HomeMy WebLinkAbout10_RESPONSE_TO_ORANGE_COUNTY_GRAND_JURY_REPORT_ENTITLED_PFAS_AND_PUBLIC_AWARENESS_–_A_CLOSER_LOOK_ATAgenda Item
Reviewed:
City Manager
Finance Director
AGENDA REPORT
MEETING DATE: AUGUST 4, 2026
TO: ALDO E. SCHINDLER, CITY MANAGER
FROM: MICHAEL GRISSO, DIRECTOR OF PUBLIC WORKS
SUBJECT: RESPONSE TO ORANGE COUNTY GRAND JURY REPORT ENTITLED
“PFAS AND PUBLIC AWARENESS – A CLOSER LOOK AT ORANGE
COUNTY DRINKING WATER”
SUMMARY
Response to the June 9, 2026, Orange County Grand Jury Report entitled “PFAS and Public
Awareness: A Closer Look at Orange County Drinking Water”.
RECOMMENDATION
It is recommended that the City Council approve the attached response to the Orange County
Grand Jury, authorize the Mayor to sign the letter on behalf of the City Council, and direct
the City Clerk to submit the response.
FISCAL IMPACT
No fiscal impacts associated with this item.
BACKGROUND AND DISCUSSION
On June 9, 2026, the Orange County Grand Jury (Grand Jury) released a report entitled
“PFAS and Public Awareness: A Closer Look at Orange County Drinking Water.” The report
examines the occurrence of per- and polyfluoroalkyl substances (PFAS) in Orange County
drinking water supplies, evaluates how local water agencies have responded to evolving
state and federal regulatory requirements, and reviews public outreach and education efforts
related to PFAS. The report also assesses the status of PFAS treatment p lanning and
implementation throughout Orange County. A copy of the Grand Jury Report is included as
Attachment 1 to this report.
PFAS are a group of synthetic chemicals commonly referred to as “forever chemicals” due
to their persistence in the environment and resistance to degradation. Because of their
widespread historic use and environmental persistence, PFAS have been detected i n water
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Grand Jury Report Response
August 4, 2026
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supplies throughout the United States, including portions of the Orange County Groundwater
Basin. The Grand Jury report recognizes that Orange County water agencies, including the
Orange County Water District (OCWD) and its member agencies, have undertaken extensive
monitoring, treatment, and public communication efforts to address PFAS and ensure
compliance with applicable drinking water regulations.
The Grand Jury investigation focused on evaluating PFAS monitoring and reporting
requirements, treatment implementation, public education efforts, and compliance with state
and federal drinking water standards. The report concluded that Orange County drink ing
water continues to meet or exceed all applicable drinking water standards and is safe for
consumption. The report further acknowledged the proactive role of OCWD and local water
agencies in monitoring groundwater supplies and implementing PFAS treatmen t facilities.
In accordance with California Penal Code Sections 933 and 933.05, the City is required to
provide a formal response to each finding and recommendation directed to the City. The
response must be submitted within the statutory timeframe established by the Gr and Jury.
The Grand Jury report contains four findings and three recommendations directed to the City
of Tustin that require a formal response. The proposed response letter, included as
Attachment 2, addresses each applicable finding and recommendation and reflects the City’s
ongoing commitment to providing safe, reliable drinking water, supporting PFAS monitoring
and treatment efforts, and enhancing public outreach and education regarding drinking water
quality.
Staff recommends approval of the attached response letter and authorization for the Mayor
to execute the response on behalf of the City Council.
Michael Grisso
Director of Public Works
Attachments:
1. Orange County Grand Jury Report entitled “PFAS and Public Awareness: A Closer
Look at Orange County Drinking Water”
2. Response Letter
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ATTACHMENT 1
Orange County Grand Jury Report entitled “PFAS and Public
Awareness – A Closer Look at Orange County Drinking Water”
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Fcalifornia stateting,4
PFAS and Public Awareness
A Closer Look at Orange County
Drinking Water
Orange County Grand Jury 2025-2026
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PFAS and Public Awareness
Orange County Grand Jury 2025-2026 Page 3 of 62
TABLE OF CONTENTS
SUMMARY ...................................................................................................................... 5
BACKGROUND .............................................................................................................. 5
REASON FOR STUDY ................................................................................................... 8
METHOD OF STUDY ...................................................................................................... 8
INVESTIGATION AND ANALYSIS .................................................................................. 9
FINDINGS ..................................................................................................................... 35
RECOMMENDATIONS ................................................................................................. 36
COMMENDATIONS ...................................................................................................... 37
REQUIRED RESPONSES ............................................................................................ 39
Acronyms ...................................................................................................................... 46
Glossary ........................................................................................................................ 50
Bibliography .................................................................................................................. 51
Appendix A .................................................................................................................... 55
Appendix B .................................................................................................................... 62
FIGURES
Figure 1 - Potential Major Exposure Pathways of PFAS to Humans ............................... 6
Figure 2 - Orange County Groundwater Public Supply Wells ........................................ 11
Figure 3 - Orange County Water District (OCWD) Service Area ................................... 12
Figure 4 - Municipal Water District of Orange County (MWDOC) Service Area ............ 13
Figure 5 - The PFAS Cycle ............................................................................................ 15
Figure 6 - Wastewater Treatment Discharges to the Santa Ana River .......................... 16
Figure 7 - CDC Multi-site Study Site Orange County, CA .............................................. 17
Figure 8 - Average PFAS Levels in Blood, CDC Multi-site Study Virtual Open House,
July 2025 ....................................................................................................... 18
Figure 9 - How are people exposed to PFAS? .............................................................. 20
Figure 10 - Are PFAS Safe? .......................................................................................... 22
Figure 11 - Highest PFAS Detections Among All OCWD Sources During UCMR 3 and
UCMR 5 Monitoring Cycles ......................................................................... 24
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Figure 12 - Highest PFAS Detections Among All OCWD Sources Listed on Each
SWRCB Monitoring Order Exhibit A ............................................................ 25
Figure 13 - PFAS Rule Enforceable Maximum Contaminant Levels and Maximum
Contaminant Level Goals ............................................................................ 27
Figure 14 - Timeline of OCWD Response to PFAS in the Santa Ana River Basin ......... 29
Figure 15 - Map of Current and Future PFAS Treatment Locations .............................. 30
Figure 16 - Approximate PFAS Capital Funding Sources .............................................. 31
Figure 17 - Summary of PFAS Treatment Facilities ...................................................... 32
Figure 18 - OCWD Share of PFAS Treatment Facility Annual O&M Cost ..................... 33
Figure 19 - PFAS Monthly Cost to OCWD Service Area Residents .............................. 34
Figure 20 - UCMR 3 Contaminants List, PFAS Contaminants ...................................... 55
Figure 21 - UCMR 5 Contaminants List, PFAS Contaminants ...................................... 56
Figure 22 - SWRCB PFAS General Monitoring Orders Issued 2020 through 2025 ....... 57
Figure 23 - SWRCB General Monitoring Order 2020-0003-DDW, PFAS Constituents . 58
Figure 24 - SWRCB General Monitoring Order 2021-0001-DDW, PFAS Constituents . 59
Figure 25 - SWRCB General Monitoring Order 2022-0001-DDW, PFAS Constituents . 60
Figure 26 - SWRCB General Monitoring Order 2025-0002-DDW, PFAS Constituents . 61
Figure 27 - EPA Eight Content Requirements of a Consumer Confidence Report ........ 62
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SUMMARY
Per- and Polyfluoroalkyl Substances (PFAS) form a broad class of thousands of
synthetic chemicals characterized by strong carbon–fluorine bonds and are among the
most durable compounds in organic chemistry. This bond strength makes PFAS highly
resistant to breaking down, allowing them to persist in the environment for decades or
longer. Because of this persistence, PFAS are often called “forever chemicals.”
Various industries have used PFAS in consumer and commercial applications since the
1940s because their chemical properties provide water, oil, and stain resistance, as well
as heat stability. These properties support applications across numerous sectors,
including aerospace, automotive, textiles, firefighting foams, food packaging,
electronics, and medical devices. As a result of their widespread use and persistence,
PFAS now appear globally in water, air, soil, wildlife, and human blood .
Scientific studies continue to show associations between PFAS exposure and harmful
health effects in humans and animals, although the degree of risk varies by compound.
In response, federal and state agencies, including the United States Environmental
Protection Agency (EPA) and the United States Food and Drug Administration (FDA),
began accelerating regulatory actions in the 2010s to reduce PFAS exposure, enhance
monitoring, and develop treatment and disposal methods.
This report identifies and describes PFAS levels detected by Orange County drinking
water agencies. It evaluates how these agencies have responded to recent PFAS
regulatory requirements. It also examines the progress of PFAS treatment facility
planning and installation, along with implementation of public education programs
related to PFAS in drinking water. This report’s findings and recommendations aim to
strengthen PFAS reporting in annual Water Quality Reports (Consumer Confidence
Reports) and expand public outreach by Orange County drinking water agencies.
BACKGROUND
PFAS are a large group of man-made "forever chemicals" produced since the 1940s,
known for extreme persistence, environmental mobility, and bioaccumulation due to
strong carbon-fluorine bonds.1 Used in water/stain-resistant coatings, firefighting foams,
industrial processes, PFAS have contaminated soil, water, and air globally.
1 Elsie M. Sunderland, et al., “A review of the pathways of human exposure to poly- and perfluoroalkyl
substances (PFASs) and present understanding of health effects,” Journal of Exposure Science &
Environmental Epidemiology, November 23, 2018, accessed March 16, 2026,
https://sunderlandlab.org/assets/sunderland_jeseerev_2018wsi.pdf .
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Contaminated drinking water has led to high levels of exposure to PFOA, PFOS, and
other PFAS2 for some populations residing near manufacturing facilities. Workers in
facilities that make or use PFAS can be exposed to higher amounts of these chemicals
and have higher levels in their blood.3 Infants may be exposed to PFAS through
breastfeeding.4
Figure 1 - Potential Major Exposure Pathways of PFAS to Humans5
PFAS, especially PFOA and PFOS, have been detected in air, water, and soil in and
around manufacturing facilities. However, these releases have been declining since
companies began phasing out the production and use of several PFAS in the early
2000s.6 Due to their chemical structure, PFAS are very stable in the environment and
are resistant to breaking down. Some PFAS are volatile and can be carried long
distances through the air, which may lead to contamination of soils and groundwater far
from the source of the PFAS emission.7
The four major sources of PFAS are: fire training/fire response sites, industrial sites,
landfills, and wastewater treatment plants/biosolids. PFAS can get into drinking water
when products containing them are used or spilled onto the ground or into lakes and
rivers. Once in groundwater, PFAS are easily transported long distances and can
2 Kyle Steenland, Tony Fletcher, and David A. Savitz, “Epidemiologic Evidence on the Health Effects of
Perfluorooctanoic Acid (PFOA),” National Library of Medicine, accessed May 12, 2026,
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2920088/.
