway or on private property (CEMC 2013). The SGMP describes profiling and management activities to properly deal with any contamination encountered. The Central Coast Water Board, San Luis Obispo County Environmental Health Services, and the appropriate local planning, and building departments must be notified prior to any changes in land use, grading activities, soil excavation, or groundwater dewatering. As per the SGMP, CEMC would be provided with advance notice of plans to conduct construction activities that may encounter petroleum affected soil or groundwater. If potentially affected soil and/or groundwater is observed during necessary construction activities, CEMC would profile the material and provide consultation on the eventual disposal or reuse of any affected soil and discharge or disposal of any affected groundwater. CEMC may be reached at (800) 338-5434. ATTACHMENT C Page 200 of 747 Technical Memorandum Higuera Street Apartments 15 Weber, Hayes and Associates 6. Cost Estimate Table 2 summarizes costs for Alternative #2 – Option 1, Connect to Existing Distribution. Table 3 summarizes costs for Alternative #2 – Option 2, Replace Existing Distribution. Table 4 compares Alternative #1 (No Action) and Alternative #2 (Consolidation). ATTACHMENT C Page 201 of 747 Technical Memorandum Higuera Street Apartments 16 7. Advantages / Disadvantages The advantage of Alternative #2 is that it provides a reliable long-term drinking water source for Higuera. In addition, monthly Operations and Maintenance (O&M) costs associated with operating a public water system would no longer exist after consolidation. The owner of Higuera would only be responsible for O&M of the water distribution system on their property. Consolidation is the simplest and most efficient option given the availability of City owned water infrastructure proximate to the site and the City’s ability to supply potable water. The disadvantages include: ƒModerate cost construction ƒHiguera would have to pay a City of San Luis Obispo water bill each month, which may be substantially higher than existing well supply O&M costs ƒChallenges regarding annexation and associated requirements ƒHiguera would be required to pay for the irrigation water system components including the connection fee, meter, and service line as these are not eligible for State Water Board financial assistance. These costs may be prohibitive. 8. Alternative Evaluation and Selection We believe the advantages outweigh the disadvantages and recommend Alternative #2. Based on the advantages listed in the sections above, we recommend water system consolidation with the City of San Luis Obispo (Alternative #2) ATTACHMENT C Page 202 of 747 Technical Memorandum Higuera Street Apartments 17 Weber, Hayes and Associates Selected Project The selected project is water system consolidation with The City of San Luis Obispo: which includes water service lines, water meters, a backflow prevention assembly, and associated appurtenances. 1. Description See the Alternative #2 “Design Criteria” section above for the project description and design details. 2. Schematic and Map of System’s Proposed Facilities See Figures 4 & 5 for a schematic and map of the proposed Alternative #2 project. 3. Justification Due to the overall viability of consolidation with the City of San Luis Obispo, only the No Action and Consolidation alternatives were considered as potential solutions in the alternatives analysis (as directed by State Water Board staff). San Luis Obispo City water is safe and reliable. The proximity of existing City water infrastructure and current City boundaries make consolidation the most effective long-term solution to solve the nitrate contamination problem. ATTACHMENT C Page 203 of 747 Technical Memorandum Higuera Street Apartments 18 4. Potential O&M Challenges and Solutions If the consolidation option is selected, then the potential O&M challenges would be minor – because City of San Luis Obispo would supply the water. Higuera would need to maintain the new and existing water distribution lines, the backflow prevention assembly and associated appurtenances (everything on the Higuera side of the San Luis Obispo water meters), which they already do. Higuera would no longer be responsible for well O&M or water system sampling and reporting. 5. Consistency with Local/County Planning To our knowledge, this project is consistent with local and County planning. 6. Green and Resilient Components See the “Comprehensive Response to Climate Change” section below for details on green and resilient components. 7. Consolidation Project: Parties Involved / New Structure The consolidation stakeholders include Higuera, its’ residents, the City of San Luis Obispo, and the County of San Luis Obispo. Higuera will become a water customer of the City of San Luis Obispo. The Higuera WS will cease to exist. ATTACHMENT C Page 204 of 747 Technical Memorandum Higuera Street Apartments 19 Weber, Hayes and Associates 8. Purchase or Acquisition of Land Necessary to Complete the Project No land will need to be purchased or acquired for the consolidation project (Alternative 2). Higuera would have to be annexed into the City of San Luis Obispo. Annexation has concomitant non-water system infrastructure requirements. 9. Final Plans, Specifications, and Other Technical Aspects of the Project The selected project includes connecting Higuera WS to the existing City of San Luis Obispo water system. The overall conceptual design and process flow details are described above in the “Alternative Analysis – Consolidation: Design Criteria” section. Further details of the proposed water system components are presented in Figures 4 & 5. Final Plans and Specifications will be developed in a later stage of this project. 10. Water Demand and Capacity Analysis As presented in the “Background Project Information” section above, the anticipated Maximum Daily Demand (MDD) ranges from 3,6251 - 5,9102-gpd for the existing system. In consideration of a Maximum Allowable Density (MAD) scenario, anticipated MAD-MDD is approximately 5,707- gpd. Maximum allowable density is considered for design based on the City’s General Plan Land Use Element and can be considered a reasonable amount of population growth expected to occur over a 20-year period. We anticipate that the City of San Luis Obispo water system has enough capacity to supply water to Higuera in both existing and future scenarios. ATTACHMENT C Page 205 of 747 Technical Memorandum Higuera Street Apartments 20 11. Estimated Useful Life We estimate the useful life for the following major components: ƒNew 1- and 2-inch water service and distribution lines (domestic & irrigation): 40-years+ ƒBackflow prevention assembly: 20+ years ƒWater Meters: 20+ years Detailed Cost Estimate for the Selected Project See Table 2 for the detailed cost estimate. A 20-year period life cycle cost analysis was performed. We consider consolidation the best, most sustainable long-term option for Higuera. Proposed Schedule We anticipate the following schedule for submittals to the TA Team: Draft Technical Memorandum February 15, 2023 Final Technical Memorandum One month after comments 60% engineering plans Six months after approved TA Work Plan and Contract 90% plans to the TA Team Four months after all comments on 60% Plans Draft Technical Package Ten Months after approved TA Work Plan and Contract Draft Environmental Package Ten Months after approved TA Work Plan and Contract ATTACHMENT C Page 206 of 747 Technical Memorandum Higuera Street Apartments 21 Weber, Hayes and Associates Schematic and Map of System’s Proposed Facilities See Figures 4 & 5 for details of the proposed facilities. Comprehensive Response to Climate Change This section describes climate change preparedness for the project and is organized as follows: Vulnerability – Describes the effects of climate changes that the proposed project is susceptible to, including critical threshold conditions that may cause damage to the facility or result in loss of services Adaptation – Describes the applied adaptation measures considered for the project, including adaptation measures deemed unnecessary, and explains why such measures were eliminated Mitigation – Describes the mitigation measures considered for the project, including mitigation measures deemed unnecessary, and explains why such measures were eliminated 1. Vulnerability Vulnerability is used to identify effects of climate change that the project may be susceptible to. Vulnerability includes sea level rise, water supply depletion, adverse water supply quality, flooding/storm surges, wildfires, and drought. The climate change effects the Project may be susceptible to are discussed below. Sea Level Rise The project is not susceptible to sea level rise, as Higuera’s elevation is approximately 120-feet above the Pacific Ocean. The ocean is located approximately 5 miles southwest of Higuera. ATTACHMENT C Page 207 of 747 Technical Memorandum Higuera Street Apartments 22 Water Supply Quality issues The Higuera WS has an existing water supply well with elevated nitrate concentrations. We recommend that this well is destroyed and that Higuera be connected to the City of San Luis Obispo water system. The City of San Luis Obispo utilizes ozone for primary disinfection and chlorination as secondary disinfection. City of San Luis Obispo water sources are considered most vulnerable to the following activities not associated with any detected contaminants, including grazing, managed forests, recreational areas, septic systems, sewer collection systems, gas stations and historic mining activities. Additionally, wildfire risk could result in increased sedimentation to reservoirs, possibly negatively impacting surface water quality. Flooding/Storm Surges The project is not susceptible to flooding or storm surges. Higuera is located outside of the Federal Emergency Management Agency’s (FEMA) 100-year flood plain or other special flood hazard areas. Forest Fires The project site is generally not susceptible to forest fires, because it is primarily surrounded by irrigated agricultural fields and urban development. Drought Longer or more frequent droughts due to climate change may adversely affect all water supplies. Statewide, rainfall and snowfall are expected to change in terms of both type and timing. At the local level, changes in the timing and intensity of precipitation could negatively affect groundwater recharge and the local groundwater supply. This could lead to water supply issues for all of California, including City of San Luis Obispo and Higuera. ATTACHMENT C Page 208 of 747 Technical Memorandum Higuera Street Apartments 23 Weber, Hayes and Associates Other No other vulnerability effects of climate change were identified for the Project. 