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,. Arbor Mobile Home Park Water System Page 2 "No public water system that was not in existence on January 1, 1998, shall be granted a permit unless the system demonstrates to the Department that the water supplier possesses adequate financial, managerial, and technical capacity to assure the delivery of pure, wholesome, and potable drinking water. This section shall also apply to any change of ownership of a public water system that occurs after January 1, 1998". If the EHD is unable to issue a permit, due to inadequate TMF capacity, then the new owner will be in violation of the Health and Safety Code Section 116725 (d) for operating a public water system without a permit, upon the operation and delivery of water to the residents and customers of the system. The TMF submittal to the EHD shall include at a minimum documentation of property ownership (deed) of parcel APN 01733007, which includes the owner's water rights, and discussion of the management and duties of the individuals responsible for the water system. To demonstrate financial capacity, documentation must be provided to the EHD that shows the new owners have the capital to operate the water system and a fee structure in place to maintain that capital as funds are expended. The expenditures will include, at a minimum, the costs to monitor the water system for chemical and microbial contaminants, maintain and operate the treatment system for the removal of Dibromo chloropropane (DBCP) including replacement of exhausted carbon media contained in the DBCP treatment vessels upon receiving results of the treated water with detectable levels of DBCP, investigate and eliminate any source of any microbial contamination, employ proper disinfection procedures to eliminate any microbial contamination from the water system, and maintain a contract with a certified treatment and distribution operator that is experienced and competent to operate this water system. It must also be demonstrated that there will be sufficient capital to replace the water system as it ages and wears. This includes, at a minimum, construction of a new drinking water well, installation of a new water treatment plant and replacement of all the water lines, valves, water storage tank sized and designed to meet fire, Maximum Day Demand and Peak Hour Demand flows and water pumps. Depending on the final administration and operation of the site as a condominium with a HOA, this water system may fall under the jurisdiction of the Public Utilities Commission (PUC). The EHD will not issue a permit to operate the water system, until the EHD receives a written statement from the PUC stating the operation of the water system by the new property owner does not fail under their jurisdiction or that the water system meets all the PUC requirements as 1 a regulated utility. Please contact me if you any further questions regarding this issue at (209) 468-0343. Sincerely, Y Adrienne Ellsaesser, REHS Lead Senior Registered Environmental Health Specialist