3 Sunderland, “A review of the pathways of human exposure.”
4 Ibid.
5 Ibid.
6 Ibid.
7 “Frequently Asked Questions (FAQs) PFAS General," California State Water Resources Control Board,
March 4, 2019, https://www.waterboards.ca.gov/pfas/docs/pfas_general_faq.pdf.
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contaminate drinking wells. PFAS in the air can also end up in rivers and lakes used for
drinking water.8
PFAS have been used extensively in surface coating and protectant formulations due to
their unique ability to repel oil, grease, and water. Major applications have included
protectants for paper and cardboard packaging products, carpets, leather products, and
textiles that enhance water, grease, and soil repellency, and in firefighting foams. PFAS
have also been used as processing aids in the manufacture of nonstick coatings on
cookware. Common consumer products containing PFAS include Teflon, Gore-Tex and
Scotchgard.9
Background Summary of PFAS and Its Effects
Source and Exposure: Primary sources include industrial sites, firefighting training,
landfills, and wastewater treatment plants. They enter drinking water, food, and indoor
dust, resulting in widespread human exposure.
Health and Environmental Impact: PFAS are associated with adverse effects,
including cancer (i.e. testicular, kidney), developmental delays, liver damage, and high
cholesterol. They do not break down easily, leading to "background" contamination even
in remote areas.10
Regulation and Action: While major US manufacturing of certain PFAS ended around
2015, they remain in products and in the environment. The EPA has established
Maximum Contaminant Levels (MCLs) for drinking water.11
"Forever Chemicals" Definition: Their chemical structure, featuring one of the
strongest bonds in organic chemistry, makes them resistant to heat, water, and oil, thus
earning them the nickname "forever chemicals.”12
In Orange County, PFAS have been detected in the Orange County Groundwater
Basin, which provides 77% to 85% of the drinking water for north and central parts of
the county. Local agencies have taken a proactive stance, shutting down dozens of
impacted wells and building some of the nation's largest treatment facilities to ensure
tap water meets safety standards.13
8 “PFAS background,” California State Water Resources Control Board , January 14, 2025,
https://www.waterboards.ca.gov/pfas/background.html
9 Ibid.
10 “PFAS Explained,” EPA, accessed March 11, 2026, https://www.epa.gov/pfas/pfas-explained.
11 “Per- and Polyfluoroalkyl Substances (PFAS), Final PFAS National Primary Drinking Water Regulation,”
Accessed May 12, 2026, https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas.
12 Ibid.
13 University of California, Irvine, “UCI PFAS Health Study, Frequently Asked Questions,” accessed May
12, 2026, https://sites.uci.edu/pfas/frequently-asked-questions/.
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REASON FOR STUDY
Recent regulatory actions related to PFAS have created significant operational,
financial, and communication challenges for drinking water agencies across California.
Orange County agencies face an intensifying timeline due to the region’s reliance on
groundwater supplies, the presence of PFAS in local aquifers, and the need to comply
with evolving state and federal standards. As regulatory and monitoring requirements
expand, agencies must rapidly adapt their treatment strategies, capital planning, and
public outreach efforts.
This study is necessary to provide a clear, up‑to‑date understanding of how Orange
County drinking water agencies are responding to these new requirements. Evaluating
the status of PFAS treatment planning and installation helps illustrate the extent of
infrastructure readiness, the pace of implementation, and the challenges agencies
encounter as they work to bring new systems online. At the same time, assessing the
development and delivery of PFAS‑related education programs offers insight into how
effectively agencies are communicating risks, regulatory changes, and water quality
information to the public.
By documenting current conditions and identifying gaps or emerging needs, the study
supports informed decision‑making among water providers, policymakers, and
ratepayers. This work helps ensure that Orange County communities receive safe
drinking water and that agencies are equipped to meet regulatory expectations while
maintaining public trust.
METHOD OF STUDY
The Orange County Grand Jury investigated the PFAS in Orange County drinking water
to provide a clear and accurate assessment. The Grand Jury based its study on a
comprehensive review of multiple sources, including interviews, public records, field
investigations, and relevant news articles. Multiple independent sources corroborated
and validated all facts, findings, and recommendations presented in the report.
• Interviewed several Orange County governmental leaders and senior staff
directly involved in managing drinking water quality
• Reviewed and analyzed key documents related to the investigation, including:
o Published Water Quality reports from all Orange County water retailers
o Records from all Orange County water agencies
• Examined news articles and publications relevant to the topic.
• Conducted extensive internet research.
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• Performed field investigations in which Grand Jury members visited several
water management agencies to directly observe and assess drinking water
processes.
INVESTIGATION AND ANALYSIS
The 2025-2026 Orange County Grand Jury investigated the presence of PFAS in
Orange County drinking water and the response of Orange County community water
systems. Community water systems (CWS) are city, county, regulated utilities, regional
water systems and even small water companies and districts where people live. Non-
community water system.14 Provide drinking water to the public at locations where
people do not reside permanently. The investigation included evaluation of Orange
County CWS compliance with federal and state PFAS monitoring and reporting
requirements and the extent of the voluntary response to PFAS contamination. The
Grand Jury also evaluated annual Consumer Confidence Reports, also called Annual
Water Quality Reports, which are issued annually by CWS and distributed to their
customers.
Orange County Drinking Water Systems
The Grand Jury investigation was limited to community water systems (CWS) operated
by cities or special districts that are regulated under the Safe Drinking Water Act .15
CWS are defined as public water systems that serve at least 15 service connections
used by yearlong residents, or regularly serve at least 25 yearlong residents of the area
served by the system.16 In Orange County, there are 31 such CWS that are operated by
cities or special districts and that sell drinking water directly to customers on a retail
basis. In this report, these Orange County CWS may be referred to as retail water
districts or water retailers.
Drinking Water Sources
North and Central Orange County
Orange County is divided into two distinct areas when it comes to drinking water
sources. There are 2.5 million residents of north and central Orange County, who
receive about 85% of their drinking water supplies from the Orange County
Groundwater Basin, and the remaining 15% of their water supplies are imported from
14 “California Code, Health and Safety Code - HSC § 116275,” FindLaw, accessed May 21,2026,
https://codes.findlaw.com/ca/health-and-safety-code/hsc-sect-116275/.
15 “Summary of the Safe Drinking Water Act,” EPA, describing statutory authority at 42 U.S.C. § 300f et
seq., accessed My 21, 2026, https://www.epa.gov/laws-regulations/summary-safe-drinking-water-act.
16 “California Code, Health and Safety Code - HSC § 116275,” FindLaw.
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the State Water Project and Colorado River delivered by Municipal Water District of
Orange County (MWDOC).17
South Orange County
Approximately 600,000 residents of south Orange County rely primarily on imported
water supplies delivered by MWDOC, and a few south County communities also have
groundwater supplies from the San Juan Basin and surface water supplies from Irvine
Lake (also referred to as the Santiago Reservoir).18
Public Supply Wells
According to the California Department of Water Resources (DWR) as of November
2024,19 there were a total of 217 public supply wells for drinking water in Orange
County. Of the 217 total wells, 211 were CWS wells and six were non-community water
system wells. See Figure 2 for a Department of Water Resources map of Orange
County groundwater public supply wells. This map illustrates the reliance of north and
central Orange County on groundwater sources, and the reliance of south Orange
County on imported water supplies.
17 “How water works in Orange County,” OCWD, accessed May 21, 2026, https://www.ocwd.com/learning-
center/how-water-works-in-oc/.
18 Ibid.
19 “California’s Groundwater Live: Well Infrastructure,” California Department of Water Resources,
accessed April 13, 2026, https://storymaps.arcgis.com/stories/f2b252d15a0d4e49887ba94ac17cc4bb.
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Source: State of California, Department of Water Resources
Figure 2 - Orange County Groundwater Public Supply Wells
Orange County Water District
Orange County Water District (OCWD) manages the Orange County Groundwater
Basin to ensure sustainable use through replenishment of groundwater and delivery of
water supplies to its 19 member agencies. Some OCWD member agencies are also
members of MWDOC.
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Figure 3 - Orange County Water District (OCWD) Service Area
Municipal Water District of Orange County
MWDOC is the wholesale water provider and resource planning agency that partners
with the Metropolitan Water District of Southern California (MWD) to deliver imported
water to its 27 member agencies.20 Some MWDOC member agencies are also
members of OCWD.
20 “How water works in Orange County,” OCWD.
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Source: MWDOC
Figure 4 - Municipal Water District of Orange County (MWDOC) Service Area
PFAS and the Health Effects of Exposure
What are PFAS?
PFAS are a large group of many thousands of manufactured chemicals that are
resistant to heat, oil, and water. Among the many thousands of different PFAS, some
have been more widely used and studied than others.21 PFAS have been used
extensively in surface coating and protectant formulations due to their unique ability to
reduce the surface tension of liquids, and their ability to repel oil, grease, water, and
staining. Major applications have included use as processing aids in the manufacture of
nonstick coatings on cookware, surface protectants for paper and cardboard such as
disposable food packaging, microwave popcorn bags, pizza boxes, and candy
wrappers. Other surface protectants include those used on furniture and carpets,
21 “PFAS Explained,” EPA.
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leather products, outdoor gear, and textiles.22 PFAS are also one of the main
components of aqueous film forming foams (AFFF) used frequently at airports and
military bases for firefighting and emergency response training activities.23 It is important
to note that PFAS-containing firefighting foams and other emergency response
materials containing PFAS are no longer in use at Orange County airports and
harbors.24
PFOA and PFOS are two types of PFAS of particular concern that are no longer
manufactured or imported into the US. Trace amounts of PFOA and PFOS may still be
contained in some imported goods and in other PFAS goods and materials that are still
produced and used in the US.25 Under the PFOA Stewardship Program with the EPA,
eight major PFAS producers have phased out PFOA and other PFAS substances from
their emissions and products; however, manufacturers are replacing substances in the
PFAS family with others such as GenX and ADONA.26
Understanding the PFAS Cycle: How PFAS Moves Through the Environment
PFAS move through the environment in a repeating cycle through air, water, soil,
products, animals, and humans. This is known as the PFAS cycle . This cycle can be
described in four stages and is illustrated at Figure 5.27
Manufacturing and use. The PFAS cycle begins during manufacturing or everyday
use of PFAS-containing consumer and industrial products. During manufacture and
use, PFAS are released into the air, water, and soil. As more PFAS are
manufactured and used, the more they accumulate because they are persistent and
resistant to degradation.
