Acting Fast on PFAS: Now is the Time

How one California water utility is leading the fight against the ‘forever chemicals’

If you work in water and wastewater, you might remember Erin Brockovich’s successful 1993 lawsuit against Pacific Gas & Electric (PG&E), which proved the company had contaminated a small California town’s water supply with a toxic compound called chromium 6. 

The $333 million settlement Brockovich negotiated is still the largest in U.S. history, and the wave of awareness her case brought to environmental toxins–helped along by the eponymous 2000 Oscar-winning Julia Roberts film–is considered by many environmentalists today to be a turning point in environmental policy.

So, when the Santa Clarita Valley (SCV) Water Agency’s Mike Alvord first heard about per- and polyfluoroalkyl substances or “PFAS” in 2019, he was certain the general public was due for a similar wake up call.

Ohio residents had launched a similar class action lawsuit alleging a DuPont chemical plant had contaminated the drinking water of 70,000 people with PFAS in the early 2000s. A film about the lawsuit titled Dark Waters starring Mark Ruffalo and Anne Hathaway premiered in 2019, just a few months after the state of California ordered water utilities like SCV to start sampling wells for PFAS. At one point Erin Brockovich herself even re-emerged into the public eye to sound the alarm on PFAS

“I really thought that was going to be the next Erin Brockovich,” says Alvord. 

But the premiere of Dark Waters came and went, and the anticipated wave of public outcry against PFAS never materialized. 

“It didn’t turn into much. Maybe [with COVID] there were too many distractions.”

Despite the relatively tepid public response, Alvord and his colleagues at SCV knew that PFAS was real and that it wasn’t going away any time soon. So instead of waiting for regulators and the public to catch up, they decided to get ahead of the problem.

What is PFAS?

PFAS (pronounced ‘Pee-Fass’) are a class of synthetic “forever chemicals” found in everything from nonstick pans to takeout containers to the foams used in firefighting.

“It’s ubiquitous. The United States has been manufacturing PFAS chemicals since the fifties, and consumers have been enjoying the benefits of PFAS chemicals for decades,” says Alvord.

Studies have shown that PFAS may be associated with reproductive health issues, testicular and kidney cancer, high cholesterol and suppression of vaccine effectiveness in children, and that it might already be present in 98 out of every 100 people’s bloodstreams.

Some European countries and Maine have banned the compounds, but American water utilities are still grappling with how to best manage these contaminants. Most of them weren’t aware of PFAS until 2015 when the EPA added it to the list of contaminants it tracks under the unregulated contaminant monitoring rule (UCMR), and to this day there are few concrete rules around PFAS.

Alvord is the Director of Operations and Maintenance at SCV, which provides water to more than 300,000 business and residential customers in Southern California. When he and his colleagues discovered that one of the agency’s wells had exceeded the EPA’s advisory level of 70 nanograms per liter for two PFAS chemicals in 2019, no law or rule required them to shut down the well.

“But we immediately shut it off. We didn’t have to, but we did–for the sake of the public and the sake of the uncertainty. We just didn’t know what was going on.”

The first line of defence: transparency

Instead of dealing with it quietly, the SCV decided to bring their fight with PFAS out into the open.

The 2019 California order had only required SCV to sample 15 of their wells for PFAS, but the agency began sampling all of them. They also began posting regular updates about their findings to their website, and took a radically transparent approach to informing their customers about the PFAS threat in Southern California.

Ariel view of Santa Clarita Valley

Alvord says that transparency didn’t just help SCV act quickly on the PFAS problem. It also helped the agency–which was formed after the state merged four separate water utilities in 2018–find its feet as a new organization, come together as a team, and build a strong work culture on short notice.

“We brought in different cultures, different personalities, and we immediately had to work together because we had to try to form our own new culture,” says Alvord. 

“If we were separate, even though we worked well together separately, I think it would have been much more difficult.”

Removing PFAS from water

Most drinking water & wastewater utilities have three lines of defence against PFAS. They can use: 

1. Reverse osmosis, which forces water through a high-pressure membrane.

2. Granular activated carbon, like the kind you find in refrigerator water filtration systems, which is also the most studied PFAS removal solution.

3. Ion exchange, a process by which PFAS compounds are absorbed into a special kind of resin. 

The problem is that none of these technologies were originally designed to remove PFAS from the water, and they each have room for improvement. 

The energy costs involved in reverse osmosis, for example, usually make it prohibitively expensive for water utilities. Granular activated carbon can also get expensive, not just materials-wise but also because of the amount of byproduct that needs to be disposed of. 

