REPORT TO COUNCIL
SUBJECT
Title
Approve the City of Sunnyvale’s 2025 Public Health Goal Report on Water Quality (2022 - 2024) and Direct Staff to File the Report with the California State Water Resources Control Board Division of Drinking Water
Report
BACKGROUND
California Health and Safety Code section 11647 requires all water retailers in California serving more than 10,000 service connections to prepare a report every three years if any water quality constituents exceeded Public Health Goals (PHGs) or federal Maximum Contaminant Level Goals (MCLGs).
Understanding PHGs, MCLGs, and MCLs
• PHGs (Public Health Goals) are non-enforceable health-based goals set by California’s Office of Environmental Health Hazard Assessment (OEHHA).
• MCLGs (Maximum Contaminant Level Goals) are similar non-enforceable goals established by the U.S. Environmental Protection Agency (USEPA) and apply only when there is no corresponding California PHG.
• MCLs (Maximum Contaminant Levels) are enforceable limits set by the USEPA or California's Division of Drinking Water (DDW). Water systems must comply with MCLs, and violations can lead to penalties, orders, or facility closures.
Unlike MCLs, PHGs and MCLGs are based solely on public health considerations and do not account for treatment technology or cost. They are not governing standards and do not require compliance by public water systems, however reporting is required as noted above.
Public Hearing Requirement
Public water systems must hold a public hearing to present and discuss the PHG report. This can be done during a regularly scheduled Council meeting. The report is now being presented to the Council to meet this requirement and to obtain approval before submitting the report to the State Water Resources Control Board’s Division of Drinking Water (DDW).
EXISTING POLICY
Goal EM-4 Adequate Water Quality: Ensure that all water meets state & federal standards for aesthetics, quality and health.
ENVIRONMENTAL REVIEW
Approval of the 2025 Public Health Goal Report is not a project within the meaning of the California Environmental Quality Act as it is an administrative activity that will not result in direct or indirect physical changes in the environment. (CEQA Guidelines Section 15378(b)(5)).
DISCUSSION
The PHG Report (Attachment 1) covers calendar years 2022-2024 and was prepared by HydroScience Engineers, Inc., a consultant employed by the City. The use of an outside consultant helps to maintain objectivity in the analysis and preparation of the report. During the three-year period covered by the report, only one constituent (Chromium VI) was detected by the San Francisco Public Utilities Commission (SFPUC) above the PHG. All water quality samples tested by Sunnyvale from its water distribution system met the MCLs and PHGs for water quality standards.
Chromium VI (Hexavalent Chromium)
On October 1, 2024, the new MCL for chromium VI became effective at 10 parts per billion (ppb). Prior to this change, chromium VI was regulated under California's 50 ppb primary drinking water standard for total chromium, established in 1977. The PHG for chromium VI in California is set at 0.02 ppb.
The detection limit for reporting results (DLR) is 0.1 ppb, which means lab results below this threshold may be unreliable due to the limitations of the testing equipment, which cannot detect levels under 0.1 ppb. SPFUC claims its laboratory equipment can detect chromium VI below the DLR of 0.1 ppb.
Chromium VI can occur naturally in California, being found in deposits throughout the State. However, it was also used in industrial processes, and waste contamination can leach into groundwater. Chromium VI is classified as carcinogenic through inhalation and ingestion, with a cancer risk of 5 in 10,000 at the MCL of 10 ppb, and 1 in 1,000,000 at the PHG level of 0.02 ppb.
SFPUC Chromium VI Monitoring Results
The City of Sunnyvale purchases approximately 50% of its water from the SFPUC, which includes treated water from the Sunol Valley Water Treatment Plant (SVWTP). SFPUC conducts annual chromium VI testing on the effluent from SVWTP. Three chromium VI samples have been tested from SVWTP effluent, with results averaging 0.1 ppb. This is significantly below the MCL of 10 ppb and at the detection limit of 0.1 ppb, where treatment systems can reliably detect chromium VI. As a result, the City plans to continue monitoring SFPUC results but has no plans to install treatment systems because the levels detected by the SFPUC are one hundred times below the MCL.
Summary and Conclusion
The City of Sunnyvale’s drinking water meets all safety standards set by DDW and the USEPA to protect public health. No additional treatment is recommended to reduce hexavalent chromium levels in the source water. The current levels of hexavalent chromium are well below the MCL and eliminating it entirely may not be feasible. Therefore, no further actions are proposed to reduce chromium VI at this time. Monitoring will continue as required by DDW.
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 by posting the Council meeting agenda on the City's official-notice bulletin board at City Hall, at the Sunnyvale Public Library and in the Department of Public Safety Lobby. In addition, the agenda and this report are available at the City Hall reception desk located on the first floor of City Hall at 456 W. Olive Avenue (during normal business hours), and on the City's website.
ALTERNATIVES
1. Approve the City of Sunnyvale’s 2025 Public Health Goal Report on Water Quality (2022-2024) and direct Staff to file with the California State Water Resources Control Board Division of Drinking Water.
2. Provide other direction to staff.
STAFF RECOMMENDATION
Recommendation
Alternative 1: Approve the City of Sunnyvale’s 2025 Public Health Goal Report on Water Quality (2022-2024) and direct Staff to file with the California State Water Resources Control Board Division of Drinking Water.
Levine Act
LEVINE ACT
The Levine Act (Gov. Code Section 84308) prohibits city officials from participating in certain decisions regarding licenses, permits, and other entitlements for use if the official has received a campaign contribution of more than $500 from a party, participant, or agent of a party or participant in the previous 12 months. The Levine Act is intended to prevent financial influence on decisions that affect specific, identifiable persons or participants. For more information see the Fair Political Practices Commission website: www.fppc.ca.gov/learn/pay-to-play-limits-and-prohibitions.html
An “X” in the checklist below indicates that the action being considered falls under a Levine Act category or exemption:
SUBJECT TO THE LEVINE ACT
___ Land development entitlements
___ Other permit, license, or entitlement for use
___ Contract or franchise
EXEMPT FROM THE LEVINE ACT
___ Competitively bid contract*
___ Labor or personal employment contract
___ Contract under $50,000 or non-fiscal
___ Contract between public agencies
_X_ General policy and legislative actions
* "Competitively bid" means a contract that must be awarded to the lowest responsive and responsible bidder.
Staff
Prepared by: Mansour Nasser, Water and Sewer Systems Division Manager
Reviewed by: Ramana Chinnakotla, Director, Environment Services Department
Reviewed by: Sarah Johnson-Rios, Assistant City Manager
Approved by: Tim Kirby, City Manager
ATTACHMENTS
1. PHG Report Final_Sunnyvale_2025