Environmental spread. After PFAS are released to the environment, they move
through wind, snowfall, rain, and runoff to soil and surface water, and infiltration to
groundwater. Industrial sites and wastewater treatment plants are key entry points
22 “Our Current Understanding of the Human Health and Environmental Risks of PFAS,” EPA, Accessed
May 21, 2026, https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-
risks-pfas.
23 Sunderland. “A review of the pathways of human exposure.”
24 “SB-1044 Compliance: Phasing Out PFAS in Class B Firefighting Foam,” CAL FIRE, accessed April 17,
2026, https://osfm.fire.ca.gov/what-we-do/pipeline-safety-and-cupa/fire-fighting-equipment-and-foam-
pfas.
25 “PFAS – Frequently Asked Questions,” California State Water Resources Control Board Division of
Water Quality (SWRCB), 5, [3] 3M Company, “Fluorochemical use, distribution and release overview.,”
AR226-0550, 1999, updated March 19, 2020, accessed March 25, 2026,
https://www.waterboards.ca.gov/pfas/docs/master_pfas_faq_mar.pdf .
26 “Risk Management for Per- and Polyfluoroalkyl Substances (PFAS) under TSCA,” EPA, accessed May
21, 2026, https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-and-
polyfluoroalkyl-substances-pfas.
27 “Understanding the PFAS Cycle,” EcoPulse, accessed April 13, 2026,
https://www.ecopulsenow.com/insights/understanding-the-pfas-cycle.
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into the environment. PFAS are absorbed from the environment by plants and
animals, and then move up the food chain.
Human exposure. Most people are exposed to PFAS through using PFAS -
contaminated products, drinking contaminated water, and eating contaminated food
such as fish caught from water contaminated by PFAS, and dairy products from
livestock exposed to PFAS.28 The US Centers for Disease Control (CDC) National
Health and Nutrition Examination Survey (NHANES) estimated that in NHANES
2017–2018 data 98% of the US population had combined PFAS serum levels
greater than 2 nanograms per milliliter.29
Re-entry. Even after disposal of PFAS products, PFAS can re -enter the environment
through landfill leachate or runoff to soils, agricultural spreading of biosolids, and
municipal wastewater treatment effluent discharges to surface water, resulting in
PFAS cycling back into soil, animal feed crops, and water.
Source: Minnesota Pollution Control Agency
Figure 5 - The PFAS Cycle
What is the Source of PFAS in Orange County Groundwater?
Wastewater treatment plants located along the Santa Ana River that discharge effluent
to the Santa Ana River upstream of managed aquifer recharge operations are sources
28 “Risk Management for Per- and Polyfluoroalkyl Substances (PFAS) under TSCA,” EPA.
29 “National Health and Nutrition Examination Survey. NHANES 2017-18 Overview,” Centers for Disease
Control and Prevention (CDC), accessed April 16, 2026,
https://wwwn.cdc.gov/nchs/nhanes/continuousnhanes/default.aspx?BeginYear=2017.
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of PFAS contamination for public water systems downstream of these wastewater
treatment plants.30 The OCWD Groundwater Replenishment System (GWRS) actively
manages and recharges the Orange County groundwater basin with surface water from
the Santa Ana River, imported surface water, and purified recycled water from the
GWRS. For much of the year, flow in the Santa Ana River consists predominantly of
effluent from municipal wastewater treatment plants upstream from the Orange County
groundwater basin.31 Figure 6 illustrates these upstream wastewater discharges to the
Santa Ana River.32 PFAS has recently been measured in the Santa Ana River at
concentrations consistent with wells surrounding the recharge facilities, suggesting that
historic concentrations of PFAS in the Santa Ana River may be a primary input of PFAS
in the Orange County groundwater basin.33
Figure 6 - Wastewater Treatment Discharges to the Santa Ana River
How Much PFAS is Found in the General Population?
Because of their widespread use and their persistence in the environment, many PFAS
are found in the blood of people and animals all over the world.34 CDC scientists have
measured PFAS in the blood serum (the clear portion of blood) of 98% of participants
30 “Per- and Polyfluoroalkyl Substances (PFAS), What are PFAS?” SWRCB, accessed May 21, 2026,
https://www.waterboards.ca.gov/santaana/water_issues/programs/pfas/.
31 “UCI PFAS Health Study,” University of California, Irvine, accessed May 12, 2026,
https://sites.uci.edu/pfas/.
32 National Water Research Institute, Report of the Scientific Advisory Panel: Orange County Water
District’s Santa Ana River Water Quality and Health Study, Fountain Valley, CA, 2004, accessed April 14,
2026, https://www.ocwd.com/wp-content/uploads/sarwqh-final-nwri-panel-report-2004.pdf.
33 Russ Detwiler, Reconstructing historical PFAS concentrations in groundwater using a reduced -order
modeling framework. Alburquerque NM, InterPore2025, May 20, 2025, accessed April 16, 2026,
https://events.interpore.org/event/56/contributions/7590/.
34 “PFAS Explained,” EPA.
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aged 12 years and older since 1999, indicating widespread exposure to PFAS in the US
population.35
Researchers at the University of California, Irvine (UCI) are participating in the CDC
Multi-site Study (MSS).36 The MSS provides information to communities about the
health effects of exposure to PFAS. The UCI MSS site is the area in Orange County,
shown at On the chart, the Orange County study site is labeled “CA.” Orange County is
the only California location included in the study.
Figure 7.
At the July 2025 MSS update, the
UCI researchers shared results
showing average levels of certain
PFAS chemicals in the blood of
adults who participated at the
Orange County study site. They
compared Orange County results
with other study locations and with
national averages. For adults at the
Orange County site, the average
blood levels were estimated to be
2.4 for PFOS, 1.2 for PFOA, 1.3 for
PFHxS, and 0.27 for PFNA
(measured in nanograms per
milliliter, ng/L) These levels were
lower than the averages seen
across all study sites. In addition, all
of these levels, except PFHxS, were
lower than the average levels found
in the general U.S. population. See
Figure 8 for the UCI MSS chart of
35 “PFAS Frequently Asked Questions,” SWRCB, 5, [8] CDC, “National Report on Human Exposure to
Environmental Chemicals,” 2019, accessed April 23, 2026,
https://www.waterboards.ca.gov/pfas/docs/master_pfas_faq_mar.pdf .
36 “Multi-site Study,” CDC, Agency for Toxic Substances and Disease Registry (ATSDR), Per- and
Polyfluoralkyl Substances (PFAS) and Your Health, accessed April 16, 2026,
https://www.atsdr.cdc.gov/pfas/health-studies/multi-site-study.html.
Source: CDC
Figure 7 - CDC Multi-site Study Site Orange
County, CA
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Average PFAS Levels in Blood.37 On the chart, the Orange County study site is labeled
“CA.” Orange County is the only California location included in the study.
Source: CDC
Figure 8 - Average PFAS Levels in Blood, CDC Multi-site Study Virtual Open House,
July 2025
Because of the phasing out of certain PFAS compounds, serum levels of PFOA and
PFOS in the general population of the US have decreased dramatically in recent years.
According to the CDC, blood levels of both PFOS and PFOA have steadily decreased in
US residents since 1999-2000.38
The half-life of PFAS in the human body is defined as the time required for the PFAS
concentrations in serum or plasma to fall by half from the starting concentration .39
Thirteen studies conducted mainly in Europe and the US involving both general
populations and exposed workers resulted in half-life estimates for PFOA of 2.73 years
(range: 1.48 to 5.1 years), 4.70 years for PFOS (range: 1.69 to 5.7 years), and 5.31
years for PFHxS (range: 2.84 to 8.5 years).40 Based on that information, with no
37 “PFAS Multi-site Study (MSS), Virtual Open House,” CDC, ATSDR, July 28, 2025, accessed April 16,
2026, https://www.atsdr.cdc.gov/media/pdfs/2025/08/Open-House-Slides-508.pdf.
38 “Per- and Polyfluoralkyl Substances (PFAS) and Your Health, Fast Facts: PFAS in the U.S. Population,”
CDC, ATSDR, https://www.atsdr.cdc.gov/pfas/data-research/facts-stats/index.html.
39 Isabella Rosato, et al. “Estimation of per- and polyfluoroalkyl substances (PFAS) half-lives in
human studies: a systematic review and meta-analysis,” Environmental Research, Volume 242, February
1, 2024, 117743, accessed April 13, 2026,
https://www.sciencedirect.com/science/article/pii/S0013935123025471.
40 Isabella Rosato, et al. “Estimation of per- and polyfluoroalkyl substances (PFAS) half-lives.”
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additional exposure, it could be anticipated that PFAS may be cleared from the body
after an average of five years. However, PFAS exposures continue in general
populations primarily through food and water despite production phase outs and
regulatory interventions.
How Are People Exposed to PFAS?
There is general agreement that dietary intake is the largest source of PFAS exposure
rather than inhalation or dermal contact.41 Direct exposures due to use in products can
be quickly phased out by production phaseouts but exposures driven by PFAS
accumulation in the environment, food chains, and contamination of groundwater and
drinking water persist because of the continuing PFAS cycle. Human exposures to
PFOS and PFOA, the two PFAS that are of greatest regulatory concern, have been
declining due to regulatory interventions while understanding of their adverse effects on
human health has been rapidly advancing. At the same time, a proliferation of new
PFASs has rapidly replaced PFOS and PFOA with shorter chain length PFASs and new
chemicals that are difficult to detect using standard methods.42 Emerging evidence from
animal experiments suggests some of these alternative PFASs can be equally
hazardous.43
41 Sunderland, “A review of the pathways of human exposure,” 136.
42 Sunderland, “A review of the pathways of human exposure,” 132.
43 Ibid.
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Source: EPA
Figure 9 - How are people exposed to PFAS?44
PFAS Exposure and Excretion
Exposure happens when a person breathes, eats, drinks, or touches a chemical and it
enters their body. Excretion is the process whereby substances, like PFAS, leave the
body. All PFAS can leave the body over time through urine, through menstrual blood or
blood donation, or through breast milk. All of these factors could affect PFAS levels
measured in blood.45 While PFAS blood test results can tell you the amount of certain
PFAS in your blood, the test results will not provide information to pinpoint a health
problem and will not predict future health outcomes. You can talk with your healthcare
provider about the benefits and limitations of PFAS blood testing.46
44 “PFAS Explained,” EPA, 2, March 11, 2026, https://www.epa.gov/system/files/documents/2023-10/final-
virtual-pfas-explainer-508.pdf.