2. Adaptation Adaptation is the term used to identify measures taken as a direct response to climate change effects. Multiple measures can be taken in response to a single vulnerability. For example, in response to sea level rise an agency may investigate constructing sea walls or levees in order to prevent flooding. Flood contingencies could also be explored to protect the project if the levees fail or in the event of severe storm surges. Adaptive measures in the Project in response to Climate Change are described below. Renewable Energy Sources Energy usage will not be significantly changed as this project consists of replacing the Higuera WS existing water supply well with water from the City of San Luis Obispo water supply. Higuera’s onsite solar arrays serve their energy demands. Drought Resiliency and Flood Contingency The City of San Luis Obispo will provide potable water for the proposed consolidation alternative. The City of San Luis Obispo has four primary water supply sources including Whale Rock Reservoir, Salinas Reservoir, Nacimiento Reservoir, and recycled water. Historic groundwater wells are also kept in operable stand-by condition, and the City has produced a Groundwater Sustainability Plan (GSP). The City currently operates well below its available water supply. Water conservation should be practiced to safeguard a long-term water supply. Water efficient fixtures are one water conservation practice to support long-term resiliency. Complimentary water conservation items are available from the City of San Luis Obispo, including low-flow ATTACHMENT C Page 209 of 747 Technical Memorandum Higuera Street Apartments 24 showerheads and adjustable faucet aerators. These items will likely be required for the project to go forward. Other conservation practices that could be utilized at the site include rainwater collection and greywater systems (City of San Luis Obispo). The project is not subject to flooding. Higuera is located outside of the Federal Emergency Management Agency’s (FEMA) 100-year flood plain. Maintaining existing permeable ground cover on the site will continue to support natural rainwater infiltration and prevent flooding. Permeable Pavements No permeable pavements are incorporated in the Project. Elevated Construction, Sea Walls, Levees No elevated construction, sea walls or levees are necessary for the Project, and none have been incorporated into the Project. Green Roofing No green roofing has been incorporated in the Project, as no building structures are involved. Fire Resistant Water Connections and Hydrants Fire resistant water connections are not part of the Project. Other No other adaptations are included in the Project. ATTACHMENT C Page 210 of 747 Technical Memorandum Higuera Street Apartments 25 Weber, Hayes and Associates 3. Mitigation Mitigation is the term used to identify measures taken to slow or stop changes caused by greenhouse gas emissions in the atmosphere. Measures identified in adaptation may also be used for mitigation. For example, water conservation may be an adaptation response to drought vulnerability but a mitigation measure by reducing the energy consumed to move excessive volumes of water. Green roofing as an adaptation measure will help to reduce the heat island effect of an urban community, and as a mitigation measure will reduce the energy consumed to heat and cool the building. Mitigation measures taken to reduce concentrations of greenhouse gases in the atmosphere as part of the Project are described below. Renewable Energy Sources The existing onsite solar array provides energy to the property but there are no additional energy draws associated with this project. Additional renewable energy sources are not a part of this project. Energy Conservation Implementation of both the water and additional wastewater components of the project in the most efficient and coordinated manner would significantly limit the energy and material consumption associated with development in the public right of way. Water Conservation Water conservation components of the Project include: x An option for new water distribution lines connecting to the existing main which will be “tight” (no leaks) ATTACHMENT C Page 211 of 747 Technical Memorandum Higuera Street Apartments 26 x Water meters on the domestic and irrigation water distribution lines x Water efficient fixtures to be installed at Higuera Other No other mitigation measures were included in the Project. ATTACHMENT C Page 212 of 747 Technical Memorandum Higuera Street Apartments 27 Weber, Hayes and Associates Limitations Our service consists of professional opinions and recommendations made in accordance with generally accepted engineering principles and practices. This warranty is in lieu of all others, either expressed or implied. The analysis and conclusions in this report are based on site observations and existing data, some of which have been conducted or collected by others, all of which are necessarily limited. Additional data from future work may lead to modifications of the opinions expressed herein. All work was conducted under the direct supervision of a Professional Engineer, registered in the state of California, and experienced in drinking water system design and water resource engineering. Thank you for the opportunity to prepare this Technical Memorandum. If you have any questions or comments regarding this project, please contact us at 831-722-3580. Sincerely yours, Weber, Hayes and Associates A California Corporation By: Richard V. Peterson, EIT Staff Engineer And: Robyn E Chaconas, EIT Project Engineer And: Craig B. Drizin, PE Principal Engineer EEEEEEE Chacacccccccccccccccccccccccconas EIT ATTACHMENT C Page 213 of 747 Technical Memorandum Higuera Street Apartments 28 References California Department of Water Resources (DWR), Water Management Planning Tool. Accessed January 2023. https://gis.water.ca.gov/app/boundaries/ California State Water Resources Control Board (CSWRCB), Urban Water Supplier Monthly Reports – City of San Luis Obispo. Accessed January 30, 2023. https://www.waterboards.ca.gov/water_issues/programs/conservation_portal/conservation_repo rting.html California State Water Resources Control Board (CSWRCB), Safe Drinking Water Information System (SDWIS) CA Drinking Water Watch. Accessed November 2022. https://sdwis.waterboards.ca.gov/PDWW/JSP/WaterSystemDetail.jsp?tinwsys_is_number=9424&ti nwsys_st_code=CA&counter=0 California State Water Resources Control Board (CSWRCB), PFAS: Per- and Polyfluoroalkyl Substances. Accessed February 2023. https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/pfas.html Central Coast Regional Water Quality Control Board (CCRWQCB), Case Closure Letter, dated January 14, 2015. https://documents.geotracker.waterboards.ca.gov/regulators/deliverable_documents/89779641 03/Unocal%20Old%20No.%202%20closure%20letter%20FINAL%20011415.pdf Chevron Environmental Management Company, Soil and Groundwater Management Plan, dated October 2013. https://documents.geotracker.waterboards.ca.gov/regulators/deliverable_documents/26899000 40/4320%20South%20Higuera%20Old%20%232%20Pipeline%20SGMP%20Final.pdf City of San Luis Obispo, Conservation Tips and Tricks – Rainwater Collection. https://www.slocity.org/government/department-directory/utilities-department/water- conservation/conservation-tips-and-tricks City of San Luis Obispo, General Plan Land Use Element. June 2022. https://www.slocity.org/home/showpublisheddocument/32297 City of San Luis Obispo, Graywater Systems. https://www.slocity.org/government/department- directory/utilities-department/water-conservation/conservation-tips-and-tricks/graywater- systems ATTACHMENT C Page 214 of 747 Technical Memorandum Higuera Street Apartments 29 Weber, Hayes and Associates County of San Luis Obispo. Domestic Water Supply Permit, Higuera Apartments 4000563. June 26, 2019. SGMA Basin Prioritization Dashboard. https://gis.water.ca.gov/app/bp-dashboard/final/. Accessed November 5, 2022. City of San Luis Obispo, Pre-application Review of Higuera Apartments Water and Wastewater Consolidation, Including Annexation to the City of San Luis Obispo letter, dated February 21, 2023. ATTACHMENT C Page 215 of 747 Technical Memorandum Higuera Street Apartments Weber, Hayes & Associates FIGURES ATTACHMENT C Page 216 of 747 ~5 mi.0'APPROXIMATESCALEBASEMAP FROMGOOGLEEARTHSan Luis Obispo City LimitsWeber Hayes AssociatesLocation MapHiguera Apartments - 4320 S. Higuera Street, San Luis Obispo, CA 93401Figure 1Feb 2023Higuera ApartmentsATTACHMENT CPage 217 of 747 160'.0'APPROXIMATESCALEBASEMAP FROMWATERMANAGEMENTPLANNINGTOOLSan Luis Obispo City Limits andApprox. Water System Service AreaHiguera ApartmentsWeber Hayes AssociatesSan Luis Obispo City Limits & Approx. Water System Service Area MapHiguera Apartments - 4320 S. Higuera Street, San Luis Obispo, CA 93401Cityand Water System boundaries obtained through the DWR Water Management Planning Tool: https://gis.water.ca.gov/app/boundaries/Figure 2Feb 2023ATTACHMENT CPage 218 of 747 Figure 3Feb 2023Weber Hayes AssociatesSchematic and Map of Water System - ExistingHiguera Apartments - 4320 S. Higuera Street, San Luis Obispo, CA 93401(E) 3/4-inch PVC distributionATTACHMENT CPage 219 of 747 Figure 4May 2023Weber Hayes AssociatesSchematic and Map of Water System - Consolidation Option 1, Connect to Existing DistributionHigueraApartments-4320S.HigueraStreet,SanLuisObispo,CA93401(E) 1-inch PVCIrrigationATTACHMENT CPage 220 of 747 Figure 5May 2023Weber Hayes AssociatesSchematic and Map of Water System - Consolidation Option 2, Replace Existing DistributionHigueraApartments-4320S.HigueraStreet,SanLuisObispo,CA93401(E) 1-inch PVC IrrigationATTACHMENT CPage 221 of 747 Technical Memorandum Higuera Street Apartments Weber, Hayes & Associates TABLES ATTACHMENT C Page 222 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL TURBIDITY 05-03-2021 0.4 NTU 5 TURBIDITY 06-29-2017 0.18 NTU 5 ALUMINUM 05-03-2021 ND UG/L 1000 ALUMINUM 06-29-2017 ND UG/L 1000 ALUMINUM 12-10-2012 ND UG/L 1000 ARSENIC 05-03-2021 ND UG/L 10 ARSENIC 06-29-2017 ND UG/L 10 ARSENIC 12-10-2012 ND UG/L 10 BARIUM 05-03-2021 300 UG/L 1000 BARIUM 06-29-2017 340 UG/L 1000 BARIUM 12-10-2012 370 UG/L 1000 CADMIUM 05-03-2021 ND UG/L 5 CADMIUM 06-29-2017 ND UG/L 5 CADMIUM 12-10-2012 ND UG/L 5 CHLORIDE 05-03-2021 310 MG/L 500 CHLORIDE 06-29-2017 340 MG/L 500 CHROMIUM 05-03-2021 15 UG/L 50 CHROMIUM 06-29-2017 11 UG/L 50 CHROMIUM 12-10-2012 11 UG/L 50 HYDROXIDE AS CALCIUM CARBONATE 05-03-2021 ND MG/L --- HYDROXIDE AS CALCIUM CARBONATE 06-29-2017 ND MG/L --- COPPER, FREE 05-03-2021 ND UG/L 1000 COPPER, FREE 06-29-2017 ND UG/L 1000 CYANIDE 05-03-2021 ND UG/L 150 CYANIDE 06-29-2017 ND UG/L 150 CYANIDE 12-10-2012 ND UG/L 150 FLUORIDE 05-03-2021 0.2 MG/L 2 FLUORIDE 06-29-2017 0.17 MG/L 2 FLUORIDE 12-10-2012 0.2 MG/L 2 IRON 05-03-2021 ND UG/L 300 IRON 06-29-2017 ND UG/L 300 LEAD 05-03-2021 ND UG/L --- LEAD 06-29-2017 ND UG/L --- LEAD 