Member Spotlight: Newport News Waterworks

When discussing safe water, utilities must begin finding a balance.

As a regional water provider,?Newport News Waterworks ?serves over 410,000 people in Hampton, Newport News, Poquoson, York County, and part of James City County with their reservoirs consisting of the Diascund Reservoir, Harwood’s Mill Reservoir, Lee Hall Reservoir, Little Creek Reservoir, and Skiffe’s Creek Reservoir.

In addition, NNWW has owned significant watersheds since its founding in 1889.?This ownership, supplemented with regulatory controls, structural improvements, inspections, water quality monitoring, and forest management, provides robust source water protection. The utility has adopted a solid and cohesive asset management program framework using mobile devices for asset condition assessment, procuring best-in-class asset management software, and prioritizing risk-based capital planning. The utility’s sustainability mission rests on providing high-quality drinking water, preserving grandfathered water rights and watershed sovereignty, embracing new technology, capitalizing on data-rich analytics, supporting a talented workforce, and providing transformational leadership, earning the utility an AMWA 2019?Sustainable Water Utility Management Award .

This month, Association of Metropolitan Water Agencies (AMWA) Director of Communications and Utility Management Programs Antoinette Barber and Marketing and Events Coordinator Wingel Caburian spoke with NNWW Director Yann Le Gouellec to discuss the utility’s approach to addressing and navigating PFAS issues.

Dr. Le Gouellec has been with NNWW for five years, having served as Assistant Director before transitioning to Director in 2021. He received his Bachelor of Civil Engineering from ESTP Paris and his Ph.D. in Civil Engineering from 美国加州大学洛杉矶分校 .

AMWA has highlighted some of the responses from the conversion with Dr. Le Gouellec below.

AMWA: Can you explain your utility’s steps to address PFAS contamination issues?

YLG:?Several years ago, we embarked on a journey that was not entirely new to us. During the Unregulated Contaminant Monitoring Rule (UCMR) 3, we were already analyzing PFOA and PFOS. At that time, the health advisory levels were much higher than they are now, and we believed we were in the clear since our levels were significantly below the sum of PFOS and PFAS, set at 70 parts per trillion. However, in 2019, we proactively initiated a source water monitoring investigation. This process involved tracing potential PFAS sources within our watershed upstream of the reservoirs. We later discovered that an airport was a major contributor of PFAS to our watershed. Although PFAS concentrations became diluted due to other streams in the watershed, we still detected levels of around 100 parts per trillion at one of our pumping stations.

As the PFAS traveled through further dilution factors, by the time it reached the terminal reservoirs where we draw our water supply, the levels dropped to under 10 parts per trillion. NNWW contacted the Virginia Department of Environmental Quality (DEQ) to address the situation, and we decided to publish the data and hire consultants to explore potential treatment options; we later recognized that others could be facing such challenges.

AMWA: Given the ever-changing PFAS regulatory landscape, what is the best way for NNWW to ensure it stays ahead of new standards and guidelines?

YLG:?Typically, we must stay closely connected with AMWA and similar associations. These organizations boast exceptional staff who help us stay ahead of the curve by anticipating the evolving regulatory landscape.

One challenge that we, as an industry, face is the need to shift our perspective from collaboration with EPA to a more advocacy-driven approach. In recent years, we had hoped that working hand-in-hand with congressional and EPA staff would lead to regulations prioritizing water safety and practicality, benefiting everyone involved. However, it appears to me that EPA may base some decisions not entirely on science or fail to allow sufficient time for the scientific process to unfold, resulting in what may seem like rushed determinations regarding specific Maximum Contaminant Levels (MCLs). Consequently, we must do a better job of advocating for the positions and concerns of water utilities, as we are responsible for delivering safe water to our valued customers.

AMWA: Can you explain further what you mean by “WE?”

YLG:?That’s an excellent question because it has several facets. During the AMWA board meeting in Toronto, I learned that while the American Water Works Association (AWWA) provides education and comments, their tax status restricts them from engaging in advocacy and lobbying. On the other hand, organizations like AMWA can undertake such activities and are particularly focused on the interests of utilities. AWWA serves the broader water industry, including consultants, manufacturers, regulators, and utilities, whereas AMWA has a distinct role. In the past, we may have emphasized collaboration and finding common ground. However, recent EPA decisions, such as the Cybersecurity rule, the CCR rule, and the handling of PFAS, have made it evident that we need a stronger defense. By aligning AMWA and NACWA, we can safeguard the interests of utilities and also of the customers we serve. It is important to remember that customers bear the burden twice: they consume PFAS and then assume the financial cost because they are passive recipients.