45 “Per- and Polyfluoralkyl Substances (PFAS) and Your Health, Preventing PFAS Exposure,” CDC,
ATSDR, accessed April 16, 2026, https://www.atsdr.cdc.gov/pfas/prevent-exposure/your-body.html.
46 “Per- and Polyfluoralkyl Substances (PFAS) and Your Health, Testing for PFAS,” CDC, ATSDR,
accessed April 17, 2026, https://www.atsdr.cdc.gov/pfas/blood-testing/index.html.
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What are the Health Effects of Exposure?
Exposure to unsafe levels of PFOA/PFOS may result in adverse health effects including
developmental effects to fetuses during pregnancy, cancer, liver effects, immune effects,
thyroid effects, and other effects such as cholesterol changes.47
Laboratory studies in animals who were exposed to PFAS found links between the
chemicals and increased cholesterol, changes in the body’s hormones, alterations of
the immunologic system, decreased fertility, increased risk of cancer (especially kidney
and testicular), low birth weight, delayed puberty onset, and birth defects. Since humans
and animals react differently to PFAS, not all effects observed in animals may occur in
humans. Although many epidemiology studies have examined the potential of PFAS to
result in adverse health effects, most of the studies are cross-sectional in design and do
not establish causality. Based on several factors outlined in the report of PFAS by the
CDC including the consistency of findings across studies, the available epidemiology
studies suggest associations between PFAS exposure and several hea lth outcomes in
humans.48
47 “PFAS Frequently Asked Questions,” SWRCB, 5, [6] A. M. Calafat, L.-Y. Wong, Z. Kuklenyik, J. A. Reidy,
and L. L. Needham, “Polyfluoroalkyl Chemicals in the US Population: Data from the National Health and
Nutrition Examination Survey (NHANES) 2003–2004 and Comparisons with NHANES 1999–2000,”
Environ. Health Perspect., vol. 115, no. 11, pp. 1596 - 1602, Nov. 2007,
https://www.waterboards.ca.gov/pfas/docs/master_pfas_faq_mar.pdf .
48 “PFAS Frequently Asked Questions,” SWRCB, 8, [1] ATSDR, “Toxicological Profile for Perfluoroalkyls,
Draft for Public Comment,” 2018, https://www.waterboards.ca.gov/pfas/docs/master_pfas_faq_mar.pdf.
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Source: EPA
Figure 10 - Are PFAS Safe?49
PFAS Regulatory Requirements
Public drinking water systems are required to follow certain regulations to ensure that
the water they serve to their customers is safe to drink.50
In recent years, specific regulations have been issued to address PFAS contamination
that require monitoring and taking actions when PFAS is detected in drinking water
sources. The following sections present PFAS regulations in the order they were issued
by the EPA and California State Water Resources Control Board (SWRCB).
PFAS Monitoring Requirements
Monitoring refers to the collection and evaluation of data for contaminants that are
suspected of being present in water. Samples are collected and analyzed according to
EPA-approved laboratory methods. Monitoring results are reported to either the EPA or
SWRCB. This data serves as a primary source of occurrence and exposure information
used to develop regulatory decisions.
OCWD conducts all sampling and analyses and reporting of monitoring results to
regulatory agencies on behalf of its member agencies. OCWD owns and operates its
49 “PFAS Explained,” EPA, 1, accessed March 11, 2026,
https://www.epa.gov/system/files/documents/2023-10/final-virtual-pfas-explainer-508.pdf.
50 “Drinking Water Standards and Regulations: An Overview,” CDC, accessed May 21, 2026,
https://www.cdc.gov/drinking-water/about/drinking-water-standards-and-regulations-an-overview.html.
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own EPA-certified laboratory where it can use analytical methods approved by the EPA.
MWDOC member agencies conduct monitoring activities using either their own staff or
contractors to collect samples, which are delivered to EPA-certified laboratories for
analyses. Laboratories report the results of their analyses to each MWDOC water
retailer, who then reports the results to either the EPA or SWRCB.
EPA Unregulated Contaminant Monitoring Rule
EPA uses the Unregulated Contaminant Monitoring Rule (UCMR) to collect data every
five years for no more than 30 priority contaminants that are suspected to be present in
drinking water and do not have health-based standards set under the Safe Drinking
Water Act (SDWA).51 The UCMR applies to all large public water systems (PWSs)
serving greater than 10,000 people, all small PWSs serving between 3,300 and 10,000
people, and a representative sample of small PWSs serving fewer than 3,300 people.
EPA establishes the list of contaminants for each five-year UCMR cycle, considering an
initial list of contaminants that are not regulated by the National Primary Drinking Water
Regulations, are known or anticipated to occur at PWSs, and may warrant regulation
under the SDWA.52
The SDWA Public Notification Rule ensures that consumers will receive notice if there is
a risk to public health from their drinking water. The Public Notification Rule requires
that all PWSs notify their customers of the availability of UCMR results no later than 12-
months after results are known. CWS are required to report UCMR results in their
Consumer Confidence Report (CCR) when unregulated contaminants are detected. The
annual drinking water quality report must include notice of availability of unregu lated
contaminant monitoring results, the average of the year’s results and the range of
detections.53
The Grand Jury obtained UCMR monitoring data for all sampling and analyses
conducted to fulfill UCMR requirements for its member agencies. The highest PFAS
detections for all OCWD sources during the UCMR 3 and UCMR 5 monitoring cycles
are shown at Figure 11.
51 “Summary of the Safe Drinking Water Act,” EPA.
52 “Learn About the Unregulated Contaminant Monitoring Rule,” EPA, accessed April 7, 2026,
https://www.epa.gov/dwucmr/learn-about-unregulated-contaminant-monitoring-rule.
53 “Public Notification Rule,” EPA, accessed April 7, 2026, https://www.epa.gov/dwreginfo/public-
notification-rule#rule-summary.
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Source: Compiled from OCWD data
Figure 11 - Highest PFAS Detections Among All OCWD Sources During UCMR 3 and
UCMR 5 Monitoring Cycles
California State Water Resources Control Board PFAS General Monitoring Orders
Beginning in 2020, the SWRCB Division of Drinking Water, based on review of
monitoring results from its 2019 PFAS monitoring orders, determined that it was
necessary to expand monitoring to groundwater sources located within the vicinity of the
PFAS detections. Several PFAS general monitoring orders were issued to PWSs 2020,
2021, 2022, and 2025 that included Orange County groundwater well locations.54
Each of the SWRCB PFAS monitoring orders included requirements for sample
collection and laboratory analysis by specific dates, to be followed by monitoring
conducted every calendar quarter thereafter.55 These PFAS monitoring orders
established Consumer Confidence Report Detection Levels (CCRDL), and Notification
and Response Levels for each PFAS chemical to be monitored. A list of the SWRCB
PFAS monitoring orders and exhibits identifying groundwater sources required to be
monitored are shown at Appendix A, as well as copies of the CCRDL for each
monitoring order.
The Grand Jury obtained monitoring data for all sampling and analyses conducted to
fulfill SWRCB monitoring order requirements for sources listed in the monitoring orders
that are owned by their member agencies. The highest PFAS detections for all these
OCWD sources are shown at Figure 12.
54 “PFAS DDW General Orders,” SWRCB, accessed May 21, 2026,
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/pfas_ddw_general_order/.
55 Ibid.
EPA UCMR Number of PFAS on
UCMR Contaminants List
Maximum PFAS Detection
Among all OCWD Sources
2012-2016 UCMR 3 6 PFAS
Figure 20, Appendix A 70 ng/L
2022-2026 UCMR 5 29 PFAS
Figure 21, Appendix A 29 ng/L
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1OCWD monitoring data as of March 19, 2026
2Outlier result. Next maximum PFAS result 88 ng/L
3Outlier result. Next maximum PFAS result 73.7 ng/L
Source: Compiled from OCWD data
Figure 12 - Highest PFAS Detections Among All OCWD Sources Listed on Each
SWRCB Monitoring Order Exhibit A
2025 SWRCB General Order DW 2025-0002-DDW
The 2025 SWRCB General Order, issued on December 12, 2025, adopted the initial
monitoring requirements in the federal PFAS Rule for each California CWS and non-
transient, non-community water system. The 2025 SWRCB Order allows previously
acquired data to count toward initial monitoring if collected on or after January 1, 2019 ,
and reported concentrations no greater than the respective MCL.56
The 2025 SWRCB General Order also included a list of Orange County groundwater
sources showing that 151 of the 198 listed sources had completed initial monitoring as
required by the federal PFAS Rule.57
PFAS Notification and Response Requirements
Notification and response levels are health-based advisory levels established by the
SWRCB Division of Drinking Water (DDW) for chemicals in drinking water that do not
have established MCLs.
When chemicals are found in drinking water at concentrations greater than their
notification levels, PWSs are required by law to make specific notifications. When
56 “ORDER DW 2025-0002-DDW,” SWRCB, accessed May 21, 2026,
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/pfas_ddw_general_order/docs/order -
dw-2025-0002-ddw-pfas-initial-monitoring.pdf.
57 “Exhibit A – List of Sources and Required Monitoring Frequency,” SWRCB, accessed May 21, 2026,
https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fwww.waterboards.ca.gov%2Fdrinkin
g_water%2Fcertlic%2Fdrinkingwater%2Fpfas_ddw_general_order%2Fdocs%2Forder -dw-2025-0002-
ddw-exhibit-a.xlsx&wdOrigin=BROWSELINK.
SWRCB Order Number of PFAS on
Order CCRDL
Selected
Monitoring Date
Range
Maximum PFAS Detection
Among All OCWD Sources
Listed on Order Exihibit A
2020-0003-DDW 18 PFAS
Figure 23, Appendix A 8/27/20 - 2/15/21 67.5 ng/L
2021-0003-DDW 18 PFAS
Figure 24, Appendix A 2/16/21 - 10/30/22 470 ng/L2
2022-0001-DDW 25 PFAS
Figure 25, Appendix A 10/31/22 - 4/24/24 169 ng/L3
2025-0002-DDW 25 PFAS
Figure 26, Appendix A 4/25/24 - 3/19/261 73.7 ng/L
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chemicals are found in drinking water at concentrations greater than their response
levels, DDW recommends removal of a drinking water source from service.58
PFAS notification and response levels specified in CCRDLs attached to SWRCB
general monitoring orders remain in effect until MCLs are established and become
effective. For example, MCLs for specific PFAS will become effective in 2029, and at
that time will supersede notification and response levels specified the 2022 CCRDL.
