August 24, 2004

 

SUBJECT: Public Hearing to Review and Receive Comments on City of Sunnyvale Public Health Goal Report (City’s Water System) Prepared for California Department of Health Services. 

 

REPORT IN BRIEF

As required by State law [Paragraph 116470(b) of the California Health and Safety Code], staff has prepared a report (Attachment A) that identifies all contaminants detected in Sunnyvale drinking water at a level that exceeds a public health goal (PHG) during the previous three years.  State law further requires that a public hearing be held in conjunction with a regularly scheduled meeting to allow the public to comment on the referenced report.  This hearing fulfills that requirement.  The attached report indicates that only two contaminants (coliform bacteria and copper) were detected at levels requiring this report, and in both instances the levels were well within allowable contamination levels and did not pose any actual health risk.

 

BACKGROUND

Section 116470 of the California Health and Safety Code requires preparation of an annual “consumer confidence report” (in Sunnyvale published as the annual “Water Quality Report”), as well as a “Public Health Goal Report” (Attachment A) every three years.  The Water Quality Report was distributed to the public as part of the Summer Quarterly Report.  The attached PHG report covers the period of calendar years 2001-2003.  It has not been publicly distributed, and such distribution is not required.  It is included as part of this agenda item and is accessible here.

 

State law (the California Health and Safety Code) does not require any action to be taken for mitigating contaminant levels that exceed the PHG but are lower than the Maximum Contaminant Level (MCL) set by the State of California or the US Environmental Protection Agency (USEPA).  Review of the report and comments received on the report are for information and recommendation purposes only.

 

EXISTING POLICY

Relevant City goals, policies and action statements include:

Council Legislative Policy Goal 3.1B: Ensure that potable [and reclaimed] water meet all quality and health standards.

Policy 3.1B.2 – Develop a comprehensive water quality monitoring program that meets or exceeds all state and federal requirements, while also meeting specific needs of the City and our citizens.

Action Statement 3.1B.2a: Establish parameters to be tested for, together with specific testing frequencies and scheduling.

Action Statement 3.1B.2d:  Provide the public with information relative to City’s water quality program, bottled water, home filtering devices, private wells, etc.

Action Statement 3.1B.2f:  Monitor state and federal legislation to ensure City’s sampling and testing procedures meet all requirements.


DISCUSSION

The California Health and Safety Code, section 116470(b) requires public water systems serving more than 10,000 service connections to prepare a report (Attachment A) by July 1, 2004, if water quality monitoring results over the past 3 years indicate levels that exceed any California Public Health Goals (PHGs) and/or federal Maximum Contaminant Level Goals (MCLGs).  PHGs are non-enforceable goals established by the California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA).  MCLGs are goals that are adopted by USEPA, and only come into play if there is no California PHG.  PHGs may not be more lenient that MCLGs.  The water section of the Field Services Division of the Department of Public Works completed and filed the report (Attachment A) with the California DHS before July 1.  The report was prepared by staff with the assistance of some outside expertise to maintain some objectivity and verify our determinations. 


Only constituents that have a California primary drinking water standard and for which either a PHG or MCLG has been set are to be addressed in the report.  If a constituent was detected by a water supplier between 2001 and 2003 at a level exceeding an applicable PHG or MCLG, the PHG reports are to provide the information required by the law.  The required information includes:

  • the numerical public health risk associated with the enforced 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.  

During the three year period covered by the report, Sunnyvale detected coliform bacteria in excess of the MCLG level of zero (0), as well as copper at levels in excess of the PHG of 0.17 mg/L.  These are the only instances that trigger the need for this report for this three year period.  This is consistent with other cities we have checked with in the area.  In general there are one or two minor items where there was a slight excedence of a PHG, but with no significant health impacts.

 

Coliform Bacteria

As described in the PHG report, coliform bacteria is an “indicator organism” used to identify the possibility of contamination.  The absence of coliform bacteria is accepted as proof that there is no fecal coliform contamination.  The presence of coliform bacteria prompts follow-up verification to eliminate the possibility of fecal contamination.   Coliform bacteria were found in approximately 0.6% of the water samples taken during the three year period.  The City takes at least 184 water samples each month to continually monitor the condition of the water.  All instances of coliform bacteria were investigated and found to not be the result of fecal contamination, and the water system was evaluated as clean in all cases.  All positive coliform bacteria results are reported to the California Department of Health Services (DHS), including all follow-up steps.  If there had been an indication of the presence of fecal coliforms in the Sunnyvale system, then a public announcement would have commenced immediately, requiring public health restrictions, possibly including boiling of water or provision of approved bottled water.  The report discusses the physical limitations in totally eliminating coliform bacteria from the water system, and high cost and impracticality of such an effort.   No further treatment for removal or elimination of coliform bacteria is recommended.

 

Copper

Copper is an essential nutrient.  The type of health risk associated with elevated levels of copper is gastrointestinal irritation.  No numerical health risk data on copper is available from OEHHA, the State agency responsible for providing that information.  That is, there is no specific level at which it is accepted that a public risk exists.  The PHG for copper is 0.17 mg/L.  While there is no MCL for copper, there is an “Action Level” of 1.3 mg/L (1300 ppb).  At that level a public water system would be required to provide some level of treatment for the removal of copper from the water, or the removal of whatever agent is causing the copper to enter the water from the water distribution system.  During 2002 the City of Sunnyvale conducted its triennial lead and copper sampling at 50 selected homeowner taps.  The results for the monitoring conducted during 2002 indicated that the 90th percentile for copper in Sunnyvale water was 0.210 mg/l. While these results indicate that the 90th percentile value for copper for this test still exceeded the PHG, it was well below the Action Level.  The report recommends that no additional action be taken by the City regarding copper.

 

As previously stated, no other contaminants were found in Sunnyvale waters at levels that exceeded published public health goals.  With the recommendation to not take any further action for the reduction in coliform bacteria or copper the final recommendation is to take no further special action regarding advanced treatment of the water supply.  The Water Section of the Field Services Division of the Department of Public Works will, of course, continue to supply drinking water, provide operation and maintenance of the water system, coordinate with water suppliers, and continue to monitor and test the water supply in accordance with all State and Federal requirements.

 

FISCAL IMPACT

There is no fiscal impact in the review and consideration of the information included in the attached report, and there are no recommended actions that would require monetary expenditure.

 

PUBLIC CONTACT

Public contact was made through posting of the Council agenda on the City's official notice bulletin board, publicized in the San Jose Mercury News, posting of the agenda and report on the City's web page, and the availability of the report in the Library and the City Clerk's Office.

 

ALTERNATIVES

1.  Council, receive and acknowledge comments from the public on the PHG Report and refer any comments to the Department of Public Works for consideration and to address as appropriate.

2.  Council request additional follow-up information from the Department of Public Works in regards to information in the PHG report, and/or questions or issues raised in the public hearing.

 

RECOMMENDATION

Staff recommends Alternative #1: Council, receive and acknowledge comments from the public on the PHG Report and refer any comments to the Department of Public Works for consideration and to address as appropriate.

 

Prepared by:
James G. Craig

Superintendent of Field Service, DPW

 

Reviewed by:
Marvin A. Rose

Director, Department of Public Works

 

Approved by:
Amy Chan

City Manager

 

ATTACHMENTS

A. City of Sunnyvale Public Health Goals Report