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Heavy Metal

Here we go again.

Hamilton is pissed. Mayor Kelly Yaede released a statement yesterday that says, in part, “Without advanced notice, we have learned today about the Trenton Water Works letter that residents are already receiving in the mail regarding lead in drinking water. I want our residents to know that we are taking action to gather further details so that you can be better informed.”

Trenton’s Water Works (TWW), as we all know, provides several communities in Mercer County besides the City of Trenton with fresh water, and has done so with varying levels of quality and safety – over the last few years. Shortly after taking office in 2010, the new Administration of then-Mayor, and later Federal Convict, Tony Mack experienced several problems at TWW that affected customers throughout the system. These problems led Hamilton’s then-Mayor, and later Federal Convict (hmm, something in the water?) John Bencivengo to seek a county takeover of TWW. In a December 2010 letter to Governor Chris Christie, Mr. Bencivengo wrote, “Numerous instances over the past several months have provided me with absolutely no confidence that this utility can remain under the supervision of the City of Trenton and be responsibly operated in a manner that protects the safety of Hamilton residents and the fiscal integrity that the consumers of our community are entitled to and deserve.”

One of those incidents was a several day interruption of water service due to brown-water in the system after severe storms. The interruption was first blamed on the weather, but later was revealed to have been caused by human error, according to a TWW whistleblower. Customers in Hamilton, along with Ewing, Lawrence and Hopewell Borough were affected, and upset. More so when Mayor Mack blew off and failed to attend  a meeting that had been scheduled by County Executive Brian Hughes with the mayors of those townships to discuss TWW’s problems.

We’re back to those bad old days, it seems. Without any advance notice, as Mayor Yaede complained, a letter was mailed to TWW’s customers – as required by Federal law – and it started popping up in customers’ mailboxes yesterday. The letter, which is on stationery containing the names of Trenton’s Mayor Eric Jackson and Public Works Director Merkle Cherry, begins,

“Trenton Water Works found elevated levels of lead in drinking water in some homes/buildings. Lead can cause serious health problems, especially for pregnant women and young children. Please read this information closely to see what you can do to reduce lead in your drinking water.”

Later on in the note, Mr. Jackson and Mr. Cherry say,

“Trenton Water Works is in the process of drafting a Request for Proposal to implement a Corrosion Control Study. This will help to reduce lead levels by identifying areas with issues allowing Trenton Water Works to adjust the corrosion control treatment to address these concerns.”

As of this morning, no further information has been provided by the City, nor any further statement by the Mayor or Director. This is what we have to go with. Which, considering that lead in the water supply is a pretty big deal – ask the folks who live in Flint, Michigan – and that Trenton has been dealing with this issue for over a year, is a big concern.

TWW Superintendent Joseph McIntyre addressed City Council in April 2016, in the wake of the water crisis in Flint, and said, “It’s been a pretty hot topic thanks to our friends in Flint. The good news is here in Trenton it’s not a hot topic as it pertains to water. We’ve never had a lead-based problem here in the water [Emphasis mine - KM].”

Yet, barely six months later, we read this headline: “20 Trenton school buildings test high for lead levels.” Even then, we were told that whatever problem there was with the water supply was localized to specific older buildings. Trenton Times reporter wrote in the piece linked just above, “In April, city officials said the water mains are lead-free, but a lead expert acknowledged that the toxin can build up in schools’ aging plumbing when water goes unused over weekends and long breaks. Elyse Pivnick, the director of environmental health for Trenton-based Isles, has said that lead-based paint in the city’s older housing and buildings remains one of the most common sources of lead exposure.”

But now, reading this letter, it would appear that the presence of heavy metal in our water supply is not just limited to Trenton’s school buildings. How prevalent is it? You can’t tell by reading yesterday’s letter.

One clue can be found in this document.

Mr. Jackson and Mr. Cherry  actually misspoke about the status of its Corrosion Control Study Request for Proposal (RFP). It’s not being drafted. It’s finished and was published on the City’s website last week, a fact that Trenton’s Scott Miller tipped me to last week. The City is open to receive proposals until August 29.

In this RFP, the City states the problem succinctly. On Page 5, the RFP states, “Lead levels exceeded 15 ppb [parts per billion] for the 90th percentile during the January 1, 2017 through June 30, 2017 monitoring period.”

For perspective, in the height of the Flint crisis, during the 6-month period of January to June of 2016, Flint’s level was 20 ppb. And the 15 ppb threshold is considered an “action level” under Federal water safety rules, which Trenton’s water has exceeded during the first half of 2017. That’s what likely triggered the mandatory warning notice to TWW customers. All we know today is that lead levels in TWW’s water exceeded 15 ppb this year. We don’t know by how much more. Pretty key information, I think.

What caused this? According to the City’s own RFP, “process changes” introduced by TWW itself. The RFP narrates, on pages 4 and 5:

Trenton Water Works obtains its entire supply from the Delaware River. The filtration plant is Trenton’s only treatment facility. This supply is treated by a conventional treatment plant (clarification followed by filtration) located at the intersection of Route 29 and Calhoun Street.

