HomeMy WebLinkAboutAgenda Report - August 18, 2010 D-18 PHAGENDA ITEMb-01
CITY OF LODI
COUNCIL COMMUNICATION
AGENDA TITLE: Set Public Hearing for October 6, 2010, to Receive Comments on and Consider
Accepting City of Lodi's Report on Water Quality Relativeto Public Health Goals
MEETING DATE: August 18, 2010
PREPARED BY: Public Works Director
RECOMMENDED ACTION: Set a public hearing for October 6, 2010, to receive comments on
and consider accepting the City of Lodi's Report on Water Quality
Relativeto Public Health Goals.
BACKGROUND INFORMATION: Attached is a report prepared by staff comparing Lodi's drinking
water with the California Environmental Protection Agency's public
health goals (PHGs) and with the United States Environmental
Protection Agency's maximum contaminant level goals (MCLGs).
PHGs and MCLGs are not enforceable standards and no action to meet them is mandated.
California Code of Regulations, Title 22, Section 116470, mandatesthat a report be prepared every three
years. The attached report is intended to provide information to the public, in addition to the Annual
Water Quality Report mailed to each customer in April 2010. On August 7, 2010, a public notice
appeared in the Lodi News Senfinel to inform any interested party of the Public Health Goals Report and
its availability. The Report is also posted on the City's website.
The law also requires that a public hearing be held (which can be part of a regularly -scheduled public
meeting) for the purpose of accepting and responding to public comment on the report. A notice of public
hearing will be published in the Lodi News Senfinel.
Our water system complies with all of the health -based drinking water standards and maximum
contaminant levels as required by the California Department of Health Services and the United States
Environmental Protection Agency. No additional actions are required or recommended.
FISCAL IMPACT: Not applicable.
FUNDING AVAILABLE: Not applicable.
j
F. Waliv San lin
Public Works Director
Prepared by Charles E. Swimley, Jr., Deputy Public Works Director— Utilities
FWS/CS/pmf
Attachment
cc: Charles E. Swimley, Jr., Deputy Public Works Director— Utilities
Mike Schafer, Laboratory/Environmental Compliance Superintendent
APPROVED: c
Konradt Rartlam, Interim City Manager
K:\WP\COUNCIL\2010\SetPH—PublicHealthGoalsReport.doc 8/4/2010
CITY OF LODI
REPORT ON WATER QUALITY
RELATIVE TO PUBLIC HEALTH GOALS
JUNE 2010
Background
Provisions of the California Health and Safety Code, Title 22, Section 116470, specify that
larger water utilities (more than 10,000 service connections), are required to prepare a special
report every three years detailing if their water quality measurements have exceeded any
Public Health goals (PHGs). These are non -enforceable goals established by the Cal -EPA's
Office of Environmental Health Hazard Assessment. The law also requires that where Cal -
EPA has not adopted a PHG for a constituent, the water suppliers are to use the enforceable
Maximum Contaminant Level Goals (MCLGs) adopted by the United States Environmental
Protection Agency (U.S. EPA). 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 per
regulations.
The law specifies what information is to be provided in the report. If a constituent was
detected in the water supply at a level exceeding an applicable PHG or MCLG, this report
provides the information required by law. Included are:
• 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;
• An estimate of the cost to install that treatment if it is appropriate and feasible.
What are PHGs?
PHGs are Public Health Goals set by the California Environmental Protection Agency's
Office of Environmental Health Hazard Assessment and are based solely on public health risk
considerations. None of the practical risk -management factors that are considered by the U.S.
EPA or the California Department of Health Services in setting enforceable drinking water
standards (Maximum Contaminant Levels or MCLs) are considered in setting the PHGs.
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. MCLGs are the federal equivalent to PHGs.
Water Oualitv Data Considered:
All of the water quality data collected by our water system in 2007-2009 for purposes of
determining compliance with drinking water standards was considered. In the attached 2009
Annual Water Quality Report which was mailed to our customers in April 2010, only data
from 2009 was summarized. The attached 2009 Annual Water Quality Report also contains
useful definitions for PHG, MCLG, MCL, microgram per liter, and milligram per liter.
Report on Water Quality Relative to Public Health Goals
June 2010
Page 2
Guidelines Followed:
The Association of California Water Agencies prepared guidelines for water utilities to use in
preparing these required reports, and these guidelines were used in the preparation of our
report. No guidance was available from state regulatory agencies.