Even ion exchange, the solution SCV settled on, can be challenging in the amount of byproduct it produces.

Staying flexible and keeping an open mind

More interesting than SCV’s technology choice itself, however, is the sheer speed with which the water agency was able to design, permit, and build the facility–during the COVID shutdown no less.

SCV’s new PFAS treatment facility in Valencia is an impressive sight: six massive vessels filled with ion exchange resin churn through up to 6,250 gallons of water per minute, enough to serve an estimated 5,000 households every year.

Most agencies would have taken years to build the facility, but that was time that Alvord says the SCV didn’t have when they embarked on the project in 2019.

“So instead, we did all of it at the same time. We were doing planning, bidding for construction, design–all of that simultaneously.”

It took just one year to construct the facility, which today produces upwards of 6,000 gallons of clean water per minute and has become a template for future plants slated for construction.

Alvord doesn’t recommend other utilities hold themselves to a similarly tight deadline. But he says the resourcefulness and speed SCV was able to bring to the treatment plant project is a product of the organization’s culture of flexibility and cooperation between groups like engineering and operations.

“Don’t just leave it up to your engineering group to do everything: spread the wealth and, you know, spread the pain,” suggests Alvord, acknowledging the tension that can sometimes exist between technically-minded engineers and operators with their eye on the bottom line.

“Engineers have to rely on operations staff to tell them what’s in the field, so make sure you do those field visits together, so that what they’re planning is going to match with what’s happening in reality.” 

The value of good communication and trust

Talking to Alvord, it quickly becomes clear that SCV’s ability to get ahead of the PFAS problem is as much an organizational achievement as it is a technical one. 

When asked about what advice he’d give to organizations and operations leaders trying to replicate those results, Alvord reiterates the importance of transparency, openness, and communication in the water industry.

“I preach that the two most important things to be successful are good communication and building relationships,” says Alvord, who also works as an instructor in the Water Systems Technology department at a local college.

“If you can learn to communicate effectively without sounding arrogant, without sounding offensive or derogatory, you’re going to be ahead of the game.”

Looking to get ahead of PFAS regulation? Start by automating your water monitoring plan with Klir. Talk to one of our specialists today.

How to Overcome NPDES Challenges: Best Management Practices

Managing permits under the National Pollutant Discharge Elimination System (NPDES) is complex and high stakes for water utilities.

Ensuring NPDES compliance at your utility is not just important—it’s critical. While some discharges are routine and controlled, others are unplanned and can come up suddenly, such as combined sewer overflows, pipe breaks, and water main leaks. Either way, under NPDES they must be properly documented and reported. Failing to meet these requirements can result in hefty regulatory fines. In some situations, mismanaging NPDES compliance could even lead to a jail sentence.

What is NPDES?

The Clean Water Act prohibits anybody from discharging pollutants through a point source (such as a water or wastewater utility), into a “water of the United States” unless they have an NPDES permit. The permit includes limits on what you can discharge, stipulates monitoring and reporting requirements, and outlines other provisions to protect water quality and human health.

Achieving NPDES coverage in California

Managing water pollutants is a huge concern for water and wastewater utilities. In California, it’s a particularly big issue.

“Unlike some other states, we don’t have a lot of water. When utilities discharge into limited receiving waters, any pollutants are more likely to have an environmental impact,” says Francois Rodigari, Director of Corporate Sustainability & Innovation for San Jose Water.

Calero reservoir, Santa Clara county, California

Despite this, for years drinking water utilities did not qualify for existing discharge permits—even for routine reasons.

“In some cases, the regional water quality control board fined utilities for discharge incidents, even though there was no NPDES permit available to them,” he adds. “While most drinking water utilities followed the general NPDES requirements, we didn’t have permit coverage and consequently we weren’t doing any reporting. Our utilities were at risk.”

Rodigari was Director of Water Quality and Environmental Services when San Jose Water decided it would seek out better ways to manage NPDES. His team was instrumental in developing the Statewide General NPDES Permit for Drinking Water System Discharges to Waters of the United States, which the California State Water Board adopted in November 2014. Today, all utilities in the state with 1,000 connections or more are required to apply for an NPDES permit (unless they qualify under another permit). 

Ensuring NPDES compliance through Best Management Practices

With a state-wide solution, it’s now easier for utilities to make NPDES permit applications. For some utilities, NPDES has also underscored the importance of building and maintaining an accessible database.

“For NPDES compliance, we have to track and report our discharges when they’re over a certain volume,” says Rodigari. “There are annual reporting requirements, too. It’s a lot of information to manage.”

