11.01 Public Health Goals Report 2016 2017 and 2018 (2) �oF o�
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�OU�T'�°°' J u ly 9, 2019
TO: Honorable Mayor and Members of the City Council
THRU: Rick Otto, City Manager
FROM: Christopher Cash, Public Works Director
REVIEW: City Manag ' Finance ��
1. SUBJECT
Public Health Goals Report for Years 2016, 2017, and 2018.
2. SUMMARY
The Public Health Goals Report for Years 2016, 2017, and 2018 is a California mandated
report to all water agencies to explain in plain language, information about the presence
of contaminants in the drinking water supply detected at levels above Public Health Goals
published by the State Office of Environmental Health Hazard Assessment during
calendar years 2016, 2017, and 2018.
3. RECOMMENDED ACTION
Receive and file.
4. FISCAL IMPACT
No Fiscal Impact.
5. STRATEGIC PLAN GOALS
Goal 1: Provide for a safe community
b: Provide and maintain infrastructure necessary to ensure the safety of the public.
Goal 2: Be a fiscally healthy community
d: Effectively manage and develop City assets.
6. DISCUSSION AND BACKGROUND
The United States Environmental Protection Agency (USEPA) and the California State
Water Resources Control Board (SWRCB), establish very conservative water quality
standards for domestic drinking water systems. These standards are based on various
risk-assessment factors and are expressed in terms of an allowable Maximum
Contaminant Level (MCL) for every regulated contaminant. The MCL is the regulatory
definition of what is "safe" and they are strictly enforced. Water agencies are required to
take specific actions to notify consumers and to mitigate the problem if an MCL is
ITEM � � 07/09/2019
exceeded. The City of Orange water system consistently meets all federal and state
drinking water MCL standards.
California also establishes Public Health Goals (PHGs) for drinking water systems. The
federal equivalent to.PHG's are called Maximum Contaminant Level Goals (MCLGs).
PHGs and MCLGs are not enforceable standards and water agencies are not required to
take any actions regarding them. These goals are not based on a comprehensive risk
assessment analysis. Instead, they are set to only represent a contaminant level that
would result in either zero health risk or "no significant" health risk for a lifetime of
exposure. Determinations of health risks at these low levels are theoretically based on
risk assessments with many assumptions.
California legislation requires water agencies with over 10,000 services to routinely report
every three years if their water exceeds any PHG or MCLG. The report must identify all
contaminants in excess of a PHG, the public health risks involved and a general estimate
of the costs that would be involved in removing the contaminants in order to meet the
goals. The purpose of this report is to provide consumers with additional information on
the contaminant levels and to furnish information about the cost to eliminate even small
traces of contaminants from the water supply.
All of the water quality data collected in 2016, 2017, and 2018, for the purposes of
determining compliance with drinking water MCL standards, was considered for the
purposes of this report. This data is summarized annually, in the Consumer Confidence
Report that is available to all customers every year.
As indicated previously, the City of Orange water system complies with all federal and
state MCL standards. The City of Orange water supply from both groundwater and
imported sources meets, with three exceptions during the last three years, all of the PHG
and MCLG standards.
� PHG/MCLG Compliance Exceptions:
Durinq Calendar Years 2016. 2017, and 2018
1. Gross (Total) Alpha Activity (Excluding Uranium) was detected in one source
water sample (well) from not detected to 4.55 pico Curies per liter (pCi/L). The
MCL is 15 pCi/L. The EPA MCLG is 0 (zero).
2. (Natural) Uranium was detected in import and five source water samples from
not detected to 7.65 pico Curies per liter (pCi/L). The MCL is 20 pCi/L. The PHG
is 0.43 pCi/L. The EPA MCLG is 0 (zero).
3. Hexavalent Chromium was detected in a single source water sample from not
detected to 1.30 ppb. The California MCL is 10 ppb and the PHG is 0.02 ppb.
In all, the City of Orange water system continues to meet and comply with all federal and
state MCL standards to protect public health.
7. ATTACHMENT
• June 2019 Report on Water Quality Relative to Public Health Goals for Years
2016, 2017, and 2018.
ITEM 2 07/09/2019
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JUNE 2019
CITY OF ORANGE
REPORT ON WATER QUALITY
RELATIVE TO PUBLIC HEALTH GOALS
FOR YEARS 2016, 2017 and 2018
Purqose
Provisions of the California Health and Safety Code (Section 116470 (b)) specify that larger
water utilities (>10,000 service connections) prepare a special report by July 1, 2019 if their
water quality measurements have exceeded any Public Health Goals (PHGs). PHGs are non-
enforceable goals established by the Cal-EPA's Office of Environmental Health Hazard
Assessment (OEHHA). The law also requires that where OEHHA has not adopted a PHG for a
constituent, the water suppliers are to use the M�imum Contaminant Level Goals (MCLGs)
adopted by United States Environmental Protection Agency (USEPA). Only constituents which
have a California primary drinking water standard and for which either a PHG or MCLG has
been set, are to be addressed. This report covers the "detection" of contaminants above both
PHGs and MCLGs found in the City's water system during calendar years 2016, 2017, and 2018.
