HomeMy WebLinkAbout07-20-22 F&A Committee Packet 1
OTAY WATER DISTRICT
FINANCE AND ADMINISTRATION
COMMITTEE MEETING
and
SPECIAL MEETING OF THE BOARD OF DIRECTORS
BY TELECONFERENCE
2554 SWEETWATER SPRINGS BOULEVARD
SPRING VALLEY, CALIFORNIA
WEDNESDAY
July 20, 2022
12:00 P.M.
This is a District Committee meeting. This meeting is being posted as a special meeting
in order to comply with the Brown Act (Government Code Section §54954.2) in the event that
a quorum of the Board is present. Items will be deliberated, however, no formal board actions
will be taken at this meeting. The committee makes recommendations
to the full board for its consideration and formal action.
AGENDA
1. ROLL CALL
2. PUBLIC PARTICIPATION – OPPORTUNITY FOR MEMBERS OF THE PUBLIC TO
SPEAK TO THE BOARD ON ANY SUBJECT MATTER WITHIN THE BOARD'S JURIS-
DICTION INCLUDING AN ITEM ON TODAY'S AGENDA
This meeting is being held via teleconference. Members of the public may submit their
comments on agendized and non-agendized items by either of the following two meth-
ods:
a) If you wish to provide public comment directly - that is, live during the “Public Par-
ticipation” portion of the meeting - please complete and submit a Request to
Speak Form before the start of the meeting. Your request to speak will be
acknowledged during the “Public Participation” portion of the meeting when the
Board will hear your comment. When called to speak, please state your Name
and the City in which you reside. You will be provided three minutes to speak.
The Board is not permitted to enter into a dialogue with the speaker during this
time.
OR
b) If you wish to have your comment read to the Board during the “Public Participa-
tion” portion of the meeting, please email your comment to BoardSecre-
tary@otaywater.gov before the start of the meeting, and it will be read aloud dur-
ing the “Public Participation” portion of the meeting. Please provide your Name
and the City in which you reside, with your comment. Your comment must not
take more than three minutes to read. The Board is not permitted to respond to
written public comment during this time.
2
The District’s meeting is streamed live. Information on how to watch and listen to the
District’s meeting can be found at this link: https://otaywater.gov/board-of-
directors/agenda-and-minutes/committee-meetings/
DISCUSSION ITEMS
3. AWARD A CONTRACT TO SAGEVIEW ADVISORY GROUP AND AUTHORIZE THE
GENERAL MANAGER TO EXECUTE A THREE-YEAR FIXED CONTRACT, PLUS
TWO (2) ONE-YEAR OPTIONS, WITH SAGEVIEW OF IRVINE, CA, FOR
DEFERRED COMPENSATION INVESTMENT ADVISOR SERVICES IN AN AMOUNT
NOT-TO-EXCEED $135,406 (WILLIAMSON) [5 minutes]
4. APPROVE THE RECOMMENDATIONS STATED IN THE JUNE 2022 PUBLIC
HEALTH GOAL (PHG) REPORT TO TAKE NO FURTHER ACTIONS IN REDUCING
THE LEVELS OF THE FIVE CONSTITUENTS LISTED IN THE REPORT TO LEVELS
AT OR BELOW THE PHGs (VACLAVEK) [10 minutes]
5. ADJOURNMENT
BOARD MEMBERS ATTENDING:
Mark Robak, Chair
Jose Lopez
All items appearing on this agenda, whether or not expressly listed for action, may be delib-
erated and may be subject to action by the Board.
The Agenda, and any attachments containing written information, are available at the Dis-
trict’s website at www.otaywater.gov. Written changes to any items to be considered at the
open meeting, or to any attachments, will be posted on the District’s website. Copies of the
Agenda and all attachments are also available by contacting the District Secretary at (619)
670-2253.
If you have any disability which would require accommodation in order to enable you to par-
ticipate in this meeting, please call the District Secretary at 670-2253 at least 24 hours prior
to the meeting.
