13. Plant F17

The two wells located at this facility have treatment facilities to remove perchlorate. SGV states that because the two wells have nitrate concentrations that exceed the maximum contaminant level, it plans to install a nitrate removal facility. SGV also plans to install an emergency generator.

The proposed expenditures are $1,660,000 in 2009.

The settlement uses SGV's request.

13.1. Positions of Parties

Prior to the settlement, DRA recommended that the treatment facilities be deferred until after this GRC cycle.

COF recommends that the proposed new generator be authorized. However, it recommends that SGV continue to blend water from other sources to maintain applicable standards instead of adding a nitrate removal facility.

FUSD agrees with the position taken by COF and adds that SGV will have more than enough water to meet forecasted needs for this GRC cycle even without the wells at Plant F17.

SGV states that the wells pump to a common perchlorate treatment facility and reservoir. SGV states this procedure is not for the purpose of blending down nitrates, and is not adequate to do so. SGV argues that without nitrate treatment, these wells could be lost at any time.

13.2. Discussion

The record demonstrates that the two wells have high nitrate concentrations that have, on occasion, exceeded the maximum allowable contaminant level. The water from these wells is pumped to a common perchlorate treatment facility and reservoir. The wells are at risk of exceeding the maximum allowable nitrate level, which would cause them to be shut down absent nitrate treatment facilities. To the extent the output from these wells blends in the reservoir, it is insufficient to eliminate the need for treatment, especially if the contamination of the wells increases, because blending only works if one of the sources is not polluted. In this case, both wells are at risk of exceeding the maximum allowable nitrate level. Given the importance of meeting all applicable drinking water standards and ensuring adequate sources of supply, especially during drought conditions, the settlement provisions regarding Plant F17 are reasonable.