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HomeMy WebLinkAbout#8 Public Health Goals AGENDA ITEM #8 r P, I Public Utility District MEETING DATE: October 2, 2024 TO: Board of Directors FROM: Chad Reed, Water Utility Director SUBJECT: Notice of Public Hearing for the District's 2024 Public Health Goals Report APPROVED BY: Brian C. Wright, General Manager RECOMMENDATION: Conduct a Public Hearing 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). PHG's are non- enforceable goals established by the California Environmental Protection Agency (Cal- EPA) office of Environmental Health Hazard Assessment (OEHHA). PHG's are long- term goals that are well beyond the current acceptable safe drinking water limits, Maximum Contaminant Level Goals (MCLG). The law also requires that where a PHG for a constituent has not been established, the water suppliers are to use the MCLG adopted by the United States Environmental Protection Agency (USEPA). The only constituents addressed in the District's Public Health Goals are constituents with a California primary drinking water standard, for which either a PHG or an MCLG has been set. While the District's drinking water supply meets or exceeds all State and Federal standards, as reported in the District's annual Consumer Confidence Report, arsenic continues to exceed the applicable PHG. The Public Health Goals Report reflects when arsenic was detected in the Truckee Donner Public Utility District in the years 2021 through 2024, at a level exceeding the PHG or MCLG. Included in the report are: • 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 arsenic Page 1 of 3 Page 10 of 231 • The best treatment technology available that could be used to reduce the arsenic level; and • An estimate of the cost to install that treatment if it is appropriate and feasible. California Senate Bill (SB) 1307 requires that public water systems 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 Board Meeting on August 3, 2022. ANALYSIS AND BODY: The Truckee Donner Public Utility District 2024 Public Health Goals Report has been prepared for review and publication (See Attachment) 1). 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 presented to the District's water utility customers in the form of a publicly scheduled hearing. The Board scheduled this hearing to be held at the regularly scheduled meeting on September 4, 2024, at 6:OOpm or shortly thereafter. As documented in the Public Health Goals Report, the District's drinking water quality meets all State of California Department of Public Health and USEPA drinking water standards set to protect public health. The only PHG covered in the District's Public Health Goals Report was arsenic, which is a naturally occurring element found in regions with volcanic and granite rock formations. During the prescribed time, 6 of the District's wells exceeded the PHG. However, none of the wells exceeded the MCLG. Treatment options were reviewed, but none were recommended. The staff is recommending no additional action be taken to address the arsenic levels, because: • Historically, the local groundwater arsenic levels have been relatively stable, with measurable concentrations below the regulatory action levels; • The cost to reduce the level of arsenic identified in this report is estimated to exceed $7.2 million dollars per year plus capital costs in excess of $8.5 million for the treatment systems; • The effectiveness of the treatment processes to provide significant reductions in constituent levels at these already low values is uncertain; and The health protection benefits of these further hypothetical reductions are not clear and may not be quantifiable. 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 Page 2 of 3 Page 11 of 231 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 2. Environmental Stewardship: Create a sustainable resilient environment for all our communities. 3. Engage with our customers and communities in a welcoming and transparent way to identify opportunities. FISCAL IMPACT: There is no direct fiscal impact with this Public Hearing. ATTACHMENTS: 1. 2024-Public Health Goals Page 3 of 3 Page 12 of 231 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. PUB`II�; 'J SPECIAL MTRICT 11570 Donner Pass Road,Truckee,CA 96161 1 (530)587-3896 1 tdpud.org 015`'ER °� LEMERSNIPFRwIamRN Page 13 of 231 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) Page 14 of 231 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. Page 15 of 231 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. Page 16 of 231 Page 17 of 231