1) Corrosion Control Study
Pursuant to Section 64673(c) CCR, the Department hereby requires Gavilan College to initiate a corrosion control study. This study shall be completed no later than April 30, 2010. The corrosion control study shall contain the elements described under Section 64683 CCR and shall determine whether additional treatment is required in order for Gavilan College to provide optimal corrosion control and comply with the lead action level. Treatment options may include alkalinity and pH adjustment, calcium hardness adjustment, and/or the addition of a corrosion inhibitor.
The corrosion control study shall evaluate the monitoring results (to be collected during the next twelve months and described under Item 2) and determine if the minimum water quality parameter levels are maintained in the distribution system. Based on the evaluation of the monitoring results, Gavilan College shall recommend to the Department in writing the treatment option that constitutes optimal corrosion control treatment for Gavilan College. The water system shall provide a rationale for its recommendation along with all supporting documentation.
2) Water Quality Parameters (WQP) Monitoring
Pursuant to Sections 64673(c)(1), 64673(c)(2)(D), 64680, and 64681 CCR, Gavilan College is hereby required to conduct two six-month rounds of tap monitoring for WQP at distribution system sites and WQP monitoring at points of entry to the distribution system.
WQP monitoring at Distribution System Sites – The minimum tap monitoring required is two samples for each applicable WQP from three sample taps. If Gavilan College chooses to collect the two rounds of recommended lead and copper tap samples (as discussed in Item 5), the WQP samples should be collected at the same time.
WQP Monitoring at Points of Entry – The minimum monitoring required at points of entry (the well) is two samples for each applicable WQP at each entry point from locations representative of each source after treatment.
The WQP to be monitored at taps and points of entry are pH, total alkalinity, calcium, conductivity, and water temperature, which are to be used to calculate the Langlier Index. Gavilan College shall continue to monitor for WQP until two consecutive rounds of lead and copper tap samples meeting the LCR action levels are collected or October 31, 2008, whichever occurs first.
WQP monitoring data should be submitted to the Department via fax or email as soon as results become available. Submittals should include a summary of analysis in the form of a table or spreadsheet and must include laboratory reports.
3) Lead Public Education and Notification Program
Gavilan College must complete its initial Lead Public Education and Notification Program (Program) by December 31, 2008 and in accordance with Section 64687 California Code of Regulations (CCR). Please submit evidence of compliance with this requirement no later than January 30, 2009. The Program shall consist of distributing printed material to the public and posting information in a public place or common area in each of the buildings served by the system.
Educational Brochure – A sample brochure is attached for your convenience. Please submit a rough draft educational brochure to the Department for approval. Once approved, Gavilan College shall distribute the brochure by posting and public distribution by December 31, 2008. This shall be repeated every 12 months for as long as Gavilan College exceeds the lead action level.
4) Lead and Copper Tap Sampling
Pursuant to Section 64673(c)(2)(D), Gavilan College is required to perform additional lead and copper tap sampling to confirm the lead action level exceedance concurrent with the required corrosion control study and water quality parameters monitoring.
The additional lead and copper sampling is to consist of two consecutive 6-month rounds of lead and copper tap samples in 2007. The samples should be collected during the periods of January to April and June to September. The minimum number of samples required for each round is forty. Gavilan College should attempt to collect samples from sampling sites used in the most recent sampling.
All water samples shall be collected from taps that are routinely used for consumption i.e. drinking, hand washing, bathing/showering, oral hygiene, etc. Sampling sites shall not include faucets that have point-of-use or point-of-entry treatment devices (such as water softeners and reverse osmosis treatment units) designed to remove inorganic contaminants. In addition, the water from the taps should have stood motionless in the plumbing system for at least six hours, but no more than 12.
If both rounds of samples show that Gavilan College does not exceed the lead and copper action levels, Gavilan College may cease to complete the corrosion control study (Item 1) and WQP monitoring (Item 2) and resume reduced monitoring of 20 lead and copper tap samples on an annual frequency. Otherwise, Gavilan College shall complete the corrosion control study by April 30, 2010 as previously mentioned."