&EPA
United States
Environmental Protection
Agency
Office of Exploratory
Research
Washington DC 20460
EPA-600/6-84-004
September 1984
Research and Development
Institutional
Responses to
Contamination of
Ground Water
Used for Public
Water Supplies:
Implications for
EPA R&D Programs
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EPA-600/6-84-004
September 1984
~ ;, INSTITUTIONAL RESPONSES TO CONTAMINATION
fg OF GROUND WATER USED FOR PUBLIC WATER SUPPLIES:
# IMPLICATIONS FOR EPA R&D PROGRAMS ; ;
FSNAl. REPORT
Submitted To:
EPA Office of Research and Development
Contract No. 68-02-3718
Project Manager: Dr. Marvin Rogul
Director of Scientific Assessment Staff
Prepared By:
ICF Incorporated
1850 K Street, N.W., Suite 950
Washington, D.C. 20006
Project Director: Theodore R. Breton
Principal Analyst: Steven N. Payne
OFFICE OF EXPLORATORY RESEARCH
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, DC 20460
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NOTICE
This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication. Mention of trade names
or commercial products does not constitute endorse
ment or recommendation for use.
bfc.
%
11
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TABLE OF CONTENTS
, '
Page
EXECUTIVE SUMMARY
I. INTRODUCTION ---- ......... ........................... ............. I~1
Background on Organic Contamination of Ground Water ........... 1-1
Purpose of Study . . . . ................... ! ....................... 1"^
Outline of Report ............................................. I~4-
II . METHODOLOGY ...................... . ............................... J1'1
Initial Survey ................ ..... ........................... II-l
Case Selection ................................................ II-3
Study Procedure ..... ............ .............................. II -7
III. ANALYSIS OF CASES ... ................... .................. ....... IH-1
Organic Contaminants Detected ................................. III-2
Sources of Contamination ...................................... Ill -4
Discovery of Ground-Water Contamination ....................... III-5
Prevention of Ground-Water Contamination ...................... III-6
Actions Taken in Response to Contamination .................... III-7
Health Guidelines .......... ........ . ..... ..................... 111-10
IV. GROUND-WATER CONTAMINATION RESEARCH AND. DEVELOPMENT NEEDS ... ..... IV- 1
.Analytical Procedures for Monitoring Contaminants ... .......... IV- 1
Determination of the Extent and Source of Contamination ....... IV-5
Engineering Control Technologies .............................. IV-6
Aquifer Management Technologies ........ . ..... ................. IV-8
Health Effects ................................................ IV-10
Other Needs ...... ............................................. IV-12
V. CONCLUSIONS
APPENDICES
A: INITIAL SURVEY RESULTS .................................... A-l
B: SAMPLE INTERVIEW QUESTIONS ............................ .... B-l
C: COMPLETE CASE STUDIES ..................................... C-l
D: LIST OF CONTACTS FOR EACH CASE ............................ D-l
111
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EXECUTIVE SUMMARY . .;
The objectives of this ground-water assessment for the EPA Office of
Research and Development are threefold. The first objective is to improve
EPA's understanding of problems faced by the states and municipalities in
ensuring that ground-water is safe for drinking. The second objective is to
provide guidance to EPA in setting research and development priorities in
ground-water and drinking water areas. The final objective is to present the
data on the original and final sets of ground-water contamination cases
examined, with source lists for contacts at each organization dealing with the
problem. These objectives reflect revisions made in the work plan which
originally called for a mini-assessment of trends in ground-water pollution.
The scope of this assessment was defined to include public water systems
' ' "=,.,..,
with confirmed drinking water contamination from synthetic organic chemicals
in ground-water. A preliminary list of municipalities with ground-water
contamination problems was developed to select a group of cases for in-depth
analysis. These cases, chosen with the assistance of regional EPA and state
. ; . - ...-:- ., ... ;." -if ' -t, : - ' . '.-,...; ,
officials, were studied through site visits and extensive telephone interviews.
