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The danger to San Diego filtration plants

Chlorine catastrophe

Bill Holman and Owen Evans. Evans: "We have usually at least 20 tons of chlorine on site at all these three facilities." - Image by Joe Klein
Bill Holman and Owen Evans. Evans: "We have usually at least 20 tons of chlorine on site at all these three facilities."

It’s an unthinkable accident: a tank rupture sends a gigantic plume of deadly chlorine gas down the valley, blanketing schools, homes, churches, and anything else in its path with a green cloud. Thousands are killed. Thousands more are incapacitated. Unthinkable, but according to a city consultant’s report submitted last November, very real. Indeed, the conclusions of not one but two city consultants: the city’s Miramar, Alvarado, and Otay water-treatment plant.

"The second largest is Alvarado filtration, which is at Lake Murray."

“The total residential population within the circle defined by toxic endpoint distances for the worst-case scenario is estimated at 78,000. For the alternative release scenario, the total residential population within the circle defined by toxic endpoint distance is estimated at 11,000.”

Yet another report, by Texas consultant Marsh & McClen-nan, dated this April, found a long list of chlorine risks and hazards, mounting by the day, at the city’s Miramar filtration plant. The report listed more than 40 “recommendations” for dealing with lax safety policies and faulty chlorine handling equipment. The fault list included lack of preventative maintenance, no fire alarm in the chlorine storage room, lack of plant security, vulnerability to terrorism, and failure to inspect aging equipment on a regular basis.

Holman and Evans. Holman: "When you have a chlorine leak you have a big cloud of green gas that’s heavier than air sitting down over the community."

Under the heading “High Probability of Occurrence/High Degree of Severity,” the consultant listed 13 changes that were needed to prevent accidents, including adoption of an “emergency response procedure,” “visual inspection” of chlorine cylinders in storage, institution of a “5-year change-out of chlorine piping,” and development of procedures “for a response to a chlorine gas line, chlorinator or valve leak.”

Under “Low Probability of Occurrence/High Degree of Severity,” the consultant recommended installing remote control video cameras to monitor the site, a complete security review, and “extending the guard’s hours to 24 hours per day on weekends.”

A city safety intern studying the problem found even more trouble at the plants. In a memo dated this May 9, Peter Higgins wrote, “At the high end we have possible scenarios of: legal liability for injured trespassers; violence in the workplace issues; terrorist actions (cause a chlorine release or tamper with water supply); vandals that could cause a release of chlorine; and plant operators who are alone and whose incapacitation could result in contaminated water reaching the public.

“Presently the gates are open all day during normal working hours and are secured when the plant operator is alone. Now the gate is kept open for convenience, but more important issues such as the safety of our employees and community are at stake.

“The administrative operations building needs a fire alarm system that would include klaxons or bells both inside and outside the building in case the operator is outdoors tending to the filters. The fire* alarm system is critically important in order to

allow some action to be taken to prevent the fire from spreading to the chemical feed room and the chlorine cylinders. It could also be critical because it may be the only forewarning of an imminent chlorine release.

“Fire could cause the chlorine cylinders to release their chlorine.... Water could react with chlorine or the lime and the potassium permanganate to cause dangerous reactions.

“The Miramar filtration plant operates 24 hours a day. Two-thirds of the time, the plant is operated by only a single person. This is not an acceptable means of operating. There are just too many hazards that the operator is exposed to and there is no one there to back up the operator to provide first aid, call for help, run the plant, etc.”

Despite the severity of the problems and potential danger to the public, sources say, city officials have been slow to act. Although the city paid a consultant to draw up an emergency plan for dealing with a chlorine disaster, it has yet to be fully implemented, and equipment at the three plants continues to deteriorate. An

unofficial tally provided by a plant worker lists at least four incidents of chlorine leakage over the past year, which threatened to get out of hand. Last month, according to the source, two employees got a dose of chlorine greater than 50 parts per million, a sig-nificant dose. Another worker was “severely exposed” to an “unknown concentration of gas” in April of last year. That May, three employees were exposed to an unknown concentration, according to the unofficial tally.

Bob McAlister, the safety officer in charge of watching over the city’s water treatment plants, acknowledges that the complaints of the past were valid, but insists that the city, goaded by state regulators, has a new attitude about worker and public safety. “Within one year we will have a major incident response plan for this department for whatever we consider to be a catastrophic event,” says McAlister, “be it earthquake, fires, security, dam failure, chlorine leak, or water outage. The chlorine response plan would be an attachment to that.

“The plan is being implemented now, and we are testing it.

Our emergency management coordinator is a key person, and he’s just been hired. Before now, I was wearing two hats, occupational safety and health manager and emergency management coordinator. Now we’ll have a single person dedicated to that duty. We are currently putting together a committee that’s called the major incident response plan committee, chaired by the emergency management coordinator.

“We are going to start with a drill at Miramar this month. We are going to do a drill with the hazardous incident response team from the San Diego Fire Department next month. Within the next month, we’ll be setting up a meeting with the principal of Miramar elementary school to brief the students [on the hazards there].

“I want to have the process safety program in place by September. Most of the key program elements are completed, and we are just going back through and reviewing them. My recommendation is that they have a security guard at the gates of every plant during regular working hours, someone that checks people in and out, and that’s part of this plan. As I’ve told the guys who work out there at the plants, I have a sincere commitment to protect them.”

Not everyone has been convinced. The string of incidents and complaints by employees led the state Department of Occupational Health and Safety (osha) to cite the city this April for what it called a “serious” violation of safety management policies. As of October 1996, the agency said the City had not “performed a hazard analysis appropriate to the complexity of the chlorination process for identifying, evaluating, and controlling hazards involved in the process.” The agency also determined that the city had inadequate procedures to maintain the “ongoing integrity of chlorination process equipment and appurtenances.”