12-10-2012 ND UG/L --- MAGNESIUM 05-03-2021 120 MG/L --- MAGNESIUM 06-29-2017 130 MG/L --- MANGANESE 05-03-2021 ND UG/L 50 MANGANESE 06-29-2017 ND UG/L 50 MERCURY 05-03-2021 ND UG/L 2 MERCURY 06-29-2017 ND UG/L 2 MERCURY 12-10-2012 ND UG/L 2 NICKEL 05-03-2021 ND UG/L 100 NICKEL 06-29-2017 ND UG/L 100 NICKEL 12-10-2012 ND UG/L 100 NITRATE-NITRITE 12-08-2021 14.4 MG/L 10 Table 1 - Water Quality Data (Well-1) 1 of 13 Weber, Hayes Associates ATTACHMENT C Page 223 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) NITRATE-NITRITE 05-03-2021 12 MG/L 10 NITRATE-NITRITE 06-29-2017 13 MG/L 10 PERCHLORATE 05-03-2021 ND UG/L 6 PERCHLORATE 12-11-2007 ND UG/L 6 NITRATE 12-08-2021 14.4 MG/L 10 NITRATE 05-03-2021 12 MG/L 10 NITRATE 02-16-2021 12 MG/L 10 NITRATE 04-22-2019 6.1 MG/L 10 NITRATE 06-29-2017 13 MG/L 10 NITRITE 12-08-2021 ND MG/L 1 NITRITE 05-03-2021 ND MG/L 1 NITRITE 06-29-2017 ND MG/L 1 NITRITE 12-10-2012 ND UG/L 1000 POTASSIUM 05-03-2021 2.9 MG/L --- POTASSIUM 06-29-2017 2.9 MG/L --- SELENIUM 05-03-2021 5.8 UG/L 50 SELENIUM 06-29-2017 9.3 UG/L 50 SELENIUM 12-10-2012 7.9 UG/L 50 SILVER 05-03-2021 ND UG/L 100 SILVER 06-29-2017 ND UG/L 100 SODIUM 05-03-2021 100 MG/L --- SODIUM 06-29-2017 90 MG/L --- SULFATE 05-03-2021 91 MG/L 500 SULFATE 06-29-2017 99 MG/L 500 CONDUCTIVITY @ 25 C UMHOS/CM 05-03-2021 1800 UMHO/CM 1600 CONDUCTIVITY @ 25 C UMHOS/CM 06-29-2017 2000 UMHO/CM 1600 ANTIMONY, TOTAL 05-03-2021 ND UG/L 6 ANTIMONY, TOTAL 06-29-2017 ND UG/L 6 ANTIMONY, TOTAL 12-10-2012 ND UG/L 6 BERYLLIUM, TOTAL 05-03-2021 ND UG/L 4 BERYLLIUM, TOTAL 06-29-2017 ND UG/L 4 BERYLLIUM, TOTAL 12-10-2012 ND UG/L 4 BORON, TOTAL 08-27-2002 150 UG/L --- CHROMIUM, HEX 08-27-2015 8.4 UG/L 10 THALLIUM, TOTAL 05-03-2021 ND UG/L 2 THALLIUM, TOTAL 06-29-2017 ND UG/L 2 THALLIUM, TOTAL 12-10-2012 ND UG/L 2 ASBESTOS 07-05-2017 ND MFL 7 ZINC 05-03-2021 ND UG/L 5000 ZINC 06-29-2017 ND UG/L 5000 COLOR 05-03-2021 ND UNITS 15 COLOR 06-29-2017 ND UNITS 15 HARDNESS, TOTAL (AS CACO3)05-03-2021 710 MG/L --- HARDNESS, TOTAL (AS CACO3)06-29-2017 780 MG/L --- CALCIUM 05-03-2021 90 MG/L --- 2 of 13 Weber, Hayes Associates ATTACHMENT C Page 224 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) CALCIUM 06-29-2017 93 MG/L --- ODOR 05-03-2021 1 TON 3 ODOR 06-29-2017 ND TON 3 PH 05-03-2021 7.7 pH --- PH 06-29-2017 7.8 pH --- ALKALINITY, TOTAL 05-03-2021 380 MG/L --- ALKALINITY, TOTAL 06-29-2017 380 MG/L --- ALKALINITY, BICARBONATE 05-03-2021 470 MG/L --- ALKALINITY, BICARBONATE 06-29-2017 460 MG/L --- ALKALINITY, CARBONATE 05-03-2021 ND MG/L --- ALKALINITY, CARBONATE 06-29-2017 ND MG/L --- TDS 05-03-2021 990 MG/L 1000 TDS 06-29-2017 1400 MG/L 1000 AGGRESSIVE INDEX 05-03-2021 13 AGGR --- AGGRESSIVE INDEX 06-29-2017 13 AGGR --- LANGELIER INDEX (PH(S))05-03-2021 0.61 LANG --- LANGELIER INDEX (PH(S))06-29-2017 0.74 LANG --- P-ISOPROPYLTOLUENE 05-12-2021 ND UG/L --- P-ISOPROPYLTOLUENE 06-29-2017 ND UG/L --- P-ISOPROPYLTOLUENE 12-10-2012 ND UG/L --- SIMAZINE 06-29-2017 ND UG/L 4 SIMAZINE 12-10-2012 ND UG/L 4 ATRAZINE 06-29-2017 ND UG/L 1 ATRAZINE 12-10-2012 ND UG/L 1 LASSO 06-29-2017 ND UG/L 2 LASSO 12-10-2012 ND UG/L 2 CHLOROMETHANE 05-12-2021 ND UG/L --- CHLOROMETHANE 06-29-2017 ND UG/L --- CHLOROMETHANE 12-10-2012 ND UG/L --- DICHLORODIFLUOROMETHANE 05-12-2021 ND UG/L --- DICHLORODIFLUOROMETHANE 06-29-2017 ND UG/L --- DICHLORODIFLUOROMETHANE 12-10-2012 ND UG/L --- BROMOMETHANE 05-12-2021 ND UG/L --- BROMOMETHANE 06-29-2017 ND UG/L --- BROMOMETHANE 12-10-2012 ND UG/L --- CHLOROETHANE 05-12-2021 ND UG/L --- CHLOROETHANE 06-29-2017 ND UG/L --- CHLOROETHANE 12-10-2012 ND UG/L --- TRICHLOROFLUOROMETHANE 05-12-2021 ND UG/L 150 TRICHLOROFLUOROMETHANE 06-29-2017 ND UG/L 150 TRICHLOROFLUOROMETHANE 12-10-2012 ND UG/L 150 TRANS-1,3-DICHLOROPROPENE 06-29-2017 ND UG/L .5 TRANS-1,3-DICHLOROPROPENE 12-10-2012 ND UG/L .5 CIS-1,3-DICHLOROPROPENE 06-29-2017 ND UG/L .5 CIS-1,3-DICHLOROPROPENE 12-10-2012 ND UG/L .5 3 of 13 Weber, Hayes Associates ATTACHMENT C Page 225 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) ACETONE 05-12-2021 ND UG/L --- ACETONE 06-29-2017 ND UG/L --- ACETONE 12-10-2012 ND UG/L --- ISOPROPYL ETHER 05-12-2021 ND UG/L --- ISOPROPYL ETHER 06-29-2017 ND UG/L --- ISOPROPYL ETHER 12-10-2012 ND UG/L --- HEXACHLOROBUTADIENE 05-12-2021 ND UG/L --- HEXACHLOROBUTADIENE 06-29-2017 ND UG/L --- HEXACHLOROBUTADIENE 12-10-2012 ND UG/L --- METHYL ETHYL KETONE 05-12-2021 ND UG/L --- METHYL ETHYL KETONE 06-29-2017 ND UG/L --- METHYL ETHYL KETONE 12-10-2012 ND UG/L --- NAPHTHALENE 05-12-2021 ND UG/L --- NAPHTHALENE 06-29-2017 ND UG/L --- NAPHTHALENE 12-10-2012 ND UG/L --- METHYL TERT-BUTYL ETHER 05-12-2021 ND UG/L 13 METHYL TERT-BUTYL ETHER 06-29-2017 ND UG/L 13 METHYL TERT-BUTYL ETHER 12-10-2012 ND UG/L 13 4-METHYL-2-PENTANONE 05-12-2021 ND UG/L --- 4-METHYL-2-PENTANONE 06-29-2017 ND UG/L --- 4-METHYL-2-PENTANONE 12-10-2012 ND UG/L --- 1,2,4-TRICHLOROBENZENE 05-12-2021 ND UG/L 5 1,2,4-TRICHLOROBENZENE 06-29-2017 ND UG/L 5 1,2,4-TRICHLOROBENZENE 12-10-2012 ND UG/L 5 CIS-1,2-DICHLOROETHYLENE 05-12-2021 ND UG/L 6 CIS-1,2-DICHLOROETHYLENE 06-29-2017 ND UG/L 6 CIS-1,2-DICHLOROETHYLENE 12-10-2012 ND UG/L 6 DIBROMOMETHANE 05-12-2021 ND UG/L --- DIBROMOMETHANE 06-29-2017 ND UG/L --- DIBROMOMETHANE 12-10-2012 ND UG/L --- 1,1-DICHLOROPROPENE 05-12-2021 ND UG/L --- 1,1-DICHLOROPROPENE 06-29-2017 ND UG/L --- 1,1-DICHLOROPROPENE 12-10-2012 ND UG/L --- 1,3-DICHLOROPROPANE 05-12-2021 ND UG/L --- 1,3-DICHLOROPROPANE 06-29-2017 ND UG/L --- 1,3-DICHLOROPROPANE 12-10-2012 ND UG/L --- 1,3-DICHLOROPROPENE 05-12-2021 ND UG/L .5 1,3-DICHLOROPROPENE 06-29-2017 ND UG/L .5 1,3-DICHLOROPROPENE 12-10-2012 ND UG/L .5 1,2,3-TRICHLOROPROPANE 04-22-2019 ND UG/L 0.005 1,2,3-TRICHLOROPROPANE 03-27-2019 ND UG/L 0.005 1,2,3-TRICHLOROPROPANE 10-10-2018 ND UG/L 0.005 1,2,3-TRICHLOROPROPANE 09-18-2018 ND UG/L 0.005 2,2-DICHLOROPROPANE 05-12-2021 ND UG/L --- 2,2-DICHLOROPROPANE 06-29-2017 ND UG/L --- 4 of 13 Weber, Hayes Associates ATTACHMENT C Page 226 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) 2,2-DICHLOROPROPANE 12-10-2012 ND UG/L --- 1,2,4-TRIMETHYLBENZENE 05-12-2021 ND UG/L --- 1,2,4-TRIMETHYLBENZENE 06-29-2017 ND UG/L --- 1,2,4-TRIMETHYLBENZENE 12-10-2012 ND UG/L --- 1,2,3-TRICHLOROBENZENE 05-12-2021 ND UG/L --- 1,2,3-TRICHLOROBENZENE 06-29-2017 ND UG/L --- 1,2,3-TRICHLOROBENZENE 12-10-2012 ND UG/L --- N-BUTYLBENZENE 05-12-2021 ND UG/L --- N-BUTYLBENZENE 06-29-2017 ND UG/L --- N-BUTYLBENZENE 12-10-2012 ND UG/L --- 1,3,5-TRIMETHYLBENZENE 05-12-2021 ND UG/L --- 1,3,5-TRIMETHYLBENZENE 06-29-2017 ND UG/L --- 1,3,5-TRIMETHYLBENZENE 12-10-2012 ND UG/L --- TERT-BUTYLBENZENE 05-12-2021 ND UG/L --- TERT-BUTYLBENZENE 06-29-2017 ND UG/L --- TERT-BUTYLBENZENE 12-10-2012 ND UG/L --- SEC-BUTYLBENZENE 05-12-2021 ND UG/L --- SEC-BUTYLBENZENE 06-29-2017 ND UG/L --- SEC-BUTYLBENZENE 12-10-2012 ND UG/L --- BROMOCHLOROMETHANE 05-12-2021 ND UG/L --- BROMOCHLOROMETHANE 06-29-2017 ND UG/L --- BROMOCHLOROMETHANE 12-10-2012 ND UG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)08-25-2022 15 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)06-23-2022 17 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)03-08-2022 29 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)12-08-2021 32 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)09-24-2021 19 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)06-24-2021 23 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)03-08-2021 23 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)11-09-2020 27 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)03-12-2020 49 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)11-18-2019 29 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)09-30-2019 22 NG/L --- PERFLUOROBUTANESULFONIC ACID (PFBS)06-03-2019 18 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)08-25-2022 3.6 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)06-23-2022 4 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)03-08-2022 5.6 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)12-08-2021 5.9 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)09-24-2021 4.6 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)06-24-2021 4.7 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)03-08-2021 3.6 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)11-09-2020 5.2 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)03-12-2020 7.2 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)11-18-2019 5.9 NG/L --- PERFLUOROHEPTANOIC ACID (PFHPA)09-30-2019 3.3 NG/L --- 5 of 13 Weber, Hayes Associates ATTACHMENT C Page 227 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) PERFLUOROHEPTANOIC ACID (PFHPA)06-03-2019 3.2 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)08-25-2022 2.2 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)06-23-2022 2.3 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)03-08-2022 2.1 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)12-08-2021 2.6 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)09-24-2021 2.1 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)06-24-2021 2.9 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)03-08-2021 2.3 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)11-09-2020 2.4 NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)03-12-2020 ND NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)11-18-2019 ND NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)09-30-2019 ND NG/L --- PERFLUOROHEXANE SULFONIC ACID (PFHXS)06-03-2019 1.6 NG/L --- PERFLUORONONANOIC ACID (PFNA)08-25-2022 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)06-23-2022 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)03-08-2022 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)12-08-2021 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)09-24-2021 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)06-24-2021 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)03-08-2021 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)11-09-2020 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)03-12-2020 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)11-18-2019 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)09-30-2019 ND NG/L --- PERFLUORONONANOIC ACID (PFNA)06-03-2019 ND NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)08-25-2022 9.4 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)06-23-2022 9.6 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)03-08-2022 15 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)12-08-2021 16 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)09-24-2021 9.5 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)06-24-2021 11 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)03-08-2021 11 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)11-09-2020 11 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)03-12-2020 19 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)11-18-2019 