HomeMy WebLinkAbout#14 Public Hearing Health Goals AGENDA ITEM #14
Public Utility District m
MEETING DATE: September 4, 2024
TO: Board of Directors
FROM: Chad Reed, Water Utility Director
SUBJECT: Request to Schedule a Public Hearing on the District's 2022 Public
Health Goals.
APPROVED BY:
Brian C. Wright, General Manager
RECOMMENDATION:
Schedule a Public Hearing for October 2, 2024 at 6:OOPM or shortly thereafter to
receive input from the public regarding the District's 2024 Public Health Goals Report.
BACKGROUND:
Provisions of the California Health and Safety Code specify that larger water utilities
(>10,000 service connections) prepare a special report if any of their water quality
measurements have exceeded any Public Health Goal (PHG). The law also requires
that where a PHG for a constituent has not been established, the water suppliers are to
use the Maximum Contaminant Level Goals (MCLG) adopted by the United States
Environmental Protection Agency (USEPA). Only constituents with a California primary
drinking water standard, and for which either a PHG or an MCLG has been set, will be
addressed. There are a few constituents that are routinely detected in water systems at
levels usually well below the drinking water standards, for which no PHG or MCLG has
yet been adopted. These will be addressed in the future, as they are adopted by either
State or Federal standards. If a constituent was detected in Truckee Donner Public
Utility District in the years 2021 through 2023 at a level exceeding an applicable PHG or
MCLG, this report provides the information required for our customers. Included is:
• The numerical public health risk associated with the Maximum Contaminant
Level (MCL) and the PHG or MCLG. (MCLs are set by the USEPA or the
California Department of Public Health in their enforceable drinking water
standards).
• 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.
• An estimate of the cost to install that treatment if it is appropriate and feasible
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Page 45 of 72
SB 1307 requires public water systems to present the report in the form of a public
hearing, providing an opportunity for customer input. Previously, the TDPUD 2021
Water Utility Public Health Goal Report was presented in a public hearing held at the
District's July 2022 Board Meeting Informational area.
ANALYSIS AND BODY:
The Truckee Donner Public Utility District 2024 Public Health Goals Report has been
prepared for review and publication. In accordance with SB 1307, following the Public
Hearing, staff will notify the California State Water Resources Control Board, Division of
Drinking Water, that a Public Health Goals Report has been prepared, and will be
presented to the District's water utility customers in a publicly scheduled hearing.
Public notice of the hearing to receive public input regarding the District's 2024 Public
Health Goals Report requires publication of a notice in a generally circulated
newspaper for two successive weeks, with at least five days between the respective
publication dates and at least 10 days prior to the public hearing. The notice will be
published in the Sierra Sun in accordance with the District Code. The District's 2024
Public Health Goals Report is Attachment 1.
GOALS AND OBJECTIVES:
District Code 1.05.020 Objectives:
1. Responsibly serve the public.
3. Provide reliable and high quality water supply and distribution system to meet
current and future needs.
6. Manage the District in an effective, efficient and fiscally responsible manner.
District Code 1.05.030 Goals:
1. Manage for Financial Stability and Resiliency
FISCAL IMPACT:
There is no anticipated fiscal impact with this public hearing.
ATTACHMENTS:
1. 2024-Public Health Goals
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TRUCKEE DONNER
DistrictPublic Mility
General Manager
Brian C.Wright
TRUCKEE DONNER PUBLIC UTILITY DISTRICT
Executive 2024 PUBLIC HEALTH GOALS REPORT
Leadership Team
Chad J.Reed
Water Utility Director
Jared Carpenter Background
Electric Utility Director
Scott Crow Provisions of the California Health and Safety Code specify that larger
ITDirector/CIO (>10,000 service connections) water utilities prepare a special report by July 1,
Steven Poncelet 2024 if water quality measurements have exceeded any Public Health Goals
PI &strategic Affairs (PHGs). PHGs are non-enforceable goals established by the California
Director Environmental Protection Agency's (Cal-EPA) Office of Environmental Health
Michael Salmon Hazard Assessment (OEHHA). The regulation also requires that where OEHHA
Chief Financial Officer has not adopted a PHG for a constituent, the water suppliers are to use the
Allian Steward Maximum Contaminant Level Goals (MCLG) adopted by the United States
Director of Human
Resources and Environmental Protection Agency (USEPA). Only constituents which have a
Risk Management California primary drinking water standard and for which either a PHG or MCLG
Board of Directors
has been set are to be addressed.
Joseph Aguera
Jeff Bender There are a few constituents that are routinely detected in water
Christa Finn systems at levels usually well below the drinking water standards for which no
Kim Harris PHG nor MCLG have been adopted by OEHHA or USEPA including Total
Tony Laliotis
Trihalomethanes. These will be addressed in a future required report after a PHG
has been adopted.
The regulation specifies what information is to be provided in the report.
If a constituent was detected in the Truckee Donner Public Utility District's
(TDPUD) water supply between 2021 and 2024, at a level exceeding an
applicable PHG or MCLG, this report provides the information required under the
regulation. Included is the numerical public health risk associated with the
Maximum Contaminant Level (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.
What Are PHGs?