If a constituent was detected in the City's water supply between 2016 and 2018 at a level
exceeding an applicable PHG or MCLG, this report provides the information required by law.
Included is the public health risk associated with the MCL and the PHG or MCLG, the category
or type of risk to health that could be associated with each constituent, the best treatment
technology available that could be used to reduce the constituent level, and an estimate of the
cost to install that treatment if it is appropriate and feasible
Background
The USEPA and the OEHHA established very conservative water quality standards for domestic
drinking water systems. These standards are based on various risk-assessment factors and are
expressed in terms of an allowable Maximum Contaminant Level (MCL) for every regulated
contaminant. The MCL is the regulatory definition of what is "safe". The MCLs are strictly
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enforced. Water agencies are required to take specific actions to notify consumers and to
mitigate the problem if an MCL is exceeded. The Cit�of Orange wateY system consistently
meets all federal and state drinking water MCL standards.
OEHHA also establishes PHGs for drinking water systems. PHGs are based solely on public
health risk considerations. None of the practical risk-management factors that are considered by
the USEPA or the California State Water Resources Control Board (SWRCB) in setting drinking
water standards (MCLs) are considered in setting the PHGs. These factors include analytical
detection capability, treatment technology available, benefits and costs. The federal equivalent
to PHGs are called Maximum Contaminant Level Goals (MCLGs). PHGs and MCLGs are not
enforceable standards. Water agencies are not reauired to take any actions re a� rdin t� hem.
These goals are not based on a comprehensive risk assessment analysis. Instead, they are set to
only represent a contaminant level that would result in either zero health risk or "no significant"
(one in a million) health risk for a lifetime of exposure. Detertninations of health risks at these
low levels are frequently and theoretically, based on risk assessments with many assumptions.
Many PHGs are set at zero.
California legislation requires water agencies to prepare a special report every three years, if
their water exceeds any PHG or MCLG. The report must identify all contaminants in excess of a
PHG/MCLG, the public health risks involved and a general estimate of the costs that would be
involved in removing the contaminants in order to meet the goals. The purpose of this report is
to provide consumers with additional information on the contaminant levels and to fiirnish
information about the cost to reduce to below the PHG/MCLG level or basically eliminate even
small traces of contaminants from the water supply.
Both the USEPA and SWRCB adopt what are known as BATs or Best Available Technologies,
which are the best-known methods of reducing contaminant levels to the MCL. Costs can be
estimated for such technologies. However, since many PHGs and all MCLGs are set much
lower than the MCL, it is not always possible, nor feasible to determine what treatment is needed
to further reduce a constituent downward to or near the PHG or MCLG, many of which are set at
zero. Estimating the costs to reduce a constituent to zero is difficult, if not impossible because it
is not possible to. verify by analytical means that the level has been lowered to zero. In some
cases, installing treatment to try and further reduce very low levels of one constituent may have
adverse effects on other aspects of water quality.
All of the water quality data collected in 2016, 2017 and 2018, for the purposes of determining
compliance with drinking water MCL standards, was considered for the purposes of this report.
Every year all water quality results are summarized in the Annual Consumer Confidence Report
which is made available to all customers and is posted online at www.cityoforange.org/ccr. As
indicated previously, the City of Orange water system complies with all federal and state MCL
standards. The City of Orange water supply, which includes water from wells and imported
sources meets all of the PHG and MCLG standaxds, with only three exceptions during the last
three years.
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PHG/MCLG Compliance Exceptions
Durin� Calendar Years 2016, 2017 and 2018
• Gross (Total) Alpha Activity (Excluding Uranium) was detected in one source water
sample (well) from not detected to 4.55 pico Curies per liter (pCi/L). The MCL is 15
pCi/L. The EPA MCLG is 0 (zero).
• (Natural) Uranium was detected in import and five sources water samples (wells) from
not detected to 7.65 pico Curies per liter (pCi/L). The MCL is 20 pCi/L. The PHG is
0.43 pCi/L. The EPA MCLG is 0 (zero).
• Hexavalent Chromium was detected in one source water sample (well) from not detected
to 1.30 ppb. The MCL is 10 ppb and the PHG is 0.02 ppb.