Certification of Posting
I certify that on July 15, 2022 I posted a copy of the foregoing agenda near the regular
meeting place of the Board of Directors of Otay Water District, said time being at least 24
hours in advance of the meeting of the Board of Directors (Government Code Section
§54954.2).
Executed at Spring Valley, California on July 15, 2022.
/s/ Tita Ramos-Krogman, District Secretary
STAFF REPORT
TYPE MEETING: Regular Board MEETING DATE: August 3, 2022
PROJECT: Various DIV. NO.: All
SUBMITTED BY: Kelli Williamson, Human Resources Manager
APPROVED BY: Adolfo Segura, Chief, Administrative Services
Jose Martinez, General Manager
SUBJECT: AUTHORIZE A THREE-YEAR FIXED CONTRACT, PLUS TWO (2) ONE-YEAR
OPTIONS, WITH SAGEVIEW ADVISORY GROUP FOR DISTRICT DEFERRED
COMPENSATION INVESTMENT ADVISOR SERVICES IN AN AMOUNT NOT-TO-
EXCEED $135,406
GENERAL MANAGER’S RECOMMENDATION:
That the Otay Water District (District) Board of Directors (Board) award
a contract to SageView Advisory Group (SageView) and authorize the
General Manager to execute a three-year fixed contract, plus two (2)
one-year options, with SageView of Irvine, CA, for deferred compensation
investment advisor services in an amount not-to-exceed $135,406.
COMMITTEE ACTION:
Please see “Attachment A”.
PURPOSE:
To obtain Board authorization for the General Manager to enter into a
three-year fixed contract with SageView, plus two (2) one-year options,
for deferred compensation investment advisor services in an amount not-
to-exceed $135,406.
ANALYSIS:
The District uses investment advisor services to provide fiduciary
governance and investment consulting services to its deferred
compensation retirement plans. SageView, registered as an investment
advisor with the SEC, was retained as the firm assisting the District
with these plans. SageView assists with:
•Deferred Compensation Committee Establishment and Creation of
Charter/By-Laws
AGENDA ITEM 3
2
•Ongoing Committee Member Fiduciary Education
•Creation of a formal Investment Policy Statement
•Conducting Semi-Annual Committee Meetings on Investment
Monitoring/Reporting
•Drafting Committee Meeting Agendas and Minutes
Additionally, SageView assists the District with the ongoing management
of Voya, the recordkeeper for the deferred compensation plans, and
participant education consulting.
In 2019, the District conducted a Request for Proposal (RFP) and entered
into a three (3) year agreement under the General Manager’s signature
authority with SageView. In an effort to continue with best practices
and to validate that the District is receiving the best available
deferred compensation investment advisor consulting services at a
competitive price, staff solicited proposals once again for Investment
Advisor Services in March 2022. An RFP was issued and advertised on the
District’s website and Periscope (formerly BidSync), the District’s
online solicitation system. The District received proposals from the
following four (4) firms:
FIRM FIVE-YEAR COST
Benefit Financial Services Group (BFSG) $112,500
Capital Research + Consulting LLC $210,000
Hyas Group $150,000
SageView Advisory Group $135,406
The four (4) proposals were jointly reviewed and rated by a three-
person panel, all members of the Deferred Compensation Committee, with
the scoresheet attached hereto as “Attachment B”. The written proposal
review included evaluation on the following criteria: background &
experience of firm; experience & credential of service team;
understanding of the scope of services and proposed methodology;
responsiveness and readability; and overall best value.
Based on the overall evaluation, which included a review and rating of
proposals and fees, staff recommends contracting with SageView Advisory
Group. While all evaluated firms are reputable, SageView scored
exceptionally well in all categories being evaluated demonstrating
their expertise and knowledge in the deferred compensation/financial
industry, and the ability to provide comprehensive resources. In
addition, the District has been extremely pleased with the services
that SageView has provided over the past three (3) years.
