County of San Diego - Recycled Water Oversight Consent AgreementELISE ROTHSCHILD
DIRECTOR
April 19, 2018
Turtn#g of ,San Pie$o
DEPARTMENT OF ENVIRONMENTAL HEALTH
LAND AND WATER QUALITY DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
Phone: (858) 565-5173 Fax: (858) 694-3670
www.sdcdeh.org
City of Poway
Michael Obermiller, Director of Public Works
P.O. Box 789
Poway, CA 92074-0789
AMY HARBERT
ASSISTANT DIRECTOR
CERTIFIED MAIL NO. 7016 3010 0001 0995 3205
RECYCLED WATER OVERSIGHT CONSENT AGREEMENT
Dear Mr. Obermiller:
The County of San Diego, Department of Environmental Health (DEH), has reviewed your
request, received on March 9, 2018, to terminate the Recycled Water Consent Agreement dated
September 20, 2013 between the City of Poway and DEH. Due to limitations with staff scheduling,
the City of Poway has requested to enter into a new Recycled Water Oversight Consent
Agreement that has the following level of oversight:
DEH will provide services for review and regulatory real time on site monitoring (annual
inspections and if needed testing as well as 4 year testing) as described for sites below (1-7).
These sites will require reimbursement from the Water Agency unless other agreements are made
between the end users, contractors, and Water Agency:
1. Newly proposed recycled water use sites (Dual Plumbed and dual source) work including
plan reviews, site inspections, and initial cross -connection oversight.
2. Existing sites having or undergoing unauthorized changes to the domestic water or
recycled water plumbing system that would require a cross connection test (including and
up to a shutdown test).
3. Dual Plumbed sites as defined in Title 22 and CDPH (annual inspections and 4 year
testing.
4. Recycled water use sites having an ongoing history of cross -connections being
established or re-established or premises having repeated violations of Title 22, Title 17,
or Regional Water Quality Control Board recycled water permit requirements. DEH may
waive this requirement if the recycled water use site can demonstrate compliance has
been maintained for a period of time acceptable to DEH in consultation with CDPH and
Water Agency.
5. Public Schools and sites that use recycled water for irrigation and are exempt from the
standard local building department permit process (annual inspections and 4 year testing).
General Hospitals (annual inspections and 4 year testing).
6. Sites that are not specified under the current regulations that would require special review
as determined by CDPH in consultation with Water Agency
"Environmental and public health through leadership, partnership and science"
City of Poway 2 April 19, 2018
7. Any site suspected of having a cross -connection with recycled water, as determined in
conjunction with the Water Agency, will be tested to ensure that any threat is mitigated.
DEH staff will only provide oversight of sites as described above. DEH will not attend any
inspections or testing at other sites unless specifically requested by the Water Agency. For the
first cross -connection test following site approval where DEH staff are not present to monitor the
inspection and test, the Water Agency shall submit a written report (H&SC 60316) documenting
the testing methods used to determine the lack of cross -connections and report their findings to
the DEH within 30 days following completion of the inspection or testing. The report content can
be negotiated between DEH and the Water Agency. These reports will be evaluated to determine
if the testing methods and results are satisfactory. Once these results are determined to be
satisfactory, DEH will allow the Water Agency to conduct future tests and inspections without a
report submittal. The Water Agency shall reimburse DEH for report reviews (CA Water Code
13554.2)
Please note a new Recycled Water Oversight Consent Agreement must be signed by an
authorized agent for the City of Poway and returned to the Department of Environmental Health
in order to finalize the requested modification of oversight.
If you have further questions, please do not hesitate to contact me at (858) 505-6843, or by email
at jamelle.mccullough@sdcountv.ca.gov
Sincerely,
Jamelle
McCullough
Digitally signed by
Jamelle McCullough
Date: 2018.04.19
10:29:38 -07'00'
JAMELLE MCCULLOUGH
Supervising Environmental Health Specialist
Recycled Water Program
(858) 505-6843
cc: Sean Sterchi, SWRCB-DDW, San Diego District Engineer
Rudy Guzman, City of Poway Assistant Director of Public Works for Utilities
Encl: Recycled Water Oversight Consent Agreement
ELISE ROTHSCHILD
DIRECTOR
April 19, 2018
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Taunt of $an it.e i APR 3 a Z131B
DEPARTMENT OF ENVIRONMENTAL HEALTH
LAND AND WATER QUALITY DIVISION
P.O. BOX 129261, SAN DIEGO, CA 92112-9261
Phone: (858) 505-6700 or (800) 253-9933 Fax (858) 505-6786
www.sdcdeh.orq
r'iVIRONME_I'jTAL
HEAI To
AMY HARBERT
RECYCLED WATER OVERSIGHT CONSENT AGREEMENT
ASSISTANT DIRECTOR
The California Department of Public Health (CDPH) has delegated authority to The County of
San Diego Department of Environmental Health (DEH) to conduct the Recycled Water
Program in accordance with the California Water Code section 13554.2 and 13554. This
agreement was entered on June 8, 2001.