CONTAMINATION TRENDS
Several distinct patterns of ground-water problems became apparent. Eighty
percent of the cases involved trichloroethylene, detected at levels as high as
5,700 ppb in public wells. Tetrachloroethylene, trichlorpethane, and other
volatile halogenated organic compounds were detected less frequently, and at
lower levels. The major sources of these organic solvents were military con-
tractors or airports, followed closely by plating industries, electronics
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E-2
industries, and chemical waste handlers/landfills. Leaking underground tanks
or improper disposal of solvents were identified as the most common point
sources of pollution. It is important to note that a large number of other
cases of ground-water contamination are likely to exist but have not been
discovered or made public due to the same fears and uncertainties exhibited by
public officials in the cases studied.
»*-
*
PATTERNS OF INSTITUTIONAL RESPONSE
Several patterns of institutional response also became apparent. In a
typical case, organic-contaminated drinking water was discovered accidentally
or by state officials testing suspected or random sites. The local water
utility usually closed the contaminated wells immediately and invoked conser-
vation measures or purchased water to replace lost capacity. At this point
the state and technical consultants joined in investigations to determine the
source of contamination and to restore long-term water supplies. In the major-
ity of cases, new or recompleted wells were selected as a long-term water
source, rather than water treatment or aquifer rehabilitation.
In a typical case, the local water authorities would be working with t'.ie
county health or environmental department, the state health department and
environmental agency, and regional EPA officials. The capabilities of state
agencies, which often took the lead in resolving ground-water contamination
cases, varied widely. The State of New York, for example, has studied
organics in ground water extensively, while Washington barely has enough staff
or funding to conduct any investigations at all. Several states, such as
Arizona, have set up their own versions of Superfund (CERCLA) to attempt to
respond to hazardous waste problems. The Department of Defense has also
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E-3
become involved in a significant number of cases-through-programs such"as the
Air Force's Installation Restoration Program. /;,;- - ,:
RESEARCH AND DEVELOPMENT NEEDS , . t -: ; ,
The major technical deficiency encountered was a paucity of information on
the health effects of organics in drinking water and a lack of consistent
health guidelines. Evaluating.the hazards of keeping contaminated'wells in
service, informing the public, and designing treatment techniques were-all
made difficult by weaknesses in health data and- inconsistencies,in recom-
mended allowable levels of contamination.- . . :. : .
Testing and monitoring techniques appeared adequate in most cases.
Research on more comprehensive and less expensive methods of analysis would,
however, aid in the detection and resolution of organics contamination cases,
as would standardized protocols for monitoring. Tracing the sources of organ-
ics in ground water proved to be a more serious problem. Several investiga-
tions were limited by costly drilling techniques, the complicated data require-
ments for ground-water modeling, or an overall lack of institutional coordina-
tion. Many regions also face a shortage of qualified hydro/geological person-
nel to carry out extensive subsurface studies.
The state-of-the-art of treatment techniques to remove organics from drink-
ing water was generally not a limiting factor, and either EPA or engineering
consultants had enough knowledge to install a pilot plant and design an effec-
tive treatment plant. Aeration techniques were usually selected although
little is known about the levels of air contamination due to aeration. The
major constraints in designing treatment methods are the uncertainties in
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E-4
specifications for allowable effluent levels of organics, not the efficacy of
removal technologies.
In conclusion, most municipalities examined in this study handled the
problem of organic chemicals in their ground water fairly well, but more work
is needed to improve several areas of response. The most critical R&D need
for states and municipalities is in health effects research, followed by estab-
lishment of consistent guidelines or standards for organics in drinking water.
The dissemination of technical information on detection, analysis, and
engineering control techniques is also necessary to help local and state offi-
cials to make informed decisions on resolving problems with organic contami-
nants in ground water.