Costs associated with SageView include a 4% increase each year for
inflation and the annual breakdown is as follows:
3
Term: Year: Total
Initial Term Year 1 - FY23 $25,000
Initial Term Year 2 - FY24 $26,000
Initial Term Year 3 - FY25 $27,040
Optional Renewal Term Year 4 - FY26 $28,121
Optional Renewal Term Year 5 - FY27 $29,245
Five-year Total $135,406
FISCAL IMPACT: Joe Beachem, Chief Financial Officer
The annual cost of the agreement is $25,000 for FY23, $26,000 for FY24,
and $27,040 for FY25, the first three (3) years, and will not exceed
$135,406 over five (5) years. Funding for this expenditure has been
budgeted in the FY23 operating budget.
LEGAL IMPACT:
None.
ATTACHMENTS:
Attachment A - Committee Action Report
Attachment B - Summary of Proposal Scoresheet
ATTACHMENT A
SUBJECT/PROJECT:
AUTHORIZE A THREE-YEAR FIXED CONTRACT, PLUS TWO (2) ONE-YEAR
OPTIONS, WITH SAGEVIEW ADVISORY GROUP FOR DISTRICT DEFERRED
COMPENSATION INVESTMENT ADVISOR SERVICES IN AN AMOUNT NOT-
TO-EXCEED $135,406
COMMITTEE ACTION:
The Finance, Administration, and Communications Committee met on July
20, 2022, to review this item. The Committee supports presentation to
the full Board.
NOTE:
The “Committee Action” is written in anticipation of the Committee moving
the item forward for Board approval. This report will be sent to the
Board as a committee approved item or modified to reflect any discussion
or changes as directed from the committee prior to presentation to the
full Board.
Background &
experience of
firm
Experience &
credential of
service team
Understanding
scope of
services &
proposed
methodology
Responsiveness
& readability
Individual
Subtotal
Technical
Score Fee Score Total Score
Firm Maximum Points 25 25 25 10 85 85 15 100
Evaluator 1 18 21 20 7 66
Evaluator 2 21.2 12.9 20 4.9 59
Evaluator 3 17 15 15 5 52 $112,500
Evaluator 1 17 20 20 6 63
Evaluator 2 17.2 21.8 13.9 9.1 62
Evaluator 3 15 20 17 7 59 $210,000
Evaluator 1 22 21 21 8 72
Evaluator 2 22.2 9.7 16.6 8.8 57.3
Evaluator 3 15 18 20 7 60 $150,000
Evaluator 1 23 23 22 9 77
Evaluator 2 21.7 22.8 22.9 8.9 76.3
Evaluator 3 24 22 20 8 74 $135,406
SageView Advisory
(Irvine, CA)
61.33
11 86.77
59.00
75.77
15
1
963.10
Summary of Proposal Scoresheet
RFP FY23-2200-020
Investment Advisor Services
74.00
62.33
72.10
BFSG
(Irvine, CA)
Capital Research +
Consulting
(Pasadena, CA)
Hyas Group
(Portland, OR)
ATTACHMENT B
STAFF REPORT
TYPE MEETING: Regular Board MEETING DATE: August 3, 2022
SUBMITTED BY: Jake Vaclavek, System Operations Manager
PROJECT: Various DIV. NO. ALL
APPROVED BY: Andrew Jackson, Chief, Water Operations
Jose Martinez, General Manager
SUBJECT: APPROVAL OF PUBLIC HEALTH GOAL REPORT RECOMMENDATION
GENERAL MANAGER’S RECOMMENDATION:
That the Board approve the recommendations stated in the June 2022 Public Health Goal (PHG) Report to take no further action in reducing
the levels of the five constituents listed in the report to levels at or below the PHGs.
COMMITTEE ACTION:
See Attachment “A.”
