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“ The Wild, Wild West – “ The Wild, Wild West –

“ The Wild, Wild West – - PowerPoint Presentation

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“ The Wild, Wild West – - PPT Presentation

Taking on Mother Nature and More Jack Hawks NARUC Committee on Water July 15 2014 Dallas TX California Update Hollywood and Maximum Contaminant Levels water quality regulatory standard A New Hexavalent Chromium MCL Effective July 1st ID: 185638

chromium water mcl california water chromium california mcl utilities drought 2014 july potable hexavalent ppb history cdph 2013 rationing

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Slide1

“The Wild, Wild West –Taking on Mother Nature and More”

Jack HawksNARUC Committee on WaterJuly 15, 2014Dallas, TXSlide2

California Update

Hollywood and Maximum Contaminant Levels (water quality regulatory standard)

A New Hexavalent Chromium MCL, Effective July 1st

The Drought: Unrelenting Pressure

How Water Utilities Are Responding

New Emergency Drought RegulationsSlide3

115 Regulated

IOWCs

9 Class A water utilities (> 10,000 connections)

5 Class B water utilities (>2,000)

24 Class C water utilities (> 500)77 Class D water utilities (< 500)1.5 Million Customers

$1.4 billion annual revenues

6 Million

ServedSlide4

Hollywood and Water Contamination

A Civil Action (1996 – John Travolta)

Trichloroethylene

 (TCE) contamination of the town's water

supply (Woburn, MA)

Financial settlement ($68 million) for town’s residents

Erin Brockovich (2000 – Julia Roberts)

Hexavalent chromium (Cr

+6

)

contamination

in Hinkley, CA

PG&E financial

settlement

($333

million) for town’s

residents

Much agitation in California State LegislatureSlide5

Hexavalent Chromium (Cr

+6

) - What a Long Strange Trip It’s BeenSlide6

What Is It?

Chromium is a naturally occurring element in rocks, animals, plants,

soil; occurs predominantly as

Trivalent

chromium (

Cr

+3

),

essential to normal glucose, protein, and fat metabolism and

thus

an essential dietary

element for humans

Hexavalent

chromium

(

Cr

+6

), used in making

 

stainless steel,

textile dyes, wood preservation,

and for anti-corrosion, treatment of cooling tower water

Human body reduces Cr

+6

to Cr

+3

USEPA has classified Cr

+6

as a human carcinogen when inhaled because of results from animal studiesSlide7

A Little History

1977

- MCL established by USEPA and adopted by California at 50

parts per billion

for Total

Chromium (includes both Cr

+6

and Cr

+3

); 1 ppb = about 1 drop of water in 250 chemical drums (3 seconds out of 100 yrs.)

1991

- USEPA raised federal MCL to 100 ppb

2000

– Julia Roberts

wins Oscar for ‘Erin Brockovich’; Prompts California legislature to force MCL development

2000 – City of Glendale begins treatment studies for

Cr

+6

2001 –

California water utilities

begin monitoring for Cr

+6

under California

UCMRSlide8

A Little More History

March

2001 –

CDHP

requests that OEHHA prepare a

Public Health Goal

for Cr

+6

May 2001 –

National

Toxicology Program (NTP) announces intent to conduct a long-term animal study to evaluate carcinogenicity of ingested Cr

+6

October 2001 – SB 351 is signed by the Governor, requiring

CDHP

to adopt a Cr

+6

MCL by

1/1/2004

November 2001 – OEHHA announces intent to develop a Cr

+6

PHG

2004 – Water Research Foundation publishes three Cr

+6

reportsSlide9

Still More History

2007

– NTP reports there to be sufficient evidence of carcinogenicity in rodents

August 2009 – OEHHA releases draft PHG at 60 ng/L (

parts per trillion; 1 ppt = 1 drop in 20

O

lympic-sized pools)

2010 – USEPA announces in second Six-year Review of existing standards, no revision to Total Chromium MCL

September 2010 – External review draft of USEPA’s IRIS

Toxicological Review of Hexavalent Chromium

December 2010 – OEHHA releases revised draft PHG for Cr

+6

at 20 ng/L

(20 ppt

)Slide10

Even More History

December 2010 – Environmental Working Group releases report:

Chromium-6 is Widespread in US Tap Water

Tested tap water in 35 cities

Range of positive tests: 30 ppt to 13 ppb

Cites WaterRF 2004 occurrence study

April 3, 2011 – EWG press release: “Utilities Knew of Chrome-6 Contamination For Years

”Slide11

Final PHG in California

July 2011 – OEHHA finalizes the PHG for Cr

+6

at 20 ppt

CDPH can now finally start working on developing an MCL required by SB 351

It is now seven and one-half years

since the

SB 351 deadlineSlide12

Water Research Foundation

Keeps Science Moving Forward

Project

#

Project Title(2011 – 2012)4365Feasibility of Microfiltration in the RCF Process for Hexavalent Chromium Removal4404Trace Level Chromium-6 Occurrence and Analysis: Reviewing and Testing the State of the Science4414Total and Hexavalent Chromium Occurrence Analysis