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I. INTRODUCTION
This study was commissioned by EPA to investigate trends,in cases of
ground-water contamination and to evaluate research and development needs of
municipalities with contaminated ground-water supplies. This section presents
background information on the growing problem of organic contaminants in
ground-water sources used for drinking water supplies, elaborates on the pur-
pose of this investigation and outlines the content of the report that follows,
\> . " - ' ' " ;
BACKGROUND INFORMATION ON GROUND WATER CONTAMINATION
Ground water is a vast but vulnerable natural resource. About 25 percent
of all fresh water used in this country comes from ground-water sources, and
somewhat over 50 percent of the U.S. population relies on ground water, often
. ' ' ' - - ' - ' . >' , ; ,' '
untreated, as a primary source of drinking water.1 Ground-water use is
proportionately higher for small water utilities and in rural areas, where
over,90 percent of the population is dependent upon public or, more often,
private wells for drinking water.2 Considering the fact that over 20
trillion gallons of ground water are withdrawn annually, one might suspect
that the nation is facing a problem with the quantity of the ground-water
resource. Except for arid regions in the West, however, natural recharge is
1 U.S. Environmental Protection Agency, Office of Drinking Water, "
Planning Workkshop to Develop Recommendations for a Ground Water 'Protection
Strategy: Appendices, Washington, B.C. U.S. Government Printing Office,
1980 p. IV-1. ' '
2 Murray, C.E., and Reeves, E.B., Estimated Use of Water in the United
States in 1975, Geological Survey,'Circular 765, Arlington, VA, USGS, 1977
p. 20.
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1-2
usually ten times as large as withdrawal, and overall ground-water quantity is
not a problem.
The current problem associated with ground-water supplies is with quality,
not quantity. Although ground water had always been considered a secure,
pristine resource, recent discoveries indicate that contamination from various
sources is a problem in many locations. One potentially serious trend becoming
evident is that many instances of ground-water contamination are associated
with organic chemicals. The earlier national organics monitoring programs
focused attention on trihalomethanes in surface-water systems, and as recently
as four or five years ago, ground water was still thought, by most, to be
relatively secure from organics contamination.
Three major national studies by EPA from 1975 through 1979 showed that a
number of volatile chlorinated hydrocarbons -(besides trihalomethanes) were
frequently found in ground water.3,'*,5 More recent studies, focusing
more on ground water, such as the Ground Water Supply Survey, the Community
Water Supply Survey, and the Rural Water Survey confirmed earlier reports that
several organic chemicals associated with solvents, especially trichloroethy-
lene and tetrachloroethylene, were present in a significant number of water
3 Symons, J.M. et,al., "National Organic Reconnaissance Survey for
Halogenated Organics," Journal of the American Water Works Association,
67:234 (1975).
4 U.S. Environmental Protection Agency, "Organic Chemicals in Drinking
Water," Washington, D.C. 1978.
5 Information on the National Organics Screening Program (NOSP) provided by
the Criteria and Standards Division, Office of Drinking Water, U.S.
Environmental Protection Agency, Washington, D.C.
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1-3
systems using ground water.6 The occurence of organic cheraicMsriri drinking
water from ground-water sources has been recognized as^ a^poteritially' serious
health hazard. . , ,. ,...,; .-'_._-., . ;. .'V-,.; . .
EPA has reacted to requests for assistance by states and t,'O:its congres-
sional mandate to .carry out the Safe Drinking Water Act and other {Statutes in
a number of ways. One major program is regulatory in nature,., .to set:standards
and guidelines to protect the public health .and to restrict. \t;he,.use- and dis-
posal of chemicals and hazardous wastes.v A recent survey .showed that EPA
drinking water research and development assistance was ,thel,highest .priority
request from the States.7 In support of the regulatory role and to provide
technical assistance to municipalities, states, and Regions with concerns
about organics in ground water, EPA has developed-.a .ground-water .resear.ch
program. . , ; ......... -;,, , -; . .. ,,.:
The EPA drinking water research plan recognizes, that th$,;l-arges,t areas of
ignorance in the drinking water field are rela.ted to the measurement, assess-
. - - * f "-..'.
ment, chronic health effects, and treatment of trace organics in ground water.
