OK, the situation – like our water supply – is a little clearer today. But, also like our water, it’s what we can’t see and don’t know that is still a concern.
We know a little more about the timeline of events. At a press conference (more about that later), TWW Filtration plant Manager on duty Bill Mitchell described how things unfolded over the weekend. (Watch the second video in the article; time notations below are from that video.)
The runoff from last week’s storms that swelled the Delaware started to create problems for TWW by Friday. By late Saturday night into Sunday morning, the situation had progressed to the point where Mitchell instructed (1:10) his workers at 1:30 AM Sunday morning to “shut the plant off. I’ll be in in the morning.”
The reason Mitchell instructed the plant to be shut down was that the turbidity (cloudiness in the water due to mud and other solids) had reached levels, in his words, “in the mid to lower 200’s NTU’s.”
That number is significant because Federal EPA regulations govern the quality of our drinking water; a set of guidelines, revised and published most recently here in 2007, lays out minimum acceptable standards for water. These guidelines also specify procedures for local water systems to notify state authorities and – more importantly – The Public – when there are issues that may impact public health and safety. They also prescribe the kind of notices required, and the level of information those notices should contain. These guidelines are laid out in several different Tiers of severity, Tier 1 being the most serious and requiring the fastest notification, 24 Hours after the situation arises.
According to those guidelines, a Tier 1 violation occurs (page 137) when, among other criteria, Turbidity levels reach 5 NTU. “Mid to lower 200’s” certainly exceeds that threshold. Mr. Mitchell said “that number doesn’t mean anything unless you’re in the industry (1:58).”
Well, to my reading of the guidelines, 200 is higher than 5, and we had a Tier 1 violation this weekend.
Without giving any other numbers, Mr. Mitchell did say that pH levels were low: the alkalinity was low (meaning the water was more acidic), and overall there was concern. Mr. Mitchell was at the plant all day Sunday. By the time he left,
partial flow into the plant had been restored (3:00). When he returned Monday morning, the system was off. He didn’t explain who made the overnight decision to shut down the plant once more (3:28). Also Monday morning, Mr. Mitchell notified (3:40)Ralph Burchaciello, Acting Director of Public Works (who really should learn not to chew gum at press conferences when cameras are rolling). How and when Mr. Burchaciello took things further up the chain of command wasn’t discussed in the press accounts nor in the video; whether he addressed it during the presser I don’t know.
One other key piece of info fro Mr. Mitchell was that the State Department of Environmental Protection was notified of the situation on Sunday morning, around 8:30 or 9:00AM (4:00). That time stamp is important. According to the EPA, Tier 1 violations require Public Notification no later than 24 hours after an event (Page 42). Consultation with the state is supposed to start within that timeframe, as well.
The plant was shut down 1:30 AM Sunday morning, NJDEP was notified by 9:00AM Sunday morning, within 8 hours. Public notice went out 4:30 PM Monday afternoon, 39 hours after the initial plant shutdown. Problem.
The notice that the city released Monday afternoon was also inadequate. The EPA details Ten Required Elements to a Public Notice (Page 38), and provides an example of what a properly constructed notice should look like (Page 40). The original notice released by the city on Monday (and still on the city’s website) falls far short of the required level and quality of information. The Update issued by the Mayor’s Office yesterday is similarly light on the required info. Problem.
However the Precautionary Boil Water Advisory, which is on the city’s website but was apparently written by the DEP – not the City of Trenton – is more informative. although even it seems to miss some required language.
So, it seems that required public notification to all TWW customers in the City and the affected townships was late, and inadequate. No wonder that folks in the townships – notably Hamilton – are pissed. I am too.
Any time is a bad time for this kind of incident. The potential risk to public health – which seems to have been averted here – is real. But at a time when the City is trying to negotiate with the townships to drop their lawsuit against us and TWW, this kind of incident is not likely to engender much good will now, is it? And after fighting a long and hard battle to retain control of a unified and city-owned TWW, any calls for state involvement are not welcome, however understandable the sentiment may be.