AMWA: How does NNWW’s budget or resource allocation effectively address PFAS contamination while ensuring financial stability?

?YLG:?This is a two-tier answer because our budget has always allocated sufficient funds for analysis, whether under UCMR 3 or now UCMR 5, as well as for our own investigations and potential pilot studies. However, when it comes to capital spending, we face uncertainty regarding EPA's finalization of the drafted rule. If the rule is implemented as is, we have not accounted for the costs, which could amount to tens of millions of dollars if we need to install GAC to comply. We face the challenge of deciding whether to install GAC for both plants, considering that one plant's finished water is slightly above the threshold of four parts per trillion while the other is just below. We cannot rely on chance alone in making this decision as discussions about sidestream treatment and other factors are ongoing. All that said, the necessary capital funds and associated budgets have yet to be secured.

Our first step is to educate city council members to prepare them for a significant increase. As you mentioned, cost management is a concern. EPA's cost estimation was based on pre-pandemic and pre-bipartisan infrastructure law conditions, which have further fueled construction cost inflation. Moreover, with a larger number of utilities now expected to comply with the rule, the supply and demand dynamics will drive costs even higher. It is worth noting that EPA sometimes includes the social cost of carbon but not in the one drafted for PFAS.

If we choose to implement GAC and it requires reactivation, we must consider the transportation logistics, as diesel trucks will be needed to transport the exhausted GAC over long distances. In addition, if EPA designates these substances as hazardous, we will also need certified drivers and appropriate trucks for compliance.

AMWA: How has NNWW successfully engaged with stakeholders to address water contamination issues?

YLG:?That's a really timely question because we just finished an?interview ?for Drinking Water Week which one of our local TV stations published. Before that, I also had a brief interview about PFAS, which the reporter had heard about from a previous interview on a different topic. However, there has been little response from customers because PFAS is not on their radar. Customers are primarily concerned about whether they can rely on getting water at their tap. Does it have the right pressure, and does it look clear? Interestingly,?Manny Teodoro's presentation at the Water Policy Conference ?noted that customers appreciate the safety aspect of bottled water, even though its regulations are less strict than those of EPA. It is the convenience of cracking open a bottle and the perception of purity that appeals to them. I am not necessarily advocating for this, but it is possible that in the future, public water utilities will align with regular treatment standards while customers may choose to have the option of additional purification methods at their homes, such as filters for their drinking water.

The challenge lies in expecting utilities to treat water to an extremely high standard of four parts per trillion or less to remove a contaminant of concern. To put it into perspective, one part per trillion is equivalent to one teaspoon in 2,000 Olympic-size swimming pools. The issue arises when this excellent water goes through a distribution system and is used generally for other purposes than drinking water, such as laundry, toilet flushing, dishwashing, lawn watering, etc. Do we really need water of such high purity for activities that do not necessarily benefit the majority of the population? In my opinion, the limited funds we invest in infrastructure should be prioritized on delivering water to our customers and ensuring we address acute issues first, and then pursue “nice-to-have” water quality standards. The draft PFAS rule primarily addresses chronic exposure, assuming someone consumes two liters of water per day for 70 years, which is often not the case. As long as we maintain the mindset of constantly chasing and removing the next detectable contaminant to make the water "better," we will not break free from this cycle.

AMWA: Please discuss in more detail “redefining water.”

YLG:?In essence, when we discuss safe water according to the Safe Drinking Water Act, the focus is often on contaminant removal. However, there comes a point where we need to strike a balance. For instance, in the case of using a reverse osmosis treatment system for drinking water, it produces ultra-pure water. But at the final stage of treatment, especially for drinking water purposes rather than industrial use, a polishing step is necessary to reintroduce minerals.

So, while we aim to remove contaminants, we also need to retain certain elements. In my opinion, safe water should be considered as water that is deemed problem-free for about 90 to 95% of the population without causing any acute or long-term issues such as nitrates or other clear concerns. The notion of parts per trillion is significantly lower than what was applicable for volatile organic compounds (VOCs). The only reason we can even discuss this topic is due to advancements in analytical instruments, which have become more sensitive. However, it does not necessarily mean drinking water quality has deteriorated; some contaminants might have been already present at levels that have not visibly impacted US population life expectancy. Life expectancy, based on water-related factors, has not decreased for the general US population over the last decades. I believe we should consider safe water also based on criteria that are measurable outcomes to human life expectancy, rather than basing decisions solely on extrapolation of laboratory animal studies.?Would complying with all drinking water standards that were in place in 2021 (i.e., before EPA’s drastic change in June 2022 for the health advisory level of PFOA and PFOS) truly leaves the water unsafe to drink?