12 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)09-30-2019 9.5 NG/L --- PERFLUOROCTANE SULFONIC ACID (PFOS)06-03-2019 7.7 NG/L --- PERFLUOROCTANOIC ACID (PFOA)08-25-2022 8.5 NG/L --- PERFLUOROCTANOIC ACID (PFOA)06-23-2022 8.3 NG/L --- PERFLUOROCTANOIC ACID (PFOA)03-08-2022 11 NG/L --- PERFLUOROCTANOIC ACID (PFOA)12-08-2021 12 NG/L --- PERFLUOROCTANOIC ACID (PFOA)09-24-2021 10 NG/L --- PERFLUOROCTANOIC ACID (PFOA)06-24-2021 11 NG/L --- PERFLUOROCTANOIC ACID (PFOA)03-08-2021 8.6 NG/L --- PERFLUOROCTANOIC ACID (PFOA)11-09-2020 11 NG/L --- 6 of 13 Weber, Hayes Associates ATTACHMENT C Page 228 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) PERFLUOROCTANOIC ACID (PFOA)03-12-2020 14 NG/L --- PERFLUOROCTANOIC ACID (PFOA)11-18-2019 11 NG/L --- PERFLUOROCTANOIC ACID (PFOA)09-30-2019 7.4 NG/L --- PERFLUOROCTANOIC ACID (PFOA)06-03-2019 6.2 NG/L --- PERFLUORODECANOIC ACID (PFDA)08-25-2022 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)06-23-2022 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)03-08-2022 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)12-08-2021 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)09-24-2021 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)06-24-2021 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)03-08-2021 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)11-09-2020 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)03-12-2020 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)11-18-2019 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)09-30-2019 ND NG/L --- PERFLUORODECANOIC ACID (PFDA)06-03-2019 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)08-25-2022 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)06-23-2022 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)03-08-2022 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)12-08-2021 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)09-24-2021 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)06-24-2021 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)03-08-2021 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)11-09-2020 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)03-12-2020 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)11-18-2019 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)09-30-2019 ND NG/L --- PERFLUORODODECANOIC ACID (PFDOA)06-03-2019 ND NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)08-25-2022 4 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)06-23-2022 4.3 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)03-08-2022 5.9 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)12-08-2021 6.7 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)09-24-2021 4.6 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)06-24-2021 5.2 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)03-08-2021 4.4 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)11-09-2020 5.1 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)03-12-2020 8.4 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)11-18-2019 5.7 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)09-30-2019 4 NG/L --- PERFLUOROHEXANOIC ACID (PFHXA)06-03-2019 3.6 NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)08-25-2022 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)06-23-2022 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)03-08-2022 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)12-08-2021 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)09-24-2021 ND NG/L --- 7 of 13 Weber, Hayes Associates ATTACHMENT C Page 229 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) PERFLUOROTETRADECANOIC ACID (PFTA)06-24-2021 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)03-08-2021 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)11-09-2020 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)03-12-2020 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)11-18-2019 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)09-30-2019 ND NG/L --- PERFLUOROTETRADECANOIC ACID (PFTA)06-03-2019 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)08-25-2022 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)06-23-2022 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)03-08-2022 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)12-08-2021 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)09-24-2021 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)06-24-2021 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)03-08-2021 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)11-09-2020 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)03-12-2020 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)11-18-2019 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)09-30-2019 ND NG/L --- PERFLUOROTRIDECANOIC ACID (PFTRDA)06-03-2019 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)08-25-2022 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)06-23-2022 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)03-08-2022 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)12-08-2021 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)09-24-2021 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)06-24-2021 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)03-08-2021 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)11-09-2020 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)03-12-2020 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)11-18-2019 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)09-30-2019 ND NG/L --- PERFLUOROUNDECANOIC ACID (PFUNA)06-03-2019 ND NG/L --- 11CL-PF3OUDS 08-25-2022 ND NG/L --- 11CL-PF3OUDS 06-23-2022 ND NG/L --- 11CL-PF3OUDS 03-08-2022 ND NG/L --- 11CL-PF3OUDS 12-08-2021 ND NG/L --- 11CL-PF3OUDS 09-24-2021 ND NG/L --- 11CL-PF3OUDS 06-24-2021 ND NG/L --- 11CL-PF3OUDS 03-08-2021 ND NG/L --- 11CL-PF3OUDS 11-09-2020 ND NG/L --- 11CL-PF3OUDS 03-12-2020 ND NG/L --- 11CL-PF3OUDS 11-18-2019 ND NG/L --- 11CL-PF3OUDS 09-30-2019 ND NG/L --- 11CL-PF3OUDS 06-03-2019 ND NG/L --- 9CL-PF3ONS 08-25-2022 ND NG/L --- 9CL-PF3ONS 06-23-2022 ND NG/L --- 8 of 13 Weber, Hayes Associates ATTACHMENT C Page 230 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) 9CL-PF3ONS 03-08-2022 ND NG/L --- 9CL-PF3ONS 12-08-2021 ND NG/L --- 9CL-PF3ONS 09-24-2021 ND NG/L --- 9CL-PF3ONS 06-24-2021 ND NG/L --- 9CL-PF3ONS 03-08-2021 ND NG/L --- 9CL-PF3ONS 11-09-2020 ND NG/L --- 9CL-PF3ONS 03-12-2020 ND NG/L --- 9CL-PF3ONS 11-18-2019 ND NG/L --- 9CL-PF3ONS 09-30-2019 ND NG/L --- 9CL-PF3ONS 06-03-2019 ND NG/L --- ADONA 08-25-2022 ND NG/L --- ADONA 06-23-2022 ND NG/L --- ADONA 03-08-2022 ND NG/L --- ADONA 12-08-2021 ND NG/L --- ADONA 09-24-2021 ND NG/L --- ADONA 06-24-2021 ND NG/L --- ADONA 03-08-2021 ND NG/L --- ADONA 11-09-2020 ND NG/L --- ADONA 03-12-2020 ND NG/L --- ADONA 11-18-2019 ND NG/L --- ADONA 09-30-2019 ND NG/L --- ADONA 06-03-2019 ND NG/L --- HFPO-DA 08-25-2022 ND NG/L --- HFPO-DA 06-23-2022 ND NG/L --- HFPO-DA 03-08-2022 ND NG/L --- HFPO-DA 12-08-2021 ND NG/L --- HFPO-DA 09-24-2021 ND NG/L --- HFPO-DA 06-24-2021 ND NG/L --- HFPO-DA 03-08-2021 ND NG/L --- HFPO-DA 11-09-2020 ND NG/L --- HFPO-DA 03-12-2020 ND NG/L --- HFPO-DA 11-18-2019 ND NG/L --- HFPO-DA 09-30-2019 ND NG/L --- HFPO-DA 06-03-2019 ND NG/L --- NETFOSAA 08-25-2022 ND NG/L --- NETFOSAA 06-23-2022 ND NG/L --- NETFOSAA 03-08-2022 ND NG/L --- NETFOSAA 12-08-2021 ND NG/L --- NETFOSAA 09-24-2021 ND NG/L --- NETFOSAA 06-24-2021 ND NG/L --- NETFOSAA 03-08-2021 ND NG/L --- NETFOSAA 11-09-2020 ND NG/L --- NETFOSAA 03-12-2020 ND NG/L --- NETFOSAA 11-18-2019 ND NG/L --- NETFOSAA 09-30-2019 ND NG/L --- 9 of 13 Weber, Hayes Associates ATTACHMENT C Page 231 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) NETFOSAA 06-03-2019 ND NG/L --- NMEFOSAA 08-25-2022 ND NG/L --- NMEFOSAA 06-23-2022 ND NG/L --- NMEFOSAA 03-08-2022 ND NG/L --- NMEFOSAA 12-08-2021 ND NG/L --- NMEFOSAA 09-24-2021 ND NG/L --- NMEFOSAA 06-24-2021 ND NG/L --- NMEFOSAA 03-08-2021 ND NG/L --- NMEFOSAA 11-09-2020 ND NG/L --- NMEFOSAA 03-12-2020 ND NG/L --- NMEFOSAA 11-18-2019 ND NG/L --- NMEFOSAA 09-30-2019 ND NG/L --- NMEFOSAA 06-03-2019 ND NG/L --- TRICHLOROTRIFLUOROETHANE 05-12-2021 ND UG/L 1200 TRICHLOROTRIFLUOROETHANE 06-29-2017 ND UG/L 1200 TRICHLOROTRIFLUOROETHANE 12-10-2012 ND UG/L 1200 FOAMING AGENTS (SURFACTANTS)05-03-2021 ND MG/L .5 FOAMING AGENTS (SURFACTANTS)06-29-2017 ND MG/L .5 1,2-DIBROMO-3-CHLOROPROPANE 04-12-2002 ND UG/L .2 CHLOROFORM 05-12-2021 4.3 UG/L --- CHLOROFORM 06-29-2017 6.3 UG/L --- CHLOROFORM 12-10-2012 6.3 UG/L 80 BROMOFORM 05-12-2021 ND UG/L --- BROMOFORM 06-29-2017 ND UG/L --- BROMOFORM 12-10-2012 4.6 UG/L 80 BROMODICHLOROMETHANE 05-12-2021 ND UG/L --- BROMODICHLOROMETHANE 06-29-2017 ND UG/L --- BROMODICHLOROMETHANE 12-10-2012 ND UG/L 80 DIBROMOCHLOROMETHANE 05-12-2021 ND UG/L --- DIBROMOCHLOROMETHANE 06-29-2017 ND UG/L --- DIBROMOCHLOROMETHANE 12-10-2012 ND UG/L 80 ETHYLENE DIBROMIDE 04-12-2002 ND UG/L .05 TTHM 05-12-2021 4.3 UG/L 80 TTHM 06-29-2017 6.3 UG/L 80 TTHM 12-10-2012 12 UG/L 80 XYLENES, TOTAL 05-12-2021 ND UG/L 1750 XYLENES, TOTAL 06-29-2017 ND UG/L 1750 XYLENES, TOTAL 12-10-2012 ND UG/L 1750 XYLENE, META AND PARA 05-12-2021 ND UG/L --- XYLENE, META AND PARA 06-29-2017 ND UG/L --- XYLENE, META AND PARA 12-10-2012 ND UG/L 1750 DICHLOROMETHANE 05-12-2021 ND UG/L 5 DICHLOROMETHANE 06-29-2017 ND UG/L 5 DICHLOROMETHANE 12-10-2012 ND UG/L 5 O-CHLOROTOLUENE 05-12-2021 ND UG/L --- 10 of 13 Weber, Hayes Associates ATTACHMENT C Page 232 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) O-CHLOROTOLUENE 06-29-2017 ND UG/L --- O-CHLOROTOLUENE 12-10-2012 ND UG/L --- P-CHLOROTOLUENE 05-12-2021 ND UG/L --- P-CHLOROTOLUENE 06-29-2017 ND UG/L --- P-CHLOROTOLUENE 12-10-2012 ND UG/L --- M-DICHLOROBENZENE 05-12-2021 ND UG/L --- M-DICHLOROBENZENE 06-29-2017 ND UG/L --- M-DICHLOROBENZENE 12-10-2012 ND UG/L --- O-DICHLOROBENZENE 05-12-2021 ND UG/L 600 O-DICHLOROBENZENE 06-29-2017 ND UG/L 600 O-DICHLOROBENZENE 12-10-2012 ND UG/L 600 P-DICHLOROBENZENE 05-12-2021 ND UG/L 5 P-DICHLOROBENZENE 06-29-2017 ND UG/L 5 P-DICHLOROBENZENE 12-10-2012 ND UG/L 5 VINYL CHLORIDE 05-12-2021 ND UG/L .5 VINYL CHLORIDE 06-29-2017 ND UG/L .5 VINYL CHLORIDE 12-10-2012 ND UG/L .5 1,1-DICHLOROETHYLENE 05-12-2021 2.2 UG/L 6 1,1-DICHLOROETHYLENE 06-29-2017 1.2 UG/L 6 1,1-DICHLOROETHYLENE 12-10-2012 ND UG/L 6 1,1-DICHLOROETHANE 05-12-2021 ND UG/L 5 1,1-DICHLOROETHANE 06-29-2017 ND UG/L 5 1,1-DICHLOROETHANE 12-10-2012 ND UG/L 5 TRANS-1,2-DICHLOROETHYLENE 05-12-2021 ND UG/L 10 TRANS-1,2-DICHLOROETHYLENE 06-29-2017 ND UG/L 10 TRANS-1,2-DICHLOROETHYLENE 12-10-2012 ND UG/L 10 1,2-DICHLOROETHANE 05-12-2021 ND UG/L .5 1,2-DICHLOROETHANE 06-29-2017 ND UG/L .5 1,2-DICHLOROETHANE 12-10-2012 ND UG/L .5 1,1,1-TRICHLOROETHANE 05-12-2021 ND UG/L 200 1,1,1-TRICHLOROETHANE 06-29-2017 ND UG/L 200 1,1,1-TRICHLOROETHANE 12-10-2012 ND UG/L 200 CARBON TETRACHLORIDE 05-12-2021 ND