PURPOSE:
The purpose of this report is to present the June 2022 PHG Report to
the Board and obtain approval for the recommendation that no action be taken to reduce the levels of the five constituents listed in the report to the PHG or below. The Board meeting will also meet the requirement to have a public hearing to accept and respond to public comment.
ANALYSIS:
California Health and Safety Code §116470 specifies that larger (>10,000 service connections) water utilities prepare a special
report every three years by July 1st if the water quality measurements have exceeded any PHGs. PHGs are non-enforceable goals established by
the Cal-EPA’s Office of Environmental Health Hazard Assessment
AGENDA ITEM 4
(OEHHA). The law also requires that where OEHHA has not adopted a PHG
for a constituent, the water suppliers are to use the Maximum Contaminant Level Goals (MCLGs) adopted by the United States Environmental Protection Agency (USEPA). Only constituents who have a
California primary drinking water standard and for which either a PHG or MCLG has been set, will be addressed.
PHGs are based solely on public health risk considerations. None of the practical risk-management factors that are considered by the
USEPA or the State Water Resources Control Board (SWRCB) in setting Maximum Contaminant Levels (MCLs), are considered in setting of the
PHGs. These factors include analytical detection capability, available treatment technology, 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 the state’s PHGs.
If a constituent was detected in the District’s distribution system, or in the treated water that the District purchases from other agencies, between calendar years 2019 and 2021, and at a level exceeding an applicable PHG or MCLG, the PHG report will provide the information required by the regulation. Included is the numerical
public health risk associated with the Maximum Contaminant Level (MCL) and the PHG or MCLG, the category or type of risk to healththat could be associated with each constituent, the best treatmenttechnology available that could be used to reduce the constituentlevel, and an estimate of the cost to install that treatment, if it
is appropriate and feasible.
The purpose of the report is to provide customers with information on health-related contaminants detected in the water supply, even when detected below the enforceable MCLs, so customers are aware of
whatever risks might be posed by the presence of these contaminants. MCLs are set at very conservative levels that provide from very low
to negligible risk, and are considered the regulatory definition of what is safe. PHGs and MCLGs are set at the theoretical level where there is no health risk. MCLGs are set at zero for many contaminants,
such as radiological and carcinogens, even though it is understood that zero is an unattainable goal and cannot be measured
analytically. Most PHGs and MCLGs are set far below the required Detection Levels for Reporting (DLR), which is the minimum level that SWRCB has determined can be accurately reported.
Below is a table summarizing the five constituents detected above the
PHG or MCLG in calendar years 2019, 2020, and/or 2021. More detail for each is provided in the PHG Report (Attachment B).
Constituent Units MCL PHG/MCLG DLR Levels Detected Arsenic ppb 10 0.004 2 ND - 3Gross Alpha pCi/L 15 0 3 ND - 7Gross Beta pCi/L 50 0 4 ND - 5UraniumpCi/L 20 0.43 1 ND - 3Bromateppb100.1 1 ND – 3.1
MCL = Maximum Contaminant Level PHG = Public Health Goal
MCLG = Maximum Contaminant Level Goal DLR = Detection Limits for Reporting
Levels Detected = Levels detected in water supplied to the District for 2019 through 2021 ND = Not Detected at or above the DLR
The table demonstrates that the PHG or MCLG for the constituents
listed are lower than the DLR, therefore, even if additional treatment is performed to reduce the levels of these constituents, the effectiveness of the treatment to reduce the levels to the PHG or
MCLG cannot be accurately determined by analytical methods.
The regulation also requires a preliminary cost-estimate of using the Best Available Technology (BAT) for reducing the level of the constituents to below the PHGs. The BAT for the five constituents is
reverse osmosis (RO).
According to the Association of California Water Agencies (ACWA), cost estimates for a treatment BAT, would be approximately $2.04 to $3.89 per 1,000 gallons to further remove these constituents using RO
treatment. The District’s average annual demand for the three-year period was 9,310 million gallons per year. Therefore, RO treatment
installed and operated by the District, or the District’s water suppliers, to meet the District’s water demands would cost anywhere
from $19 to $36 million per year, which translates to an average monthly cost increase of $31.51 to $59.70 per District customer (using the January 2022 meter count of 50,250 meters). These
estimates include all costs, including capital, land, construction, engineering, planning, environmental, contingency, and O&M costs for the life of the facilities.