PFAS National Primary Drinking Water Regulation
In April 2024 EPA announced the final National Primary Drinking Water Regulation for
six PFAS (the federal PFAS Rule).59 The PFAS Rule applies to all CWS. The EPA
expects that over many years this rule will prevent PFAS exposure in drinking for
approximately 100 million people, prevent thousands of deaths, and reduce tens of
thousands of serious PFAs-attributable illnesses.60
The PFAS Rule establishes initial monitoring and compliance monitoring requirements,
and enforceable maximum contaminant levels (MCL) for six PFAS in drinking water.
Initial monitoring for six listed PFAS must be implemented beginning April 2024 and
must be completed no later than April 26, 2027. Compliance monitoring requirements
beginning April 26, 2027, will be either triennial, annual, or quarterly as determined by
the SWRCB based on results of the initial monitoring.
Maximum Contaminant Level (MCL) is the highest level of a contaminant allowed in
drinking water. EPA has established legally enforceable MCLs of 4.0 parts per trillion
(ppt) for PFOA and PFOS, and 10.0 ppt for PFHxS, PFNA, and HFPO-DA (GenX
chemicals). Figure 13 shows the MCLs and MCLG effective April 26, 2029.
Ensuring compliance with drinking water MCLs for the PFAS of most concern is the
reason over $600 million (see Figure 17) is being spent to construct PFAS treatment
facilities in Orange County.
58 “Drinking Water Notification Levels,” SWRCB, accessed May 21, 2026,
https://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/NotificationLevels.html.
59 “Per- and Polyfluoroalkyl Substances (PFAS), Final PFAS National Primary Drinking Water Regulation,”
EPA, accessed May 21, 2026, https://www.epa.gov/sdwa/and-polyfluoroalkyl-substances-pfas.
60 Ibid.
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Source: EPA
Figure 13 - PFAS Rule Enforceable Maximum Contaminant Levels and Maximum
Contaminant Level Goals61
In addition to ongoing compliance monitoring and MCLs, the PFAS Rule also includes
additional requirements with future effective dates. Between April 2027 and April 2029, if
monitoring shows that drinking water levels exceed MCLs, CWS must implement
solutions that reduce these PFAS; results of initial monitoring must be included in the
CCR; results of compliance monitoring must be included in the CCR; and public
notification is required for monitoring and testing violations. Starting April 2029, CWS
that have MCL violations must take action to reduce levels of these PFAS in their
drinking water, and public notification is required for MCL violations.
Compliance with Regulatory Requirements
Consumer Confidence Reports
The Grand Jury reviewed the 2025 Consumer Confidence Reports (Water Quality
Reports) issued by 31 water retailers serving Orange County. The CCR is to be
delivered to all billing customers by July 1 of each year and must include specified
information. All 31 water retailers complied with the eight content requirements specified
by the EPA, shown in Appendix B.62 Seven of the 11 water retailers operating PFAS
61 “PFAS National Primary Drinking Water Regulation, April 2024,” EPA, accessed May 12, 2026,
https://www.epa.gov/system/files/documents/2024-04/pfas-npdwr_fact-sheet_general_4.9.24v1.pdf.
62 “Consumer Confidence Report Rule: A Quick Reference Guide,” EPA, accessed April 18, 2026,
https://www.epa.gov/sites/default/files/2014-05/documents/guide_qrg_ccr_2011.pdf.
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treatment facilities in Orange County included a PFAS advisory section in their CCRs,
while only 55 percent of the 31 water retailers included any PFAS advisory statement.
The Grand Jury found that the 31 Orange County water retailers reported either “not
detected” results or concentrations below notification thresholds for the six PFAS listed
in the EPA PFAS Rule on their 2025 CCRs. After PFAS treatment facilities became
operational, OCWD member retailers operating these facilities consistently reported “not
detected” results for the same six PFAS. The Grand Jury found that PFAS results from
individual wells do not necessarily reflect the quality of water delivered to custom ers, as
some tested wells were later placed into inactive status or destroyed. CCRs
documented PFAS constituents exceeding notification levels as required and did not
report “not detected” results for those constituents. Monitoring results and CCRs are
available in the Safe Drinking Water Information System (SDWIS), California’s official
database for tracking public water systems, drinking water quality monitoring, regulatory
compliance, and enforcement.63
Notification and Response
As of 2020, drinking water retailers with PFAS detections above notification and
response levels at wells without PFAS treatment facilities began to rely on imported
water, or groundwater blended with imported water to deliver drinking water with PFAS
concentrations below notification and response levels. As of 2021, multiple water
retailers in Orange County shut down groundwater wells after PFAS concentrations at
those wells exceeded established response levels.64
PFAS Rule Initial Monitoring
When the 2025 SWRCB General Order adopting the PFAS National Primary Drinking
Water Regulation was issued in December 2025, 76% of listed Orange County
groundwater sources had already completed initial monitoring required to be completed
by April 2027. Most of the remaining Orange County sources received credit for
previously acquired data, leaving only 6% with all requirements to be completed by April
2027.
63 “Drinking Water Watch,” SWRCB, Division of Drinking Water, Safe Drinking Water Information System
(SDWIS), accessed April 26, 2026, https://sdwis.waterboards.ca.gov/PDWW/.
64 “Orange County launches first water plant to remove PFAS toxins,” Solano Public Health, accessed
April 29, 2026,
https://publichealth.networkofcare.org/solano/CommunityResources/News/Article?articleId=124536.
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Proactive Response to PFAS Impacts
PFAS Impacts and OCWD Response
OCWD coordinated a regional response to PFAS contamination in partnership with its
member agencies. These efforts focus on restoring the groundwater basin, which
supplies up to 85 percent of the water used by approximately 2.5 million residents in
north and central Orange County. A timeline of OCWD response to PFAS in the Orange
County Groundwater Basin is shown in Figure 14. As PFAS-impacted groundwater wells
began to be shut down in early 2020, public education became a critical component of
community water systems’ response. OCWD dedicated resources to public outreach,
including the development of informational web pages to inform the public about PFAS
impacts and the measures being implemented to address them.65
Source: Compiled from multiple OCWD sources
Figure 14 - Timeline of OCWD Response to PFAS in the Santa Ana River Basin
PFAS contamination has impacted more than 100 groundwater wells across 15 water
retailers. As of this report, 53 wells have returned to service following construction of
treatment facilities. Figure 15 Figure 15 - Map of Current and Future PFAS Treatment
shows a map of current and future PFAS treatment locations in Orange County.
65 “PFAS education center,” Orange County Water District, accessed April 8, 2026,
https://www.ocwd.com/what-we-do/water-quality/pfas/.
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Figure 15 - Map of Current and Future PFAS Treatment Locations
PFAS Treatment Facilities and Capital Costs
Construction of PFAS treatment facilities began in 2020. OCWD executed the PFAS
Treatment Facilities and Program Agreement, under which OCWD funds capital costs
and shares operating and maintenance (O&M) costs with participating water retailers.
Figure 16 summarizes projected PFAS capital funding sources as of January 2026,
including OCWD pay-as-you-go (PAYGO) revenue, state and federal grants, an EPA
Water Infrastructure Finance and Innovation Act (WIFIA) loan, and litigation settlement
proceeds. The Grand Jury commends OCWD for securing diversified funding sources to
advance timely treatment facility construction.
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Source: OCWD data
Figure 16 - Approximate PFAS Capital Funding Sources
Figure 17 - Summary of PFAS Treatment FacilitiesFigure 17 Summary of PFAS
Treatment Facilities summarizes PFAS treatment facilities by water retailer, opening
date, treatment technology, capacity, location, connections, number of wells, and capital
costs. Facilities began entering service in mid‑2021, starting with a treatment plant in
Fullerton, with additional facilities becoming operational over time. Most facilities use ion
exchange technology. Capital costs vary based on the number of affected wells,
conveyance pipeline requirements, and treatment facility configuration.
OCWD is funding the reasonable costs of designing and constructing PFAS treatment
facilities for its member water retailers. Each retailer could either have OCWD design
and build the treatment facility or receive reimbursement for designing and constructing
the treatment system independently. As of this report, 38 wells with PFAS treatment
were built by OCWD and fifteen wells with PFAS treatment were designed and built by
the water retailers.
Eighteen wells with PFAS treatment construction projects by OCWD have been
completed on schedule. Ten wells with PFAS treatment projects, which were built by
OCWD, were completed on schedule; however, OCWD experienced cost overruns due
to specialized design requirements or owner-requested improvements. An additional 10
wells with PFAS treatment projects that were done by OCWD were completed late and
over budget, primarily due to pandemic-related material delays, design complexity,
owner-requested improvements, and utility coordination challenges.
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Source: Multiple OCWD and water retailer data
Figure 17 - Summary of PFAS Treatment Facilities
Community Water System Opening
Date Type Capacity Location Connections Wells Total Cost
($M)
Actual-to
Date ($M)
Remaining
Budget ($M)
Sep-2024 Ion Exchange 51,000 gal/min
Nine (9) PFAS treatment facilities
at Linda Vista, Katella Ave., Santa
Cruz, Energy Field, Brookhurst,
Willow Park, Downtown, Boysen
Park, and La Palma
14 $117.1 $117.1 $0.0
Dec-2028 Ion Exchange 8,000 gal/min Wells 48 & 53 2 $16.0 $0.8 $15.3
Dec-2028 Ion Exchange 8,000 gal/min Wells 39 & 47 2 $16.0 $0.9 $15.1
Dec-2029 Ion Exchange TBD Well 51 1 $7.0 $0.0 $7.0
City of Buena Park Jun-2026 Packer 2,200 gal/min
Linden Well - Install Packer to
reduce flow from PFAS zone(s) in
the well - not treatment.
