GRA's full-day symposium on January 25th in Glendale, which focused on the rapidly developing problem of how to address low levels of hexavalent chromium in groundwater, was well attended and provided a comprehensive overview of this controversial drinking water issue. The symposium was well received by GRA members and other water agency, regulatory, consultants, and environmental professionals. Many attendees appreciated that GRA had brought science and common sense to the hexavalent chromium issue, which has become a front-page news issue in Southern California since the film Erin Brockovich premiered. The meeting defined the current knowledge of the problem using the San Fernando Valley as a case study. GRA brought together leading national and state experts to present on all facets of the issue, including senior staff from the U. S. Environmental Protection Agency (USEPA), Cal/EPA's Department of Toxic Substances Control (DTSC), Office of Environmental Health Hazard Assessment (OEHHA), and Department of Health Services (DHS), water agencies, and prominent law firms.

The symposium consisted of four sessions that focused on hexavalent chromium's Geochemical Characteristics and Distribution; Risk/Toxicology and Testing; Social, Political, and Legal Issues; and Regulatory Approach and Remediation. There was also a lunchtime presentation on the hexavalent chromium issue in drinking water by representatives of the Cities of Burbank and Glendale. A complete description of the individual speaker's presentations (as well as additional information and links) is provided on GRA's web page (www.grac.org), which will also provide updates on this and other breaking groundwater issues.

Session One - Geochemical Characteristics and Distribution

The first session on geochemical characteristics and distribution provided a solid foundation for the day, with summaries of chromium's geochemical characteristics by Douglas Kent with the US Geological Survey, Menlo Park, and Carl Palmer with the Idaho National Engineering and Environmental Laboratory (INEEL), Idaho Falls. Under natural conditions, total chromium is present primarily as chromium (III), or trivalent chromium, which tends to form insoluble hydrous oxides at neutral to alkaline pH values. Chromium (VI), or hexavalent chromium, is generally not known to be the predominant natural form of total chromium in groundwater, with some exceptions. Hexavalent chromium behavior at contaminated sites is complex. Dixon Oriola of the Los Angeles Regional Water Quality Control Board provided an overview of hexavalent chromium contamination in the San Fernando Valley, where the Board has recently launched a comprehensive investigation concentrating on hexavalent chromium sources associated with industrial activities between the 1940's and 1980's.

Session Two - Risk, Toxicology, and Testing

The second session focused on risk, toxicology, and testing for hexavalent chromium. Dr. Bruce Macler, a toxicologist with USEPA, Region 9 opened the session with the USEPA's risk management approach that established the Maximum Contaminant Level (MCL) set by the USEPA for total chromium of 100 ug/l. USEPA recognizes hexavalent chromium as a known human carcinogen by inhalation, but not by oral ingestion. In contrast, Dr. Robert Howd of OEHHA explained that OEHHA considers hexavalent chromium an oral carcinogen based on cancer evidence via the oral route and has developed a Public Health Goal (PHG) of 2.5 ug/l for total chromium. Dr. David Spath, DHS, then described DHS's current reevaluation of the existing MCL for total chromium and consideration of a new MCL for hexavalent chromium triggered by the new PHG. DHS must consider the feasibility of setting MCLs as close to the PHG as feasible while also reviewing the technical and economical feasibility for water purveyors to achieve such MCLs. In January 2001, an emergency regulation was released that requires vulnerable water systems to monitor for hexavalent chromium so that DHS can develop a database on chromium's distribution. Dr. Bart Simmons with DTSC's Hazardous Materials Laboratory discussed the analytical methods used for hexavalent chromium analysis of soil and groundwater. Some of the key considerations with regard to DHS' specified method for analysis of hexavalent chromium in drinking water (EPA 218.6) is the detection limit for reporting (1 ug/l), the short holding time (24 hours), and the low number of laboratories certified in California for the analysis.

Lunchtime Speakers - A Tale of Two Cities

A tale of two cities was provided by the two lunchtime speakers, Don Froelich, City of Glendale, and Fred Lantz, Burbank Water and Power. Both speakers highlighted the political and technical communication challenges of the hexavalent chromium controversy, which has produced a high number of concerned calls from citizens about the quality of water since the chromium issue has appeared in numerous press articles. The cost to treat the groundwater to the PHG would be millions of dollars. A common challenge the cities are faced with on all levels is communicating the technical issues related to hexavalent chromium in drinking water, such as the difference between California's total chromium PHG and MCL, USEPA's MCL and MCLG, and the relative proportion of hexavalent to total chromium.