Best Available Treatment Technology and Cost Estimates:
Both the U.S. EPA and the California Department of Health Services adopt what are known
as Best Available Technologies or BATs 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 a 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. For example; to meet the Copper PHG, chemicals to further coat
home plumbing would need to be added to Lodi's drinking water, and in GAC treatment
systems, more frequent change outs of carbon and larger vessels keeping water in contact with
activated carbon longer can both increase the risk of bacterial contamination.
The estimates below reflect only wellhead treatment capital and annual operation and
maintenance costs for typical wells. Design, potential costs for additional land and other site
specific requirements are not included, thus the potential costs are understated. These costs
are not indicative of the total past and potential future costs to remediate groundwater
throughout Lodi.
Constituents Detected That Exceed a PHG or a MCLG:
The following is a discussion of constituents that were detected in one or more of our drinking
water sources at levels above the PHG, or if no PHG, above the MCLG.
TrichloroethyleneCE): The PHG for TCE is 1.7 micrograms per liter (ug/L or parts per
billion). The MCL or drinking water standard for TCE is 5 ug/L. We detected TCE at levels
not exceeding the MCL in the discharge from 1 of Lodi's 25 City Wells used in 2009. The
average for this City Well in 2007-09 was:
City Well No. 2 - 2.6 ug/L
The category of health risk associated with TCE, and the reason that a drinking water standard
was adopted for it, is the people who drink water containing TCE above the MCL throughout
their lifetime could theoretically experience an increased risk of getting cancer. The California
Department of Health Services says that "Drinking water which meets this standard (the
MCL) is associated with little to none of this risk and should be considered safe with respect
to TCE." (CDHS Blue Book of drinking water law and regulations, Section 64468.21 Title 22,
CCR.) The Best Available Technology for TCE to lower the level below the MCL is either
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 3
Granular Activated Carbon or Packed Tower Aeration. The estimated cost to install such a
treatment system on one City Well and enhance the capacity on one City Well with an
existing treatment system that would reliably reduce the TCE level to below 1.7 ug/L would
be approximately $490,000 and require annual Operation and Maintenance at a cost of
approximately $77,000 per year. This would result in an assumed increased cost for each
customer of approximately $5 per year*.
Dibromochloropropane (DBCP): The PHG for DBCP is 1.7 nanograms per liter (ng/L or
parts per trillion). The MCL for DBCP is 200 ng/L. We detected DBCP at levels not
exceeding the MCL in the discharges from thirteen of Lodi's 25 City Wells used in 2009.
City Well No. 8 was not used in 2009, but could be used if treatment were installed and is
included in cost calculations. The averages for these City Wells in 2007-09 were:
City Well No.
1R
City Well No.
4R
City Well No.
6R
City Well No.
8
City Well No.
13
City Well No.
14
City Well No.
16
City Well No.
17
City Well No.
19
City Well No.
21
City Well No.
22
City Well No.
23
- 82
ng/L
- 37
ng/L
- 150
ng/L
- 223
ng/L
- 65
ng/L
- 58
ng/L
- 47
ng/L
- 217
ng/L
- 80
ng/L
- 1
ng/L
- 56
ng/L
- 48
ng/L
The category for health risk associated with DBCP, and the reason that a drinking water
standard was adopted for it, is the people who drink water containing DBCP above the MCL
throughout their lifetime could theoretically experience an increased risk of getting cancer.
The California Department of Health Services says that "Drinking water which meets this
standard (the MCL) is associated with little to none of this risk and should be considered safe
with respect to DBCP." (CDHS Blue Book of drinking water law and regulations, Section
64468.3, Title 22, CCR) The numerical health risk for an MCLG of zero is zero. The Best
Available Technology for DBCP to lower the level below the MCL is either Granular
Activated Carbon or Packed Tower Aeration. To attempt to maintain the DBCP levels at zero,
Granular Activated Carbon Treatment Systems with longer empty bed contact times and more
frequent carbon change -outs would likely be required. The estimated cost to install such a
treatment system on eight City Wells, and enhance capacities on six City Wells with existing
treatment systems that would reliably reduce the DBCP level to zero would be approximately
$3.9 million. The increased annual Operation and Maintenance costs would be approximately
$580,000 per year. This would result in an assumed increased cost for each customer of
approximately $42 per year*. (Note: this increase cost may not be reimbursable under the
terms of Lodi's settlement agreement with DBCP manufacturers.)
