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Wastewater Fact Sheet No. 1 |
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“Toilet to Tap Water Project” Fundamental Problems and MCLs and Standards This is the first of a series of fact sheets dealing with concerns and issues associated with the East Valley Water Reclamation Project (EVWRP). This project, euphemistically referred to as the “toilet to tap water” project, has been proposed to recycle reclaimed water for use as potable water, i.e., for drinking and cooking purposes. The fundamental problems with this proposal, described in the Environmental Impact Report (EIR), issued by the Los Angeles Department of Water and Power (DWP) in 1991, are four-fold: First, the different contaminants and pollutants present in the reclaimed water to be treated are unknown. Their amounts and concentrations are also unknown. Second, there is no indication of what contaminants and pollutants and their concentrations will be left in the treated reclaimed water. Third, there is no detailed information or data describing the composition and amounts of contaminants and pollutants in the receiving waters, i.e., the ground waters and aquifers into which the treated waters will be injected. Fourth, there are no detailed qualitative and quantitative data regarding the presence of contaminants and pollutants in the ground waters and aquifers following injection of the treated reclaimed water. All of this information and these data would be available after appropriate scientific study had been carried out. This kind of information, however, is not presented in the EIR. Yet, without this kind of information, no meaningful assessment of the safety and effectiveness of the proposed project can be indicated. Another major problem involves the use and miss-use of terms like Maximum Contaminant Levels (MCLs) and Standards. MCLs apply to clean water, not to treated or reclaimed water. MCLs are based on economics and technical feasibility. This means that MCLs are determined by costs and what is technically achievable, or practical. In contrast, Standards are based solely on considerations of human health and safety. This was recently affirmed by the U.S. Supreme Court in its decision regarding the functions of the U.S. Environmental Protection Agency (EPA) (Docket No. 991257). According to the Court’s ruling, EPA Standards, in this case dealing with Air Quality, must be based solely on human health and safety. Economic considerations may be taken into account, but not at the expense of health and safety concerns. From this ruling, it seems reasonable to assume that the same criteria would apply to potable water standards. Since the issuance of DWP’s EIR on the treatment of reclaimed water for potable purposes in 1991, there have been a number of findings of contaminants and pollutants with potentially devastating impacts on water quality. These include MTBE, Perchlorates, Arsenic, and Hexavalent Chromium or Chrome 6 (Cr VI) among others. “The recent discovery” of Cr VI in drinking water sources is more correctly understood as the recent acknowledgement of the presence of Cr VI for over forty years as a poison in various sources of water. Some of these sources were and continue to be destined for drinking and cooking usage. The Chromium problem provides a good model for the kinds of problems that must be dealt with for each contaminant and each pollutant involved in the “toilet to tap water” project. The federal MCL for Chromium in drinking water is 100 parts per billion (ppb) or micrograms per liter (mg/L). The California State MCL is 50 ppb. Neither of these values is a Standard for Chromium in drinking water. EPA’s Office of Environmental Health Hazard Assessment (OEHHA) in Oakland, California has defined the legally required and acceptable drinking water Standard for Chromium. The Standards are defined as public health goals (PHGs) for total Chromium at 2.5 ppb and for Cr VI at 0.2 ppb. We owe Dr. David Morry, the scientist responsible for writing the reports defining these Chromium PHGs, our thanks for his efforts to gather and collate the scientific data on which the PHGs are based. We believe that there should be a single PHG for Chromium since recent analyses of California waters show that 85% of the total Chromium is due to Cr VI. Thus the appropriate PHG for Hexavalent Chromium is 0.06 ppb, or, rounded up, 0.1 ppb. This lower, more restrictive Standard for Chromium in potable water is also supported by the fact that Cr VI is an accumulative poison in living organisms, including humans. Future fact sheets will
discuss: · Why the Cr VI problem alone warrants the call for a new EIR for the “toilet to tap water” project. · The damage to humans caused by ingestion of Cr VI. · How Cr VI acts in the human body. · Some of the politics behind current policies of state agencies regarding the “toilet to tap water” project. · The control of Cr VI in our drinking and cooking water. |