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Page 2 of 3 <br />exceedance, staff coordinated with the DDW, which resulted in the issuance of DDW Citation <br />and Compliance Order No. 02 02 25J 001 (Order) on September 9, 2025. The Order required <br />notification to affected customers and the preparation of a Corrective Action Plan and an <br />Operational Evaluation Report (CAP/OER). The CAP/OER was submitted to DDW in <br />November 2025 and approved in March 2026. The CAP/OER identified several factors <br />contributing to elevated DBPs, including: <br />• Source Water Blend: Increased surface water from Zone 7 with high organic content in <br />early 2025, combined with a limited groundwater supply due to the loss of City <br />groundwater wells (normally low in organic content), resulted in higher DBP precursors <br />entering the Kilkare system. <br />• Disinfection Practices: Disinfection by breakpoint chlorination at Kilkare is necessary <br />to prevent nitrification; however, this method can accelerate DBP formation under high- <br />organic conditions. <br />• Distribution System Characteristics: The Kilkare service area has long water <br />residence times due to low customer demands and lengthy runs of piping, with multiple <br />tanks and booster stations required to deliver water to customers at high elevations. <br />Long water residence times during warm weather periods increase DBP formation. <br />• Limited Control and Predictive Information: The City currently lacks access to real- <br />time data on Zone 7 source water quality and has no active local supply to offset source <br />water changes. <br />To address these challenges, the CAP/OER identified immediate actions, short-term actions, <br />and a feasibility study for long-term solutions focused on reducing water age, optimizing <br />source water blends, maintaining disinfectant residuals, and improving monitoring and <br />coordination with Zone 7. The City’s immediate actions have reduced the LRAA for TTHMs <br />and HAA5 at monitoring location S-31 below the MCLs, with Q4 2025 calculated values of <br />0.079mg/L and 0.058 mg/L, respectively. Short-term actions and the feasibility study for long- <br />term solutions are currently underway, with required completion dates of June 2026 and <br />December 2026, respectively. <br /> <br />DISCUSSION <br />The City’s existing agreement with Carollo provides professional services in support of the <br />Water System Management Plan (WSMP), including identifying and implementing water <br />quality improvements. This agreement was used to have Carollo prepare the CAP/OER in <br />response to the DDW order. <br /> <br />Additional support from Carollo is needed to implement the actions identified in the CAP/OER. <br />Services include developing standard operating procedures for DBP management, conducting <br />hydraulic modeling to identify opportunities to reduce water age and improve source blending, <br />and conducting a feasibility study to evaluate long-term disinfection practices and DBP control <br />measures. <br /> <br />The Third Amendment increases the agreement compensation amount by $75,000 to perform <br />these time-sensitive, compliance-driven services. Because the services are required to meet <br />regulatory deadlines in order to continue delivering water services to the Kilkare area, the <br />amendment was executed, and staff are now seeking formal ratification by the City Council. <br /> <br />Page 230 of 846