Staff’s recommendation is that no action be taken for the District to
install RO treatment or request suppliers to install RO treatment for the following reasons:
•Water served by the District during this three-year period metor exceeded all SWRCB and USEPA drinking water standards set to
protect public health. SWRCB considers water that meets these
standards as safe to drink.
•To reduce the levels of the constituents identified in thisreport that are already significantly below the health based
MCLs established that already provide safe drinking water,costly treatment processes would be required, translating to anaverage monthly cost increase of $31.51 to $59.70 per Districtcustomer.
•The effectiveness of the treatment processes to provide any
significant reductions in constituent levels to the PHGs isdifficult, if not impossible, to determine since the analyticalDLR is higher than the PHG.
•The health protection benefits of these further hypotheticalreductions are not at all clear and may not be quantifiable.
FISCAL IMPACT: Joe Beachem, Chief Financial Officer
None.
STRATEGIC GOAL:
To meet the District’s Mission of providing high quality and reliable
water and wastewater services to the customers of the Otay Water District, in a professional, effective, and efficient manner.
LEGAL IMPACT:
None.
Attachments: Attachment A – Committee Action Attachment B – Otay Water District Public Health Goals
Report on Water Quality Attachment C – Public Health Goal Table
ATTACHMENT A
SUBJECT/PROJECT: APPROVAL OF PUBLIC HEALTH GOAL REPORT RECOMMENDATION
COMMITTEE ACTION:
The Finance and Administration Committee reviewed this item at a meeting held on July 20, 2022 and the following comments were made:
NOTE:
The “Committee Action” is written in anticipation of the Committee
moving the item forward for board approval. This report will be sent to the Board as a committee approved item, or modified to reflect any discussion or changes as directed from the committee prior to
presentation to the full board.
ATTACHMENT B
OTAY WATER DISTRICT
Public Health Goals
Report on Water Quality
June 2022
2
OTAY WATER DISTRICT
PUBLIC HEALTH GOALS REPORT ON WATER QUALITY
SECTION 1: BACKGROUND INFORMATION………………………………………...3
What Are Public Health Goals (PHGs)? ....................................................................................3
Reporting Requirements ........................................................................................................4
Water Quality Data Considered ..............................................................................................4
Best Available Treatment Technology and Cost Estimates .......................................................5
SECTION 2: CONSTITUENTS DETECTED THAT EXCEED A PHG ................. 5
Arsenic .................................................................................................................... 5
Bromate .................................................................................................................. 6
Radiological: Gross Alpha & Uranium .....................................................................................7
Radiological: Gross Beta ........................................................................................................8
SECTION 3: RECOMMENDATIONS FOR FURTHER ACTION ......................... 8
3
SECTION 1: BACKGROUND INFORMATION
Background:
California Health and Safety Code Health and Safety Code §116470 specifies that larger
(>10,000 service connections) water utilities prepare a special report by July 1, 2022, if
their water quality measurements have exceeded any Public Health Goals (PHGs). PHGs
are non-enforceable goals established by the Cal-EPA’s Office of Environmental Health
Hazard Assessment (OEHHA). The law also requires that where OEHHA has not adopted
a PHG for a constituent, the water suppliers are to use the Maximum Contaminant Level
Goals (MCLGs) adopted by United States Environmental Protection Agency (USEPA).
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. Public Health Goal Reports are
required every three years for water utilities that meet the criteria mentioned above.
The Association of California Water Agencies (ACWA) formed a workgroup which
prepared guidelines for water utilities to use in preparing these required reports. The
ACWA guidelines were used in the preparation of this report. The ACWA guidelines
included health risk information from OEHHA.