PHGs are set by the California Office of Environmental Health Hazard
Assessment (OEHHA) which is part of Cal-EPA and are based solely on public
health risk considerations. None of the practical risk-management factors that
are considered by the USEPA or the California Department of Health Services
(CDHS) in setting drinking water standards are considered in setting the PHGs.
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These factors include analytical detection capability, treatment technology
available, benefits and costs. The PHGs are not enforceable and are not required
to be met by any public water system. MCI-Gs are the federal equivalent to
PHGs.
Water Quality Data Considered
All of the water quality data collected by the TDPUD water utility between 2021 and
2024, for purposes of determining compliance with drinking water standards was considered.
This data was all summarized in our 2021, 2022, and 2023 Annual Water Consumer Confidence
Reports which were posted on the TDPUD website for customers to review by July 1st of each
subsequent year.
Guidelines Followed
The Association of California Water Agencies (ACWA) formed a workgroup which
prepared guidelines for water utilities to use in preparing these newly required reports. The
ACWA and California Department of Public Health guidelines were used in the preparation of
this report.
Best Available Treatment Technology and Cost Estimates
Both the USEPA and CDHS 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
or close to 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.
Constituents Detected That Exceed a PHG or a MCLG
The following is a discussion of constituents that were detected in one or more of the
TDPUD's drinking water sources at levels above the PHG, or if no PHG, above the MCLG.
Arsenic: The MCL for arsenic is 10 parts per billion (ppb), the PHG and MCLG for arsenic is
0.004ppb. We have detected arsenic in 6 of our 10 wells, Martis Valley Well 9.8, Glenshire Dr
Well 9.0, Airport Well 7.3, Prosser Village Well 2.4, Sanders Well 8.8, and Old Greenwood Well
10. It is important to note that the Glenshire Drive Well, Old Greenwood Well and Prosser
Village Well are delivered through a California State Water Resources Control Board (SWRCB)
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approved blending permit maintaining post blend water deliveries with arsenic concentrations
below the MCL.
The category of health risk associated with arsenic, and the reason that a drinking water
standard was adopted for it, is that continuous long-term exposures to drinking water
containing arsenic levels above the MCL may increase the risk of cancer. The California Office of
Environmental Health Hazard Assessment (OEHHA) has set the PHG at 0.004ppb. The PHG is
based on a level that will result in not more than 1 excess cancer in 1 million people who drink 2
liters daily of this water for 70 years. The actual cancer risk may be lower or zero. The BAT that
we are using for this report to lower the level below the MCL to .004ppb is fixed bed adsorption
system. The estimated cost to install and operate such a treatment system on all 6 Wells that
would reliably reduce the Arsenic level to .004ppb would be approximately $8,505,000 initial
construction cost with additional estimated 0&M cost of an $7,245,000 per year. This would
result in an assumed increased cost for each customer of approximately$528 per year.
Lead: The MCL for Lead in drinking water is 15ppb, while the PHG and MCLG is
0.2ppb. The current PHG for Lead was established in 2009, lowered from the previous
PHG of 2.Oppb established in 1997, based upon calculated carcinogenic health effects and
neurobehavioral deficits. The District conducts sampling for the presence of lead every three
years in accordance with the Lead and Copper Rule (LCR). Action levels for lead is based on
90th percentile concentration levels from first draw residential sample taps. The District's last
LCR monitoring period and sample collection was in 2016, in which sample testing results
indicated a 90th percentile level of 7.Oppb.
Levels of lead in surface and groundwater throughout the United States typically range
between 5 and 30 ppb (OEHHA, 2009). In drinking water, the major source of lead is due to the
leaching from residential plumbing and solder used in pipe joints. The leaching of lead from
residential plumbing is of particular concern in circumstance where older plumbing
infrastructure is exposed to aggressive water quality conditions.
Lead is listed as a carcinogen and as a reproductive and developmental toxic chemical under
the Safe Drinking Water and Toxic Enforcement Act of 1986 (California Health and Safety Code).
The calculated health risk for lead at the MCL (15ppb) is two per million. The calculated health
risk at the PHG (0.2ppb) is not available.
BAT for drinking water systems exceeding the 90th percentile for the action level of lead
concentrations (15ppb) is "optimized corrosion control". For systems in which the lead
concentration levels are above the PHG of 0.2ppb, it is not clear what additional steps could be
considered, particularly without causing other potential water quality problems. Without
further comprehensive study, it is uncertain if a true assessment of the cost of mitigation for
lead concentrations well below the action level can be determined with any degree of accuracy.
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RECOMMENDATIONS FOR FURTHER ACTION
The drinking water quality of the Truckee Donner Public Utility District at this time
meets all California State Water Resources Control Board and USEPA drinking water standards
set to protect public health. To further reduce the levels of the constituents identified in this
report that are already below the health-based MCLs established to provide "safe drinking
water", additional costly treatment processes would be required. The effectiveness of the
treatment processes to provide any significant reductions in constituent levels at these already
low values is uncertain. The health protection benefits of these further hypothetical reductions
are not at all clear and may not be quantifiable. Therefore, no action is proposed.
The money that would be required for these additional treatment processes might provide
greater public health protection benefits if spent on other water system operation, surveillance,
and monitoring programs.
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