Specifically, inspectors said, the city needed to develop “a program for inspection and testing of chlorine piping and equipment” that would assure “replacement of piping and other material in contact with chlorine, based on the rate of corrosion, testing, etc. The purpose of this is to prevent the inadvertent release of concentrated chlorine gas, causing injury to an employee.”

“Cal-OSHA’s last comments to me were that they were happy with the progress the program is making,” McAlister says. But plant workers say conditions at the plant are so bad they are willing to go public. Owen Evans and Bill Holman have worked at the city plants for a cumulative total of 20 years. During an interview with them and another source close to the City who requested anonymity, they outlined a chilling scenario of death and disaster if the City does not move soon to deal with the festering problems.

Q. What does the city do with all the chlorine it has stored at its treatment plants?

Owen Evans: In water treatment we use chlorine to disinfect the water supply. It kills pathogens, disease carrying organisms. We have usually at least 20 tons of chlorine on site at all these three facilities.

Q: These three facilities, where are they?

O.E.: Miramar filtration plant is the largest; it’s on Scripps Lake Road up in Scripps Ranch near Lake Miramar. The second largest is Alvarado filtration, which is at Lake Murray, La Mesa. And the smallest facility is Otay filtration plant, which is down at Lower Otay Lake. They all have the same basic storage capacity in terms of chlorine.

Q: So the chlorine is in the liquid form?

O.E.: Yes, it starts out in a liquid form, which is under pressure. It is evaporated into a gaseousiorm through an evaporator, which is a water bath, basically, and then it’s fed into the water in different application points in the process.

Chlorine is an acutely hazardous chemical. Fifty parts per million in a volume of air is enough to kill you, period, and it wouldn’t take very long. Four of five parts is enough to send you into a coughing fit and send you out of the room, and you might not want to come back for a long time. So we get a lot of this stuff; it’s under pressure, the piping is subject to failure, and that’s just the nature of the mechanics of running that kind of gas through piping systems.

There is also a factor where we have to change chlorine cylinders on a daily basis since there are only two tons worth during the summertime, vvhen you tend to go through two tons per day; therefore you have to always make and break the connections every day. That is one area of concern, obviously, because that’s a potential for a leak, and then just the normal switchover when one ton empties out: you switch over to another two-ton manifold system. You’re going to have a leak at that time. And that switchover is done routinely all hours. I did it last night on graveyard by myself; I switched from one set of ton cylinders over to another, and it’s a matter of manipulating the valves. It could be a critical time when you’re there by yourself.

Q. The City consultants have prepared a response plan for chlorine release, but you feel there are shortcomings with it?

O.E.: Their response plan calls for a response within 30 minutes. Obviously within 30 minutes all the chlorine is out of the cylinder and into the community.

Bill Holman : Historically throughout the United States when you have a chlorine leak you have a big cloud of green gas that’s heavier than air sitting down over the community, and there’s some pictures of this stuff, and it’s like a five-mile gas cloud sitting down over a valley in our community where there’s the lewest point that it seeks out. It’s ugly stuff, and we have to evacuate people. And with the density of residents near the plants, we’re looking at anywhere from 70,000 to 160,000 people. That’s scary.

Q: Are chlorine leaks a frequent problem?

B.H.: This happens quite often. You know, you take care of it. You take a deep breath and you fix it. Your eyes are watering and you say, “Ah, no big deal.” There are certain operators around that are still doing that, and it doesn’t go reported because we haven’t had a proper policy. A lot of people were intimidated: they just fix it so that they didn’t get into trouble for whatever it was, whatever mistake they made from fatigue, from working rotating shifts, for whatever reason it was buried. When I got hit the last time in April, I actually had to go and seek medical attention. I was still fighting it and my supervisor made me go seek medical attention.

I was like, “Ah, I’m okay.” Well, I wasn’t. My eyes were swollen shut, I wasn’t okay. I thought about some of my partners: one gentleman who’s about 130 pounds in his late 50s, another friend of mine who’s been a partner of mine since I’ve been with the City, a female who’s about 130 pounds. I started thinking if that would have been them, they might not have come out of that.

And then what really started this going for me was after that happened to me no one contacted me from management to see how I was doing. To this day no one ever contacted me or went to the hospital to see how I was doing. They had been asked to do risk assessments over and over again. They wouldn’t do it because they didn’t want to be on record. It wasn’t until the Cal-OSHA came in that they were forced to do it. When that report came back and I read it, it scared me. I knew, I’d been through it. I read the reports and said, “Oh my God, this is a real deal.” I got rid of that macho attitude about the whole thing, about “I can do it,” and said, “You know what? Maybe I can’t, and if I want a sacrifice for being macho, I die. But if this thing gets away, it’s going to take out 73,000 people.”

Q: So it starts with a valve problem or something?

B.H.: It could start with a valve problem, it could start with a terrible maintenance program. There’s pipes that are old, they just get painted. Different plants have different levels. One plant that I worked in had a very scary chlorine room; things were happening all the time, leaks and this. It’s mechanical, it can fail.

Q: Which plant was that?

B.H.: That was Alvarado. I’ve not worked there in a long time. I understand that it’s gotten better, but there was a time when that room was scary, the pipes were old. The equipment was old....

I mean, I go into that chlorine room, and I say, “Hey, you know, is this thing going to blow up on me or not?” And that’s pretty scary, not only for me personally but for the entire community, and to just touch on one of the reasons why the two operators actually are there all the time is important: if you have a small leak, chances are it’s going to turn into a big leak over time. If you have only one individual there, he is not allowed by law to go in there and fix the problem, so if you have a small leak, and he has to say, you know, call Mo, Larry, and Curly on the phone, help, help, help, I’ve got a leak, and you know it’s leaking, it’s leaking, by the time somebody comes in a half an hour later, that thing could turn into a huge cloud going down the boulevard, and that’s not the way to run an operation, and that’s another resource allocation that the management of the water utilities department has chosen not to put the money into.