This study was initiated to investigate trends in cases of ground-water contam-
ination and to comment on the needs of States and municipalities in studying
and resolving local cases of drinking water problems caused by contaminated
ground water.
6 Coniglio, W.A., Miller, K., and MacKeever, D. "The Occurrence of Volatile
Organics in Drinking Water," U.S. Environmental Protection Agency, Office of
Drinking Water, briefing paper, March 6, 1980, p. 10.
7 U.S. Environmental Protection Agency, Office of Research and Development
"Decision Unit Analysis - Drinking Water," prepared for the Office of
Management and Budget, 1982, p. 1.
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1-4
PURPOSE OF STUDY
Orginally, this study was intended to be a mini-assessment of trends in
ground-water pollution. Early discussions between the Office of Research and
Development and ICF Incorporated centered around a proposed work plan to
characterize the current extent of ground-water contamination, project trends
in ground-water contamination, assess the potential health hazards associated
with these trends, and to identify policy implications, information gaps, and
research needs. After ICF presented its detailed work plan for the mini-
assessment, ORD decided that the available data were inadequate to fully
support the type of inquiry initially sought and that a change in study
emphasis was mandatory. The background research and investigations preceeding
this decision are not presented in this report.
The scope of the effort was changed to provide a narrower but more
in-depth study. The main tasks of the revised work plan were to:
identify cases of drinking water contamination associated with
ground-water' contamination;
contact the local and state organizations involved to determine
the facts of each case, institutional responses, and any difficul-
ties encountered;
organize the findings to permit others to derive insights on
preferred methods in technical areas such as detection, analysis,
monitoring, or treatment; and
use the data to derive suggestions for EPA research needs.
The procedures used to perform these tasks are described in the section
entitled Methodology.
OUTLINE OF REPORT
The remainder of this report is organized into sections addressing the
methodology employed, characteristics of the cases analyzer!, research and
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1-5
development needs, and conclusions on trends in organic contamination of ground
water. The methodology section describes the procedure used to identify water
systems with contaminated ground water and to select the cases studied in
depth. The analysis section describes various technical and organizational
aspects of the case studies, as well as problems commonly encountered. The
section on ground-water R&D discusses the areas of assistance most frequently
requested by municipalities and states with ground-water problems and outlines
^
these areas in a format consistent with EPA's Drinking Water and Ground Water
Research Plans.
Several important components of this report are included as Appendices.
These include the results of the initial survey of water systems, the complete
case studies (the subject of most of the effort expended in this assessment)
and a list of contacts at every agency involved in each case. The last two
items, especially, will be valuable for follow-up studies on specific technical
topics. , : - , _
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........ , j( II,. ., METHODOLOGY . _; , ,, ......
Since the data available on ground-water contamination are inadequate to
support a statistically-based inquiry, the case study method was ~chosen to gain
an in-depth understanding of the problems involved in responding to ground-
water contamination. Briefly, the general approach in the project was to:
, . Compile data on cases of drinking water problems associated
with ground-water contamination;
.Select .a cross-section of cases for in-depth analysis, involving
site visits and phone interviews;
Contact the key individuals in the selected group of cases to
obtain detailed information on how the water utility discovered
and dealt with the problem;
Identify common patterns of problems and responses; and
Make suggestions on research and program needs to EPA, based on
the findings of the cases studied in depth.
'A more detailed explanation of the methodology is presented below.
INITIAL INVESTIGATION
In compiling data on cases of drinking water contamination, an effort was
made to investigate those cases considered significant by .state and local
authorities. State public health agencies were contacted to identify instances
of drinking water problems caused by actual or potential ground-water contami-
nation. The data compiled on each case included location, contaminants iden-
tified, and a brief description, if possible, of the extent of the problem and
any action taken. Over one hundred cases in the ten.regions were identified
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II-2
in this step. Several criteria were established to narrow the scope of the
investigation. Those cases that clearly did not include public systems, those
that involved only inorganic contaminants (including heavy metals), or those
which were known to be actively involved in lawsuits were screened out.