The treatment plant was constructed in two phases during the 1950s. In the early 1990’s a new disinfection system was installed using Wallace and Tiernan evaporators, chlorinators, injectors, and associated appurtenances. The pretreatment was modified and various plant upgrades were made during a large upgrade project completed in 2010/2011. This upgrade brought the firm capacity to 60 MGD [million gallons per day] with the average daily production of approximately 27 MGD. The treatment plant consists of a river intake, screen house, raw water pumping, rapid mix, chemical feed, SuperPulsators for flocculation and sedimentation, filters, clearwell and high-lift pumping.

During the most recent upgrades the coagulant was changed from Aluminum Sulfate to Ferric Chloride to generate a heavier floc. Also added was a slaking system for pH and Alkalinity adjustment.

Starting in 2017 the water filtration plant is being converted from chlorine gas to sodium hypochlorite.

TWW has had some operational issues with the slaking system. The system has been maintenance intensive. The most recent contracts for the system include a $227,000 contract for maintenance services, $13,700 contract for a softening system maintenance contract and supply of salt, $101,300 contract for the supply of quicklime. Additionally, TWW is concerned about the impacts of the various process changes on the corrosivity of the drinking water.

The Lead levels exceeded 15 ppb for the 90thpercentile during the January 1, 2017 through June 30, 2017 monitoring period. Any immediate measures would  be sought as part of the study as part of the services. [Emphasis mine - KM]

To this layman, it sure does sound like TWW is admitting, “Hey, we started doing something as far back in 2010 and 2011, and as recently as this year, that’s screwing things up. Any solutions you can suggest that would be helpful right away would be really appreciated!”

This is a problem that’s been developing for quite some time. This most recent RFP for a Corrosion Control Study may be related to deeper and more fundamental problems going on with TWW, which led to ANOTHER RFP issued earlier this Spring, seeking “Management Advisory Services” for TWW.

So, what the hell is going on at Trenton’s Water Works? And why in hell is the first we are hearing of this in the form of a not-very-informative letter mailed to customers’ homes?

Why isn’t TWW’s Superintendent McIntyre telling us what’s going on?

Why isn’t Director of Public Works Merkle Cherry telling us what’s going on?

Why isn’t Mayor Eric Jackson telling us what’s going on?

Hamilton Mayor Kelly Yaede is pissed. So, I imagine, are all of TWW’s customers, including me.

What’s Going On?

1 comment to Heavy Metal

  • W. Pyle

    Under the Federal Lead and Copper Rule Trenton is required to conduct periodic collection of samples and subsequent testing for lead and copper concentrations. The sites must meet specified criteria established by the LCR. For a utility of the size of the Trenton Water Works the criteria are as follows:

    Collect samples from Single Family Residences (SFRs)*:

    • with copper pipe and lead solder installed after 1982 (but before the effective date of the State’s lead ban), or with lead pipes; and/or

    • Are served by Lead Service Lines (LSLs).

    For any system with LSLs, 50% of the samples must come from LSL sites and 50% of the samples must come from sites with lead pipes or copper pipes with lead solder.

    The number of samples and the frequency of sampling required by the LCR for a system that is the size of the Trenton Water Works is shown in the table below:

    No. of Samples Standard Monitoring No. of Samples Reduced Monitoring
    100 50
    Semi annual Triennial

    To determine the Trenton Water Works’ past record the DEP Water Watch web site was checked to see the monitoring results. The available monitoring history reveals that prior to the collection of samples this year and dating back to at least January 1, 2003, Trenton Water Works was apparently directed by the regulatory agency to comply with the LCR under the reduced monitoring requirements. This meant that the frequency of the monitoring was not semi annual but triennial. The history also shows that for 2017 Trenton Water Works resumed standard monitoring. The return to standard monitoring was done by all other large water utilities in the State and was in large part due to the heightened awareness of lead in drinking water.

    Looking at the data for the most recent sampling (first half of 2017) that triggered the public notification shows that there were 119 samples recorded. Fourteen (14) of those samples had lead levels that exceeded the LCR action level of 15 ppb. To determine if the samples complied with the LCR the samples were sorted by increasing lead concentration. After doing so, the 90th percentile sample was checked for its lead concentration. In this case the 107th sample is the 90th percentile sample and its lead concentration is 17.6 ppb. Since it is greater than action level of 15 ppb, the LCR requires public notification.

    Taking another look at the sample data for the most recent data shows that the 106th sample has a lead concentration of 16.4 ppb. The 105th sample has a lead concentration of 13.4 ppb, which is less than the action level of 15 ppb. If that were the 90th percentile sample, then there would have been no public notice required and the sampling would have been deemed compliant. If that were the case though, the utility still should have and may have looked at those samples that exceeded the action level and notified the customers and advise them about the results and what they could and should do to minimize the lead concentration.