Q. After the complaint to Cal-osha, the City hired a consulting firm to draft a plan for dealing with a chlorine emergency at its water treatment plants. What did they conclude? Source: I think you’d never get any of them to say it because they’re taking checks from the City, but I think they were appalled that we had no plan with the size of the facilities that we are and our interface with the community, our proximity. In Miramar we’re within 1000 feet of an elementary school.

Q. What school is that? Source: Miramar Ranch Elementary.

Q. What is the risk to the community?

Source: I think it’s pretty big. We have one operator on site. The way the policy is written now, you don’t go in unless you have backup. In fact, now the policy is to the point that it says you don’t go in at all. You hit the button and you get out. Hopefully that would remediate the majority of the leaks because we’re shutting it off at the main cylinder valves, but there’s still the potential of expo-sure to that, and plant operators and maintenance people are the best qualified to handle these, and they’ve handled these for years. That’s why you don’t hear about chlorine leaks, because people have gone in and taken care of it, sustained the exposures, and kept their mouths shut. That’s not consistent with the law, it’s not in the community’s best interest or the employee’s best interest to do that any longer, but I think that the threat is still very great, especially with one person on shift. If he has a leak at the Miramar facility, hopefully he can shut it down and get out.

If it’s a major problem where that won’t remediate it, he has no choice but to get out and attempt to notify Station 38 and get notification out to the community. It’s a very well-devised plan, but it’s not implemented, and the follow-through as far as who’s going to respond if you have a major incident is yet being developed.

Q. People could theoretically get killed by this if they’re moving in the area?

Source: Yes. And the other side of that is, what if you have an operator who goes into that room and is overcome because of the exposure? You have nobody operating that treatment plant for the next eight hours until the next guy comes in. One of the things we asked for very early on was a risk assessment, a comprehensive risk assessment, that involved not just chlorine only, but all the risks associated with one person working alone in a facility like this. We had asked for a comprehensive risk assessment on several occasions. In one meeting, when we asked for it, the comment was, “Won’t that become a public document?” “Yes, it will.” “Then we don’t want to do that.”

O.E.: They hired four consultants. Spent 50,000-some-odd dollars paying these consultants. I think they asked the consultants obviously what to

come back with. They didn’t want the consultants to say, “Hey, you really need two operators a shift to make sure that this is taken care of, and you really need to train your people so they can actually take care of the problem.” Ah they came up with is a draft plan. The plan hasn’t actually been implemented because there’s not a manager who will put his signature on a piece of paper saying okay, this is the plan, we will now implement it.

Q. So there is still no sign as to when the City will implement the emergency response plan? Source: No. In fact, the current policy is, hit an emergency shutoff at the one facility, at the Miramar plant, and get out of the plant. There is no protection for the employee except to get out of the environment, and generally there is one person on that shift.

Q. And also, what about notifying the surrounding community?

Source: There is no notification procedure. If the operator had the opportunity to call Station 38 — now there should be call sheets that would hopefully notify people, but it’s not very well defined, and the average

person on the shift at this point has no clue because this policy and this procedure has been in a state of flux for almost seven years. I know there are people who say, “I don’t know what I can do anymore. What can I do?” and the response is: you protect yourself and get out. That’s not satisfactory for the employee; that’s not satisfactory for the public water supply or that community. Any of the communities, particularly with Alvarado and the density of community around that area, and Miramar’s the same way. Otay’s a little different because it’s more remote, but construction is going gang-busters down there, so there’s beginning to be more and more population surrounding the facilities. It’s a big concern. Not to mention the fact, on the occasion of 4/14/96, where Bill was overcome, and we were fortunate on that incident that he was able to make a phone call and shut that treatment plant down. He was extremely sick. We referred him to Industrial Medical and had him evaluated. But had it been someone else or had the exposure been a little bit greater we could have lost him on shift. And if that would have been the case, the public water supply would have been untreated during that interim period until [another worker] came in eight hours later to relieve him. They could have found Bill dead on the floor.

Q. So the risks from chlorine and security gaps are continuing to this day?

Source: Right. Even if they eventually got to the point in the very near future where they

developed the response teams to deal with a chlorine release, the procedure says you’ll have that second person there within 15 minutes. You can empty a tiny cylinder, if there’s a significant enough leak, in about 10 minutes. In fact, we had a chlorine response drill, I believe in May 1995, and haz-mat was parked at the front gate of Alvarado, and it took them two and a half hours to remediate that leak on that drill. In the first 10 or 15 minutes, that would have emptied that cylinder, and that community would have been at significant risk, and a drill has not been conducted since that time.

Q. How would they improve on that? You’re saying that the currently proposed, unimplemented plan is inadequate? Source: I don’t think it is [adequate]. If they’re talking about bringing in off-site personnel and bringing them there within 15 minutes, it’s not going to happen. It’s going to be more like 30 or 45 minutes. During that time, if you have the emergency shutoff equipment, you can shut the treatment plant down, and at that point the risk is low pressure and running out of water in the system, depending on what your storage levels are. The best way to resolve this problem is to staff appropriately, so if you have a release you can take care of it immediately, and that means a minimum of two people, maybe three, and that’s what they haven’t wanted to deal with for almost seven years. From a strictly operational, common-sense standpoint, that would be the way to do it.

Unfortunately, what happens is you get people that want to increase the output of the treatment plant and attempt to show DHS [department of health services] that we can maintain water quality, when in reality we can’t, DHS realizes that this was not a water quality test on those filers and the treatment plant; it was strictly a hydraulic test. We’re not even permitted to exceed that six gallons a minute per square foot without requesting DHS approval to that.