Seventy-seven cases passed this screen and were considered for the final
analysis. A review of the cases indicates the following characteristics:
Geography: The 77 sites identified were concentrated in
areas of high population density, indicative of more frequent
contamination as well as more intensive water testing:
Region
1
2
3
4
5
6
7
8
9
10
Total
No. of Sites Identified
.4
27
7
8
12
1
3
9
6
77
Contaminant: Some cases involved more than one contaminant.
The preliminary data collection effort yielded the following con-
tamination pattern:
Contaminant
Trichloroethylene (TCE)
Unspecified "Organic"
Tetrachloroethylene
Unspecified "Solvents"
PCB
Trichloroethane (TCA)
Toluene
Dichloroethylene (DCE)
Acetone
Dibromochloropropane (DBCP)
Phenols
Benzene
No. of Cases Identified
39
17
9
6
6
5
4
3
2
2
2
2
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II-3
If the cases identified as unspecified "organics" or "solvents"
are attributed to TCE (the preliminary investigation 'indicates
this is likely), then 81 percent of the seventy-seven cases
involve TCE. Nineteen contaminants identified only once are not
listed above. One possible fault with the table above is that
some officials might have confused TCE with' TCA. "
Source of contamination: Where the source was'identified,
almost half of the cases were associated with landfills or waste
dumps. Another twenty to thirty percent were linlced to industrial
sites. A smaller proportion of cases were linked to buried pipe
or tanks and septic systems.'
Magnitude of problem: The populations affected ranged from
less than 1,000 persons to over. 400-,000. Mos,t water systems
affected appeared to be in the range of 2,500 to SO'OdO customers.
Action taken: In cases where responses to contaminated
drinking water were reported, over half of the systems qjosed
down one or more wells. Roughly fifteen to twenty percent either
changed supplies or purchased water, and about ten percent of
those systems that reported taking action implemented'granular
activated carbon (GAG) treatment, aeration, or other advanced
treatment methods. ' '' ' ' ' '' '
CASE SELECTION ' '' '"" "'
Site characteristics such as location, contaminants, source of contami-
nants, magnitude of the problem, and action taken were considered to assemble
an intermediate group of cases representative of the whole. Regional EPA and
state drinking water officials were then contacted for.assistance in selecting
the final group of cases for site visits and interviews. In some instances,
the cases they suggested for analysis involved a more serious problem or had
received more publicity than a "typical" case, so an effort was made to balance
the relatively controversial cases with more ordinary ones. The regional and
state officials identified those cases where knowledgeable local officials were
actually available for detailed interviews. The cases .selected for study dif-
fer from a truly representative sample in that the information about how each
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II-4
community detected and responded to its drinking water problem was readily
available.
Since the final set of cases was selected on the basis of several general
criteria, rather than"chosen randomly, statistical measures of the study
results are inappropriate. The field experience and in-depth examination of a
small number of cases, however, provide an understanding of typical problems
and responses from which general inferences can be drawn.
Budget constraints dictated that only a limited number of cases could be
investigated in depth. A two-tiered approach was proposed to study as many
cases as possible while allowing in-depth analysis. Two sets of cases were
selected: a group of seven cases designated for site visits and a group of
eight cases studied through extensive telephone interviews. The more compli-
cated cases, listed in Exhibit II-l, were selected for site visits because
numerous officials had to be contacted to trace .the decision-making process.
The second group of cases, listed in Exhibit II-2, were more clear-cut so that
telephone interviews were usually adequate. The following table displays the
distribution of those cases investigated in-depth by Region and state.
DISTRIBUTION OF CASE STUDIES
EPA Region
I
II
III
IV
V
IX
Totals
State
Massachusetts
New Jersey
New York
Pennsylvania
Florida
Indiana
Michigan
Minnesota
Arizona
California
Washington
11
Site Visits Telephone Interviews Total Cases
1
1
1
1
1
1
1
2
1
1
1
1
1
2
3
1
1
1
2
1
1
1
1
15
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II-7
STUDY PROCEDURE
The first step in investigating the final set of cases was to identify the
lead agency responsible for coordinating actions taken in response to each
case of organics in ground water. Interviews with officials at the lead agency
were followed by contacts with other organizations involved in particular
aspects of the problem. Often, the interviews would trace two different paths
of response to the contamination problem: the local and health agencies
concerned with supplying safe drinking water, and the state environmental and
EPA offices responsible for finding and halting the source of contamination.