4418

Guidelines for Hexavalent Chromium Treatment Testing

4423Assessment of Single-Pass Ion Exchange and Adsorptive Media for Hexavalent Chromium Removal from Drinking Water

WITAF 320/ 4432

National implications of Community-level Cost for a Theoretical Cr(VI) SDWA Standard

4445

Development of a Uniform Approach to Prepare Drinking Water Hex Chrome Compliance Plans

4449

Sources, Fate & Treatment of Hexavalent ChromiumSlide13

Environmental Groups File Suit

July 18,

2013 – NRDC, EWG

file suit in

Superior

Court to force CDPH to propose and finalize a

MCL for Cr

+6

Court rules in

plaintiffs’

favor and requires CDPH to propose an MCL by August 31, 2013Slide14

History in the Making

8/23/2013:

CDPH

Proposes Cr

+6

MCL at

10

ppb

Water Industry Comments Due 10/13/2013

AWWA

CA-NV

Section/CWA/ACWA

Coordinate comments

Hire two

expert engineering firms to analyze the CDPH supporting evidence and produce technical

documents

Bottom Line: CDPH Vastly Underestimates Incidence, Compliance Costs of

Cr

+6Slide15

History in the Making

20,000 comments received by CDPH

About 250 were “significantly distinct”

Remaining were form emails or post cards

California Administrative

Procedure

Act allows up to one year to finalize a regulation

(i.e., 8/23/2014)

December 17, 2013

Court finds in favor of NRDC/EWG and orders CDPH to finalize MCL by April 15,

2014

If there are substantial changes to the rule, must finalize by June 15, 2014 and allow an additional

15-day

comment periodSlide16

History Made

CDPH refutes, dismisses most comments

Reiterates MCL of 10 ppb

New MCL

went into effect

on July 1, 2014

Where is USEPA on all this?

Not enough evidence in second six-year review (2010) to warrant a federal

Cr

+6

MCL, nor change the total chromium MCL

USEPA will await occurrence data on total chromium and Cr+6 under

UCMR 3 (thru 2015)

Continued IRIS review of Cr

+6

No decision on Cr

+6

anytime soonSlide17

Impact of New MCL

For

customers

in

affected service areas

Statewide capital costs - $4.1 billion

Annual O&M - $231 million

Cal Water

most affected

of California IOUs

25 wells affected at 10 ppb

Capital costs up to $66 million, O&M up to $11 million/yr

All affected water utilities, agencies, municipalities, districts struggling with compressed compliance time frameSlide18

Regulatory Response

Memorandum

Account Effective

on July 1

Cal Water can apply for cost recovery in future

Not an automatic process

Willows District Case History (2,610 customers)

Tested in 2011-12; CR

+6

levels averaged 16 ppb

Total chromium averaged 24 ppb (vs. 50 ppb MCL)

Capital costs – up to $17.3 million; O&M $360,000/yr

Staggering treatment, selection of SBA, other cost reductions, etc. will reduce bill impacts

Cal Water estimates impact from $63/month to $111/monthSlide19

Drought Update

U.S. Drought Monitor

California – 7/8/14

100% of California in drought for first time in recorded

history

78% likelihood of El

Nino prediction

in fall 2014 … But

El

Nino years do not guarantee above-average

precipitation.

A scary fire seasonSlide20

California Used to Extremes

Folsom Reservoir, July 20, 2011 97% Capacity

Folsom Reservoir,

January 16, 2014 17

%

CapacitySlide21

2013 Redefined “Dry” in California

January 18, 2013

January 18, 2014Slide22

California Precipitation

Variable & Extreme

Over Time & Location

Most Occurs Nov.- March

SOURCE:

http://education.usgs.gov/california/resources.html#water

California Statewide PrecipitationSlide23

6/9/14

Statewide Average - 0%

Means major reservoirs will not be

replenished

Means reliance on groundwater has increase to 65+% from 38%Means falling groundwater levels, land subsidence, lower GW storage capacity, water quality degradation

0%

0%

0%

Snow

Water Content

North Sierra/Trinity 0%

Central Sierra 0%

South Sierra 0%Slide24

CA Reservoir Storage

July 8, 2014Slide25

Current Water Supplier Restrictions*

Mandatory:

62

water suppliers

Includes 6 rationingVoluntary

:

154

water suppliersDrought impacts are strongly tied to local and regional water supply conditions

*

As of July 7, 2014, compiled by DWR

Slide26

The State’s Response

2013

California Water Plan Update 2013 (draft)