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 4
1,1,2,2- Tetrachloroethylene (PCE): The PHG for PCE is 0.06 micrograms per liter (ug/L or
parts per billion). The MCL or drinking water standard for PCE is 5 ug/L. We detected PCE at
levels not exceeding the MCL in the discharges from two (2) of Lodi's 25 City Wells used in
2009. City Well No. 8 was not used in 2009, but could be used if treatment were installed and
is included in cost calculations. The averages of these City Wells in 2007-09 were:
City Well No. 6R - 1.84 ug/L
City Well No. 8 - 0.82 ug/L
City Well No. 12 - 0.47 ug/L
The category of health risk associated with PCE, and the reason that a drinking water standard
was adopted for it, is the people who drink water containing PCE above the MCL throughout
their lifetime could theoretically experience an increased risk of getting cancer. The California
Department of Health Services says that "Drinking water which meets this standard (the
MCL) is associated with little to none of this risk and should be considered safe with respect
to PCE." (CDHS Blue Book of drinking water law and regulations, Section 64468.2, Title 22,
CCR.) The Best Available Technology for PCE to lower the level below the MCL is either
Granular Activated Carbon or Packed Tower Aeration. Since the PCE level in these three
City Wells is already below the MCL, a Granular Activated Carbon Treatment System with
larger vessels would likely be required to attempt to keep PCE levels below the PHG. The
estimated cost to install such a treatment system on three City Wells that would reliably
reduce the PCE level to the PHG of 0.06 ug/L would be approximately $1.5 million and
require annual Operation and Maintenance at a cost of approximately $180,000 per year. This
would result in an assumed increased cost for each customer of approximately $14 per year*.
Coliform Bacteria: In 2007-09, we collected 3,185 samples from our distribution system for
coliform analysis. Of these samples, 0.47% were positive for coliform bacteria. In 2007-09 a
maximum of 4.3% (February 2007) of these samples were positive for one month.
The MCL for coliform is 5% positive samples of all samples per month and the MCLG is
zero. The reason for the coliform drinking water standard is to minimize the possibility of the
water containing pathogens which are organisms that cause waterborne disease. Because
coliform is only an indicator of the potential presence of pathogens, it is not possible to state a
specific numerical health risk. While U.S. EPA normally sets MCLGs "at a level where no
known or anticipated adverse effects on persons would occur" they indicate that they cannot
do so with coliforms.
Coliform bacteria are organisms that are found just about everywhere in nature and are not
generally considered harmful. They are used as an indicator because of the ease in monitoring
and analysis. If a positive sample is found, it indicates a potential problem that needs to be
investigated and follow up sampling done. It is not at all unusual for a system to have an
occasional positive sample. It is difficult, if not impossible, to assure that a system will never
get a positive sample. A further test that is performed on all total coliform positive results is
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 5
for Fecal Coliform or E. Coli. There were no positive Fecal Coliform or E. Coli results in
2007-09.
To reduce the number of positive results for coliform bacteria, the City of Lodi occasionally
chlorinates the water system. The sources of water (City Wells) and all new or repaired water
mains follow disinfection procedures and pass bacteriological testing before being allowed
"on-line".
Full time chlorination will not guarantee that a system will never get a positive sample. If the
City were to go to full time chlorination of the drinking water system, the estimated cost to
install chlorine generation systems on twenty-six City Wells would be approximately $2.0
million and annual Operation and Maintenance cost would be approximately $70,000 per
year. This would result in an assumed increased cost for each customer of approximately $12
per year.*
Copper: The PHG for copper is 0.17 milligrams per liter (mg/L or parts per million). There is
no MCL for Copper. Instead the 901h percentile value of all samples from household taps in
the distribution system cannot exceed an Action Level of 1.3 mg/L.
The category of health risk for copper is gastrointestinal irritation.
All of Lodi's source water samples for copper in 2007-09 were less than the PHG. Based on
sampling of the distribution system in 2009, our 901h percentile value for copper was 0.34
mg/L.
Our water system is in full compliance with the Federal and State Lead and Copper Rule.
Based on sampling, it was determined, based on State regulatory requirements, that Lodi
meets the Action Level for copper. Therefore, based on criteria set forth by the California
Department of Health Services we meet the criteria for "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 copper findings. We continue to monitor our water
quality parameters that relate to corrosivity, such as the pH, hardness, alkalinity, total
dissolved solids, and will take action if necessary to maintain our system in an "optimized
corrosion control" condition.
Since we are meeting the "optimized corrosion control" requirements, there is no apparent
reason to initiate additional corrosion control treatment as it involves the addition of other
chemicals and there could be additional water quality issues raised. Therefore, no estimate of
cost has been included.