1 $0.6 $0.1 $0.6
Jun-2021 Ion Exchange 2,400 gal/min Kimberly Well 1A 1 $5.3 $4.1 $1.3
Dec-2023
Granular
Activated
Carbon (GAC)
5,000 gal/min Main Plant 3A 1 $13.7 $13.7 $0.0
Dec-2026
Granular
Activated
Carbon (GAC)
4,000 gal/min Main Plant Wells 5,6,7,8 4 $12.5 $2.6 $9.9
Jun-2027 Ion Exchange 4,400 gal/min Kimberly Well 2 1 $10.9 $4.3 $6.6
Dec-2029 Ion Exchange 1,600 gal/min
Sunclipse Well 10 - Pipeline for
Treatment at Kimberly 2 Plant
Well 15 - New Well Site Needed
2 $15.3 $0.0 $15.3
Jun-2023 Ion Exchange 17,600 gal/min Wells 21, 23, 28, 29, 30, 31 6 $24.3 $24.3 $0.0
Dec-2026 Ion Exchange 2,000 gal/min Well 19 1 $6.5 $1.9 $4.7
Dec-2028 Ion Exchange 13,590 gal/min Wells 22, 26, and 27 3 $31.7 $1.6 $30.2
Dec-2030 Ion Exchange 2,000 gal/min Well 25 1 $7.0 $0.0 $7.0
Dec-2029 Ion Exchange 3,000 gal/min Well 3A 1 $8.0 $0.0 $8.0
Dec-2030 Ion Exchange 3,000 gal/min Well 6 1 $8.0 $0.0 $8.0
Sep-2022 Ion Exchange 8,420 gal/min Wells 9, 19, 23, 24 4 $10.0 $9.9 $0.1
Apr-2026 Ion Exchange 7,940 gal/min Wells 20, 21, 22 3 $14.7 $14.7 $0.0
Apr-2026 Ion Exchange 3,200 gal/min Well 28 1 $5.0 $4.0 $1.0
Dec-2028 Ion Exchange 5,500 gal/min Wells 25, 27 2 $13.0 $0.4 $12.7
Dec-2029 Ion Exchange 3,200 gal/min Well 26 1 $7.0 $0.1 $6.9
Dec-2029 Ion Exchange TBD Well 29 - New Well Currently Being
Drilled by City 1 $6.0 $1.0 $5.0
May-2023 Ion Exchange 2,500 gal/min Well 40 1 $5.8 $5.8 $0.0
Sep-2026 Ion Exchange 2,500 gal/min Well 38 1 $7.4 $7.4 $0.0
Dec-2026 Ion Exchange 2,000 gal/min Well 31 1 $8.5 $6.8 $1.7
Apr-2027 Ion Exchange 3,600 gal/min Well 27&28 2 $17.0 $8.7 $8.3
May-2027 Ion Exchange 9,200 gal/min Wells 27, 28, 31, 38, 40 at John
Garthe Reservoir 5 $31.4 $0.0 $31.4
Dec-2029 Ion Exchange 12,400 gal/min Wells 16, 29, 33, 41, 43(fut) at
Walnut Reservoir 5 $25.0 $0.1 $24.9
May-2025 Ion Exchange 6,400 gal/min
Main Street and Prospect Avenue
to remove PFAS from four (4) wells
in Tustin
4 $32.7 $32.7 $0.0
Dec-2029 Ion Exchange 2,000 gal/min Edinger Well 1 $7.0 $0.0 $7.0
Dec-2030 Ion Exchange 2,300 gal/min 17th St Wells (2 wells treated)2 $7.0 $0.0 $7.0
Dec-2030 Ion Exchange 2,500 gal/min WM-3 (New Well)1 $8.0 $0.0 $8.0
Dec-2030 Ion Exchange 2,500 gal/min WM-SC4 (New Well)1 $8.0 $0.0 $8.0
East Orange County Water
District Jun-2024 Ion Exchange 3,200 gal/min Treatment for East and
VanderWerff Wells 19,000 2 $8.9 $8.9 $0.0
Nov-2023 Ion Exchange 3,200 gal/min Bradford and Fairhaven Plants 3 $4.4 $4.4 $0.0
Jul-2027 Ion Exchange 940 gal/min Sherrill Plant 1 $3.1 $0.8 $2.4
Dec-2028 Ion Exchange 7,620 gal/min La Jolla, Fern Plants 3 $8.3 $0.5 $7.8
Dec-2028 Ion Exchange 7,620 gal/min Clair, Beach, and Dale Plants 4 $12.8 $0.9 $11.9
Dec-2030 Ion Exchange 2,500 gal/min Lowden 1 $8.0 $0.0 $8.0
Dec-2030 Ion Exchange 2,500 gal/min Orangewood 1 $8.0 $0.0 $8.0
Irvine Ranch Water District Oct-2024 Ion Exchange 3,200 gal/min Orange Park Acres Well No. 1 125,000 1 $7.2 $7.2 $0.0
Serrano Water District Feb-2022 Ion Exchange 3,200 gal/min Wells 3 and 5 5,659 2 $6.0 $6.0 $0.0
Yorba Linda Water District Dec-2021 Ion Exchange 13,200 gal/min All ten (10) Yorba Linda wells 11,786 10 $27.7 $27.7 $0.0
Note: $M = Dollars in Millions 106 $607.8 $318.9 $288.9
City of Anaheim
City of Tustin 14,500
64,000
City of Fullerton 32,000
Golden State Water
Company
City of Garden Grove 34,300
City of Orange
46,300
36,000
45,576City of Santa Ana
City of Westminster
City of Huntington Beach
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Operations and Maintenance Costs
Under the PFAS Treatment Facilities and Program Agreement, OCWD reimburses 50
percent of eligible operations and maintenance (O&M) costs incurred by participating
water agencies. Eligible O&M costs include treatment media replacement, power and
chemical costs, routine maintenance, repairs, staffing, compliance monitoring,
regulatory compliance activities, additional pumping, waste disposal, sewer costs, and
other necessary system maintenance expenses.
Actual PFAS treatment expenses (see Figure 18), which can be found in Annual
Comprehensive Financial Reports (ACFRs),66 varied primarily due to construction timing
and the performance of ion exchange resin media. Specialized resins are a key element
in PFAS treatment and help remove PFAS from water using electrostatics. Construction
delays meant some treatment facilities were not operational as expected, resulting in
lower O&M costs. In FY22 and FY23, initial resin media lasted longer than anticipated
and reduced O&M costs. In contrast, FY25 experienced more resin changeouts than
anticipated and higher O&M costs. Resin media life varies by treatment system and
operating conditions, such as run time, cycling frequency, and production flow rates.
OCWD is updating resin performance assumptions and changeout frequency estimates
to improve future O&M forecasts.
Source: OCWD
Figure 18 – OCWD’s Share of PFAS Treatment Facility Annual O&M Cost
Program Status and Future Plans
The overall OCWD PFAS Treatment Systems Project currently includes 11 water
retailers, with construction planned or underway for four additional retailers, expanding
the program to 15. Fifty-three treatment systems are operational. Construction
66 “Sound financial management,” Orange County Water District, accessed April 8, 2026,
https://www.ocwd.com/what-we-do/sound-financial-management/.
$-
$1,000,000
$2,000,000
$3,000,000
$4,000,000
$5,000,000
$6,000,000
$7,000,000
FY22 FY23 FY24 FY25
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continues on 20 additional systems, with design work underway for 24 more. Here is a
list of PFAS projects in design or under construction as of May 2026 :
• Golden State Water Company Wells SLON and SORG are still in planning. Well
SSYC is in design and is anticipated to start construction in Fiscal Year 26/27.
• Tustin 17th Street Well is nearing the start of design.
• Huntington Beach Well 3A, Anaheim Wells 39 and 47, Tustin Edinger Well are all
in the design phase and are anticipated to start construction in Fiscal Year 26/27.
• Buena Park Linden Well is currently in construction.
Figure 19 - PFAS Monthly Cost to OCWD Service Area ResidentsFigure 19 PFAS
Monthly Cost to OCWD Service Area Residents indicates the estimated average
monthly cost of PFAS treatment to OCWD service area residents is $1.42 per person.
OCWD anticipates continued design and construction activity over several years.
Source: OCWD
Figure 19 - PFAS Monthly Cost to OCWD Service Area Residents
Total Capital Costs $570,000,000
State & Fed Grants $152,000,000
Litigation Proceeds $121,000,000
Net Capital Costs $297,000,000
Amortized Debt Costs
4.50%Interest Rate
25 Years
$297,000,000 Amount
Annual Debt Payment $20,029,391
Estimated Annual O&M Cost $22,000,000
Total Annual Cost $42,029,391
Total Monthly Cost $3,502,449
OCWD Population from 19
Member Agencies 2,469,000 persons
Monthly cost per person $1.42
Average PFAS Impact to OCWD Service Area Residents
Over a 25 year period
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FINDINGS
In accordance with California Penal Code Sections 933 and 933.05 , the 2025-2026
Orange County Grand Jury requires (or, as noted, requests) responses from each
agency affected by the findings presented in this section. The responses are to be
submitted to the Presiding Judge of the Superior Cou rt.
Based on its investigation described herein, the 2025-2026 Orange County Grand Jury
has arrived at the following six principal findings:
F1 Commercial and industrial chemical manufacturers are a major source of PFAS
contamination. Settlement litigation funds are available for community water
systems to make claims.
F2 PFAS is widespread, and contamination has been detected in Orange County
groundwater sources. Community water systems are required to report PFAS
monitoring results in their annual Consumer Confidence Reports.
F3 PFAS exposure is associated with potential adverse human health effects.
F4 OCWD has taken a proactive leadership role in addressing PFAS in the Orange
County Groundwater Basin, though PFAS treatment implementation varies
across local cities and water districts.
F5 Groundwater supplies must either be treated to remove PFAS or must be
replaced with imported water supplies that are significantly more expensive than
groundwater. Over $500 million is being spent on construction, operations, and
maintenance of PFAS treatment facilities in Orange County.
F6 Orange County drinking water meets or exceeds state and federal standards and
is safe for consumption without additional home filtration.
F7 Research on newer PFAS compounds and long-term exposure effects is
ongoing.
F8 There are limited online PFAS education and outreach programs among O range
County water retailers. Most retailers rely on OCWD for PFAS education and
outreach. PFAS advisories were included in approximately 55% of the Orange
County water retailers’ annual water quality reports in 2025.
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RECOMMENDATIONS
In accordance with California Penal Code Sections 933 and 933.05 , the 2025-2026
Orange County Grand Jury requires (or, as noted, requests) responses from each
agency affected by the recommendations presented in this section. The responses are
to be submitted to the Presiding Judge of the Superior Court.