As many as eight agencies were contacted in the course of a single case study.
Both the site visits and the extensive telephone interviews were structured
around a general set of questions. The interview format was tailored to each
case and each agency involved to maximize the amount of detailed information
gathered and to avoid redundant questioning. The use of interviewers know-
ledgeable about municipalities' problems with organics in drinking water
allowed some flexibility in studying each case and eliminated the need for a
formal, more limited interview methodology.
A sample set of questions, included as Appendix B, shows the type of infor-
mation typically gathered. The sample questions are divided into categories
including general information,about the contamination problem, how the-
organics in drinking water were detected, how the scope of the problem was
evaluated, and what actions were taken in response. This list of questions
was developed to guide the interviewers. It was not used in a survey context.
-------
-------
III. ANALYSIS OF CASES
A case study was written on each of the ground-water contamination inci-
dents investigated through site visits and telephone interviews. The full
description of each case is included in Appendix C. The. description of the
cases studied through site visits are of course more detailed than those
studied through telephone interviews, but both types are organized in the'fol-
lowing format.
Summary
Discovery of the Contamination Problem
Actions to Protect Water Quality
Current Status
Institutional Involvement
Health Guidelines
Conclusions
The case studies provide useful accounts of the chronology of events, the fac-
tors contributing to decision-making, and the problems encountered in response
to each incident of organics in ground water used for public drinking water
supplies. The overall progression of events and organizational responsibili-
ties in the cases should be helpful in, explaining how a typical contamination
problem is handled; A detailed source list of over eighty persons contacted
for information on the cases is included as Appendix D.
To allow examination of trends and problems in particular aspects of
ground-water contamination cases, the important factors in each case were also
broken out horizontally. Topic areas addressed include the contaminants
involved, usual sources of ground-water contamination, the means by which con-
tamination was detected, whether aquifer contamination could have been pre-
-------
III-2
vented, actions taken in response to contamination, and a comparison of various
state health guidelines. Section IV contains an in-depth discussion of the
technical problems encountered in ground-water contamination cases.
Organic Contaminants Detected
The scope of this study was limited to cases of drinking water contamina-
tion caused by organic chemicals in ground water. In both the preliminary
data collection effort and the final set of case studies, trichloroethylene
was, by far, the most prevalent synthetic organic compound present in ground-
water supplies. The preliminary survey indicated that fifty to eighty percent
of the cases screened involved trichloroethylene, often in conjunction with
other organics. In the 15 in-depth studies, eighty percent of the sample
cases involved trichloroethylene; other organics were present in greater than
trace amounts as indicated below.
Highest Level Detected
Occurrences . in Public Well
Trichloroethylene
Tetrachloroethylene
1,1,1 trichloroethane
1,2 dichloroethane
1,1 dichloroethylene
cis-1,2 dichloroethylene
trans-1,2 dichloroethylene
12
7
5
3
5,700 ppb
375 ppb
1,500 ppb
12 ppb
79 ppb
Single incidents of contamination by vinyl chloride, methyl tertiary butyl
ether, diisopropyl ether, phallates and dioxane were also noted. Several
associated or degradation compounds often present at lower levels than the
"primary" organic contaminants were not always reported, on the assumption
that they would also be controlled by whatever means was chosen to control the
"primary" contaminants.
-------
III-3
As shown, trichloroethylene was, by far, the most ubiquitous contaminant
reported. The insights gained through the case studies indicate that the
majority of contaminants reported generally as "organics" or "solvents"
probably are trichloro'ethylene, with trichloroethane or tetrachloroethylene
being the other most prevalent compounds.