There’s an element of people within the City that would like to save the costs and not upgrade those facilities but just run more water through them. The feedback they get from the operations staff is that it’s not prudent and you can’t do that. The consultants express the same concerns, that a 43-minute test is not an appropriate snapshot for how you want to run a facility.

Q. How many people have been exposed to chlorine gas over the last year?

Source: Probably about 16 — 15 or 16. All but two said they » had been exposed. The one employee who said he had not been exposed in fact had been, but said he had not been.

Q: You’ve mentioned that the City management has told the workers not to report this to the State. Can you give me some examples of that?

Source: I can give you three specifics. At the Alvarado Water Treatment Plant, they had a dead bird in one of their reservoirs. The supervisor was preparing to notify dhs as a courtesy; he knew exactly what they needed to do to isolate that reservoir and insure the water was appropriately disinfected. In fact, at that point the superintendent told him, “You are not to call them,” so DHS was not notified.

On another occasion, recently at Alvarado they ran a flow test that exceeded the design capacity of that treatment plant; they’re rated at 120 million a day. The superintendent came over in the absence of that

senior supervisor and directed the staff to run 130 million through that plant; they were going to test it.

The operations supervisor said we need to notify DHS; this was not consistent with what their requirements were. They were told, “No, they don’t have the strength to pull your certificates; we’re not going to notify them.” The second level supervisor called me and explained what was going on, and at that point, I said, “Are you going to call DHS?” He said, “Yes, I am.” I said, “Good, because if you won’t, I am, because the next step is they’ll be at another plant, trying to do the same thing.”

So, in fact, f don’t know if he prevailed on the superintendent at that point to make the call, but I know I’m following up with DHS. The [DHS]

sanitary engineer who attended that and monitored it to make sure it was done properly had said the superintendent did cooperate with him and was grateful that the superintendent had called him. My response was that the only reason the superintendent had called him was because other people threatened to call you; they were going to do this without notifying you.

The third one was at the Otay plant. A manhole that DHS had specifically requested be sealed, because having it not sealed would compromise the filtered water quality. The superintendent directed the senior supervisor to remove that manhole. At that point he said, “We can’t do that; we need to contact dhs; they’ve forbidden us to do that.” The comment was, “I’ve heard your concern, you just do it.” So apparently an altercation resulted as part of that. What finally happened with that was DHS did become involved in that again, and the superintendent backed off and said he didn’t really want the manhole removed, he just wanted to drill through a bolt.

Q. What about other safety and security issues at the plant?

O.E.: We have a facility that is basically wide open. I mean, this is the water system for 500,000 residents of San Diego and Del Mar. This is just Miramar; Alvarado has its own problems and Otay because of its remote location also has those kind of problems. You have people coming across the border all the time and border patrol and people driving around that place.

These filters and basins are wide open. The chemical feed rooms, the chlorine rooms are wide open.

Q. Other than chlorine, what other chemicals used at the treatment plants are valuable to someone who might want to come in and steal them? Source: The primary chemical that we’re concerned about in that regard is potassium chromanganate because it’s used in methamphetamine production, and the people that purchase that are required to sign a release form, or sign a form, so that they’re registered with the DEA to buy that chemical. If we were to come out and say that we have 50,000 pounds of potassium chromanganate on site at a facility, and the wrong people read that or get that information, with one person on shift, they’re tremendously at risk. That’s one reason why nobody has said an awful lot about that. We’ve missed an analytical balance that’s disappeared from the Miramar plant. Otay has unique problems because they’re close to the border; you have people coming in and out through that plant. Illegal, undocumented workers going across that area all the time; there’s no security, there’s no camera, there’s nothing. There’s one person on shift.

Q. Is that all the time, just one person there?

Source: The majority of the time, yes. During the day shift, during the week, they normally have more than that because they have supervision and maintenance there, but after-hours, after four o’clock in the afternoon, during the weekends, there’s only one person on shift.

Q. They lock the gate, but then somebody could come in and climb over?

Source: Yes, climb right over the fence. The Alvarado plant has had a lot of equipment disappear. They have quite a history of things disappearing at that facility. The Miramar plant has had several items disappear — diesel fuel, acts of vandalism. Both of those facilities have security guards who are on duty after-hours; at the Miramar plant it’s just Monday through Friday from seven to five in the morning. At the Alvarado plant, I don’t know what the hours are; Otay has nothing. The Otay and Miramar plants are moving forward to get camera equipment so we can monitor the front gates. In fact, we’re moving forward now to get intrusion alarms, infrared detectors in the hallways so we know someone’s come in, and a bar code reader, because as part of that new chlorine response policy, we’re supposed to be able to account for everyone on site and we can’t, so we have to have that on a database so that when somebody comes in and they’re a bar-coded, legitimate employee, we have a record of them coming in and then we’ll need a security guard to log the rest of the people in. Those facilities are absolutely wide open. Anybody can come in, cut a lock on a gate, and get at the treated water supply. It’s very frightening; it’s been that way for years.

Q. The City has a plan to spend about $800 million or so upgrading the waterworks. But you say you’re skeptical about that. Your fear is that if they put more money in it now, they might just waste it on consultants or something and not actually improve the system? O.E.: Right, and that’s just going by the history. The water fund is not lacking funds; there’s a lot of money in the water fund. You look at the budget every year. There’s a lot of money, and then they carry money over to the next year because they didn’t spend it, and then they move money over to the general fund. Well why is it that they can’t put the resources of the water fund into the actual making of the water, the actual treatment and distribution of that water? They’ve got 900 employees, not counting the millions and millions of dollars they spend for outside consultants and for privatizing major construction projects, and how many people are actually doing the work? They’ve got bureaucrat after bureaucrat, engineers, analysts, deputy directors, department heads, and all these people are just going to meetings and talking about great ways of saving a nickel, and when it comes around full circle, are we putting out the best water?