Governor establishes Drought Task Force

2014

Governor proclaims Drought Emergency on Jan. 17

California Water Action Plan released

Drought Legislation: SB 103/104

Governor issues Executive Order April 25 to re-double drought effortsSlide27

Governor’s April 25 Proclamation

Highlights

Facilitate water transfers and exchanges

Urban water suppliers directed to address outdoor

water use

Californians directed to eliminate water waste

Limit outdoor watering; irrigation, washing hard surfaces, car washing;

commercial establishments

Homeowner

association

rules voided

Assist with temporary interconnections between water systems

Protect threatened and endangered species

CEQA / Water Code sections

suspended to speed up actions, including water transfersSlide28

CPUC’s Regulatory Response

February 27, 2014 – CPUC adopted

Res. W-4976

Drought

procedures for water conservation, rationing and service connection moratoria

Comply

with Governor’s call for 20%

voluntary conservation

Tariff

Rule No. 14.1

Water Conservation and Rationing Plan

Lists non-essential and unauthorized water uses

Tariff

Schedule 14.1

Mandatory rationing

Requires DWA approval

All

Class

A and B utilities

have

Rule 14.1 in

place

CPUC

monitoring vulnerable systemsSlide29

Tariff Rule

14.1 Highlights

Voluntary Conservation Plan

Customers

Notified by Bill Insert or Direct Mailing

Option to Request Activation of Staged Mandatory Rationing (Schedule 14.1)

Small Utilities (< 2,000 connections) Shall Make Conservation Kits Available

Section A of Rule: Non-Essential UsesSlide30

Non-Essential, Unauthorized Water Use

Anything more than “minimal”

landscaping

“Excessive” water use (per utility notification)

Potable water in gutters, streets

Private car washing (except w/shut-off nozzle)

Washing buildings, driveways, patios, etc., w/potable water

Use of potable water for lawns, gardens, etc., other than drip irrigation or hand watering on specific schedules

Use of potable water for construction purposes, dust control, etc., if other sources availableSlide31

Non-Essential, Unauthorized Water Use

Use of potable water for street cleaning

Operation of commercial car washes unless 50% recycling per cycle

Use of potable water for outside plants, lawn, landscape, turf during certain hours

Use of potable water for decorative fountains, unless recycled water used

Use of potable water for filling/refilling swimming pools

Water service in restaurants, unless requested

Use of potable water to flush hydrants, except when required for public safetySlide32

Schedule 14.1 - Rationing

Utility makes decision on whether more stringent measures are

required

Must file w/CPUC to activate staged mandatory rationing measures in Rule

14.1

Filing conditioned on:

Declaration of Mandatory Rationing – can be made by utility or governing

agency (e.g., State Water Board)

Whether utility is unable to address voluntary conservation levels set by itself, its supplier or governing agency

Whether utility chooses to subsequently activate a different stage

Utility may not activate Schedule 14.1 unless authorized by

CPUC

Customer notification, public hearing requiredSlide33

Schedule 14.1: Enforcement

Utility may charge a water use violation fine if non-essential/unauthorized use is

observed (min. 3 Ccf/person/ month)

After

one written warning, utility can install flow-restricting

device

All monies collected via fines or penalties will be used to offset lost revenuesSlide34

Recovery of Lost Revenues

Utilities

w/partial

decoupling

WRAMs

Can file for memorandum (tracking) accounts to track expenses, monies collected and lost revenues – can letter request recovery of the net balance, but … they must subtract amount equal to 20bp reduction in current authorized ROE – even then, recovery cannot exceed authorized ROR

Utilities w/full decoupling

WRAMs

Can file for memo account that only tracks expenses incurred and monies collected, since WRAM already protects for lost revenuesSlide35

New

Emergency Regulations

Issued by State Water Resources Control Board July 8; approval on July 15

th

Mandatory conservation actions, monthly data collection of water production, temporary water restrictions – prohibits:

The direct application of water to any hard surface for washing.

Watering

of outdoor landscapes that cause runoff to adjacent property,

walkways

, roadways, parking

lots, etc.

Using hose

to wash

automobiles, unless fitted

with

shut-off

nozzle.

Using

potable water in a fountain or decorative water feature, unless the water is

recirculated

.

Violations punishable by fines of $500 per day; any employee of a public agency may write and issue a ticket to a violator – raises all sorts of “water police” questionsSlide36

New

Emergency Regulations

State Board Chair Felicia Marcus has stated that new regs

don’t apply to CPUC-regulated water utilities, but CPUC may well adopt them

CWA’s July 14 comments note that Rule and Schedule 14.1 constitute drought management response

Water IOUs will

continue to work with the CPUC to coordinate their existing drought response plans and programs with the State Board’s new regulationsSlide37

Questions?

Thank

You

Jack Hawks

California Water Association

jhawks@calwaterassn.com

415.561.9650