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This paper discusses startup activities and the first year of operation of the 100 mgd Twin Oaks Valley WTP (TOVWTP) in San Diego, California, with particular attention to the permitting process with the state regulator, California Department of Public Health (CDPH) and the adaptation of the Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) framework to meet CDPH's requirements. The information presented here has industry-wide value given the sensitivity of the issues discussed and the scale of this facility. Issues to be discussed are: development of a practical integrity verification plan (IVP); on-site validation of the volumetric concentration factor (VCF), including verification of the actual VCF in the membrane tank compared the theoretical guidelines provided in the Membrane Filtration Guidance Manual (MFGM), and impact of the return stream on VCF; correlation between LRV for different target organism; and, membrane integrity test frequency during plant startup.