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Bill Holman and Owen Evans. Evans: "We have usually at least 20 tons of chlorine on site at all these three facilities." - Image by Joe Klein
Bill Holman and Owen Evans. Evans: "We have usually at least 20 tons of chlorine on site at all these three facilities."

It’s an unthinkable accident: a tank rupture sends a gigantic plume of deadly chlorine gas down the valley, blanketing schools, homes, churches, and anything else in its path with a green cloud. Thousands are killed. Thousands more are incapacitated. Unthinkable, but according to a city consultant’s report submitted last November, very real. Indeed, the conclusions of not one but two city consultants: the city’s Miramar, Alvarado, and Otay water-treatment plant.

"The second largest is Alvarado filtration, which is at Lake Murray."

“The total residential population within the circle defined by toxic endpoint distances for the worst-case scenario is estimated at 78,000. For the alternative release scenario, the total residential population within the circle defined by toxic endpoint distance is estimated at 11,000.”

Yet another report, by Texas consultant Marsh & McClen-nan, dated this April, found a long list of chlorine risks and hazards, mounting by the day, at the city’s Miramar filtration plant. The report listed more than 40 “recommendations” for dealing with lax safety policies and faulty chlorine handling equipment. The fault list included lack of preventative maintenance, no fire alarm in the chlorine storage room, lack of plant security, vulnerability to terrorism, and failure to inspect aging equipment on a regular basis.

Holman and Evans. Holman: "When you have a chlorine leak you have a big cloud of green gas that’s heavier than air sitting down over the community."

Under the heading “High Probability of Occurrence/High Degree of Severity,” the consultant listed 13 changes that were needed to prevent accidents, including adoption of an “emergency response procedure,” “visual inspection” of chlorine cylinders in storage, institution of a “5-year change-out of chlorine piping,” and development of procedures “for a response to a chlorine gas line, chlorinator or valve leak.”

Under “Low Probability of Occurrence/High Degree of Severity,” the consultant recommended installing remote control video cameras to monitor the site, a complete security review, and “extending the guard’s hours to 24 hours per day on weekends.”

A city safety intern studying the problem found even more trouble at the plants. In a memo dated this May 9, Peter Higgins wrote, “At the high end we have possible scenarios of: legal liability for injured trespassers; violence in the workplace issues; terrorist actions (cause a chlorine release or tamper with water supply); vandals that could cause a release of chlorine; and plant operators who are alone and whose incapacitation could result in contaminated water reaching the public.

“Presently the gates are open all day during normal working hours and are secured when the plant operator is alone. Now the gate is kept open for convenience, but more important issues such as the safety of our employees and community are at stake.

“The administrative operations building needs a fire alarm system that would include klaxons or bells both inside and outside the building in case the operator is outdoors tending to the filters. The fire* alarm system is critically important in order to

allow some action to be taken to prevent the fire from spreading to the chemical feed room and the chlorine cylinders. It could also be critical because it may be the only forewarning of an imminent chlorine release.

“Fire could cause the chlorine cylinders to release their chlorine.... Water could react with chlorine or the lime and the potassium permanganate to cause dangerous reactions.

“The Miramar filtration plant operates 24 hours a day. Two-thirds of the time, the plant is operated by only a single person. This is not an acceptable means of operating. There are just too many hazards that the operator is exposed to and there is no one there to back up the operator to provide first aid, call for help, run the plant, etc.”

Despite the severity of the problems and potential danger to the public, sources say, city officials have been slow to act. Although the city paid a consultant to draw up an emergency plan for dealing with a chlorine disaster, it has yet to be fully implemented, and equipment at the three plants continues to deteriorate. An

unofficial tally provided by a plant worker lists at least four incidents of chlorine leakage over the past year, which threatened to get out of hand. Last month, according to the source, two employees got a dose of chlorine greater than 50 parts per million, a sig-nificant dose. Another worker was “severely exposed” to an “unknown concentration of gas” in April of last year. That May, three employees were exposed to an unknown concentration, according to the unofficial tally.

Bob McAlister, the safety officer in charge of watching over the city’s water treatment plants, acknowledges that the complaints of the past were valid, but insists that the city, goaded by state regulators, has a new attitude about worker and public safety. “Within one year we will have a major incident response plan for this department for whatever we consider to be a catastrophic event,” says McAlister, “be it earthquake, fires, security, dam failure, chlorine leak, or water outage. The chlorine response plan would be an attachment to that.

“The plan is being implemented now, and we are testing it.

Our emergency management coordinator is a key person, and he’s just been hired. Before now, I was wearing two hats, occupational safety and health manager and emergency management coordinator. Now we’ll have a single person dedicated to that duty. We are currently putting together a committee that’s called the major incident response plan committee, chaired by the emergency management coordinator.

“We are going to start with a drill at Miramar this month. We are going to do a drill with the hazardous incident response team from the San Diego Fire Department next month. Within the next month, we’ll be setting up a meeting with the principal of Miramar elementary school to brief the students [on the hazards there].

“I want to have the process safety program in place by September. Most of the key program elements are completed, and we are just going back through and reviewing them. My recommendation is that they have a security guard at the gates of every plant during regular working hours, someone that checks people in and out, and that’s part of this plan. As I’ve told the guys who work out there at the plants, I have a sincere commitment to protect them.”

Not everyone has been convinced. The string of incidents and complaints by employees led the state Department of Occupational Health and Safety (osha) to cite the city this April for what it called a “serious” violation of safety management policies. As of October 1996, the agency said the City had not “performed a hazard analysis appropriate to the complexity of the chlorination process for identifying, evaluating, and controlling hazards involved in the process.” The agency also determined that the city had inadequate procedures to maintain the “ongoing integrity of chlorination process equipment and appurtenances.”