If a constituent was detected in the Otay Water District’s (District) distribution system or
in the treated water the District’s purchases from other agencies, between 2019 and
2021, at a level exceeding an applicable PHG or MCLG, this report provides the
information required by the law. Included is 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 and an estimate
of the cost to install that treatment if it is appropriate and feasible.
What Are Public Health Goals (PHGs)?
PHGs are set by California OEHHA, which is part of Cal-EPA, and are based solely on
public health risk considerations. None of the practical risk-management factors that are
considered by the USEPA or the State Water Resources Control Board (SWRCB) in
setting drinking water standards (MCLs) are considered when setting the PHGs. These
factors include analytical detection capability, available treatment technology, 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 the state’s PHGs.
4
Reporting Requirements:
The purpose of this report is to inform consumers of the District’s drinking water PHGs
that were exceeded during 2019, 2020, and 2021, pursuant to California Health and
Safety Code Section 116470(b). In addition, this report provides information about the
cost of achieving a water quality level that does not exceed the PHGs. For general
information about the quality of the water delivered by the District, please refer to the
Consumer Confidence Report, also known as the Annual Water Quality Report. An
electronic version of these annual reports can be found at www.otaywater.gov.
Included in this report is information regarding the public health risk associated with the
MCL and the PHG, such as the possible type of health risk associated with each
constituent, the best available treatment technology that may reduce the constituent
level, and an estimate of the cost to install, operate and maintain such treatment.
Water Quality Data Considered:
All of the water quality data collected by the District’s water system between 2019 and
2021 for purposes of determining compliance with drinking water standards was
considered. This data was summarized in the District’s Consumer Confidence Reports
for 2019, 2020, and 2021, which is made available every year in June, to all of the
District’s customers.
For each regulated contaminant, the CDPH establishes Detection Limits for the purposes
of Reporting (DLR). DLRs are the minimum levels at which any analytical result must be
reported to the SWRCB. Results indicated below the DLRs cannot be quantified with any
certainty. In some cases, PHGs are set below the DLRs making them impossible to
achieve analytically. Any contaminant reported below the DLR will be considered zero
for the purpose of this report, which is accepted by the SWRCB.
5
Best Available Treatment Technology and Cost Estimates:
Both the USEPA and SWRCB adopt what are known as Best Available Technologies
(BATs), which are the best methods of reducing contaminant levels to the MCL. Costs
can be estimated for such technologies. However, since many PHGs and 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 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.
SECTION 2: CONSTITUENTS DETECTED THAT EXCEED A PHG
The following is a discussion of constituents that were detected in the District’s
distribution system, or one or more of our drinking water treated water sources at
levels above the PHG, or MCLG (if no PHG has been established).
Arsenic:
Arsenic is a naturally occurring element in the earth's crust and is very widely
distributed in the environment. All humans are exposed to microgram quantities of
arsenic (inorganic and organic) largely from food (25 to 50 μg/day) and to a lesser
degree from drinking water and air. In certain geographical areas, natural mineral
deposits may contain large quantities of arsenic, and this may result in higher levels of
arsenic in water. Waste chemical disposal sites may also be a source of arsenic
contamination of water supplies. The main commercial use of arsenic in the U.S. is in
pesticides, herbicides, and in wood preservatives. Misapplication or accidental spills of
these materials could result in contamination of nearby water supplies. Arsenic does not
tend to accumulate in the body at low environmental exposure levels.
6
Studies in humans have shown considerable individual variability in arsenic toxicity. The
levels of arsenic that most people ingest in food and water (up to 50 μg/day) have not
usually been considered to be of health concern for non-cancer effects.
