Topic: SWRCB Preliminary Staff Report: New Hexavalent Chromium Drinking Water MCL
The State Water Resources Control Board’s Division of Drinking Water released a Draft Hexavalent Chromium (Cr6) Maximum Contaminant Level (MCL) Preliminary Staff Report in March 2022.
In 2017, CalMutuals helped to inform a state court decision that invalidated a 10 parts per billion maximum contaminant level (MCL) for chromium 6 approved in 2012 and ordered the state to conduct an economic feasibility analysis of a new standard. The state’s newly proposed MCL for chromium 6 lacks the required analysis. This is a dangerous precedent as DDW devises plans to set new standards for perchlorate, PFAS, dioxane and other contaminants of emerging concern. For further analysis of our points of concern, review our comment letter in response to the DDW’s preliminary staff report here.
The complete proposed regulation for Chromium will be released summer of 2022 for public comments. We will be encouraging our members to send comment letters raising issues that can impact mutual water companies and small water systems.
To get immediate alerts and template letters, please email Ceili Tuttle (firstname.lastname@example.org).
Topic: OEHHA Propose Public Health Goal for PFOS and PFOA
In 2019 the legislature began requiring water systems to monitor for PFOS and PFOA and upon identification publish their findings online and report them to their customers. In early 2020 the Division of Drinking Water (‘DDW’) issued updated response levels of 10 Parts-per-trillion (‘PPT’) for PFOA and 40 PPT for PFOS. Through today the Environmental Protection Agency’s Federal healthy advisory level is 70 PPT for PFOS and PFOA. As more research has been conducted additional compounds from the PFAS classification have been added to monitoring mandates and continued reduction of acceptable concentrations of PFAS in drinking water are ongoing.
Now, as of July 2021, The Office of Environmental Health Hazard Assessment (‘OEHHA’) has proposed Public Health Goals (‘PHG’) for PFOS and PFOA. OEHHA’s PHG is theoretically the concentration where the State Water Resources Control Board (SWRCB) should try to set notification levels (NLs). The proposed PHG for PFOA is 0.007 parts-per-trillion (‘PPT’) and 1 PPT for PFOS. These levels, especially for disadvantaged water systems and without grant funding, present major concerns for mutual water companies. Due to the passage of AB756 (C. Garcia), PFOS and PFOA response and notification levels are transformed into enforceable standards much like an MCL, and CalMutuals is concerned with the ambiguity and difficult-to-reach concentrations established by this regulatory framework. The ambiguity of what these standards mean for mutual water systems combined with the dramatic decrease in expected treatable levels from a federal vs state perspective has a harmful effect on public confidence in water supplies. Though one should keep in mind that the EPA’s federal level is a combined value for PFOS and PFOA the comparison of 70 PPT to the proposed 0.007 PPT represents a 99.99% reduction in acceptable concentrations.
There will be a virtual workshop on this proposed action the SWRCB takes based on the report on September 28th. Details are available on the OEHHA website. You can read OEHHA’s draft proposed public health goal document here: and you can read CalMutuals’ comment letter here, and submit your own here if you would like.