Specifically, inspectors said, the city needed to develop “a program for inspection and testing of chlorine piping and equipment” that would assure “replacement of piping and other material in contact with chlorine, based on the rate of corrosion, testing, etc. The purpose of this is to prevent the inadvertent release of concentrated chlorine gas, causing injury to an employee.”

“Cal-OSHA’s last comments to me were that they were happy with the progress the program is making,” McAlister says. But plant workers say conditions at the plant are so bad they are willing to go public. Owen Evans and Bill Holman have worked at the city plants for a cumulative total of 20 years. During an interview with them and another source close to the City who requested anonymity, they outlined a chilling scenario of death and disaster if the City does not move soon to deal with the festering problems.

Q. What does the city do with all the chlorine it has stored at its treatment plants?

Owen Evans: In water treatment we use chlorine to disinfect the water supply. It kills pathogens, disease carrying organisms. We have usually at least 20 tons of chlorine on site at all these three facilities.

Q: These three facilities, where are they?

O.E.: Miramar filtration plant is the largest; it’s on Scripps Lake Road up in Scripps Ranch near Lake Miramar. The second largest is Alvarado filtration, which is at Lake Murray, La Mesa. And the smallest facility is Otay filtration plant, which is down at Lower Otay Lake. They all have the same basic storage capacity in terms of chlorine.

Q: So the chlorine is in the liquid form?

O.E.: Yes, it starts out in a liquid form, which is under pressure. It is evaporated into a gaseousiorm through an evaporator, which is a water bath, basically, and then it’s fed into the water in different application points in the process.

Chlorine is an acutely hazardous chemical. Fifty parts per million in a volume of air is enough to kill you, period, and it wouldn’t take very long. Four of five parts is enough to send you into a coughing fit and send you out of the room, and you might not want to come back for a long time. So we get a lot of this stuff; it’s under pressure, the piping is subject to failure, and that’s just the nature of the mechanics of running that kind of gas through piping systems.

There is also a factor where we have to change chlorine cylinders on a daily basis since there are only two tons worth during the summertime, vvhen you tend to go through two tons per day; therefore you have to always make and break the connections every day. That is one area of concern, obviously, because that’s a potential for a leak, and then just the normal switchover when one ton empties out: you switch over to another two-ton manifold system. You’re going to have a leak at that time. And that switchover is done routinely all hours. I did it last night on graveyard by myself; I switched from one set of ton cylinders over to another, and it’s a matter of manipulating the valves. It could be a critical time when you’re there by yourself.

Q. The City consultants have prepared a response plan for chlorine release, but you feel there are shortcomings with it?

O.E.: Their response plan calls for a response within 30 minutes. Obviously within 30 minutes all the chlorine is out of the cylinder and into the community.

Bill Holman : Historically throughout the United States when you have a chlorine leak you have a big cloud of green gas that’s heavier than air sitting down over the community, and there’s some pictures of this stuff, and it’s like a five-mile gas cloud sitting down over a valley in our community where there’s the lewest point that it seeks out. It’s ugly stuff, and we have to evacuate people. And with the density of residents near the plants, we’re looking at anywhere from 70,000 to 160,000 people. That’s scary.

Q: Are chlorine leaks a frequent problem?

B.H.: This happens quite often. You know, you take care of it. You take a deep breath and you fix it. Your eyes are watering and you say, “Ah, no big deal.” There are certain operators around that are still doing that, and it doesn’t go reported because we haven’t had a proper policy. A lot of people were intimidated: they just fix it so that they didn’t get into trouble for whatever it was, whatever mistake they made from fatigue, from working rotating shifts, for whatever reason it was buried. When I got hit the last time in April, I actually had to go and seek medical attention. I was still fighting it and my supervisor made me go seek medical attention.

I was like, “Ah, I’m okay.” Well, I wasn’t. My eyes were swollen shut, I wasn’t okay. I thought about some of my partners: one gentleman who’s about 130 pounds in his late 50s, another friend of mine who’s been a partner of mine since I’ve been with the City, a female who’s about 130 pounds. I started thinking if that would have been them, they might not have come out of that.

And then what really started this going for me was after that happened to me no one contacted me from management to see how I was doing. To this day no one ever contacted me or went to the hospital to see how I was doing. They had been asked to do risk assessments over and over again. They wouldn’t do it because they didn’t want to be on record. It wasn’t until the Cal-OSHA came in that they were forced to do it. When that report came back and I read it, it scared me. I knew, I’d been through it. I read the reports and said, “Oh my God, this is a real deal.” I got rid of that macho attitude about the whole thing, about “I can do it,” and said, “You know what? Maybe I can’t, and if I want a sacrifice for being macho, I die. But if this thing gets away, it’s going to take out 73,000 people.”

Q: So it starts with a valve problem or something?

B.H.: It could start with a valve problem, it could start with a terrible maintenance program. There’s pipes that are old, they just get painted. Different plants have different levels. One plant that I worked in had a very scary chlorine room; things were happening all the time, leaks and this. It’s mechanical, it can fail.

Q: Which plant was that?

B.H.: That was Alvarado. I’ve not worked there in a long time. I understand that it’s gotten better, but there was a time when that room was scary, the pipes were old. The equipment was old....

I mean, I go into that chlorine room, and I say, “Hey, you know, is this thing going to blow up on me or not?” And that’s pretty scary, not only for me personally but for the entire community, and to just touch on one of the reasons why the two operators actually are there all the time is important: if you have a small leak, chances are it’s going to turn into a big leak over time. If you have only one individual there, he is not allowed by law to go in there and fix the problem, so if you have a small leak, and he has to say, you know, call Mo, Larry, and Curly on the phone, help, help, help, I’ve got a leak, and you know it’s leaking, it’s leaking, by the time somebody comes in a half an hour later, that thing could turn into a huge cloud going down the boulevard, and that’s not the way to run an operation, and that’s another resource allocation that the management of the water utilities department has chosen not to put the money into.