To support the state’s water utilities as they navigate NPDES, the San Jose Water Environmental Compliance group also led an effort to update the Best Management Practices Manual (BMP) for Drinking Water System Releases for the California-Nevada Section of the American Water Works Association. The manual provides directions on how to minimize and handle the number of planned and unplanned discharges.

How to handle common NPDES challenges:

For many utilities, moving toward NPDES compliance is part of an ongoing commitment to implementing best management practices. For others, it means taking a brand new approach to managing data and meeting reporting requirements. 

Wherever you are in the process, achieving NPDES compliance probably means your utility will be going through some changes. 

With this in mind, we asked Rodigari to share some of his team’s best practices for improving utility performance and making NPDES reporting easier.

1. An effective data management system is key to achieving ISO 14001 standards

Achieving compliance in line with ISO 14001 standards means setting up an effective environmental management system. The requirements are extensive, Rodigari says. “Most utilities are actively working toward meeting the management framework, but it remains a complex process.”

Rodigari says choosing a secure, robust compliance system to manage your utility’s data is a critical part of the ISO 14001 journey.

“As an industry, we can no longer depend on spreadsheets,” he says. “The environmental and economic risks are too great.”

NPDES reporting requires utilities to track permit obligations, discharges, reporting, and fines. With the right platform in place, you can achieve compliance, but your utility can also raise its game. “When you can visualize your data and reports, it’s easier to see the ways you can improve your utility’s performance,” he says.

2. Track hazardous waste sites assessment data for reporting—and future projects

As a 150-year-old utility, San Jose Water often learns about legacy sites through site assessments for construction, renovation, or facility retirement. 

“When we complete an assessment, we generate a lot of data about the soil and hazmat that we might not have already known existed on the site,” Rodigari says. 

San Jose Water uses this information to prepare bidding documents. “Contractors need to know about any precautions they need to take during demolition and disposal,” he says. 

If the findings require action, the utility might map the site and construct barriers to ensure runoff doesn’t migrate to another property. In other cases, the utility works with Santa Clara County and the Department of Environmental Health to propose a cleanup and remediation plan. 

Furthermore, the utility maps the sites to protect workers. “If future work will disturb the soil, workers need to know,” Rodigari says.

With more than 100 properties, San Jose Water can’t manage everything with individual engineering reports, Rodigari adds. “We need our data to be readily available and easy to retrieve. It’s critical for managers to have that information.”

3. Keep a central record of hazmat manifests

A utility is required—and has an obligation—to manage hazardous materials manifests in order to minimize liability from cradle to grave, Rodigari says. “When you have multiple entities generating and disposing of waste on your utility’s behalf, you need a system that allows everyone to report uniformly.” 

In California there are tax requirements associated with generating hazmat and solid waste. Manifests play a key role in the ability to draw an inventory and understand its fate, he adds, so it’s important to store them in a platform that is easy to query.

4. Remove the burden of gathering environmental and compliance data with automated reports and alerts

Automating NPDES reports can lift a huge administrative burden for a utility. The first challenge, however, is making sure you have all of the relevant data in the right place.

Rodigari says it can take time to harmonize NPDES data sources, but it should be an important priority. “Across our utility, several teams generate discharges, from operations to contractors to field service. Ensuring all reports are properly filed in one platform and easy to retrieve is a best practice that can protect your utility from liability.”

For San Jose Water, fully automating all NPDES reporting is a goal for the longer term. In the meantime, the utility is aiming to collect all data in one platform, Rodigari says. And, to ensure compliance, the utility’s platform is programmed to send reminders to parties responsible for collecting data that the NPDES permit requires. “If there’s a failure to document, the platform issues an escalation. This helps managers track and follow up on missed deadlines.”

Collecting all data on NPDES permits within a single platform helps to ensure compliance.

Improving performance and environmental impact with NPDES best practices

Rodigari says he’s confident that the state-wide NPDES permit has improved best management practices in California’s water utilities. For San Jose Water, that’s meant a major shift in the way the utility manages discharges.

“We’re doing a better job of ensuring water quality, including reducing turbidity, and removing chlorine prior to discharge,” Rodigari says. “We’re also minimizing water loss during discharges, and we’ve set some ambitious goals in terms of non-revenue water.”

Rodigari credits the utility’s hard work, as well as the way the industry is starting to think about data and reporting. “Making sense of our data is an important step in the path to improving our environmental impact and organizational performance,” he says. “That’s the point of NPDES.”

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