Radionuclides
Many naturally occurring substances and a few man-made ones have the potential to emit
ionizing radiation, and are therefore referred to as radionuclides. Of the radionuclides that have
been observed in drinking water, most are naturally occurring. The naturally occurring
constituents of greatest concern in drinking water are uranium and radium-226 and radium-228.
Most of the naturally occurring radionuclides are alpha particle emitters. Contamination by man-
made nuclear materials can also occur. The man-made radionuclides, which are primarily beta
and photon emitters, are produced by a number of activities that involve the use of concentrated
radioactive materials. These include production of electricity, nuclear medicines used in therapy
and diagnosis, and various commercial products such as televisions or smoke detectors. The City
of Orange is only required to monitor its ground water and surface water supplies for naturally
occurring radionuclides. Exposure to radionuclides from drinking water results in an increased
risk of cancer. In addition to cancer, exposure to uranium has the potential to cause kidney
damage. In California, the radionuclides currently regulated in drinking water are gross alpha
particle activity, radium-226 and radium-228, uranium; and beta and photon emitters. Of those
radionuclides, gross alpha particle activity and uranium were detected in import and ground
water sources serving the City of Orange below the MCL but above the PHG/MCLG.
Gross (Total) Alnha
Gross or total alpha particle activity is used as a screening tool to possibly avoid testing for other
radionuclides. There is no PHG for gross alpha particle activity but the MCLG set by the
USEPA is 0 (zero) pico Curies per liter (pCi/L). The MCL for drinking water standard is 15
pCi/L. Orange is required to monitor each of its drinking water wells for gross alpha particle
activity at least once every four years. During the three-year•period (2016-2018) covered by this
report, gross alpha particle activity was measured in 1 of the City's wells in amounts ranging
from not-detected to 4.55 pCi/L. Gross Alpha particle was NOT detected in any import water
sources. The levels detected were below the MCL at all times. The Citv water system is in �
com�liance with federal and state rules for oss alpha particle activit�
The category of health risk associated with gross alpha particle activity is carcinogenicity.
People who drink water containing gross alpha particle activity above the MCL throughout their
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lifetime could experience an increased risk of getting cancer. The Best Available Treatment
Technologies (BAT) to lower the level of alpha particles to the MCLG is reverse osmosis, while
ion exchange is also a possible treatment option. It is not known if either technology is feasible
of achieving the MCLG level of zero pCi/L. In studies conducted to remove contaminant via
Reverse Osmosis by CH2M Hill for City of Scottsdale, AZ, the annualized capital and O&M
costs ranged from $1.82 to $6.65 per 1,000 gallons treated. To treat the affected well, it is
estimated that it would cost approximately $9 million per year to reduce the level of alpha
particle activity. While one well is currently affected, with the randomly occurring nature of
how total alpha particle activity is being detected in the wells, successful reduction treatment for
total alpha particle activity over time may include more wells, which in turn, would considerably
raise the cost. In addition, since there is little data readily available to estimate cost of treatment
to achieve absolute zero, installation of treatment may not necessarily achieve the MCLG and the
costs may be significantly higher to do so.
Uranium
Uranium is the heaviest naturally occurring element. It is a mixture of three radioactive isotopes:
U-238, U-235, and U-234. The isotope U-238 comprises over 99% of naturally occurring
uranium. A Public Health Goal (PHG) for uranium was first established in 2001. The MCL for
Uranium is 20 pico-Curies per liter (pCi/1). The PHG for uranium is 0.43 pCi/l. The EPA
MCLG is 0 (zero). The category of health risk for uranium is cancer and possible kidney
toxicity.
Uranium test results for the City for the period 2016-2018 from all groundwater and import
sources had a range of not detected to 7.65 pCi/1. Uranium was found to occur in five
groundwater wells. Uranium was also detected in import water sources in amounts ranging from
not detected to 3.0 pCi/L. The levels detected were below the MCL at all times. The Ci, water
system is in�ull compliance with,federal and state rules for uranium.
Treatment considerations would again focus on the five affected groundwater (well) sources and
import connections. Treatment options include reverse osmosis or ion exchange. As similarly
discussed for gross alpha particle activity, costs to remove uranium are estimated to run upwaxds
of$36 million annually. It is to be noted that in treating (for removal) of any one of the above
contaminants, would effectively remove all the noted contaminates in this report. Efficiencies in
excess of 95% removal would be necessary to achieve PHG levels for uranium and could likely
be more costly than referenced due to the variable removal rate. Likewise and similar to gross
alpha, the randomly occurring nature of uranium may necessitate further treatment at differing
wells which could raise the cost significantly.