Q. After the complaint to Cal-osha, the City hired a consulting firm to draft a plan for dealing with a chlorine emergency at its water treatment plants. What did they conclude? Source: I think you’d never get any of them to say it because they’re taking checks from the City, but I think they were appalled that we had no plan with the size of the facilities that we are and our interface with the community, our proximity. In Miramar we’re within 1000 feet of an elementary school.

Q. What school is that? Source: Miramar Ranch Elementary.

Q. What is the risk to the community?

Source: I think it’s pretty big. We have one operator on site. The way the policy is written now, you don’t go in unless you have backup. In fact, now the policy is to the point that it says you don’t go in at all. You hit the button and you get out. Hopefully that would remediate the majority of the leaks because we’re shutting it off at the main cylinder valves, but there’s still the potential of expo-sure to that, and plant operators and maintenance people are the best qualified to handle these, and they’ve handled these for years. That’s why you don’t hear about chlorine leaks, because people have gone in and taken care of it, sustained the exposures, and kept their mouths shut. That’s not consistent with the law, it’s not in the community’s best interest or the employee’s best interest to do that any longer, but I think that the threat is still very great, especially with one person on shift. If he has a leak at the Miramar facility, hopefully he can shut it down and get out.

If it’s a major problem where that won’t remediate it, he has no choice but to get out and attempt to notify Station 38 and get notification out to the community. It’s a very well-devised plan, but it’s not implemented, and the follow-through as far as who’s going to respond if you have a major incident is yet being developed.

Q. People could theoretically get killed by this if they’re moving in the area?

Source: Yes. And the other side of that is, what if you have an operator who goes into that room and is overcome because of the exposure? You have nobody operating that treatment plant for the next eight hours until the next guy comes in. One of the things we asked for very early on was a risk assessment, a comprehensive risk assessment, that involved not just chlorine only, but all the risks associated with one person working alone in a facility like this. We had asked for a comprehensive risk assessment on several occasions. In one meeting, when we asked for it, the comment was, “Won’t that become a public document?” “Yes, it will.” “Then we don’t want to do that.”

O.E.: They hired four consultants. Spent 50,000-some-odd dollars paying these consultants. I think they asked the consultants obviously what to

come back with. They didn’t want the consultants to say, “Hey, you really need two operators a shift to make sure that this is taken care of, and you really need to train your people so they can actually take care of the problem.” Ah they came up with is a draft plan. The plan hasn’t actually been implemented because there’s not a manager who will put his signature on a piece of paper saying okay, this is the plan, we will now implement it.

Q. So there is still no sign as to when the City will implement the emergency response plan? Source: No. In fact, the current policy is, hit an emergency shutoff at the one facility, at the Miramar plant, and get out of the plant. There is no protection for the employee except to get out of the environment, and generally there is one person on that shift.

Q. And also, what about notifying the surrounding community?

Source: There is no notification procedure. If the operator had the opportunity to call Station 38 — now there should be call sheets that would hopefully notify people, but it’s not very well defined, and the average

person on the shift at this point has no clue because this policy and this procedure has been in a state of flux for almost seven years. I know there are people who say, “I don’t know what I can do anymore. What can I do?” and the response is: you protect yourself and get out. That’s not satisfactory for the employee; that’s not satisfactory for the public water supply or that community. Any of the communities, particularly with Alvarado and the density of community around that area, and Miramar’s the same way. Otay’s a little different because it’s more remote, but construction is going gang-busters down there, so there’s beginning to be more and more population surrounding the facilities. It’s a big concern. Not to mention the fact, on the occasion of 4/14/96, where Bill was overcome, and we were fortunate on that incident that he was able to make a phone call and shut that treatment plant down. He was extremely sick. We referred him to Industrial Medical and had him evaluated. But had it been someone else or had the exposure been a little bit greater we could have lost him on shift. And if that would have been the case, the public water supply would have been untreated during that interim period until [another worker] came in eight hours later to relieve him. They could have found Bill dead on the floor.

Q. So the risks from chlorine and security gaps are continuing to this day?

Source: Right. Even if they eventually got to the point in the very near future where they

developed the response teams to deal with a chlorine release, the procedure says you’ll have that second person there within 15 minutes. You can empty a tiny cylinder, if there’s a significant enough leak, in about 10 minutes. In fact, we had a chlorine response drill, I believe in May 1995, and haz-mat was parked at the front gate of Alvarado, and it took them two and a half hours to remediate that leak on that drill. In the first 10 or 15 minutes, that would have emptied that cylinder, and that community would have been at significant risk, and a drill has not been conducted since that time.

Q. How would they improve on that? You’re saying that the currently proposed, unimplemented plan is inadequate? Source: I don’t think it is [adequate]. If they’re talking about bringing in off-site personnel and bringing them there within 15 minutes, it’s not going to happen. It’s going to be more like 30 or 45 minutes. During that time, if you have the emergency shutoff equipment, you can shut the treatment plant down, and at that point the risk is low pressure and running out of water in the system, depending on what your storage levels are. The best way to resolve this problem is to staff appropriately, so if you have a release you can take care of it immediately, and that means a minimum of two people, maybe three, and that’s what they haven’t wanted to deal with for almost seven years. From a strictly operational, common-sense standpoint, that would be the way to do it.

Unfortunately, what happens is you get people that want to increase the output of the treatment plant and attempt to show DHS [department of health services] that we can maintain water quality, when in reality we can’t, DHS realizes that this was not a water quality test on those filers and the treatment plant; it was strictly a hydraulic test. We’re not even permitted to exceed that six gallons a minute per square foot without requesting DHS approval to that.