At the press conference, the Mayor declined to speak to who was in the plant assisting Mr. Mitchell over the weekend, citing it as a “personnel matter.” Since the failure of communication along the chain of command is at issue here; as well as questions of who made some decisions on plant shutdowns; as well as news accounts raising the issue of the technical qualifications (or lack of same) possessed by some employees on site or on call and AWOL; I beg to differ. The Mayor has stressed who was in the loop during these events: he brought Mr. Mitchell and Mr. Burchaciello, he made a point of explaining that a former TWW superintendent was brought in to consult. These are “personnel matters,” too. All of the key players, and their roles, should be disclosed. If there are certain civil service privacy protections that might be in play here, fine; let City Council pursue this in executive session when they investigate the matter, as they should.
The Mayor was pretty sanguine yesterday in his presentation: “I don’t know why I wasn’t contacted but based on the professionalism of the people at the plant, I believe they had things under control. These people know this business, they did a fine job,” Mack said.
We had a major breakdown in communication here, affecting not only 80,000 Trentonians, but also another 175,000 TWW customers who trust us to send them safe drinking water.
I hope we don’t have to start boiling the city’s Press Releases before they are safe for consumption.
Kevin,
Delaware River turbidities can range from low single digits to around 1,000. After a period of no rainfall the lower turbidities are typically present. After some rainfall the turbidities will rise as runoff from the basin enters the river and the flow increases. After heavy rainfall, the turbidities will rise into the lower hundreds. When the river reaches flood stage, the turbidities can reach the 1,000 level. The problem a water treatment facility faces is not just the higher turbidities but also the rate at which the turbidities rise. If the turbidities rise very rapidly, the plant must change the treatment very rapidly to achieve effective removal of the material causing the turbidity.
Reportedly, the Trenton treatment plant experienced a rapidly changing source of supply. The changes included significant increases in turbidity and chemical characteristics including pH, alkalinity, and temperature. When Mr. Mitchell reported that turbidity levels had reached levels “in the mid to lower 200’s NTU’s”, he had to be referring to the turbidity level in the river and not the turbidity in the water delivered to the distribution system and to customers. With the investment in the recent plant upgrade, it would be reasonable to expect that the investment would deliver a return of being able to effectively treat the rapidly changing supply. In light of the decision to shut down the plant, apparently effective treatment didn’t occur. There are typically a few measures of treatment effectiveness. But the one that probably drove the decision to shut down the plant was deteriorating (rising) filtered water turbidity. This would be the water that is delivered to the distribution system. A plant like the Trenton plant is required by regulation to deliver water that meets a more stringent requirement than the 5 NTU requirement. That requirement is as follows:
The combined filter effluent turbidity for conventional and direct filtration systems must be less than or equal to 0.3 nephelometric turbidity unit (NTU) for 95 percent of the readings taken each month and may at no time exceed 1 NTU. (EPA Guidance Manual LT1ESWTR Turbidity Provisions)
When the treatment process is effective, filtered water turbidity should be less than 0.1 NTU. When the level approaches 0.3 NTU, and especially when it is apparent that there are problems with the treatment process, the filters would be shut down manually or automatically by a plant’s computerized control system. If it is a plant wide problem, all of the filters would eventually be shut down. It seems as though this is what was done this past weekend. Since Trenton has the luxury of its reservoir, it is an easier decision to shutdown and then try to methodically bring the plant back on line rather than violate the combined filtered effluent turbidity standard. If the plant was not shut down and the standard was violated, then the primacy agency would have to be contacted, in Trenton’s case it would the NJDEP, and a decision would be made as to whether it would be a Tier 1 or Tier 2 violation. If it was deemed a Tier 1 violation, the public and the utility’s customers would have to be notified in accordance with the EPA requirements as found in the Public Notification Handbook of March 2007.
If it were determined to be a Tier 1 violation, a boil water order would not necessarily be required. The notification template included in the Handbook uses language to that effect.
Other than a quote attributed to the Acting Business Administrator in the Times that stated that all of the water delivered to the distribution was in compliance with all water quality standards, there has been little else provided to dispel the idea that untreated water was delivered to the distribution system. As noted previously, it is highly likely that the plant was shut down prior to any water quality violation.
Whether there was a violation or no violation, a boil water order is not required. Then the question is why was the boil water order issued. As noted previously, it was done because of the loss of pressure in parts of the distribution system. The question that has not been asked is what caused the loss of pressure in the distribution system. That loss of pressure and not the problems at the treatment facility would have been the cause of the “dirty” water occurrences throughout the distribution system. Additionally, there still remains the unanswered question of why did the plant experience the treatment failure and what will be done to eliminate the causes of that treatment failure.