Hexavalent Chromium (Chromium VI)
Hexavalent chromium (or Chromium-6), is a highly toxic form of the naturally occurring metal
chromium. It is an odorless and tasteless metallic element. Chromium is found naturally in
rocks, plants, soil and volcanic dust, and animals. The most common forms of chromium that
occur in natural waters in the environment are:
Trivalent chromium(chromium-3)
Hexavalent chromium(chromium-6)
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Chromium-3 is an essential human dietary element. It is found in many vegetables, fruits, meats,
grains and yeast. Chromium-6 occurs naturally in the environment from the erosion of natural
chromium deposits. It can also be produced by industrial processes. There are demonstrated
instances of chromium being released to the environment by leakage,poor storage, or inadequate
industrial waste disposal practices.
Chromium-6 is recognized as a human carcinogen via inhalation, which can increase the risk of
lung cancer. Exposure to hexavalent chromium from breathing dust or fumes is considered to
have a much higher risk than exposure from drinking water. Research data collected from China
found increased rates of stomach cancer in people who may have been exposed to very high
levels of hexavalent chromium in drinking water.
In 2010, the USEPA released a draft human health assessment proposing to classify hexavalent
chromium as a likely to be carcinogenic via ingestion. USEPA was advised by a peer review
panel in 2012 to consider the results from research funded through the American Chemistry
Council. The new research replicates the earlier National Toxicology Program (NTP) study at
lower doses of hexavalent chromium and seeks to identify the underlying cause for
carcinogenicity from oral exposure. The completion of the USEPA human risk assessment and
fmal determination of human carcinogenicity of hexavalent chromium via oral ingestion is still
pending. In 2012, the USEPA finalized the third Unregulated Contaminant Monitoring Rule
(UCMR3) which requires water systems serving greater than 10,000 persons to monitor for
hexavalent chromium and total chromium.
In July, 2011 California finalized its Public Health Goal at 0.02 ug/L in drinking water.
California found sufficient evidence that hexavalent chromium is carcinogenic by oral exposure,
based on the NTP long term animal study. The California PHG is based solely on health effects
and is set at a level determined to not pose any significant risk to health.
Hexavalent chromium test results for the City for the period (2016-2018) from a single well that
had one detection for a range of not detected to 1.3 ppb. Hexavalent chromium was NOT
detected in any import water sources. The level detected was below the MCL of 10 ppb at all
times. The City water system is in full compliance with federal and state rules for hexavalent
chromium.
The treatment consideration for hexavalent chromium would focus on a single affected
groundwater (well) source. Treatment options include reverse osmosis or ion exchange. As
similarly discussed for gross alpha particle activity and uranium above, costs to remove
hexavalent chromium are estimated to run upwards of$10 million annually.
Other Discussion (Lead & Copperl
There is no MCL for Lead or Copper. Instead, the 90�` percentile value of all samples from
household taps in the distribution system cannot exceed an Action Level (AL) of 0.015 mg/1 for
lead and 1.3 mg/1 for copper. The PHG for lead is 0.0002 mg/1. The PHG for copper is 0.3 mg/1.
The category of health risk for exposure to lead is potential damage to the brain, red blood cells,
and kidneys especially in young children or pregnant women. The risk of exposure for copper is
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stomach and intestinal distress, liver or kidney damage, and complications of Wilson's disease in
genetically predisposed people
Lead and copper test results were not detected for all samples taken from imported water
sources. Lead and copper tests results for wells were none detected for lead and 0.0014 to
0.0021 mg/L for copper over the test period. Based upon extensive sampling of our distribution
system from customer's internal taps, our 90th percentile for lead was 0.0047 mg/L (no home
above the AL) and the 90th percentile for copper was 0.16 mg/L (no homes above the AL).
Therefore, Orange remains under the AL for lead and copper and are deemed to have "optimized
corrosion control" for our system.
In general, optimizing corrosion control is considered to be the best available technology to deal
with corrosion issues and with any lead or copper findings. We continue to monitor our water
quality parameters related to corrosivity, such as pH, hardness, alkalinity, and total dissolved
solids. The Langelier Index (LI) is another indicator of corrosivity. A positive LI indicates non-
corrosive water. All City water sources have positive LI's and are therefore considered non-
corrosive.
Conclusion
PHGs and MCLGs are not enforceable and are not required to be met by any public water
system. They are set based upon "zero" or "no significant" risks without consideration of
practical risk management factors such as analytical detection ability to test at PHG or MCLG
threshold levels, available treatment technologies, benefits, and costs. Public water systems are
held accountable to Maximutn Contaminant Levels (MCLs) for compliance with water quality
standards. The Citv of OYan�e water system continues to meet all federal and state drinking
water standards to protect public health. ,
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