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November 20, 2015 Sacramento City Council 915 I Street Sacramento, CA 95814 RE: Disinfection Byproducts in Sacramento Drinking Water Mayor Pro Tem Angelique Ashby and Member of the Council: We would like to comment on the issue of disinfection byproducts (DBPs) in the City’s drinking water as reported upon in the recent Sacramento ABC 10 news story. Bill Allayaud (signee of this letter) attended the presentation made by City Manager Shirey and the Department of Utilities on November 10th and was able to make a few comments that night, but was limited by the two-minute time frame. Therefore, on behalf of the Environmental Working Group (EWG), we would like to make further, more detailed comments. Most importantly, EWG disagrees with the City Manager’s characterization of the potential harmful effects of DBPs, particularly his focus on the fact that the annual running average concentration of DBPs measured in the city’s drinking water supply did not exceed the EPA’s maximum contaminant level (MCL). While it is correct that there was no exceedance of the MCL and therefore no drinking water standard was violated, the implication that there were no potential public health impacts posed by the concentration of DBPs measured in the city’s water is incorrect. Yet, the City Manager repeatedly stated that an individual could drink two liters of water with concentration of DBPs as high as the maximum legal limit, 80 parts per billion (ppb), for 70 years before they would increase their risk of developing cancer and he chastised ABC 10 for needlessly alarming residents about the quality of their water. It is widely understood by public health experts that the EPA’s legal limit, or MCLs, are not intended to be a true safe exposure level. To develop these MCL values, the agency factors both safety (that is, the public health goal) as well as the cost and feasibility for utilities to achieve the limits. Accordingly, for many of the contaminants in our nation’s drinking water, including DBPs, the MCL allows higher concentrations than is truly safe (see below for why this is the case). In addition, EWG believes the City Manager should have focused more attention on the spikes in concentration of DBPs, particularly trihalomethanes (THMs), which occurred in the city’s drinking water while aluminum chlorohydrate (ACH) was being tested as a coagulant. In 1999, the EPA set the legal limit for THMs at 80 ppb due to the their potential link to cancer, birth defects, and other adverse health outcomes. It is a fact that during the six months of the ACH study that the city was monitoring the El Centro Reservoir (a three million gallon storage facility serving the Natomas area), DBP readings soared to as high as 126.5 ppb. The overall average during this period exceeded 80 ppb, the concentration the EPA

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November 20, 2015 Page 2 of 4 presently says is concerning for long-term exposure. At another test site called the Airport Turnout, one of two in the distribution system monitored continually during the ACH study, the city measured nine readings above 80 ppb with readings as high as 140 ppb. In fact, with the exception of two very low readings that were collected while the Sacramento River Water Treatment Plant was offline, this distribution area experienced multiple readings exceeding 80 ppb. If the two exceptionally low months (January and February 2014) are taken out, the average for the Airport Turnout was 85 ppb over the one-year test period. Why is this a concern? As EWG has highlighted in many previous reports on the safety of our nation’s tap water, scientific investigations shows that exposure to concentration of DPBs at or below the MCL are a public health concern.

According to an EWG report published in 2007,

“[E]pidemiological studies have associated [40 ppb of THMs] with adverse health effects in infants, ranging from low birth weight to neurological abnormalities.

Epidemiological studies have found increased incidences of neural tube defects, small body length, and small head size in women drinking water containing only 40 ppb THMs (Kanitz 1996; Klotz 1999), and a recent study finds an increased risk of bladder cancer associated with exposures as low as 50 ppb (Villanueva 2007). Researchers have also found links to low birth weight and first trimester miscarriage in pregnant women drinking water with just 60 ppb and 75 ppb, respectively (Bove 2002). These levels are all below the EPA’s current MCL of 80 ppb, suggesting that the federal limit is not low enough to be health protective.”

(July, 2007 http://www.ewg.org/research/chlorine-pollutants-high-levels-dc-tap-water/thm-levels-often-higher-what-studies-show-are).

In a 2013 EWG report on the safety of the nation’s tap water, we highlight the following:

“[T]he significant toxicity of trihalomethanes and other water contaminants generated by water treatment chemicals, documented by large numbers of scientists around the world, makes a compelling case for lowering the federal legal limit to well below 80 parts per billion. Since 1998, the evidence implicating trihalomethanes in serious disorders has mounted:

In 2011 a French research team, pooling data from studies in France, Finland and Spain, found that men exposed to more than 50 parts per billion of trihalomethanes had significantly increased bladder cancer risks (Costet 2011).