The MCL for arsenic is 10 parts per billion (ppb), the PHG for arsenic is .004 ppb. The
DLR, which is the lowest level that SWRCB has determined can be measured with
certainty, is 2 ppb. Arsenic levels in water that the District purchases from other
agencies from 2019 through 2021 averaged from >2 ppb to 3 ppb. The health risk
associated with arsenic, and the reason that a drinking water standard was adopted for,
is that people who drink water containing arsenic above the MCL of 10 ppb throughout
their lifetime could experience an increased risk of cancer. The PHG of .004 ppb is
estimated on a level that will result in no more than one additional cancer case in a
population of one million people who drink two liters of water daily for 70 years. The
actual cancer risk may be lower or zero. Since the DLR for arsenic (2 ppb) is greater than
the PHG (.004 ppb), it would be difficult to assess the effectiveness of any treatment
technique on reaching the PHG level.
The BAT, cited in literature, to remove arsenic is reverse osmosis (RO). All costs,
including capital, land, construction, engineering, planning, environmental, contingency,
and O&M costs, are included but only general assumptions are made for these items.
According to the ACWA cost estimates for a treatment technology BAT would cost
approximately $2.04 to $3.89 per 1,000 gallons to treat arsenic using RO treatment. The
District’s average annual demand for the three-year period was 9,310 million gallons per
year. Therefore, RO treatment installed and operated by the District’s water suppliers to
meet the District’s water demands would cost from $19 to $36 million per year, which
translates to an average monthly cost increase of $31.51 to $59.70 per District
customer.
Bromate:
Bromate in water is formed when water containing naturally occurring bromide is
disinfected with ozone. Bromate also has a long history of use as a food additive in flour.
The MCL for bromate is 10 ppb, the PHG is 0.1 ppb based on a running annual average
(RAA). The DLR is 1 ppb. The RAA of bromate levels in water that the District purchases
from other agencies from 2019 through 2021 averaged from <1 ppb to 3.1 ppb.
The SWRCB and USEPA have determined that bromate is a health concern at certain
levels of exposure. The category of health risk associated with bromate, and the reason
that a drinking water standard was adopted for it, is that some people who drink water
containing bromate in excess of the MCL over many years may have an increased risk of
7
cancer. The PHG of 0.1 ppb is estimated on a level that will result in not more than one
additional cancer case in a population of one million people who drink two liters of
water daily for 70 years. The actual cancer risk may be lower or zero. The SWRCB and
USEPA set the drinking water standard for bromate at 10 ppb to reduce the risk of
cancer or other adverse health effects.
One of the most effective treatment BATs for bromate reduction is RO. RO treatment
reduces the natural occurring bromide in source water, therefore reducing bromate
formation when ozone is applied. Because the DLR for bromate (1 ppb) is greater than
the PHG (0.1ppb), it would be difficult to assess the effectiveness of RO treatment on
reaching the PHG level. According to ACWA cost estimates for a treatment, BAT would
cost approximately $2.04 to $3.89 per 1,000 gallons to treat bromate using RO
treatment. The District’s average annual demands for the three-year period were 9,310
million gallons per year. Therefore, RO treatment installed and operated by the District’s
water suppliers to meet the District’s water demands would cost from $19 to $36
million per year, which translates to an average monthly cost increase of $31.51 to
$59.70 per District customer.
Radiological: Gross Alpha & Uranium:
Gross alpha particle activity detections are typically due to uranium. Uranium is a
naturally occurring radioactive element that is ubiquitous in the earth’s crust. Uranium
is found in ground and surface waters, due to its natural occurrence in geological
formations.
The requirement for radiological monitoring, including uranium, is four consecutive
quarters every four years. The California MCL for uranium is 20 pCi/L. Uranium levels in
water that the District purchases from other agencies from 2019 – 2021 averaged from
<1 pCi/L to 3 pCi/L.
The PHG for uranium is 0.43 pCi/L and the DLR is 1 pCi/L. The numerical health risk for
uranium based on the California PHG is 1 x 10-6. This means one additional cancer case
per million population. The health risk category for uranium is carcinogenicity.
Carcinogenic risk means capable of producing cancer.