UG/L .5 CARBON TETRACHLORIDE 06-29-2017 ND UG/L .5 CARBON TETRACHLORIDE 12-10-2012 ND UG/L .5 1,2-DICHLOROPROPANE 05-12-2021 ND UG/L 5 1,2-DICHLOROPROPANE 06-29-2017 ND UG/L 5 1,2-DICHLOROPROPANE 12-10-2012 ND UG/L 5 TRICHLOROETHYLENE 05-12-2021 ND UG/L 5 TRICHLOROETHYLENE 06-29-2017 ND UG/L 5 TRICHLOROETHYLENE 12-10-2012 ND UG/L 5 1,1,2-TRICHLOROETHANE 05-12-2021 ND UG/L 5 1,1,2-TRICHLOROETHANE 06-29-2017 ND UG/L 5 1,1,2-TRICHLOROETHANE 12-10-2012 ND UG/L 5 1,1,1,2-TETRACHLOROETHANE 05-12-2021 ND UG/L --- 11 of 13 Weber, Hayes Associates ATTACHMENT C Page 233 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) 1,1,1,2-TETRACHLOROETHANE 06-29-2017 ND UG/L --- 1,1,1,2-TETRACHLOROETHANE 12-10-2012 ND UG/L --- TETRACHLOROETHYLENE 05-12-2021 4.7 UG/L 5 TETRACHLOROETHYLENE 06-29-2017 2.7 UG/L 5 TETRACHLOROETHYLENE 12-10-2012 3.5 UG/L 5 1,1,2,2-TETRACHLOROETHANE 05-12-2021 ND UG/L 1 1,1,2,2-TETRACHLOROETHANE 06-29-2017 ND UG/L 1 1,1,2,2-TETRACHLOROETHANE 12-10-2012 ND UG/L 1 CHLOROBENZENE 05-12-2021 ND UG/L 70 CHLOROBENZENE 06-29-2017 ND UG/L 70 CHLOROBENZENE 12-10-2012 ND UG/L 70 BENZENE 05-12-2021 ND UG/L 1 BENZENE 06-29-2017 ND UG/L 1 BENZENE 12-10-2012 ND UG/L 1 TOLUENE 05-12-2021 ND UG/L 150 TOLUENE 06-29-2017 ND UG/L 150 TOLUENE 12-10-2012 ND UG/L 150 ETHYLBENZENE 05-12-2021 ND UG/L 300 ETHYLBENZENE 06-29-2017 ND UG/L 300 ETHYLBENZENE 12-10-2012 ND UG/L 300 BROMOBENZENE 05-12-2021 ND UG/L --- BROMOBENZENE 06-29-2017 ND UG/L --- BROMOBENZENE 12-10-2012 ND UG/L --- ISOPROPYLBENZENE 05-12-2021 ND UG/L --- ISOPROPYLBENZENE 05-12-2021 ND UG/L --- ISOPROPYLBENZENE 06-29-2017 ND UG/L --- ISOPROPYLBENZENE 06-29-2017 ND UG/L --- ISOPROPYLBENZENE 12-10-2012 ND UG/L --- ISOPROPYLBENZENE 12-10-2012 ND UG/L --- STYRENE 05-12-2021 ND UG/L 100 STYRENE 06-29-2017 ND UG/L 100 STYRENE 12-10-2012 ND UG/L 100 O-XYLENE 05-12-2021 ND UG/L --- O-XYLENE 06-29-2017 ND UG/L --- O-XYLENE 12-10-2012 ND UG/L 1750 N-PROPYLBENZENE 05-12-2021 ND UG/L --- N-PROPYLBENZENE 06-29-2017 ND UG/L --- N-PROPYLBENZENE 12-10-2012 ND UG/L --- RADIUM-226 06-29-2017 1.28 PCI/L --- RADIUM-228 06-29-2017 1.84 PCI/L --- GROSS ALPHA PARTICLE ACTIVITY 06-29-2017 4.03 PCI/L 15 TERTIARY BUTYL ALCOHOL (TBA)05-12-2021 ND UG/L --- TERTIARY BUTYL ALCOHOL (TBA)06-29-2017 ND UG/L --- TERTIARY BUTYL ALCOHOL (TBA)12-10-2012 ND UG/L --- ETHYL-TERT-BUTYL ETHER 05-12-2021 ND UG/L --- 12 of 13 Weber, Hayes Associates ATTACHMENT C Page 234 of 747 Higuera Apartments Technical Memorandum Analyte Sample Date Result Unit MCL Table 1 - Water Quality Data (Well-1) ETHYL-TERT-BUTYL ETHER 06-29-2017 ND UG/L --- ETHYL-TERT-BUTYL ETHER 12-10-2012 ND UG/L --- TERT-AMYL-METHYL ETHER 05-12-2021 ND UG/L --- TERT-AMYL-METHYL ETHER 06-29-2017 ND UG/L --- TERT-AMYL-METHYL ETHER 12-10-2012 ND UG/L --- NITRATE (AS NO3)12-10-2012 54 MG/L 45 DISTRIBUTION SYSTEM SAMPLE RESULTS LEAD 5/27/20 0.0025 MG/L --- LEAD 11/10/20 ND MG/L --- LEAD 6/21/21 0.011 MG/L --- COPPER 5/27/20 ND MG/L --- COPPER 11/10/20 ND MG/L --- COPPER 6/21/21 ND MG/L --- Notes: MCL = Maximum Contminant Level MG/L = milligrams per Liter NG/L = nanogram per Liter PCI/L = picocuries per Liter UG/L = micrograms per Liter TON = threshold odor number NTU = Nephehelometric Turbidity Units *Analytical data obtained from CA Drinking Water Watch @ https://sdwis.waterboards.ca.gov Result exceeds the MCL 5 Sample 90th precentile, 1 sample exceeds Action Level 13 of 13 Weber, Hayes Associates ATTACHMENT C Page 235 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Soft (Non-Construction) CostsSLO - Water Development Impact Fee for multi-family connections (≤ 450 sqft)15,17322 EA 113,804SLO - Water Development Impact Fee for multi-family connections (451-800 sqft)112,0002EA24,000SLO - Water Development Impact Fee for single family connection (801-1,200 sqft)113,7141EA13,714SLO - Water Development Impact Fee for 3/4-inch irrigation meter17,2431EA17,243SLO Engineering Fee - Improvement Plan Check, based on total project (non-construction and construction) costs18,828 1 LS18,828SLO Engineering Fee - Construction Inspection, based on total project (non-construction and construction) costs32,917 1 LS32,917SLO Engineering Fee - Trenched Water Service2,8881LS2,888SLO Engineering Fee - Encroachment Permit6,0001LS6,000SLO Engineering Fee - Traffic Control Plan Review and Inspection (minor)2,3441LS2,344SLO Utilities Fee - Meter Services1,7591LS1,759Permitting/City Fees | Subtotal---- --233,495Environmental Preconstruction Surveys (if necessary, split with wastewater cost)7,500 0.5 LS3,750Admin Costs - Coordination, bid documents, contractor selection20,0001LS20,000SLO Annexation Steps and Fees (less Pre-application review, annexation and rezone fees; split with wastewater cost)90,0000.5 LS45,000LAFCO Costs (completed in design phase; split with wastewater cost)7,5000.5 LS3,750Potholing for Contamination Delineation (if necessary, split with wastewater cost)15,0000.5 LS7,500Soft (Non-Construction) Costs | Subtotal------ ---313,495Table 2Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 1, Connect to Existing Distribution)Page 1 of 3Weber Hayes AssociatesATTACHMENT CPage 236 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Table 2Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 1, Connect to Existing Distribution)Construction Cost for Connection to City Water SystemEngineering oversight during consolidation related construction1,50025Days37,500Contractor mobilization / demobilization10,0001LS10,000Connect the 2-inch water service line (multi-family domestic) to the 12-inch water main (N end of site) 5,000 1 EA 5,000Connect the 1-inch water service line (single-family domestic) to the 12-inch water main (S end of site) 5,000 1 EA 5,000Connect the 1-inch water service line (irrigation) to the 12-inch water main (N end of site)5,0001EA5,000Precast water meter Armorcast box for the 2-inch (MF domestic) distribution line (City of SLO Standard Detail 6210)2,500 1 EA2,500Precast water meter Armorcast box for the 3/4-inch (SF domestic & irrigation) distribution line (City of SLO Standard Detail 6210)1,500 2 EA3,000Febco/Wilkins Backflow Prevention Assembly for 1-inch irrigation distribution line (City of SLO Standard Detail 8560)4,000 1 EA4,000Distribution system water line (SF domestic); 1-inch PVC & Trenching / Backfill (with locating wire) - includes the off-haul of excavated soil70100FT7,000Connect the 1-inch irrigation connection to the existing 1-1/2-inch irrigation line 7025 FT1,750Traffic Control along Higuera Street during construction activities associated with the distribution system installation. 15,0001LS15,000Destroy existing well and abandon associated distribution line15,0001LS15,000Construction Cost for Connection to City Water System | Subtotal------ --- 110,750Frontage Improvements (minor improvements - accessible path)35,000 0.5 LS 17,500Total Consolidation Costs - Existing Distribution | Total------ ---441,745Page 2 of 3Weber Hayes AssociatesATTACHMENT CPage 237 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Table 2Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 1, Connect to Existing Distribution)"20-year" Operations & Maintenance Cost (including: (1) maintaining water system piping and appurtenances downstream of the SLO water meter; (2) annual testing of backflow prevention assembly100240 Months 24,000"20-Year" water usage bills from SLO; based on average daily domestic demand of 1,8242 gpd & $0.0105 per gallon, and average daily irrigation demand of 360 gpd & $0.0157 per gallon (estimated avg cost per residential unit per month is $57)989240 Months 237,431"20-year" Capital Expenditures (expect pipe & appurtenances to last 20+ years) 020 Years0Subtotal of Operations & Maintenance and Capital Expenditure (20-years)------ ---261,431Project Lifecycle (20-years) | Existing Distribution Piping703,175Notes:SLO -City of San Luis Obispo1 = Size and number of dwelling units is based on information provided by property owner. Fees are based on SLO Comprehensive Fee Schedule, Fiscal Year 2022-2023gpd = gallons per daySF = Single-FamilyMF = Multi-Family2 = gallons per day estimate is based on the 2014-2022 average City of SLO residential water usage of 57 gallons per person per day and using the current population of 32Page 3 of 3Weber Hayes AssociatesATTACHMENT CPage 238 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Soft (Non-Construction) CostsSLO - Water Development Impact Fee for multi-family connections (≤ 450 sqft)15,17322 EA 113,804SLO - Water Development Impact Fee for multi-family connections (451-800 sqft)112,0002EA24,000SLO - Water Development Impact Fee for single family connection (801-1,200 sqft)113,7141EA13,714SLO - Water Development Impact Fee for 3/4-inch irrigation meter17,2431EA17,243SLO Engineering Fee - Improvement Plan Check, based on total project (non-construction and construction) costs19,701 1 LS19,701SLO Engineering Fee - Construction Inspection, based on total project (non-construction and construction) costs37,512 1 LS37,512SLO Engineering Fee - Trenched Water Service2,8881LS2,888SLO Engineering Fee - Encroachment Permit6,0001LS6,000SLO Engineering Fee - Traffic Control Plan Review and Inspection (minor)2,3441LS2,344SLO Utilities Fee - Meter Services3,6581LS3,658Permitting/City Fees | Subtotal---- --240,863Environmental Preconstruction Surveys (if necessary, split with wastewater cost)7,500 0.5 LS3,750Admin Costs - Coordination, bid documents, contractor selection20,0001LS20,000SLO Annexation Steps and Fees (less Pre-application review, annexation and rezone fees; split with wastewater cost)90,0000.5 LS45,000LAFCO Costs (completed in design phase; split with wastewater cost)7,5000.5 LS3,750Potholing for Contamination Delineation (if necessary, split with wastewater cost)15,0000.5 LS7,500Soft (Non-Construction) Costs | Subtotal------ ---320,863Table 3Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 2, Replace Existing Distribution)Page 1 of 3Weber Hayes AssociatesATTACHMENT CPage 239 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Table 3Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 2, Replace Existing Distribution)Construction Cost for Connection to City Water SystemEngineering oversight during consolidation related construction1,50025Days37,500Contractor mobilization / demobilization10,0001LS10,000Connect the 2-inch water service line (multi-family domestic) to the 12-inch water main (N end of site) 5,000 1 EA 5,000Connect the 1-inch water service line (single-family domestic) to the 12-inch water main (S end of site) 5,000 1 EA 5,000Connect the 1-inch water service line (irrigation) to the 12-inch water main (N end of site)5,0001EA5,000Precast water meter Armorcast box for the 2-inch (MF domestic) distribution line (City of SLO Standard Detail 6210)2,500 1 EA2,500Precast water meter Armorcast box for the 3/4-inch (SF domestic & irrigation) distribution line (City of SLO Standard Detail 6210)1,500 2 EA3,000Febco/Wilkins Backflow Prevention Assembly for 1-inch irrigation distribution line (City of SLO Standard Detail 8560)4,000 1 EA4,000Distribution system water line (SF domestic); 1-inch PVC & Trenching / Backfill (with locating wire) - includes the off-haul of excavated soil70100FT7,000Connect the 1-inch irrigation connection to the existing 1-1/2-inch irrigation line 7025 FT1,750Traffic Control along Higuera Street during construction activities associated with the distribution system installation. 