BACKGROUND:

The August 20, 2000 Los Angles Times article on chromium contamination written by Andrew Blankstein and Chip Jacobs brought attention to the physical presence of chromium and hexavalent chromium (chromium 6) in the San Fernando Groundwater Basin. The thrust of the initial article concerned state and federal regulations relating to total chromium and the lack of a standard for the maximum contaminant level (MCL) for chromium 6. The articles referenced levels of chromium found in area wells, but did not state that any regulations had been compromised in the water delivered to customers. Unfortunately, the articles did not note the difference between well data points and the water delivered to a customer. These articles coupled with the movie Erin Brockovich, which portrayed the plight of the people of Hinkley, California exposed to air born and water sources of chromium and the legal action against Pacific Gas and Electric (PG&E), raised reader concern about the quality of public drinking water. Numerous newspaper articles have followed. Various City and County of Los Angeles officials and State Senator Adam Schiff (D-Burbank) have voiced concern.

ANALYSIS:

Burbank Water and Power has been sensitive to the presence of chromium in the groundwater supplies serving the City of Burbank. This sensitivity and awareness of chromium issues has been the result of our on going monitoring of state and federal regulations, the Burbank-Environmental Protection Agency Consent Decrees, California Department of Health Services (CDHS) water quality permit compliance monitoring and reporting activities, and our involvement with basin management and regulatory agencies.

A special Chromium Task Force was formed as an outgrowth of the Upper Los Angeles River Area (ULARA) Watermaster's activity. The first meeting of this group was held on February 19, 1998. The Task Force is composed of ULARA groundwater producers and regulatory agencies (CDHS, Regional Board, EPA, and CDTSC) on a voluntary basis. The purpose of the Task Force has been to share information, increase our knowledge of the aerial extent of contamination in drinking water wells, and to track the progress of state and federal water standards relating to chromium.

The U.S. Environmental Protection Agency (USEPA) MCL for total chromium is 100 parts per billion (ppb). The California Department of Health Services (CDHS) and the World Health Organization MCL are 50 ppb. The water delivered to Burbank customers during calendar year 1999 was in the range from Non Detect to 26 ppb. This value was reported to all water customers in the June 2000 water bills in Burbank Water and Power "Annual Water Quality Report." BWP has provided customers an annual report for the last 10 years.

Current regulatory discussion has focused on whether a new drinking water standard for total chromium should be established, and if so, at what level and for which forms of chromium.

Two forms of chromium species may be present in drinking water supplies: chromium 3 and chromium 6. Chromium 3 is an essential nutrient at trace concentrations. Chromium 6 is a species of health concern, and its toxicity is the basis for setting the chromium drinking water standard. There are uncertainties in the balance of the two species in drinking water supplies, and there is evidence that chromium 6 may be reduced to chromium 3 in the human body, particularly in the reducing environment of saliva and gastric juices.

The U.S. Environmental Protection Agency (USEPA) classified chromium 6 as a human carcinogen by inhalation. In 1991, USEPA reviewed the existing chromium standard, and raised the maximum contaminant level (MCL) from 0.05 mg/L (1975 Interim Drinking Water Standard) to 0.1 mg/L as total chromium, based on its decision that chromium 6 was not carcinogenic by ingestion. 0.1 mg/L is 100 parts per billion.

The California EPA Office of Environmental Health Hazard Assessment (OEHHA) takes exception to USEPA's conclusion on chromium 6. The California Department of Health Services (CDHS) reviewed the chromium risk assessment data in 1994, and maintained the chromium MCL of 0.05 mg/L. In 1999, OEHHA determined that a health protective level against carcinogenicity for chromium 6 was 0.2 mg/L, and adopted a Public Health Goal (PHG) for total chromium at 2.5 mg/L. 2.5 mg/L is 2.5 ppb. The PHG was calculated assuming that total chromium is made up of no more than 7.2 percent chromium 6.

The California chromium MCL is currently under review. CDHS has indicated that it must have more occurrence data before considering revising the total chromium MCL, or adopting an MCL for chromium 6. CDHS will likely add chromium 6 to the list of unregulated chemicals for which monitoring is required when the Department amends the existing unregulated chemicals regulation (2001).

The water supply for Burbank comes from the Metropolitan Water District of Southern California (MWD), the Groundwater Treatment Plant on Hollywood Way and the Lake Street GAC Treatment Plant. Burbank Water and Power (BWP) operates the treatment facilities under a permit from the CDHS. The permit specifies the type of test, frequency and the method to be performed. The BWP employs state certified laboratories to perform the required and voluntary analytical testing. The laboratories send the test results directly to the DHS and the BWP at the same time. This procedure eliminates concern about possible tampering with the test results. The water produced by the local wells and the city treatment plants is tested monthly for total chromium and chromium 6. Production from the Groundwater Treatment Plant is blended with additional MWD water before it is delivered to the distribution system.

Attachment A shows the total chromium and chromium 6 levels for the production wells in the Burbank Operable Unit Treatment Facility for the last twelve months. Examination of this data shows that the chromium levels are not uniform from well to well, or from month to month. We do not detect any trend of increasing levels. Water from these wells is blended by the selection of various wells' need to match a flow quantity needed on any given day. It is not correct to identify any single well value as representative of the water delivered to consumers.

Attachment B shows the total chromium and chromium 6 as it is received from the Burbank Operable Treatment Facility after it has been treated for volatile organic removals and after it has been blended with additional water from the MWD before it enters the water distribution system. The average total chromium and chromium 6 value to the distribution system has been 11 ppb and 6 ppb.

Attachment C shows the total chromium and chromium 6 levels for the production well and the water to the distribution system from the Lake Street Granulated Activated Carbon Treatment Facility. This facility is not used during the winter months. The average total chromium and chromium 6 value to the distribution system has been 8 ppb and 4 ppb.

The State Legislature passed SB 2127, sponsored by Senator Schiff, requiring an accelerated review of the San Fernando Valley's chromium-tainted water. This bill now sits on Governor Davis' desk. If this bill is approved, a report and recommendations on the chromium issues is due by January 2002. Senator Schiff has also called for a hearing on the chromium issues to be held in Burbank on October 26, 2000. The BWP will provide testimony at this hearing. Los Angeles County officials have begun testing for chromium 6 at various county facilities. The Board of Supervisors ordered this action last week. The BWP has been testing for Total Chromium and chromium 6 at individual production wells in addition to the introduction of water to the distribution system for almost two years and has been sharing the results with various governmental regulatory agencies. The annual summary is provided to our customers in the Annual Water Quality Report.

Chromium contamination in the San Fernando Valley water basin has been the result of industrial production over a long period of time. The Los Angeles Regional Water Quality Control Board reports have identified 205 industrial sites in Burbank, Glendale, and Los Angles that could have soil contaminated with chromium 6. From many sites, the soil contamination is connected with contamination of the ground water. The USEPA has been monitoring the groundwater contamination with monitoring wells located within the basin. The data from the Burbank Ground Water Treatment Plant production wells has been provided to the USEPA monthly. The Regional Board will be continuing with the site chromium investigations.

The BWP is supportive of SB 2127. We will continue to work with the Chromium Task Force and various regulatory agencies in establishing standards for chromium in the drinking water. We will share our data with these agencies and provide testimony at the Schiff hearings in October. We will be pleased to report to the City Council Environmental Oversight Committee and Burbank Water and Power Board on water test results and regulatory developments on a monthly basis. Additionally, BWP intends to develop a citywide communication to all water users based on this report.