REPORT TO COUNCIL
SUBJECT
Title
Public Hearing and Approval of the City of Sunnyvale’s 2019 Public Health Goal Report on Water Quality (2016-2018); Direct Staff to file with the California State Water Resources Control Board Division of Drinking Water and Find that the Action is Exempt from CEQA.
Report
BACKGROUND
The California Health and Safety Code requires all California water retailers serving more than 10,000 service connections to prepare a report every three years to inform consumers of water quality constituents that exceeded the 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 the United States Environmental Protection Agency (USEPA), and only come into play if there is no California PHG. Public water systems are governed by Maximum Contaminant Levels (MCL) and not MCLG/PHGs.
PHG/MCLG vs. MCL
PHGs are set by OEHHA (and MCLGs by USEPA) based solely on public health risk considerations. MCLs are set by USEPA or the California State Water Resources Control Board (SWRCB) Division of Drinking Water (DDW) as the contaminants maximum level which public water systems must not exceed. Violations of MCLs can result in fines, abatement orders, or closure of facilities. When the USEPA, or the DDW, adopts an MCL, they take into account such factors as (1) analytical methodologies, (2) effectiveness of available treatment technologies, and (3) health benefits versus costs. PHGs (and MCLGs) are not enforceable and are not required to be met by any public water system.
Public water systems are required to hold a public hearing for accepting and responding to public comment on the report, which may be done as part of a regularly scheduled Council meeting. The report is now being presented to Council to satisfy the public hearing requirements and to obtain Council approval before submittal to the California State Water Resources Control Board 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 2019 Public Health Goal Report is not a project within the meaning of the California Environmental Quality Act as is it 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 2016-2018 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, one constituent (coliform bacteria) was detected above the federal MCLG.
Coliform Bacteria
Coliform bacteria, is a non-harmful indicator organism, whose presence in a water sample, triggers follow-up testing for the presence of any pathogens. The MCLG for coliform bacteria is zero percent positive samples of all samples collected. There is no California PHG for coliform bacteria. Each month, the City collects at least 140 samples from sites located throughout the distribution system that are analyzed for the presence of coliform bacteria. It is not unusual for a water supply system to have an occasional positive sample for coliform bacteria.
During this reporting period, such coliform testing for the City resulted in average monthly results of 0% to 1% of samples testing positive, which exceeded the MCLG of zero percent. The federal Maximum Contaminant Level (MCL) for coliform bacteria, which is the enforceable standard that we are required to meet, is five percent (5%) positive samples of all samples collected each month. Further, in all cases (where there was a positive result for coliform bacteria), follow up testing revealed negative results for E. coli or other harmful pathogens. Therefore, this detection did not trigger any further notification to the public; however, the City does conduct flushing operations when a sample tests positive for any coliform.
When a constituent exceeds the MCLG and or PHG, the water supplier is required to consider best available technology available, if any, that could be used to remove or reduce the constituent to a level at or below the PHG or MCLG. The City already has a vigilant monitoring and maintenance program that is intended to meet the requirements of the Total Coliform Rule and protect public health. The Total Coliform Rule requires water systems to find and fix problems and pathways that could allow pathogens to enter the distribution system. A more detailed description of this testing, monitoring and maintenance program is presented in the PHG Report in Attachment 1. The Report concludes that the City already uses best available technology to address total coliform and no further action is proposed or warranted at this time. The DDW identifies best available technologies as follows:
1. Protection of wells from coliform contamination by appropriate placement and
construction;
2. Maintenance of a disinfectant residual throughout the distribution system;
3. Proper maintenance of the distribution system (e.g. including appropriate pipe
replacement and repair procedures, main flushing programs, proper operation and maintenance of storage tanks and reservoirs, and continual maintenance of positive water pressure in all parts of the distribution system); and
4. Filtration and/or disinfection of surface water, in compliance with Section 64650, or disinfection of ground water.
Report Conclusion
The drinking water for the City meets all standards established by DDW and USEPA to protect public health. No additional treatment is recommended to decrease the incidence of total coliform in system water testing. The level of total coliform detected is well below the MCL and elimination may be impossible. Therefore, no additional actions are proposed at this time for reducing coliform bacteria. The City and its water suppliers will continue to implement the best available technology for total coliform as well as the monitoring and maintenance program.
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 agenda on the City's official-notice bulletin board outside City Hall, at the Sunnyvale Senior Center, Community Center and Department of Public Safety; and by making the agenda and report available at the Sunnyvale Public Library, the Office of the City Clerk and on the City's website.
ALTERNATIVES
1. Find that the Action is Exempt from CEQA pursuant to CEQA Guidelines Section 15378(b)(5)), Approve the City of Sunnyvale’s 2019 Public Health Goal Report on Water Quality (2016-2018) 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: Find that the Action is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15378(b)(5), Approve the City of Sunnyvale’s 2019 Public Health Goal Report on Water Quality (2016-2018) and Direct Staff to file with the California State Water Resources Control Board Division of Drinking Water.
Staff
Prepared by: Mansour Nasser, Water and Sewer Systems Division Manager
Reviewed by: Ramana Chinnakotla, Director, Environment Services Department
Reviewed by: Teri Silva, Assistant City Manager
Approved by: Kent Steffens, City Manager
ATTACHMENTS
1. City of Sunnyvale 2019 Public Health Goals Report