Arsenic: The PHG for Arsenic is 0.004 micrograms per Liter (ug/L or parts per billion). The
MCL, or drinking water standard for arsenic is 10 ug/L. There were arsenic levels detected at
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 6
levels not exceeding the MCL in discharges from 25 of Lodi's 25 wells used in 2007-09. The
average of these wells in 2007-09 were:
City Well No.
1R -
5.7
ug/L
City Well No.
2 -
3.3
ug/L
City Well No.
3R -
4.7
ug/L
City Well No.
4R -
3.7
ug/L
City Well No.
5 -
4.5
ug/L
City Well No.
6R -
3.8
ug/L
City Well No.
7 -
5.0
ug/L
City Well No.
9 -
4.0
ug/L
City Well No.
IOC -
4.6
ug/L
City Well No.
I IR -
5.3
ug/L
City Well No.
12 -
2.4
ug/L
City Well No.
13 -
7.5
ug/L
City Well No.
14 -
3.2
ug/L
City Well No.
15 -
4.5
ug/L
City Well No.
16 -
3.5
ug/L
City Well No.
17 -
3.9
ug/L
City Well No.
18 -
2.3
ug/L
City Well No.
19 -
2.3
ug/L
City Well No.
20 -
3.3
ug/L
City Well No.
21 -
3.4
ug/L
City Well No.
22 -
2.4
ug/L
City Well No.
23 -
3.3
ug/L
City Well No.
24 -
6.1
ug/L
City Well No.
25 -
6.5
ug/L
City Well No.
26 -
9.6
ug/L
Arsenic is a naturally occurring element found in many types of rocks and soils. Leaching of
these deposits are the primary source of arsenic found in this area. Some people who drink
water containing arsenic in excess of the MCL over many years may experience skin damage
or circulatory system problems, and may have an increased risk of getting cancer. The PHG
of 0.004 ug/L for arsenic is far below the Detection Limit Requirement (DLR) of 2 ug/L for
arsenic. The DLR is the level that can be reliably determined by current laboratory methods.
The Best Available Treatment (BAT) for arsenic removal is dependant on the water chemistry
of the source to be treated. While research into new methods of removing arsenic continues,
the current recommendations include:
• Activated Alumina
• Coagulation / Filtration
• Lime Softening
• Reverse Osmosis
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 7
All of the above listed methods take space, are expensive, and have a concentrated residual,
which requires safe disposal. An estimate of the best approach for arsenic removal in Lodi
cannot be made at this time.
Uranium: The PHG for Uranium is 0.43 picocuries per liter (pCi/L). The MCL or drinking
water standard for Uranium is 20 pCi/L. There were Uranium levels detected at levels not
exceeding the MCL in discharges from 2 of Lodi's 25 City wells used in 2009. The average
of these wells in 2007-09 were:
City Well No. 9 - 7.78 pCi/1
City Well No. 12 - 10.2 pCi/1
The California Department of Health Services (CDHS), which sets drinking water standards,
has determined that total Uranium is a health concern at certain levels of exposure. This
radiological constituent is a naturally occurring contaminant in some groundwater and surface
water supplies. This constituent has been shown to cause cancer in laboratory animals such as
rats and mice when the animals are exposed at high levels over their lifetimes. Constituents
that cause cancer in laboratory animals also may increase the risk of cancer in humans who
are exposed over long periods of time.
The Best Available Technologies (BATs) for removal of Uranium from drinking water are:
Ion Exchange - Reverse Osmosis or Lime Softening. These methods are expensive and
require disposal of a waste stream, which would contain concentrated radionucleotides. The
estimated cost to install such a treatment system on fifteen City Wells that have historically
exceeded the PHG which would reliably reduce the Uranium level to the PHG of 0.43 pCi/L
would be approximately $19.6 million and require annual Operation and Maintenance at a
cost of approximately $820,000 per year. This would result in an assumed increased cost for
each customer of approximately $121 per year*.
Recommendations For Further Action:
The drinking water quality of the City of Lodi Public Water System meets all State of
California, Department of Health Services and U.S. EPA drinking water standards set to
protect public health. To further reduce the levels of the constituent's identified in this report
that are already below the Maximum Contaminant Levels established by the State and Federal
government, 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 theoretical health protection
benefits of these further hypothetical reductions are not at all clear and may not be
quantifiable. Therefore, staff is not recommending further action at this time. However, the
point of this process is to provide you with information on water quality in Lodi and rough
costs to make certain improvements.