In 2007, a scientific team in Spain associated exposure to trihalomethanes greater than 35 parts per billion with increased bladder cancer risks (Villanueva 2007).

In 2007, researchers from four Taiwanese universities reported that people faced twice the odds of dying from bladder cancer if they drank water with trihalomethane contamination greater

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November 20, 2015 Page 3 of 4

than 21 parts per billion. This study was cited in the 2011 National Report on Carcinogens, a Congressionally-mandated report produced by the National Toxicology Program, a federal interagency scientific body (Chang 2007, NTP 2011).

A 2010 study by the National Cancer Institute found that about a quarter of the human population may have a genetic susceptibility that raises its risk of bladder cancer from trihalomethanes (Cantor 2010).

(February, 2013 http://www.ewg.org/research/water-treatment-contaminants)

Again, EWG is concerned about routine exposures to concentrations of DPBs typically measured in our tap water and certainly exceeding the EPA MCL for even short periods must be avoided if possible. And with regards to the potential hazards for pregnant mothers who are exposed to even low levels of DBPs, we wrote:

“The EPA standard for trihalomethanes is based on preventing bladder cancer, but the agency has noted that these chemicals may present reproductive and developmental risks as well (EPA 2012a). A spike that lasts three months exposes a pregnant woman and her fetus to excessive trihalomethane for an entire trimester, a critical window of development. Scientific research has shown that such intensive exposure can have serious consequences for the child (emphasis added). Three studies published last year:

Australian scientists found that when women in their third trimester of pregnancy consumed water with 25 parts per billion of chloroform, their newborns were small for their gestational age, meaning that they typically had birth weights in the lowest ten percent of newborns and were at higher risk for a various health problems (Summerhayes 2012). Canadian researchers found that exposure to more than 100 parts per billion of trihalomethanes during the last trimester of pregnancy was associated with newborns small for their gestational age (Levallois 2012). Taiwanese researchers linked stillbirth risks to trihalomethane levels as low as 20 parts per billion (Hwang 2012).

Numerous other studies have associated reproductive and developmental problems with trihalomethanes. Among them:

In 2008, scientists from the University of North Carolina found that women exposed to more than 80 parts per billion of trihalomethanes during their third trimester of pregnancy faced twice the risk of delivering a child small for gestational age (Hoffman 2008). British scientists found a link between 60 parts per billion of trihalomethane exposure and stillbirths (Toledano 2005). In 2003, a team from the Harvard School of Public Health linked exposures to more than 80 parts per billion of trihalomethanes during the second trimester of pregnancy to low birth weight and small-for-gestational-age newborns (Wright 2003).

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In 2002 researchers at the Federal Agency for Toxic Substances and Disease Registry reviewed the findings of 14 major studies and concluded that there was “moderate evidence” for an association between trihalomethane exposure, small-for-gestational-age newborns, neural tube defects and miscarriage (Bove 2002). The neural tube is the structure in the fetus that develops into the brain and spinal cord.”

(February, 2013 http://www.ewg.org/research/water-treatment-contaminants)

The evidence cited above is why we are troubled by the revelations presented in the ABC 10 story. While the experiment with ACH was eventually stopped as it became clear it would not be an appropriate form of treatment, we wonder why it took the Department of Utilities so many months to come to that determination. Clearly, the State Drinking Water Program had not mandated that this trial be commenced or that is be continued months after troubling readings were coming in from the monitoring stations. Meanwhile, some city residents, likely including pregnant women, were exposed to excessive concentrations of DBPs.

EWG strongly believes that exposures to DBPs at levels below the EPA’s MCL are a health concern. We are even more concerned about exposures to concentrations of DBPs that repeatedly spike over the legal limit. The City Manager’s trivialization of this concern is not sound science or good public policy. Exposing citizens to toxic chemicals in order to lower costs is not an acceptable practice.

Sincerely,

Bill Allayaud Nneka Leiba, MPhil, MPH California Director of Government Affairs Deputy Director of Research