15,0001LS15,000Destroy existing well and abandon associated distribution line15,0001LS15,000Construction Cost for Connection to City Water System | Subtotal------ --- 110,750New MF Distribution PipingDistribution system water line (MF domestic); 2-1/2-inch PVC & Trenching / Backfill (with locating wire) - includes the off-haul of excavated soil75550FT41,250Branch connections from the 2-1/2-inch (MF domestic) distribution line to serve each dwelling unit75025 LS18,750New MF Distribution Piping | Subtotal------ --- 60,000Frontage Improvements (minor improvements - accessible path / trim vegetation)35,000 0.5 LS 17,500Total Consolidation Costs - Replace Distribution | Total------ ---509,113Page 2 of 3Weber Hayes AssociatesATTACHMENT CPage 240 of 747 Higuera ApartmentsTechnical MemorandumCONSOLIDATION - ITEMCost per unit# Units UnitCOST ($)Table 3Engineer's Opinion of Probable Costs for Consolidation (Alternative #2 - Option 2, Replace Existing Distribution)"20-year" Operations & Maintenance Cost (including: (1) maintaining water system piping and appurtenances downstream of the SLO water meter; (2) annual testing of backflow prevention assembly50240 Months 12,000"20-Year" water usage bills from SLO; based on average daily domestic demand of 1,8242 gpd & $0.0105 per gallon, and average daily irrigation demand of 360 gpd & $0.0157 per gallon (estimated avg cost per residential unit per month is $57)989240 Months 237,431"20-year" Capital Expenditures (expect pipe & appurtenances to last 20+ years) 020 Years0Subtotal of Operations & Maintenance and Capital Expenditure (20-years)------ ---249,431Project Lifecycle (20-years) | Replace Distribution Piping758,543Notes:SLO -City of San Luis Obispo1 = Size and number of dwelling units is based on information provided by property owner. Fees are based on SLO Comprehensive Fee Schedule, Fiscal Year 2022-2023gpd = gallons per daySF = Single-FamilyMF = Multi-Family2 = gallons per day estimate is based on the 2014-2022 average City of SLO residential water usage of 57 gallons per person per day and using the current population of 32Page 3 of 3Weber Hayes AssociatesATTACHMENT CPage 241 of 747 Higuera Apartments Technical Memorandum Consideration Alternative #1 No-Action Alternative #2 - Option 2 Consolidation with City of San Luis Obispo (SLO) Meets Regulatory Compliance No Yes Meets O&M Needs No Yes Financially Viable N/A Most likely Long Term Sustainability No Most likely Environmental Concerns No Minor; land disturbance installing new water main, distribution lines, and appurtenances. Potential hydrocarbon contamination concerns Satisfy Public Concerns No Most likely Water Rates N/A Yes, SLO water rates Other considerations Does not resolve the elevated nitrate MCL violation City of SLO provides acceptable water quality. This is the most sustainable, long term solution for Higuera Total Lifecycle Cost (20-years)N/A 758,543 Notes N/A = Not Applicable Table 4 Alternative Comparison Summary 1 of 1 Weber, Hayes and Associates ATTACHMENT C Page 242 of 747 Technical Memorandum Higuera Street Apartments Weber, Hayes & Associates APPENDIX A County of San Luis Obispo Health Agency Compliance Order No. 04_70_21R_001 ATTACHMENT C Page 243 of 747 COUNTY OF SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT Michael Hill Health Agency Director Penny Borenstein, MD, MPH Health Officer/Public Health Director Environmental Health Services 2156 Sierra Way, Suite B | San Luis Obispo, CA 93401 | (P) 805-781-5544 | (F) 805-781-4211 www.slopublichealth.org/ehs January 15, 2021 System No. 4000563 Ronald Schriner Higuera Apartments 1749 San Luis Drive San Luis Obispo, CA 93401 COMPLIANCE ORDER NO. 04_70_21R_001 NITRATE MAXIMUM CONTAMINANT LEVEL VIOLATION FOR THE 2017 CALENDAR YEAR Enclosed is Compliance Order No. 04_70_21R_001 (hereinafter “Order”), issued to Higuera Apartments (hereinafter “System”) public water system. Please note that there are legally enforceable deadlines associated with this Order. Higuera Apartments will be billed at the County of San Luis Obispo Health Agency Public Health Department Environmental Health Services (hereinafter “SLOEHS”) hourly rate for the time spent on issuing this Order. California Health and Safety Code (hereinafter “CHSC”) Section 116577 provides that a public water system must reimburse the SLOEHS for actual costs incurred by the SLOEHS for specified enforcement actions, including preparing, issuing, and monitoring compliance with an order. At this time, the SLOEHS has spent approximately 0.5 hours on enforcement activities associated with this violation. The System will receive a bill sent from the SLOEHS in August of the next fiscal year. This bill will contain fees for any enforcement time spent on the Higuera Apartments for the current fiscal year. Any person who is aggrieved by a citation, order or decision issued under authority delegated to an officer or employee of the SLOEHS under Article 8 (commencing with CHSC, Section 116625) or Article 9 (commencing with CHSC, Section 116650), of the Safe Drinking Water Act (CHSC, Division 104, Part 12, Chapter 4), may file a petition with the State Water Board for reconsideration of the citation, order or decision. Petitions must be received by the State Water Board within 30 days of the issuance of the citation, order or decision by the officer or employee of the State Water Board. The date of issuance is the date when the SLOEHS mails a copy of the citation, order or decision. If the 30th day falls on a Saturday, Sunday, or state holiday, the petition is due the following business day by 5:00 p.m. ATTACHMENT C Page 244 of 747 Compliance Order No. 04_70_21R_001 2 Information regarding filing petitions may be found at: http://www.waterboards.ca.gov/drinking_water/programs/petitions/index.shtml If you have any questions regarding this matter, please contact me at (805) 781-5553. Sincerely, Leslie Terry Supervising Environmental Health Specialist County of San Luis Obispo Health Agency Public Health Department Environmental Health Services 2156 Sierra Way, Suite B San Luis Obispo, CA 93401 Mail: PO Box 1489 San Luis Obispo, CA 93406 Enclosures Certified Mail No. 0926 5269 1000 0600 0207 cc: Jeff Densmore, District Engineer Santa Barbara District Division of Drinking Water State Water Resources Control Board ATTACHMENT C Page 245 of 747 COUNTY OF SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT Michael Hill Health Agency Director Penny Borenstein, MD, MPH Health Officer/Public Health Director Compliance Order No. 04_70_21R_001 1 2 County of San Luis Obispo Health Agency 3 Department of Public Health 4 Environmental Health Services 5 6 Name of Public Water System: Higuera Apartments 7 Water System No: 4000563 8 9 Attention: Ronald Schriner 10 1749 San Luis Drive 11 San Luis Obispo, CA 93401 12 13 Issued: January 15, 2020 14 15 COMPLIANCE ORDER FOR NONCOMPLIANCE 16 CALIFORNIA HEALTH AND SAFETY CODE, SECTION 116555, 17 CALIFORNIA CODE OF REGULATIONS, TITLE 22, SECTION 64431 18 19 NITRATE MAXIMUM CONTAMINANT LEVEL VIOLATION 20 FOR THE 2017 CALENDER YEAR 21 22 The California Health and Safety Code (hereinafter “CHSC”), Section 116655 authorizes 23 the County of San Luis Obispo Health Agency Public Health Department Environmental 24 ATTACHMENT C Page 246 of 747 Compliance Order No. 04_70_21R_001 2 Health Services (hereinafter “SLOEHS”), to issue a Compliance Order to a public water 1 system when the SLOEHS determines that the public water system has violated or is 2 violating the California Safe Drinking Water Act (hereinafter “California SDWA”), (CHSC, 3 Division 104, Part 12, Chapter 4, commencing with Section 116270), or any regulation, 4 standard, permit, or order issued or adopted thereunder. 5 6 The SLOEHS, acting by and through its primacy delegation from the State Water 7 Resources Control Board, hereby issues Compliance Order No. 04_70_21R_001 8 (hereinafter “Order”), pursuant to Section 116655 of the CHSC to Higuera Apartments 9 (hereinafter “System”), for violation of CHSC, Section 116555(a)(1) and the California 10 Code of Regulations (hereinafter “CCR”), Title 22, Section 64431. 11 12 STATEMENT OF FACTS 13 The CHSC, Section 116555(a)(1) and the CCR, Section 64431 requires all public water 14 systems to comply with primary drinking water standards. Primary drinking water 15 standards include maximum levels of contaminants and the monitoring and reporting 16 requirements as specified in regulation adopted by the State Water Board that pertain to 17 contaminant levels. 18 19 The SLOEHS has received water quality laboratory results for Well No. 1 that have 20 elevated levels of nitrate. The nitrate maximum contaminant level (hereinafter “MCL”) is 21 10 milligrams per liter (hereinafter “mg/L”) as nitrogen, as stated in the CCR, Section 22 64431. A summary of the System’s nitrate monitoring results is presented in Table 1 23 below. 24 Table 1. Well No. 1 Results Nitrate Results 25 26 Sample Date Result (mg/L) 6/29/2017 13 4/22/2019 6.1 ATTACHMENT C Page 247 of 747 Compliance Order No. 04_70_21R_001 3 1 2 3 DETERMINATION 4 The SLOEHS has determined that System has failed to comply with primary drinking water 5 standards pursuant to the CHSC, Section 116555(a)(1) and CCR, Title 22, Section 64431 6 in that the has exceeded the nitrate MCL. 7 8 DIRECTIVES 9 The System is hereby directed to take the following actions: 10 1. By September 1, 2023, comply with CHSC, Section 116555(a)(1) and CCR, Title 11 22, Section 64431. 12 13 2. By January 31, 2021, notify all persons served by the System of the violation of 14 CCR, Title 22, Section 64432.1(a) and Section 64469(a) and (c), in conformance 15 with 64 Sections 64463.4(b) and (c), and 64465. Public notification to the persons 16 served by the System must continue every 3 months until the SLOEHS determines 17 that the nitrate MCL violation is resolved. Appendix 1: Notification Template must 18 be used to fulfill this directive, unless otherwise approved by the SLOEHS. The 19 contents of the public notice must be approved by the SLOEHS prior to issuance. 