Based on its investigation described herein, the 2025-2026 Orange County Grand Jury
makes the following recommendations:
R1 By September 30, 2026, Orange County Water District (OCWD), in coordination
with state and federal agencies, should pursue cost recovery efforts against
PFAS manufacturers to offset treatment, monitoring, and long-term remediation
costs incurred by local water agencies and ratepayers. [F1, F5]
R2 By July 1, 2029, OCWD and its member agencies should monitor PFAS in
groundwater and surface water sources and promptly implement PFAS treatment
when response levels are exceeded. [F2, F4]
R3 By September 30, 2026, OCWD, in collaboration with the Orange County Health
Care Agency, should update public education and guidance continually as
scientific understanding and regulatory standards evolve. [F3]
R4 By July 1, 2029, all Orange County water retailers should consistently include a
PFAS advisory, treatment facilities status, and compliance information in
consumer confidence reports and on agency websites, using clear and
understandable language for the public. [F2, F8]
R5 By September 30, 2026, OCWD and all Orange County water retailers should
enhance coordinated public education efforts to reassure their customers about
drinking water safety. [F6, F8]
R6 By September 30, 2026, OCWD should continuously monitor national and
international PFAS research developments and incorporate new findings into
future groundwater management, treatment planning, and regulatory compliance
strategies. [F7]
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COMMENDATIONS
Many Orange County water agencies have demonstrated exceptional leadership in
addressing PFAS through large‑scale treatment investments, rigorous monitoring, and
public communication. Together, these agencies serve more than two million residents
and have implemented some of the most advanced PFAS treatment systems in the
nation. The following commendations recognize high‑impact programs and measurable
achievements across the region.
Orange County Water District (OCWD)
OCWD has implemented the largest PFAS treatment program in the United States,
designing and constructing treatment systems for over 100 impacted wells across 15
cities and retail water districts, improving water quality for approximately 1.5 million
people. OCWD secured a $94M EPA Water Infrastructure Finance and Innovation Act
(WIFIA) loan, $152M in state and federal grant funding, and $131M in PFAS
manufacturers litigation settlement funds to support this effort, which includes the
build‑out of more than 30 PFAS treatment facilities.
The Grand Jury offers additional commendations to OCWD and its member agencies
for their collaborative cost‑sharing agreement. Under this arrangement, OCWD fully
funds all PFAS facility design and construction capital expenditures. Ongoing operations
and maintenance costs are then shared equally, with OCWD covering 50% and each
participating water retailer contributing the remaining 50% for the PFAS treatment
facilities they operate. This approach reflects progressive public‑sector planning,
demonstrating how agencies can work together to address complex and costly
challenges. It also serves as a strong model for future government/private -sector
cost‑sharing agreements, illustrating how thoughtful collaboration can enhance
efficiency and long‑term public benefit.
Anaheim Water Utility
Anaheim has launched one of the largest municipal PFAS treatment programs in the
country, a multi‑phase, $150M effort to construct treatment systems at nine groundwater
sites. The utility serves 64,000 metered customers, historically relying on groundwater
for 80% of its supply. PFAS treatment systems for Wells 39 and 47 are among the first
in a series of facilities designed to restore local production while meeting stringent state
and federal standards.
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Yorba Linda Water District (YLWD)
YLWD operates the J. Wayne Miller, Ph.D. Water Treatment Plant, recognized as the
nation’s largest PFAS ion‑exchange treatment facility. The plant serves approximately
80,000 customers and has delivered PFAS‑free water for nearly three consecutive
years. This facility allows YLWD to optimize its groundwater resources while proactively
meeting evolving PFAS regulatory standards.
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RESPONSES
The following excerpts from the California Penal Code provide the requirements for
public agencies to respond to the Findings and Recommendations of this Grand Jury
report:
§933
(c) No later than 90 days after the grand jury submits a final report on the operations of
any public agency subject to its reviewing authority, the governing body of the public
agency shall comment to the presiding judge of the superior court on the findi ngs and
recommendations pertaining to matters under the control of the governing body, and
every elected county officer or agency head for which the grand jury has responsibility
pursuant to Section 914.1 shall comment within 60 days to the presiding judge of the
superior court, with an information copy sent to the board of supervisors, on the findings
and recommendations pertaining to matters under the control of that county officer or
agency head and any agency or agencies which that officer or agency head supervises
or controls. In any city and county, the mayor shall also comment on the findings and
recommendations. All of these comments and reports shall forthwith be submitted to the
presiding judge of the superior court who impaneled the grand jury. A copy of all
responses to grand jury reports shall be placed on file with the clerk of the public
agency and the office of the county clerk, or the mayor when applicable, and shall
remain on file in those offices. One copy shall be placed on file with the a pplicable
grand jury final report by, and in the control of the currently impaneled grand jury, where
it shall be maintained for a minimum of five years.
§933.05.
(a) For purposes of subdivision (b) of Section 933, as to each grand jury finding, the
responding person or entity shall indicate one of the following:
(1) The respondent agrees with the finding.
(2) The respondent disagrees wholly or partially with the finding, in which case the
response shall specify the portion of the finding that is disputed and shall include an
explanation of the reasons, therefore.
(b) For purposes of subdivision (b) of Section 933, as to each grand jury
recommendation, the responding person or entity shall report one of the following
actions:
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(1) The recommendation has been implemented, with a summary regarding the
implemented action.
(2) The recommendation has not yet been implemented, but will be implemented in the
future, with a timeframe for implementation.
(3) The recommendation requires further analysis, with an explanation and the scope
and parameters of an analysis or study, and a timeframe for the matter to be prepared
for discussion by the officer or head of the agency or department being investigated o r
reviewed, including the governing body of the public agency when applicable. This
timeframe shall not exceed six months from the date of publication of the grand jury
report.
(4) The recommendation will not be implemented because it is not warranted or is not
reasonable, with an explanation, therefore.
(c) However, if a finding or recommendation of the grand jury addresses budgetary or
personnel matters of a county agency or department headed by an elected officer, both
the agency or department head and the board of supervisors shall respond if requested
by the grand jury, but the response of the board of supervisors shall address only those
budgetary or personnel matters over which it has some decision -making authority. The
response of the elected agency or department head shall address all aspects of th e
findings or recommendations affecting his or her agency or department.
(d) A grand jury may request a subject person or entity to come before the grand jury for
the purpose of reading and discussing the findings of the grand jury report that relates
to that person or entity in order to verify the accuracy of the findings prio r to their
release.
(e) During an investigation, the grand jury shall meet with the subject of that
investigation regarding the investigation, unless the court, either on its own
determination or upon request of the foreperson of the grand jury, determines that such
a meeting would be detrimental.
(f) A grand jury shall provide to the affected agency a copy of the portion of the grand
jury report relating to that person or entity two working days prior to its public release
and after the approval of the presiding judge. No officer, agency, departmen t, or
governing body of a public agency shall disclose any contents of the report prior to the
public release of the final report.
(Amended by Stats. 1997, Ch. 443, Sec. 5. Effective January 1, 1998.)
Comments to the Presiding Judge of the Superior Court in compliance with Penal
Code §933.05 are required from:
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Orange County Board of Supervisors 90 Day Response Required
Findings: F3
Recommendations: R3
Orange County Water District Board of Directors 90 Day Response Required
Findings: F1, F2, F3, F4, F5, F6, F7, F8
Recommendations: R1, R2, R3, R5, R6
Orange County Health Care Agency 90 Day Response Requested
Findings: F3
Recommendations: R3
City of Anaheim 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Brea 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
City of Buena Park 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Fountain Valley 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
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City of Fullerton 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Garden Grove 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Huntington Beach 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of La Habra 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
City of La Palma 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Newport Beach 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Orange 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
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City of San Clemente 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
City of Santa Ana 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Seal Beach 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Tustin 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
City of Westminster 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
East Orange County Water District 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
El Toro Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
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Emerald Bay Service District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
Golden State Water Company 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
Irvine Ranch Water District 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
Laguna Beach County Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
Mesa Water District 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
Moulton Niguel Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
Santa Margarita Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
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Serrano Water District 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
South Coast Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
Trabuco Canyon Water District 90 Day Response Required
Findings: F2, F6, F8
Recommendations: R4, R5
Yorba Linda Water District 90 Day Response Required
Findings: F2, F4, F6, F8
Recommendations: R2, R4, R5
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Acronyms
ACFRS Annual comprehensive financial reports
ADONA Ammonium 4 8-dioxa-3h-perfluorononanoate
AFFF Aqueous film forming foams used frequently at airports and military bases
for firefighting and emergency response training activities
AL Regulatory Action Level The concentration of a contaminant which, if
exceeded, triggers treatment or other requirements that a water system
must follow
ATSDR Agency for Toxic Substances and Disease Registry
CCR Consumer Confidence Report
CCRDL Consumer Confidence Report Detection Levels
CDC United States Centers for Disease Control and Prevention
CWS Community Water System
DDW Division of Drinking Water
DWR Department of Water Resources
Effluent Liquid waste from industrial facilities
EPA US Environmental Protection Agency
FDA Food and Drug Administration
GenX Is a Chemours trademark name for a synthetic, short
chain organofluorine chemical compound, the ammonium
salt of hexafluoropropylene oxide dimer acid (HFPO-DA). It can also be
used more informally to refer to the group of related fluorochemicals that
are used to produce GenX.
GWRS Ground water replacement system
HALF LIFE Time required for a quantity to reduce to half of its original value
HFPO-DA Hexafluoropropylene oxide dimer acid
MSS Multi site study
MCL Glossary of Terms Maximum Contaminant Level. The highest level of a
contaminant that is allowed in drinking water. Primary MCLs are set as
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close to the public health goals and maximum contaminant level goals as
is economically and technologically feasible. Secondary MCLs are set to
protect the odor, taste, and appearance of drinking water.
MCLG Maximum Contaminant Level Goal. The level of a contaminant in drinking
water below which there is no known or expected risk to health. The
United States Environmental Protection Agency (USEPA) sets maximum
contaminant level goals.
MRDL Maximum Residual Disinfectant Level. The highest level of a disinfectant
allowed in drinking water. There is convincing evidence that the addition of
a disinfectant is necessary for control of microbial contaminants.
MRDLG Maximum Residual Disinfectant Level Goal The level of a drinking water
disinfectant below which there is no known or expected risk to health.
MRDLGs do not reflect the benefits of the use of disinfectants to control
microbial contaminants.