There’s an element of people within the City that would like to save the costs and not upgrade those facilities but just run more water through them. The feedback they get from the operations staff is that it’s not prudent and you can’t do that. The consultants express the same concerns, that a 43-minute test is not an appropriate snapshot for how you want to run a facility.

Q. How many people have been exposed to chlorine gas over the last year?

Source: Probably about 16 — 15 or 16. All but two said they » had been exposed. The one employee who said he had not been exposed in fact had been, but said he had not been.

Q: You’ve mentioned that the City management has told the workers not to report this to the State. Can you give me some examples of that?

Source: I can give you three specifics. At the Alvarado Water Treatment Plant, they had a dead bird in one of their reservoirs. The supervisor was preparing to notify dhs as a courtesy; he knew exactly what they needed to do to isolate that reservoir and insure the water was appropriately disinfected. In fact, at that point the superintendent told him, “You are not to call them,” so DHS was not notified.

On another occasion, recently at Alvarado they ran a flow test that exceeded the design capacity of that treatment plant; they’re rated at 120 million a day. The superintendent came over in the absence of that

senior supervisor and directed the staff to run 130 million through that plant; they were going to test it.

The operations supervisor said we need to notify DHS; this was not consistent with what their requirements were. They were told, “No, they don’t have the strength to pull your certificates; we’re not going to notify them.” The second level supervisor called me and explained what was going on, and at that point, I said, “Are you going to call DHS?” He said, “Yes, I am.” I said, “Good, because if you won’t, I am, because the next step is they’ll be at another plant, trying to do the same thing.”

So, in fact, f don’t know if he prevailed on the superintendent at that point to make the call, but I know I’m following up with DHS. The [DHS]

sanitary engineer who attended that and monitored it to make sure it was done properly had said the superintendent did cooperate with him and was grateful that the superintendent had called him. My response was that the only reason the superintendent had called him was because other people threatened to call you; they were going to do this without notifying you.

The third one was at the Otay plant. A manhole that DHS had specifically requested be sealed, because having it not sealed would compromise the filtered water quality. The superintendent directed the senior supervisor to remove that manhole. At that point he said, “We can’t do that; we need to contact dhs; they’ve forbidden us to do that.” The comment was, “I’ve heard your concern, you just do it.” So apparently an altercation resulted as part of that. What finally happened with that was DHS did become involved in that again, and the superintendent backed off and said he didn’t really want the manhole removed, he just wanted to drill through a bolt.

Q. What about other safety and security issues at the plant?

O.E.: We have a facility that is basically wide open. I mean, this is the water system for 500,000 residents of San Diego and Del Mar. This is just Miramar; Alvarado has its own problems and Otay because of its remote location also has those kind of problems. You have people coming across the border all the time and border patrol and people driving around that place.

These filters and basins are wide open. The chemical feed rooms, the chlorine rooms are wide open.

Q. Other than chlorine, what other chemicals used at the treatment plants are valuable to someone who might want to come in and steal them? Source: The primary chemical that we’re concerned about in that regard is potassium chromanganate because it’s used in methamphetamine production, and the people that purchase that are required to sign a release form, or sign a form, so that they’re registered with the DEA to buy that chemical. If we were to come out and say that we have 50,000 pounds of potassium chromanganate on site at a facility, and the wrong people read that or get that information, with one person on shift, they’re tremendously at risk. That’s one reason why nobody has said an awful lot about that. We’ve missed an analytical balance that’s disappeared from the Miramar plant. Otay has unique problems because they’re close to the border; you have people coming in and out through that plant. Illegal, undocumented workers going across that area all the time; there’s no security, there’s no camera, there’s nothing. There’s one person on shift.

Q. Is that all the time, just one person there?

Source: The majority of the time, yes. During the day shift, during the week, they normally have more than that because they have supervision and maintenance there, but after-hours, after four o’clock in the afternoon, during the weekends, there’s only one person on shift.

Q. They lock the gate, but then somebody could come in and climb over?

Source: Yes, climb right over the fence. The Alvarado plant has had a lot of equipment disappear. They have quite a history of things disappearing at that facility. The Miramar plant has had several items disappear — diesel fuel, acts of vandalism. Both of those facilities have security guards who are on duty after-hours; at the Miramar plant it’s just Monday through Friday from seven to five in the morning. At the Alvarado plant, I don’t know what the hours are; Otay has nothing. The Otay and Miramar plants are moving forward to get camera equipment so we can monitor the front gates. In fact, we’re moving forward now to get intrusion alarms, infrared detectors in the hallways so we know someone’s come in, and a bar code reader, because as part of that new chlorine response policy, we’re supposed to be able to account for everyone on site and we can’t, so we have to have that on a database so that when somebody comes in and they’re a bar-coded, legitimate employee, we have a record of them coming in and then we’ll need a security guard to log the rest of the people in. Those facilities are absolutely wide open. Anybody can come in, cut a lock on a gate, and get at the treated water supply. It’s very frightening; it’s been that way for years.

Q. The City has a plan to spend about $800 million or so upgrading the waterworks. But you say you’re skeptical about that. Your fear is that if they put more money in it now, they might just waste it on consultants or something and not actually improve the system? O.E.: Right, and that’s just going by the history. The water fund is not lacking funds; there’s a lot of money in the water fund. You look at the budget every year. There’s a lot of money, and then they carry money over to the next year because they didn’t spend it, and then they move money over to the general fund. Well why is it that they can’t put the resources of the water fund into the actual making of the water, the actual treatment and distribution of that water? They’ve got 900 employees, not counting the millions and millions of dollars they spend for outside consultants and for privatizing major construction projects, and how many people are actually doing the work? They’ve got bureaucrat after bureaucrat, engineers, analysts, deputy directors, department heads, and all these people are just going to meetings and talking about great ways of saving a nickel, and when it comes around full circle, are we putting out the best water?

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