Session Three - Social, Political and Legal Issues

The third session focused on the social, political and legal issues associated with hexavalent chromium in groundwater, and featured presentations from three prominent environmental attorneys and a speaker from the California League of Conservation Voters (CLCV). Dr. Joe Lyou of the CLCV opened the session by providing the perspective of the citizen and environmental groups, and described the public's general unwillingness to tolerate any level of industrial contamination in their water supply, irrespective of the "safe" levels mandated by Federal or State government. He stressed that hexavalent chromium was just the latest symptom of a bigger problem: the failure to recognize contamination problems and take action until after the damage has been done. The second speaker was Joe Gonzalez, an environmental attorney with Masry and Vititoe, the plaintiff law firm featured in the movie "Erin Brockovich" on the Hinkley case. Mr. Gonzalez gave an impassioned plea to polluters, regulators and the impacted parties to resolve these issues without involving lawyers and expressed disappointment that the regulatory system had not been able to protect the State's water resources from contamination. Steve Hoch with Hatch and Parent (and former lead counsel for PG&E in the Hinkley case) rejected some of the preceding opinions, noting that in many instances contingency law firms do not take on cases to "save the planet" but rather to win big financial judgments. He also focused on the position of public and private water utilities caught in the middle between the polluter and the public. The final presenter was Tom Meador with the law firm of Weston, Benshoof, Rochefort, Rubalcava and MacCuish. He presented the view of the "accidental discharger" and indicated that most large corporations will take action to address their contamination problems; however, they must be held to a reasonable standard. He also highlighted that many of the sources of hexavalent chromium are small "mom and pop" plating operations that do not have the financial resources to clean-up large, regional contamination problems and he suggested that a State fund might be needed to implement these clean-ups.

Session Four - Regulatory Approach and Remediation

The final session on regulatory approach and remediation expanded on the problems described by the lunch-time speakers, and addressed consequences of the concerns resulting from the very low PHGs developed by OEHHA. Mel Blevins, the Court-appointed Upper Los Angeles River Area (ULARA) Watermaster since 1979, has been asked repeatedly to give updates to the Los Angeles City Council on the chromium issue, including past historical discharges to surface drainage areas. Mr. Blevins has also been asked to participate in the request from cities looking to obtain compensation for dealing with chromium-related impacts to water distribution, including the city of Glendale, which is currently choosing not to use large amounts of water that currently meet health standards. Dr. Kimiko Klein with the Human and Ecological Risk Division (HERD) of Cal/EPA DTSC then presented the current implementation of PHGs for contaminated soils. DTSC is faced with selecting clean up levels for soil based on (1) direct cancer toxicity values, and (2) potential impact from soil to groundwater. Dr. Klein also mentioned the current debate on whether the PHG should be considered an Applicable, Relevant or Appropriate Requirement (ARAR) in feasibility studies. Dr. Carl Palmer of INEEL summarized six current remediation techniques for sites contaminated with hexavalent chromium: "pump and treat", electrokinetics (electromigration), reduction, bioremediation (microbes), permeable reactive barriers (PRBs), and natural attenuation. These technologies have the potential for promising applications, with the underlying requirement for a detailed understanding of the complex geochemical conditions of a contaminated site.

GRA wishes to thank our cooperating organizations:

The International Association of Hydrogeologists (IAH), California Groundwater Association (CGA), American Ground Water Trust (AGWT), Water Education Foundation (WEF), National Ground Water Association (NGWA), Professional Environmental Marketing Association (PEMA), and Association of California Water Agencies (ACWA). We also wish to thank our co-sponsors Best Sulfur Products, Calscience Environmental Laboratories, Inc., CH2M HILL, Earth Tech, Hatch & Parent, Montgomery Watson, and Pat-Chem Laboratories.

GRA also thanks the speakers, break and lunch sponsors, and the GRA organizing committee led by Jim Carter. The CrVI issue is evolving rapidly, and GRA plans an update symposium within a year.