The BAT cited in literature to remove gross alpha particle activity and uranium is reverse
osmosis. All costs including capital, land, construction, engineering, planning,
environmental, contingency and O&M costs are included but only general assumptions
can be made for these items. According to ACWA cost estimates for a treatment, BAT
would cost approximately $2.04 to $3.89 per 1000 gallons to treat Alpha and Uranium
using RO treatment. The District’s average annual demands for the three-year period
were 9,310 million gallons per year. Therefore, RO treatment installed and operated by
8
the District’s water suppliers to meet the District’s water demands would cost from $19
to $36 million per year, which translates to an average monthly cost increase of $31.51
to $59.70 per District customer.
Gross Beta:
Certain minerals are radioactive and may emit a form of radiation known as photons
and beta radiation. The MCL is 50 pCi/L and the DLR is 4 pCi/L. There is no PHG for gross
beta particle activity and the MCLG is zero pCi/L.
Gross beta levels in water that the District purchases from other agencies from 2019 to
2021 averaged from <4 pCi/L to 5 pCi/L. The SWRCB and USEPA, which set drinking
water standards, have determined that gross beta particle activity is a health concern at
certain levels of exposure. This radiological constituent is a naturally occurring
contaminant in some groundwater and surface water supplies. The category of health
risk associated with gross beta particle activity, and the reason that a drinking water
standard was adopted for it, is that some people who drink water containing beta and
photon emitters in excess of the MCL over many years may have an increased risk of
getting cancer. The numerical health risk for the MCLG of zero pCi/L is zero. The SWRCB
and USEPA set the drinking water standard for gross beta particle activity at 50 pCi/L to
reduce the risk of cancer or other adverse health effects.
The BATs identified to treat gross beta particle activity are ion exchange and RO. The
most effective method to consistently remove beta and photon emitters to the MCLG is
to install RO treatment. All costs including capital, land, construction, engineering,
planning, environmental, contingency and O&M costs are included but only general
assumptions can be made for these items. According to ACWA cost estimates for a
treatment BAT would cost approximately $2.04 to $3.89 per 1000 gallons to treat gross
beta using RO treatment. The District’s average annual demands for the three-year
period were 9,310 million gallons per year. Therefore, RO treatment installed and
operated by the District’s water suppliers to meet the District’s water demands would
cost from $19 to $36 million per year, which translates to an average monthly cost
increase of $31.51 to $59.70 per District customer.
SECTION 3: RECOMMENDATIONS FOR FURTHER ACTION
All water served by the District met all SWRCB and USEPA drinking water standards set
to protect public health during this three-year period. The SWRCB considers water that
9
meets all standards as safe to drink. To further reduce the levels of the constituents
identified in this report that are already significantly below the health-based MCLs
established to provide safe drinking water, additional costly treatment processes would
be required, translating to an average monthly cost increase of $31.51 to $59.70 per
District customer.
The effectiveness of the treatment processes to provide any significant reductions in
constituent levels to the PHGs is difficult, if not impossible to determine since the
analytical DLR is much higher than the PHG in most cases. The health protection
benefits of these further hypothetical reductions are not at all clear and may not be
quantifiable. Therefore, no further action is recommended.
ATTACHMENT C
CONSTITUENTS DETECTED ABOVE PUBLIC HEALTH GOALS 2019-2021
Constituent Units MCL PHG/MCLG DLR Levels Detected
Arsenic ppb 10 0.004 2 ND - 3
Gross Alpha pCi/L 15 0 3 ND - 7
Gross Beta pCi/L 50 0 4 ND - 5
Uranium pCi/L 20 0.43 1 ND - 3
Bromate ppb 10 0.1 1 ND – 3.1
MCL = Maximum Contaminant Level PHG = Public Health Goal MCLG = Maximum Contaminant Level Goal DLR = Detection Limits for Reporting
Levels Detected = Levels detected in treated water supplied to the District for 2019 through 2021. ND = Not Detected at or above the DLR