20 The System must edit the wording of the public notice as necessary. The 21 public notice must be completed in accordance with the following: 22 23 x By mail or direct delivery of the public notice to each customer served by the 24 water system and; 25 26 x By one of the following secondary methods to reach persons not likely to be 27 reached by mail or direct delivery; 28 ATTACHMENT C Page 248 of 747 Compliance Order No. 04_70_21R_001 4 1 2 ¾ By publication in a local newspaper, by delivery to community organizations 3 or by posting in conspicuous public places served by the water system or 4 on the internet. If the water system opts to issue the notice via internet 5 website, the public notice must remain posted for a minimum of seven (7) 6 consecutive days. 7 8 The System must determine which option will be used to conduct the secondary 9 distribution of the notice and notify the SLOEHS of their decision no later than 10 January 31, 2021. 11 12 3. By February 29, 2021, complete Appendix 2: Certification of Completion of Public 13 Notification Form. Submit it together with a copy of the public notice required by 14 Directive 2 to the SLOEHS within 10 days following each public notification. 15 16 4. Prepare for SLOEHS approval, a Corrective Action Plan, identifying improvements 17 to the water system designed to correct the water quality problems identified and 18 ensure that the System delivers water to consumers that meets drinking water 19 standards. The plan must include a time schedule for completion of each of the 20 phases of the project such as design, construction, and startup, and a date that 21 shows when the System will be in compliance. The date must be no later than 22 September 1, 2023. 23 24 5. By February 28, 2021, submit and present the Corrective Action Plan required 25 under Directive No. 4 above, to the SLOEHS office located at 2156 Sierra Way, 26 Unit B, San Luis Obispo, CA 93401 or mailed to PO Box 1489, San Luis Obispo, 27 CA 93406. 28 ATTACHMENT C Page 249 of 747 Compliance Order No. 04_70_21R_001 5 1 6. Perform the actions outlined in the SLOEHS approved Corrective Action Plan, and 2 each and every element of said plan, according to the time schedule set forth 3 therein. 4 5 7. By March 31, 2021, and every three months thereafter, submit a report to the 6 SLOEHS in the form provided as Appendix 3, showing actions taken during the 7 previous quarter (calendar three months) to comply with the Corrective Action 8 Plan. 9 10 8. By January 31, 2021 complete and return to the SLOEHS the “Notification of 11 Receipt” form attached to this Order as Appendix 4. Completion of this fo rm 12 confirms that the System has received this Order and understands that it contains 13 legally enforceable directives(s) with due dates. 14 15 All submittals required by this Order, unless otherwise specified in the directives above, 16 must be electronically submitted to the SLOEHS at the following address. The subject line 17 for all electronic submittals corresponding to this Order must include the following 18 information: Water System name and number, compliance order number, and title of the 19 document being submitted. 20 Leslie Terry 21 lterry@co.slo.ca.us 22 The SLOEHS reserves the right to make modifications to this Order as it may deem 23 necessary to protect public health and safety. Such modifications may be issued as 24 amendments to this Order and shall be effective upon issuance. 25 26 ATTACHMENT C Page 250 of 747 Compliance Order No. 04_70_21R_001 6 Nothing in this Order relieves the System of its obligation to meet the requirements of the 1 California SDWA (CHSC, Division 104, Part 12, Chapter 4, commencing with Section 2 116270), or any regulation, standard, permit or order issued or adopted thereunder. 3 4 PARTIES BOUND 5 This Order shall apply to and be binding upon the System, its owners, shareholders, 6 officers, directors, agents, employees, contractors, successors, and assignees. 7 8 SEVERABILITY 9 The directives of this Order are severable, and the System shall comply with each and 10 every provision thereof notwithstanding the effectiveness of any provision. 11 12 FURTHER ENFORCEMENT ACTION 13 The California SDWA authorizes the SLOEHS to: issue a citation or order with assessment 14 of administrative penalties to a public water system for violation or continued violation of 15 the requirements of the California SDWA or any regulation, permit, standard, citation, or 16 order issued or adopted thereunder including, but not limited to, failure to correct a 17 violation identified in a citation or compliance order. The California SDWA also authorizes 18 the SLOEHS to take action to suspend or revoke a permit that has been issued to a public 19 water system if the public water system has violated applicable law or regulations or has 20 failed to comply with an order of the SLOEHS and to petition the superior court to take 21 various enforcement measures against a public water system that has failed to comply 22 with an order of the SLOEHS. The SLOEHS does not waive any further enforcement action 23 by issuance of this Order. 24 25 _______________________________ January 15, 2021 _____ 26 Leslie Terry Date 27 County of San Luis Obispo Health Agency 28 ATTACHMENT C Page 251 of 747 Compliance Order No. 04_70_21R_001 7 Public Health Department 1 Environmental Health Services 2 3 4 Appendices (4): 5 6 1. Notification Template 7 2. Certification of Completion of Public Notification 8 3. Quarterly Progress Report Template 9 4. Notification of Receipt Form 10 11 Certified Mail No. 0926 5269 1000 0600 020712 ATTACHMENT C Page 252 of 747 Compliance Order No. 04_70_21R_001 APPENDIX 1. NOTIFICATION TEMPLATE IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER Este informe contiene información muy importante sobre su agua potable. Tradúzcalo o hable con alguien que lo entienda bien. DRINKING WATER WARNING Higuera Apartments water has high levels of nitrate DO NOT GIVE THE WATER TO INFANTS UNDER 6 MONTHS OLD OR PREGNANT WOMEN OR USE IT TO MAKE INFANT FORMULA Water sample results received April 22, 2019 showed nitrate levels of 6.1 milligrams per liter. This is above the nitrate standard, or maximum contaminant level (MCL), of 10 milligrams per liter. Nitrate in drinking water is a serious health concern for infants less than six months old. What should I do? x DO NOT GIVE THE WATER TO INFANTS. Infants below the age of six months who drink water containing nitrate in excess of the MCL may quickly become seriously ill and, if untreated, may die because high nitrate levels can interfere with the capacity of the infant’s blood to carry oxygen. Symptoms include shortness of breath and blueness of the skin. Symptoms in infants can develop rapidly, with health deteriorating over a period of days. If symptoms occur, seek medical attention immediately. x PREGNANT WOMEN SHOULD NOT CONSUME THE WATER. High nitrate levels may also affect the oxygen-carrying ability of the blood of pregnant women. x Water, juice, and formula for children under six months of age should not be prepared with tap water. Bottled water or other water low in nitrates should be used for infants until further notice. x DO NOT BOIL THE WATER. Boiling, freezing, filtering, or letting water stand does not reduce the nitrate level. Excessive boiling can make the nitrates more concentrated because nitrates remain behind when the water evaporates. x If you have other health issues concerning the consumption of this water, you may wish to consult your doctor. What happened? What is being done? Nitrate in drinking water can come from natural, industrial, or agricultural sources (including septic systems, storm water run-off, and fertilizers). Levels of nitrate in drinking ATTACHMENT C Page 253 of 747 Compliance Order No. 04_70_21R_001 water can vary throughout the year. We will let you know if the amount of nitrate is again below the limit. We are working with the State Water Resources Control Board – Division of Drinking Water to evaluate the water supply and researching options to correct the problem. We anticipate resolving the problem within three years. For more information, please contact Leslie Terry at (805) 781-5553 or lterry@co.slo.ca.us. Please share this information with all the other people who drink this water, especially those who may not have received this notice directly (for example, people in apartments, nursing homes, schools, and businesses). You can do this by posting this public notice in a public place or distributing copies by hand or mail . Secondary Notification Requirements Upon receipt of notification from a person operating a public water system, the following notification must be given within 10 days [Health and Safety Code Section 116450(g)]: x SCHOOLS: Must notify school employees, students, and parents (if the students are minors). x RESIDENTIAL RENTAL PROPERTY OWNERS OR MANAGERS (including nursing homes and care facilities): Must notify tenants. x BUSINESS PROPERTY OWNERS, MANAGERS, OR OPERATORS: Must notify employees of businesses located on the property. This notice is being sent to you by Higuera Apartments. State Water System ID#: 4000563 Date distributed: [Insert date the notice is distributed]. ATTACHMENT C Page 254 of 747 Compliance Order No. 04_70_21R_001 INFORMACIÓN IMPORTANTE SOBRE SU AGUA POTABLE Este aviso contiene información muy importante sobre su agua potable. Tradúzcalo o hable con alguien que lo entienda bien. ADVERTENCIA SOBRE EL AGUA POTABLE El agua de Higuera Apartments tiene altos niveles de nitratos NO DE ÉSTA AGUA A BEBÉS MENORES DE 6 MESES O A MUJERES EMBARAZADAS. TAMPOCO USE ÉSTA AGUA PARA PREPAPAR FORMULA INFANTIL Los resultados de las pruebas del agua recibidas el April 22, 2019 mostraron niveles de nitrato de 6.1 milígramos por litro. Estos niveles exceden el estándar o nivel máximo de contaminante (MCL) de 10 milígramos por litro. Los nitratos en el agua potable son una preocupación seria en bebés menores de seis meses. ¿Qué debe hacer? x NO DE ÉSTA AGUA A BEBÉS MENORES DE 6 MESES. Los bebés menores de 6 meses que toman agua con nitrato en exceso del nivel máximo de contaminante (MCL), se pueden enfermar seriamente y rápidamente. Y si los bebés no reciben atención médica, pueden morir debido a que los altos niveles de nitratos pueden interferir con la capacidad de la sangre de los bebés para transportar oxígeno. Los síntomas incluyen falta de aire y coloración azulada de la piel. Los síntomas en los bebés se pueden desarrollar rápidamente y la salud se deteriora en cuestión de días. Si hay síntomas de intoxicación por altos niveles de nitratos, busque atención médica de inmediato. x LAS MUJERES EMBARAZADAS NO DEBEN CONSUMIR AGUA CON ALTOS NIVELES DE NITRATOS. Los altos niveles de nitrato también pueden afectar la capacidad de la sangre de mujeres embarazadas para transportar oxígeno. x No use agua de la llave para preparar jugo, agua, y formula para bebés menores de 6 meses. Use agua embotellada u otra agua baja en nitratos para los bebés menores de 6 meses hasta nuevo aviso. x NO HIERVA EL AGUA. Hervir, congelar, filtrar, o dejar reposar el agua, no reduce