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Division of Drinking Water (DDW) 97-005 Policy

NHW Production Well Field Location Map

The first update to the DDW 97-005 process in 20 years, the emergence of PFOA/PFOS sampling requirements, and the adoption of an MCL for 1,2,3-trichloropropane (1,2,3-TCP) have placed important experience in the hands of just a few consultants

Groundwater contamination from a wide range of chemicals continues to impact and impair the use of many groundwater systems in California today.  In many areas impaired groundwater systems represent a key local water source that, if remediated appropriately, can provide a sustainable supply of safe drinking water.  The Division of Drinking Water (DDW) of the State Water Resources Control Board recognizes this.  However, navigating the pathway towards approval for using remediation project-generated water has become more complex in recent times.

In an effort to ensure groundwater remediation projects, which target direct domestic end use, fully address the requirements of federal and state Safe Drinking Water Acts, DDW provided (in 2015) a revised draft of their Process Memo 97-005 for Addressing the Direct Domestic Use of Extremely Impaired Sources.  Updates to the permit application process include a paradigm shift in characterization of overall potential health effects through the use of Maximum Contaminant Level (MCL)-equivalents to evaluate Treated Water Goals.  This process is used by DDW to evaluate the appropriateness of treatment for an extremely impaired source considering the cumulative risks for actual and potential contaminants which are regulated and/or non-regulated.

In addition, the regulation of “emerging” contaminants is moving forward at pace.  In late 2017 DDW adopted an MCL for 1,2,3-trichloropropane (1,2,3-TCP) of 5 parts per trillion (5 ppt), and in August 2019, DDW issued updated Notification Levels (NLs) for Perfluorooctanoic acid (PFOA; 5.1 ppt) and Perfluorooctanesulfonic acid (PFOS; 6.5 ppt); these are fluorinated organic chemicals that are part of a larger group of chemicals referred to as per- and poly-fluoroalkyl substances (PFAS).

Advisian is one of the leading experts in helping water agencies permit water supply under the updated guidance and regulations; we have extensive experience in applying the revised 2015 draft Process Memo 97-005 and have recently engaged with DDW on numerous applications for public water utilities in southern California on behalf of our client’s for small and large-scale water treatment systems.