MWD Metropolitan Water District
MWDOC Municipal Water District of Orange County
N/A Not applicable
ND Not detected
NHANES National Health and Nutrition Examination Survey
NL California Notification Level Non-regulatory, health-based advisory levels
established by the State Board for contaminants in drinking water for
which an MCL has not been established
NR Not required to be tested; < = average is less than the detection limit for
reporting purposes
NTU Nephelometric turbidity units
OCWD Orange County Water District
O & M Operations and Management
PAYGO “Pay as you go”
PDWS Primary Drinking Water Standard MCLs, MRDLs and treatment techniques
(TTs) for contaminants that affect health, along with their monitoring and
reporting requirements
pCi/L picoCuries per liter
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PFAS RULE Establishes enforceable drinking water standards for six PFAS chemicals
PFAS Per- and polyfluoroalkyl substances
PFBA Perfluoro Butanoic Acid
PFBS Perfluoro Butane Sulfonic Acid
PFHpA Perfluoro Heptanoic Acid
PFHxA Perfluoro Hexanoic Acid
PFHxS Perfluoro Hexane Sulfonic Acid
PFNA Perfluorononanoic acid
PFOA Perfluoro Octanoic Acid
PFOS Perfluoro Octane Sulfonic Acid
PFPeA Perfluoro Pentanoic Acid
PHG Public Health Goal The level of a contaminant in drinking water below
which there is no known or expected risk to health. The California
Environmental Protection Agency (CalEPA) sets public health goals.
PPB Parts per billion
PPM Parts per million
PPT Parts per trillion
PQL Practical Quantitation Level
PWS Public water supply
RAA Highest Running Annual Average
SAR Santa Ana River
SDWA Safe Drinking Water Act
SDWIS Safe Drinking Water Information System
SWRCB State Water Resources Control Board
WIFIA Water Infrastructure Finance and Innovation Act
TT Treatment Technique. A required process intended to reduce the level of a
contaminant in drinking water
UCI University of California, Irvine
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UCMR Unregulated Contaminant Monitoring Rule
US United States
µmho/cm Micromho per centimeter (equivalent to 1 microsiemens/cm)
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Glossary
Cross Sectional Study Examines prevalence of a condition or characteristic
at a single point in time across a population to identify
patterns, associations, and risk factors
Ion Exchange Technology Process that removes/replaces dissolved ions in a
solution using solid materials.
Non-Community Water Systems Public water systems at locations where people do
not reside
Non-Transient Water Systems Public water systems that service at least 25 of the
same people over six months of the year, but do not
live there
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Orange County Grand Jury 2025-2026 Page 53 of 62
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Appendix A
Unregulated Contaminated Monitoring Rule (UCMR)
Contaminants Lists, PFAS Contaminants
Figure 20 - UCMR 3 Contaminants List, PFAS Contaminants
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Figure 21 - UCMR 5 Contaminants List, PFAS Contaminants
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State Water Resources Control Board PFAS General
Monitoring Orders, 2020-2025
SWRCB Order
Exhibit Title Internet URL Web Address
2020 SWRCB General Order
DW 2020-0003-DDW
https://www.waterboards.ca.gov/board_decisions/adopte
d_orders/drinking_water/2020/pfas_go_2020_0003_ddw/
pfas_go_2020_0003_ddw.pdf
Exhibit A – List of Sources Subject to
General Order No. DW 2020-0003-DDW
(for DDW Section 5),
https://wqts.com/wp-
content/uploads/2020/09/go_exhibit_a_section5.pdf
2021 SWRCB General Order
DW-2021-0001-DDW
https://www.waterboards.ca.gov/board_decisions/adopte
d_orders/drinking_water/2021/pfas_go_2021_0001_ddw/
a5.pdf
Exhibit A – List of Sources Subject to
General Order No. DW 2021-0001-DDW
(For DDW Section 5)
https://www.waterboards.ca.gov/board_decisions/adopte
d_orders/drinking_water/2021/pfas_go_2021_0001_ddw/
a5.pdf
2022 Amended General Order DW 2022-
0001-DDW
https://www.waterboards.ca.gov/drinking_water/certlic/dri
nkingwater/pfas_ddw_general_order/docs/amended-
pfas-general-order-2022-final.pdf
Exhibit A – List of Sources Subject to
General Order No. DW 2022-0001-DDW
(Amended)
https://www.waterboards.ca.gov/drinking_water/certlic/dri
nkingwater/pfas_ddw_general_order/docs/pfas_go_2022
-0001-DDW_ExhibitA.pdf
2025 SWRCB General Order
DW 2025-0002-DDW
https://www.waterboards.ca.gov/drinking_water/certlic/dri
nkingwater/pfas_ddw_general_order/docs/order-dw-
2025-0002-ddw-pfas-initial-monitoring.pdf
Exhibit A – List of Sources Subject to
General Order DW 2025-0002-DDW
https://view.officeapps.live.com/op/view.aspx?src=https%
3A%2F%2Fwww.waterboards.ca.gov%2Fdrinking_water
%2Fcertlic%2Fdrinkingwater%2Fpfas_ddw_general_ord
er%2Fdocs%2Forder-dw-2025-0002-ddw-exhibit-
a.xlsx&wdOrigin=BROWSELINK
Figure 22 - SWRCB PFAS General Monitoring Orders Issued 2020 through 2025
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State Water Resources Control Board General
Monitoring Orders PFAS Constituents Lists
Figure 23 - SWRCB General Monitoring Order 2020-0003-DDW, PFAS Constituents
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Figure 24 - SWRCB General Monitoring Order 2021-0001-DDW, PFAS Constituents
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Figure 25 - SWRCB General Monitoring Order 2022-0001-DDW, PFAS Constituents
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Figure 26 - SWRCB General Monitoring Order 2025-0002-DDW, PFAS Constituents
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Appendix B
Source: EPA
Figure 27 - EPA Eight Content Requirements of a Consumer Confidence Report
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ATTACHMENT 2
Response Letter
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OFFICE OF THE CITY COUNCIL
MAYOR AUSTIN LUMBARD • MAYOR PRO TEM RAY SCHNELL • RYAN GALLAGHER • LEE K. FINK • JOHN NIELSEN
300 Centennial Way, Tustin, CA 92780 • 714 -573-3010 • tustinca.org
August 4, 2026
Honorable Sheila F. Hanson, Presiding Judge
Superior Court of California, County of Orange
700 Civic Center Drive West
Santa Ana, CA 92701
RE: Response to 2025-2026 Orange County Grand Jury Report “PFAS and Public
Awareness: A Closer Look at Orange County Drinking Water”
Dear Judge Hanson,
The City of Tustin has reviewed the Orange County Grand Jury Report titled “PFAS and Public
Awareness: A Closer Look at Orange County Drinking Water”. In accordance with California
Penal Code Sections 933 and 933.05, the City of Tustin submits the following response to the
findings and recommendations included within the report. Each of the applicable findings and
recommendations is listed below in italics, followed by the City’s response.
Findings:
F2: PFAS is widespread, and contamination has been detected in Orange County groundwater
sources. Community water systems are required to report PFAS monitoring results in their
annual Consumer Confidence Reports.
Response: The City of Tustin agrees that community water systems are required to report PFAS
monitoring results in their annual Consumer Confidence Reports when concentrations exceed the
Report Detection Level, consistent with requirements established by the California Division of
Drinking Water.
F4: OCWD has taken a proactive leadership role in addressing PFAS in the Orange County
Groundwater Basin, though PFAS treatment implementation varies across local cities and
water districts.
Response: The City of Tustin concurs with this finding.
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F6: Orange County drinking water meets or exceeds state and federal standards and is safe
for consumption without additional home filtration.
Response: The City of Tustin concurs with this finding.
F8: There are limited online PFAS education and outreach programs among Orange County
water retailers. Most retailers rely on OCWD for PFAS education and outreach. PFAS
advisories were included in approximately 55% of the Orange County water retailers’ annual
water quality reports in 2025.
Response: The City of Tustin maintains a PFAS education and outreach on its website
www.tustinca.org/1131/Understanding-PFAS which contains PFAS information and steps the City
has taken in partnership with OCWD. As requested, the City of Tustin also works with OCWD to
provide Tustin-specific fact sheets and other information for public distribution.
Recommendations:
R2: By July 1, 2029, OCWD and its member agencies should monitor PFAS in groundwater
and surface water sources and promptly implement PFAS treatment when response levels
are exceeded.
Response: OCWD continues to maintain a proactive and comprehensive monitoring program for
PFAS and funds treatment in cooperation with its Producers. These PFAS water quality monitoring
efforts have continued for more than a decade and include multiple US EPA Unregu lated
Contaminant Monitoring Rule programs that include PFAS (UCMR3 and UCMR5) as well as
multiple PFAS monitoring orders issued by the California Division of Drinking Water. OCWD has
steadily expanded PFAS monitoring to include additional drinking water wells, groundwater
monitoring wells, and surface waters throughout the Orange County groundwater basin and the
Santa Ana River watershed. Through these efforts, OCWD will ensure that all its Producer
agencies meet the initial monitoring requirements contained within US EPA’s PFAS National
Primary Drinking Water Regulation (NPDWR). OCWD has continued to meet with and maintain
communication with many local water agencies and regulatory agencies to share PFAS monitoring
results and related information. OCWD has also performed multiple phases of pilot testing of
PFAS treatment media to help Producers determine the best treatment options. OCWD has
implemented a PFAS treatment policy to fund 100% of the design and construction, and 50% of
the operation and maintenance costs for Producer drinking water well treatment facilities. OCWD
and the Producer water systems have worked closely and collaboratively to develop this PFAS
treatment policy and maintain PFAS agreements in support of the policy resulting in
implementation of treatment throughout OCWD well in advance of much of the rest of the
country.
R4: By July 1, 2029, all Orange County water retailers should consistently include a PFAS
advisory, treatment facilities status, and compliance information in consumer confidence
reports and on agency websites, using clear and understandable language for the public.
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Response: Pursuant to requirements set forth by the California Division of Drinking Water, the City
of Tustin will continue to meet all consumer confidence reporting requirements and will include
updated information regarding PFAS and related City facilities on the City's website.
R5: By September 30, 2026, OCWD and all Orange County water retailers should enhance
coordinated public education efforts to reassure their customers about drinking water safety.
Response: The City Tustin and OCWD has and will continue providing the public with educational
PFAS information, resources, and updates posted on our website.
Should you have any questions or need any additional information, please contact the Director of
Public Works, Michael Grisso, at (714) 361-4719 or via email at mgrisso@tustinca.org.
Respectfully,
_______________________
Austin Lumbard, Mayor
cc: Orange County Grand Jury
700 Civic Center West
Santa Ana, CA 92701
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