el nivel de nitratos. Hervir el agua en exceso puede causar que los nitratos se concentren más, porque los nitratos se quedan cuando el agua se evapora. x Si tiene otros problemas de salud por el consumo de ésta agua, usted debería consultar con su doctor. ATTACHMENT C Page 255 of 747 Compliance Order No. 04_70_21R_001 ¿Qué sucedió? ¿Qué se está haciendo al respecto? El nitrato en el agua potable puede originar de fuentes naturales, industriales, o agriculturales (incluyendo sistemas sépticos, escorrentía de agua de lluvia, y fertilizantes). Los niveles de nitrato en el agua potable pueden variar a través del año. Le informaremos si el nivel de nitratos vuelve a estar debajo del límite. Para más información, por favor contacte a Leslie Terry al (805) 781-5553 o lterry@co.slo.ca.us. Por favor comparta esta información con todas las demás personas que tomen de esta agua, especialmente aquellos que no hayan recibido éste aviso directamente (por ejemplo, las personas en apartamentos, asilos, escuelas, y negocios). Puede hacerlo poniendo este aviso en un lugar público o distribuyendo copias en persona o por correo. Requisitos de Notificación Secundaria Al recibir la notificación de alguien que opere un sistema de agua público, se debe dar la siguiente notificación dentro de 10 días conforme a la Sección 116450(g) del Código de Salud y Seguridad: x ESCUELAS: Deben notificar a los empleados de la escuela, estudiantes, y a los padres (si los estudiantes son menores). x DUEÑOS O GERENTES DE PROPIEDAD PARA ALQUILER RESIDENCIAL (incluyendo asilos e instituciones de cuidado): Deben notificar a sus inquilinos. x DUEÑOS DE PROPIEDAD DE NEGOCIOS, GERENTES, U OPERADORES: Deben notificar a los empleados de los negocios situados en la propiedad. Este aviso es enviado por Higuera Apartments. Núm. de Identificación del Sistema Estatal de Agua: 4000563 Fecha de distribución: [Insert date the notice is distributed]. ATTACHMENT C Page 256 of 747 Compliance Order No. 04_70_21R_001 APPENDIX 2. CERTIFICATION OF COMPLETION OF PUBLIC NOTIFICATION Compliance Order Number: 04_70_21R_001 Name of Water System: Higuera Apartments System Number: 4000563 Attach a copy of the public notice distributed to the water system’s customers. This form, when completed and sent to lterry@co.slo.ca.us for the SLOEHS, certifies that public notification to water users was completed as required by Title 22, California Code of Regulations, Sections 64463-64465. Public notification for failure to comply with the nitrate maximum contaminant level was conducted on: Notification was made on _______________________________________________ (date). For the month, year of _____________________________, ___________. To summarize report delivery used and good-faith efforts taken, please check all items below that apply and fill-in where appropriate: For Community and non-transient non-community public water systems The notice was distributed by mail or direct delivery to each customer on: One or more of the following methods were used to reach persons not likely to be reached by a mailing or direct delivery or persons served by a transient public water system (renters, nursing home patients, prison inmates, etc.): Posted the notice at the following conspicuous locations served by the water system. (If needed, please attach a list of locations). Publication of the notice in a local newspaper or newsletter of general circulation (attach a copy of the published notice, including name of newspaper and date published). Posted the notice on the Internet at www. Other method used to notify customers. I hereby certify that the above information is factual. Certified by: Printed Name Title Signature Date Disclosure: Be advised that the California Health and Safety Code, Sections 116725 and 116730 state that any person who knowingly makes any false statement on any report or document submitted for the purpose of compliance with the Safe Drinking Water Act may be liable for, respectively, a civil penalty not to exceed five thousand dollars ($5,000) for each separate violation or, for continuing violations, for each day that violation continues, or be punished by a fine of not more than $25,000 for each day of violation, or by imprisonment in the county jail not to exceed one year, or by both the fine and imprisonment. ATTACHMENT C Page 257 of 747 Compliance Order 04_70_21R_001 APPENDIX 3. QUARTERLY PROGRESS REPORT Water System: Higuera Apartments Water System No: 4000563 Compliance Order No: 04_70_21R_001 Violation: Nitrate Maximum Contaminant Level Calendar Quarter: Date: This form should be prepared and signed by System personnel with appropriate authority to implement the directives of the Compliance Order and the Corrective Action Plan. Please attach additional sheets as necessary. The quarterly progress report must be submitted by the 10th day of each subsequent quarter, to the SLOEHS to the following email address: lterry@co.slo.ca.us titled appropriately. Summary of Compliance Plan: Tasks completed in the reporting quarter: Tasks remaining to complete: Anticipated compliance date: Printed Name Signature Title Date ATTACHMENT C Page 258 of 747 Appendix 4 - Notification of Receipt Compliance Order Number: 04_70_21R_001 Name of Water System: Higuera Apartments System Number: 4000563 Certification I certify that I am an authorized representative of the Higuera Apartments and that Compliance Order No. 04_70_21R_001 was received on ___________________. Further I certify that the Order has been reviewed by the appropriate management staff of the Higuera Apartments and it is clearly understood that Compliance Order No. 04_70_21R_001 contains legally enforceable directives with specific due dates. Signature of Water System Representative Date THIS FORM MUST BE COMPLETED AND RETURNED TO THE SAN LUIS OBISPO HEALTH AGENCY PUBLIC HEALTH DEPARTMENT ENVIRONMENTAL HEALTH SERVICES, NO LATER THAN JANUARY 31, 2021 Disclosure: Be advised that the California Health and Safety Code, Sections 116725 and 116730 state that any person who knowingly makes any false statement on any report or document submitted for the purpose of compliance with the Safe Drinking Water Act may be liable for, respectively, a civil penalty not to exceed five thousand dollars ($5,000) for each separate violation or, for continuing violations, for each day that violation continues, or be punished by a fine of not more than $25,000 for each day of violation, or by imprisonment in the county jail not to exceed one year, or by both the fine and imprisonment. ATTACHMENT C Page 259 of 747 Page 260 of 747 Initiation of Higuera Apartments Annexation ANNX-0662-2024, RZ-0665-2024 (4320 South Higuera) City Council Hearing June 18, 2024 Applicant: Sacramento State Office of Water Programs Project Site 2 4320 South Higuera Approximate three-acre parcel Access via South Higuera Developed property with 24-unit apartment and potentially unpermitted structures, including two (2) detached single-family residences, two (2) trailers, and various accessory structures (e.g., sheds, storage containers, solar panel system) Located in unincorporated area of the County; Residential Multi-Family land use category Immediately outside of the City limits Within the urban reserve line and sphere of influence Project Description Initiation of an Annexation with Prezoning Application for the Higuera Apartments at 4320 South Higuera Forwarded to Council for early policy consideration If authorization is provided to process, staff will return with detailed analysis of the project Nitrate contamination of the existing water system (single well with chlorination and distribution systems) Contamination dates to 2017 SLOEHS issued Compliance Order in 2021 State Water Board identified consolidation with City as the most preferred long-term solution to providing safe and reliable water to the property Will provide Property Owner with technical and financial assistance to facilitate the project May order mandatory consolidation of water and wastewater systems in accordance with Sections 116680-116686 of the California Health and Safety Code Annexation required for City to provide water and wastewater services to the property 3 Map of Existing Water and Wastewater System 4 Preliminary Policy and Capacity Analysis Annexation Required City policies and regulations do not permit water and wastewater connections to users outside of the City limits o LUE Policy 1.13.1 (Water and Sewer Service) o WWE Policy B 2.2.1 (Service Outside of the City Limits) o Municipal Code Chapter 13.04 (Water Service) Major City Goal – Housing & Homelessness Focused objective is to facilitate the continuance of existing residences by connecting to the City’s water and wastewater system for the provision of safe and reliable water General Plan Amendment Logical extension of the City limits within the existing URL Limited to a three-acre parcel located immediately outside of the City limits along an arterial street that is substantially surrounded by other developed properties in the City Adequate Capacity to Serve Water –Higuera Apartments projected to utilize 0.08% of the ~2,500 acre-feet of water available for community growth through 2035 Wastewater –WRRF in process of being upgraded to improve water quality and increase capacity of the facility from 3.0 MGD to 5.4 MGD 5 Next Steps Development review by City staff Environmental review o Assessment of environmental impacts related to the required infrastructure improvements to serve the property Plan for Services o Analysis of the annexation area’s impact on overall City services and implementation of the derived recommendations Pre-Annexation Agreement o Zoning clarifications; required public and private infrastructure and utility improvements; payment of applicable fees; etc. Planning Commission public hearing for recommendation City Council public hearing for consideration of a resolution of intent Submittal to LAFCO 6 Financial Incentives City may be eligible for future funding opportunities as a voluntary participant (e.g., loans for infrastructure improvements, refinancing of existing loans, etc.) Incentives updated on annual basis in the Drinking Water State Revolving Fund (DWSRF) 7 Environmental Determination Recommended action to proceed with application processing is not subject to CEQA Does not constitute a “project” under Section 15378 Does not commit the City to a definite course of action in regard to a project under Section 15352 Detailed project analysis will include environmental review 8 Recommendation Authorize staff to proceed with processing the Annexation with Prezoning Application for a three- acre parcel located at 4320 South Higuera Street in order for the City to provide water and wastewater services If authorization is provided to process the application, staff will return with a detailed analysis of the project 9