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Report on Water Quality Relative to Public Health Goals
June 2010
Page 8
This report was completed by City of Lodi Public Works Department staff. Any questions
relating to this report should be directed to: City of Lodi, Laboratory/Environmental
Compliance Superintendent Michael Schafer, 1331 South Ham Lane, Lodi, CA 95242 or call
(209) 333-6868.
*All annual customer costs were based on an assumed annualized cost of capital expenditures equal to 10% of
capital costs plus annual and maintenance costs divided by 23,000 customers.
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Please immediately confirm receipt
cf this fax by calling 333-6702
CITY OF LODI
P. O. BOX 3006
LODI, CALIFORNIA 95241-1910
ADVERTISING INSTRUCTIONS
SUBJECT: PUBLIC HEARING TO RECEIVE COMMENTS ON AND CONSIDER
ACCEPTING THE CITY OF LODI'S REPORT ON WATER QUALITY
RELATIVE TO PUBLIC HEALTH GOALS
PUBLISH DATE: SATURDAY, AUGUST 21,2010
TEAR SHEETS WANTED: One (1) please
SEND AFFIDAVIT AND BILLTO:
LNS ACCT. #0510052
DATED: THURSDAY, AUGUST 19,2010
ORDERED BY: RANDI JOHL
CITY CLERK
Al Al I I
NIFER ROBISO , CM
A SISTANT CITY CLERK
RANDI JOHL, CITY CLERK
City cf Lodi
P.O. Box 3006
Lodi, CA 95241-1910
MARIA BECERRA
ADMINISTRATIVE CLERK
Verify Appearance of this Legal in the Newspaper — Copy to File
Faxed to the Sentinel at 369-1084 at (time) on (date) (pages)
LNS Phoned to confirm receipt of all pages at (time) CF MB JMR (initials)
forms\advins.doc
DECLARATION OF POSTING
PUBLIC HEARING TO RECEIVE COMMENTS ON AND CONSIDER
ACCEPTING THE CITY OF LODI'S REPORT ON WATER QUALITY RELATIVE
TO PUBLIC HEALTH GOALS
On Friday, August 20, 2010, in the City of Lodi, San Joaquin County, California, a Notice
of Public Hearing to receive comments on and consider accepting the City of Lodi's
Report on Water Quality Relative to Public Health Goals (attached and marked as
ExhibitA) was posted at the following locations:
Lodi Public Library
Lodi City Clerk's Office
Lodi City Hall Lobby
Lodi Carnegie Forum
declare under penalty of perjurythat the foregoing is true and correct.
Executed on August 20, 2010, at Lodi, California.
v•0•
MITI
AkiloLoili
N:\Administration\CLERK\Forms\DECPOSTPW.DOC
ORDERED BY:
RANDI JOHL
CITY CLERK
MARIA BECERRA
ADMINISTRATIVE CLERK
i
h1l
CITY Off' LODI
Carnegie Forum
305 West Pine Street, Lodi
Date: October 6, 2010
Time: 7:00 p.m.
For information regarding this notice please contact:
Rand! Johl,
City Clerk
Telephone: (209) 333-6702
NOTICE OF PUBLIC HEARING
NOTICE S HEREBY GIVEN that on Wednesday, October 6, 2010, at the hour of
7:00 p.m., or as soon thereafter as the matter may be heard, the City Council will
conduct a public hearing at the Carnegie Forum, 305 West Pine Street, Lodi, to consider
the following matter:
a) Receive comments on and consider accepting the City cf Lodi's
Report on Water Quality Relative to Public Health Goals.
Information regarding this item may be obtained in the Public Works Department,
221 West Pine Street, Lodi, (209) 333-6706. All interested persons are invited to
present their views and comments on this matter. Written statements may be filed with
the City Clerk, City Hall, 221 West Pine Street, 2"a Floor, Lodi, 95240, at any time prior
to the hearing scheduled herein, and oral statements may be made at said hearing.
If you challenge the subject matter in court, you may be limited to raising only those
issues you or someone else raised at the public hearing described in this notice or in
written correspondence delivered to the City Clerk, 221 West Pine Street, at or prior to
the close of the public hearing.
By Order of the Lodi City Council:
City Clerk
Dated: August 18,2010
Approved as to form:
D. Stephen Schwabauer
City Attorney
CLERK\PUBHEAR\NOTICES\NotPW.doc 8/18/10