    The most recent sample data shows the following:
    40 (33.6%) non detected levels of lead
    20 (16.8%) had a lead concentration greater than or equal to 2 ppb and less than 3 ppb
    14 (11.7%) had a lead concentration greater than or equal to 3 ppb and less than 4 ppb
    6 (5%) had a lead concentration greater than or equal to 4 ppb and less than 5 ppb
    7 (5.8%) had a lead concentration greater than or equal to 5 ppb and less than 6 ppb
    6 (5%) had a lead concentration greater than or equal to 6 ppb and less than 7 ppb
    3 (2.5%) had a lead concentration greater than or equal to 7 ppb and less than 8 ppb
    2 (1.7%) had a lead concentration greater than or equal to 8 ppb and less than 9 ppb
    2 (1.7%) had a lead concentration greater than or equal to 9 ppb and less than 10 ppb
    5 (4.2%) had a lead concentration greater than or equal to 10 ppb and less than 14 ppb
    0 (0%) had a lead concentration greater than or equal to 14 ppb and less than 16 ppb
    3 (2.5%) had a lead concentration greater than or equal to 16 ppb and less than 17 ppb – 90th percentile included here
    4 (3.4%) had a lead concentration greater than or equal to 17 ppb and less than 20 ppb
    4 (3.4%) had a lead concentration greater than or equal to 20 ppb and less than 30 ppb
    3 (2.5%) had a lead concentration greater than or equal to 30 ppb and less than 40 ppb
    1 (0.8%) had a lead concentration of 45.5 ppb
    1 (0.8%) had a lead concentration of 51.4 ppb
    1 (0.8%) had a lead concentration of 106 ppb

    How do these 2017 results compare to the previous test results that were collected during July, August and September of 2014? Based upon the three years since that sample and number of samples obtained and analyzed (52), the 2014 sampling was conducted under the reduced monitoring protocol.

    The 2014 sampling data show the following:
    19 (36.5%) non detected levels of lead
    11 (21.1%) had a lead concentration greater than or equal to 2 ppb and less than 3 ppb
    3 (11.7%) had a lead concentration greater than or equal to 3 ppb and less than 4 ppb
    3 (0.6%) had a lead concentration greater than or equal to 4 ppb and less than 5 ppb
    1 (0.2%) had a lead concentration greater than or equal to 5 ppb and less than 6 ppb
    5 (9.6%) had a lead concentration greater than or equal to 6 ppb and less than 7 ppb
    3 (2.5%) had a lead concentration greater than or equal to 7 ppb and less than 8 ppb
    0 (0.0%) had a lead concentration greater than or equal to 8 ppb and less than 9 ppb
    2 (3.8%) had a lead concentration greater than or equal to 9 ppb and less than 10 ppb
    2 (3.8%) had a lead concentration greater than or equal to 10 ppb and less than 11 ppb
    0 (0.0%) had a lead concentration greater than or equal to 11 ppb and less than 12 ppb
    1 (3.8%) had a lead concentration greater than or equal to 12 ppb and less than 13 ppb – 90th percentile included here
    0 (0.0%) had a lead concentration greater than or equal to 13 ppb and less than 14 ppb
    2 (3.8%) had a lead concentration greater than or equal to 14 ppb and less than 15 ppb
    0 (0.0%) had a lead concentration greater than or equal to 15 ppb and less than 16 ppb
    1 (3.8%) had a lead concentration greater than or equal to 16 ppb and less than 17 ppb
    0 (0.0%) had a lead concentration greater than or equal to 17 ppb and less than 21 ppb
    2 (3.8%) had a lead concentration greater than or equal to 21 ppb and less than 22 ppb

    The data for each monitoring period does not identify where the sample was taken or provide a code that would allow the comparison based upon the location of samples from one monitoring period to the next. Therefore, the data provided does not allow a location by location comparison from one monitoring period to the next or any other monitoring period to see the consistency of the results or the lack of consistency of the results for those same monitoring sites that were monitored in each period. The data also does not provide the selection criteria for each sampling site. Consequently, the data doesn’t provide the necessary data to compare the results based upon the selection criteria.

    Base upon the percentage of samples that had non-detectable levels of lead, the data suggest that the delivered water (treated water pumped out of the treatment plant) is not a contributor to the lead found in the samples. If the delivered water did indeed contain detectable levels of lead, it would be present in all of the samples. This is supported by the delivered water sampling data posted on the Internet. All of the monitoring results from 2009 to June of 2017 show non-detectable lead levels.

    The results of the most recent monitoring period compared to the results of the previous monitoring period do not show a gross increase in the lead concentrations found. Nevertheless, the news of a corrosion control study is not a bad idea considering the change in the treatment process that occurred. It may seem that it is a knee jerk reaction to the lead action level being exceeded and it may be. However, it may not be that and it may be that operating personnel may have been planning it before the 2017 monitoring results were available. It also may have been recommended by the operating personnel during the design phase of the treatment plant improvements. Someone may be able to verify that and also explain why it was not performed. The absence of such a study could have only been absent with the approval of NJDEP. NJDEP also would have approved any new process and the equipment to perform that process. Moreover, NJDEP also monitors the ongoing compliance of meeting the standards established by NJDEP for the control of corrosion. There has not been any report that those standards have been violated.

    For anyone desiring to do what they can to reduce their exposure to lead in their drinking water EPA provides the recommendations included at the following site:

    https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water#reducehome