Tuesday, July 15, 2014
Tuesday, July 8, 2014
This is a message from the State Water Resources Control Board.
Friday, July 4, 2014
If you analyzed your water after treatment, it would appear the cyclophosphamide had gone, which it has, but only to be replaced by a very similar compound. Is that good? Is the water after treatment more protective of the environment and of public health? I don’t think we have any idea, which is exactly the point.
Thursday, June 5, 2014
- "A peremptory writ of mandate issue, pursuant to Code of Civil Procedure section 1085, Health and Safety Code sections 116365 and 116365.5, and Government Code sections 11342.2, 11346.3, and 11346.9, ordering Respondent to withdraw the current MCL and to promulgate instead a new MCL at a level that is economically feasible;"
- " In the alternative, that an alternative writ of mandate be issued, exparte, ordering Respondent to request that OEHHA review the PHG as required by 116365(e)(1) or, in the alternative, to show cause why a peremptory writ of mandate should not issue."
- “DPH (Department of Public Health)failed to comply with its mandatory statutory duties to (a) determine the economic feasibility of compliance with the proposed MCL, (b) base the MCL on the economic feasibility of compliance, and (c) to consider the costs of compliance to public water systems, customers, and other affected parties, including the cost per customer and aggregate cost of compliance, using best available technology.”
- “Despite acknowledging that the national MCL for chromium is the national primary drinking water standard adopted by the U.S. EPA to address exposures to hexavalent chromium, DPH failed and refused to consider the national standard in its adoption of the California hexavalent chromium MCL, as required by Health and Safety Code section 116365, subdivision (b)(2).”
- “DPH violated its clear, present, and mandatory obligation under Government Code section I 1346.9, subdivision (a)(3), to substantively respond to all relevant public comments…”
- “DPH failed to comply with its clear, present, and mandatory duty under Government Code section 11346.3 to assess the potential for adverse economic impact on California business enterprises and individuals, avoiding the imposition of unnecessary or unreasonable regulations or reporting, recordkeeping, or compliance requirements.”
- “In issuing the hexavalent chromium MCL based on a PHG that is based on obsolete science, DPH exceeded its quasi-legislative authority to promulgate MCLs that are reasonably necessary to effectuate the purpose of the SDWA and that are consistent with the SDWA. DPH has not adopted an MCL consistent with the SDWA's statutory requirements that the MCL be based on a PHG that, in turn, is based on current scientific data, evaluated using the most current scientific principles, practices, and methods.”
Friday, March 28, 2014
Why I Think California’s Proposed Hexavalent Chromium Drinking Water MCL May Do More Harm Than Good.
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Monday, March 17, 2014
The document starts off sounding great:
“The Administration has evaluated the current governance structure of the state’s drinking water and water quality activities and concluded that aligning the state’s drinking water and water quality programs in an integrated organizational structure would best position the state to both effectively protect water quality and the public health as it relates to water quality, while meeting current needs and future demands on water supplies.”
That sounds fantastic! It’s enough to make even a confirmed cynic like me have some hope that the process really will make an improvement in the overall governance of the water cycle here in the Golden State. There will be some seriously hard work to make this transfer live up to all that hype. One of the hardest parts will be the change management for all 291 of the employees of the Drinking Water Program that will find themselves part of a new food chain. As someone who works along with Drinking Water Program employees on a local level, and with the good folks in the Environmental Review Unit in Sacramento, I can honestly say it’s those front line workers that really make the Drinking Water Program work so well. But as with any big change, it can be disconcerting for those same employees trying to deal with new processes, new reporting schemes, etc. The State Water Board would do well to give a great deal of thought to providing as much support as possible to their valuable employees in order to make the transition as smooth for them as possible. Lest you think I’m being overly kind, I assure you my motives are purely selfish. The smoother the transition goes for the Drinking Water Program folks that I work with, the smoother I know the process will go for me and others like me.
One of the big concerns with this transfer has been how the Regional Water Boards would play into it. The good news is it appears they will not. The Transition Plan clearly states:
“Regulatory staff would remain in locally-based offices and would continue their close working relationships with water system personnel, local environmental health and public health agencies, and relevant community organizations. The Regional Water Boards would not implement any Drinking Water Program functions.”
Music to my ears. Not to put too fine a point on it, but the regional boards have a tendency to make their own unique interpretations of how regulations should be implemented and enforced, resulting in a patchwork of rules depending upon where your reside in the State. That is definitely not what is needed in the Drinking Water Program.
California is not breaking any new ground with this move. “Thirty states, as well as U.S. EPA, consolidate their drinking water and water quality programs into a single entity.” So there is plenty of experience out there to draw on. But that doesn’t make the transition any the less exciting in its potential. “California will achieve comprehensive and harmonized water quality policy through water program consolidation... Locating the Drinking Water Program at the State Water Board also would promote a comprehensive approach to the development of community strategies for drinking water, wastewater, water recycling, pollution prevention, desalination, and storm water, while protecting public health.” Management of the entire water cycle is precisely what is required to help better manage the resource, especially in the groundwater and recycled water segments. “Integrating water quality management in a single governmental entity for state- level activities is a key element of the California Water Action Plan and would also further the Groundwater Strategy under development by the State Water Board.” Anything that furthers the cause of reforming groundwater management is a very good thing.
All in all, I think the Transition Plan sounds great, and I’m looking forward to seeing the combination of programs under the State Water Board lead to better management of the entire water cycle in California.