The purpose of this letter is for DEH and each individual Water Agency supplying recycled
water or Water Agency supplying domestic water to a recycled water use site to agree on
criteria for DEH service limitations and reimbursement [California Health and Safety Code
(H&SC) 116800] for new project reviews and existing recycled water use site monitoring in
accordance with California Code of Regulations Title 22, this Consent Agreement, and
specification of the delegation agreement between CDPH and DEH.
This Agreement between DEH and the Water Agency is for DEH oversight based on one of
two options listed below. The Water Agency will indicate which option it wishes for DEH
oversight.
OPTION 1:
DEH will provide services for review and regulatory real time on site monitoring (annual
inspections and if needed testing as well as 4 year testing) as described for sites below (1-7).
These sites will require reimbursement from the Water Agency unless other agreements are
made between the end users, contractors, and Water Agency:
1. Newly proposed recycled water use sites (Dual Plumbed and dual source) work
including plan reviews, site inspections, and initial cross -connection oversight.
2. Existing sites having or undergoing unauthorized changes to the domestic water or
recycled water plumbing system that would require a cross connection test (including
and up to a shutdown test).
3. Dual Plumbed sites as defined in Title 22 and CDPH (annual inspections and 4 year
testing).
4. Recycled water use sites having an ongoing history of cross -connections being
established or re-established or premises having repeated violations of Title 22, Title 17,
or Regional Water Quality Control Board recycled water permit requirements. DEH may
"Environmental and public health through leadership, partnership and science"
waive this requirement if the recycled water use site can demonstrate compliance has
been maintained for a period of time acceptable to DEH in consultation with CDPH and
Water Agency.
5. Public Schools and sites that use recycled water for irrigation and are exempt from the
standard local building department permit process (annual inspections and 4 year
testing). General Hospitals (annual inspections and 4 year testing).
6. Sites that are not specified under the current regulations that would require special
review as determined by CDPH in consultation with Water Agency
7. Any site suspected of having a cross -connection with recycled water, as determined in
conjunction with the Water Agency, will be tested to ensure that any threat is mitigated.
DEH staff will only provide oversight of sites as described above. DEH will not attend any
inspections or testing at other sites unless specifically requested by the Water Agency. For the
first cross -connection test following site approval where DEH staff are not present to monitor
the inspection and test, the Water Agency shall submit a written report (H&SC 60316)
documenting the testing methods used to determine the lack of cross -connections and report
their findings to the DEH within 30 days following completion of the inspection or testing. The
report content can be negotiated between DEH and the Water Agency. These reports will be
evaluated to determine if the testing methods and results are satisfactory. Once these results
are determined to be satisfactory, DEH will allow the Water Agency to conduct future tests and
inspections without a report submittal. The Water Agency shall reimburse DEH for report
reviews (CA Water Code 13554.2)
OPTION 2:
The Water Agency will continue to receive the current level of service and monitoring as of
March 20, 2018. The current level of monitoring includes plan review (CA Water Code
13554.2) and real time monitoring of all new and existing cross -connection control shutdown
testing of the domestic water system as described in the County of San Diego Recycled Water
Plan Check and Inspection Manual (2001 Edition). DEH staff would be present to monitor all
existing domestic water cross -connection annual or 4 year shutdown testing. Since DEH staff
would be present, the required report submittal described in Option 1 would not be required as
the testing methods would be documented by DEH staff. When DEH provides services,
reimbursement from the Water Agency will be required unless other agreements are made
between DEH, end users, contractors, and Water Agency.
Along with options 1 or 2, the following will apply:
The Water Agency agrees to report any violation of their Regional Water Quality Control Board
discharge permit Order, Title 22, or Title 17 to DEH and CDPH within 24 hours.
DEH agrees to meet on a quarterly basis with agencies to share information within the region
on recent enforcement actions, any trends in violations, technical issues that have been
encountered and how they are being resolved, new and updated State policies and regulations
on recycled water, updates to the Recycled Water Plan Check and Inspection Manual, and
steps that can be taken to avoid notices of violation while ensuring protection of public health.
"Environmental and public health through leadership, partnership and science'
At the Water Agency's request, DEH will provide additional services and technical assistance
to Water Agency for cross -connection testing at existing recycled water sites. The Water
Agency may also request additional DEH support in response to a cross -connection, including
but not limited to, a review of the recycled water site. DEH agrees to notify the Water Agency a
minimum of 60 days prior to any proposed fee increases for comments.
As witnessed by the signatures below, the Water Agency and the County agree to accept and
abide by the terms and conditions of this Agreement. This Agreement shall become operative
as of March 28, 2018 and shall remain in effect unless terminated by either party following 60
days written notice, and may be amended at any time by mutual agreement between DEH and
Water Agency.
Water Agency preference Option 1.
Water Agency: City of Poway Water Utilities
P.O. Box 789
Poway, CA 92074-0789
Print Name: tiiicAcmi Qberrn:I /
Signature:
County of San Diego Department of Environmental Health
Print Name: 1.15(/ 0\6 a oti
Signature:V)001t6.
Date: 2.5L
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'Environmental and public health through leadership, partnership and science'