1 MEMORANDUM
DATE: June 12, 2023
TO: Justin Hess, City Manager
FROM: Dawn Roth Lindell, General Manger, Burbank Water and Power BY: Richard Wilson, Assistant General Manager - Water
SUBJECT: Notification to Council of Presence of Perfluorohexane Sulfonic Acid (PFHxS) and Perfluorooctanoic acid (PFOA) in Groundwater Sources
RECOMMENDATION
Notify City Council of Exceedance of notification limits for PFAS in untreated groundwater. PFAS was removed by our treatment process and was never
BACKGROUND
PFHxS and PFOA are members of a large class of chemicals known as per- and polyfluoroalkyl substances (PFAS). They are widely used, long lasting chemicals that break down very slowly over time . These
chemicals are used in numerous commercial products to offer water and stain-repellent properties and in fire-fighting foams. They do not occur naturally. These compounds persists in the environment and in biological organisms. Scientific studies have shown that exposure to some PFAS in the environment may be linked to harmful health effects in humans and animals.
The purpose of this memorandum is to notify City Council of the exceedance of the notification requirement for PFHxS and PFOA established by the Division of Drinking Water (DDW).
DISCUSSION
Pursuant to Health and Safety Code Section 116455 that governs drinking water standards, Burbank Water and Power is required to inform City Council of concentrations that exceed the notification level. Notification levels are health-based ATTACHMENT 1
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2 advisory levels established by the State Water Resources Control Board Division of Drinking Water (DDW) for chemicals in potable water that lack legally enforceable limits.
The notification level for Perfluorohexane Sulfonic Acid (PFHxS) in the untreated groundwater sources was exceeded at four out of eight ground water wells and for PFOA was exceeded at one well, both from samples taken during the first quarter of 2023. We alerted DDW immediately upon receiving the sample results.
The notification level for PFHxS is 3 parts per trillion (ng/L). The sample results were in the range of 3.9 ng/L to 20 ng/L.
The notification level for PFOA is 5.1 parts per trillion (ng/L). The sample result was 5.3 ng/L.
Note that these samples are for raw, untreated water and PFHxS and PFOA was removed by our treatment plant and was never detected in Burb water.
It is also important to understand that PFHxS and PFOA have existed in our ground water for quite some time and we began monitoring for both beginning in 2019. The sample testing method that we were using at the time was to detect 18 chemicals (including PFHxS), but only two of them perfluorooctanoic acid (PFOA) and perfurooctanesulfonic acid (PFOS) had notification levels. Regardless, we collected and reported all of the data to the division of drinking water. Beginning October 31, 2022, an exceedance of the notification level for PFHxS must be reported.
The existence of these chemicals are not new, but reporting the exceedance of the notification levels and the requirements for reporting are new. The guidance for the notification level issuance specifically for PFHxS (see highlighted text in Attachment 1) only provides guidance for exceeding a response level, which is completely different from a notification level. Upon further discussion with the Division of Drinking Water on June 8, 2023, we were advised to review the General Order Requiring Monitoring for PFAS, which is for the generic category of these chemicals, and does mention a 30-day notification period from the date sample results are confirmed. We missed this and in the future, we will take the corrective action outlined below.
On April 13, 2023 we contacted DDW for guidance on the methodology used for the PFOA samples taken during the first quarter of 2023 and we were told that no action would be required. However, today we were informed by DDW that notification to our governing bodies is required and to include PFOA in this notification (see Attachment 2).
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3 To eliminate future confusion on the methodologies to be employed and the notification requirements, we will take the following actions:
1. Schedule a meeting with DDW every three months as soon as test sample results are returned by the analyzing laboratory to review and discuss all quarterly sampling data, regardless of the results, to ensure clarity of understanding with the new reporting requirements and methodologies for the growing list of contaminants;
2. As a matter of course, provide immediate notification of an exceedance board and City Council of quarterly sampling data as soon as test results are available;
3. Provide a public notification plan within 24 hours after determination that said notification is required within 30 days per the Health and Safety Code and as determined by DDW.
4. BWP will meet the 30-day notification limit early or on time.
cc: Javier Martinez, Manager, Production and Operations Nareh, Ghevondian, Water Quality Analyst
ATTACHMENT 1
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