Trichloroethylene (TCE) seems to have become the "reference standard" for
organic compounds in ground-water contamination, although other studies have
mentioned that 1,1,1 trichloroethane is the compound most often detected in
!
certain states. Several offices reported that the presence of TCE is generally
used as an indicator for more hazardous compounds usually found in much lower
concentrations, such as 1,2 dichloroethane.
It also should be noted that levels of organic contamination in industrial
or private wells were usually higher than in public wells. This occurs because
the industrial wells are closer to the contamination site and because the more
numerous private wells are usually completed in shallower, more vulnerable
aquifers. Most states have regulations mandating an undeveloped zone around
public wells, but private wells have traditionally been less protected.
Additionally, private wells are more common in the older parts of municipal
areas, where medium to heavy industry has often been operating (and using
organic solvents) for many years, than in the newer suburbs.
In the cases studied, it would not be unreasonable to state that at least
five to ten private wells were known to be contaminated for every municipal
well contaminated by organics. Although fewer persons in municipal areas rely
on private supplies than on public drinking water, the degree of contamination
is usually significantly higher. For this reason and since the option of
connecting to public water is usually available in municipal areas, steps to
-------
III-4
protect private well owners should be considered when organics contamination
Is detected at public wells. The County Health Departments have usually super-
vised testing of private wells, while State Health Departments oversee public
water supplies.
Sources of Contamination
Several definite trends were observed in the sources of organics contribut-
ing to ground-water contamination in the final set of sites studied. The table
below displays the frequency of occurrence for five categories of sources.
Note that some sites were contaminated by more than one source.
Confirmed or Suspected Source Cases
Airport/military base or contractor
Plating industries
Electronic industries
Landfills/chemical waste handlers
Other industrial
5
4
3
3
3
In all cases where a source was confirmed, either the use or disposal of sol-
vents or degreasers was mentioned as the cause of ground-water contamination.
The list above suggests the type of industries that should be investigated
for potentially hazardous organics use and disposal practices. In the experi-
ence of several state officials, wherever TCE has been used in any significant
quantity, a problem exists. More specific point sources that were found in
follow-up investigations at the above sites were leaking underground storage
tanks, dry well/pump disposal of used solvents, and chemical tank or barrel
rinse areas. No contamination incidents were reported as the result of one
isolated spill, but many cases were reported where continuous disposal took
' '' s~
place over several years.
-------
III-5
In the dozen cases where a point source was identified,.actions.were taken
to eliminate that source. The organics still contained in the unsaturated
zone remain in many cases as non-point sources, contributing to contamination
in the saturated aquifer zone with every major .rainstorm. Above-ground ...
sources, however, have been controlled and are in most cases being strictly
monitored. .r ,
Discovery of Ground-Water Contamination ..........
The presence of organic compounds in drinking water wells was discovered
by a wide variety of methods in the cases 'studied. The following table shows
how many contamination incidents were detected by each of, five methods.
Method of Discovery of Organics Number of Cases
State/County Monitoring Program .. , 4 , .
Contamination Suspected ' 4
Accidental Testing . ,,4
Testing for Trihalomethanes 2
Federal Monitoring Program 1
The federal monitoring programs have turned up many cases of organics
contamination nation-wide, but these programs were usually involved only
indirectly, by heightening awareness of potential ground-water quality
problems, in the cases examined in this study. Several incidents of organics
contamination discussed in this report were discovered by state monitoring
programs, and many more are likely to be discovered as more states begin .
testing public water supplies. Budget constraints and limited laboratory
capacities are major factors hindering state monitoring programs.
Somewhat surprisingly,. in several of the water systems studied, synthetic
organics were discovered while testing for .trihalomethanes. Trihalomethanes
-------
III-6
are rarely found,in well water supplies due to the lack of organic 'precursors
(humic and fulvic acids) in ground water and less frequent chlorination. The
four water systems that were suspected of containing organics were tested
because of taste and o.dor complaints or because organics were detected in
nearby industrial wells or ground-water supplies.
In four of the fifteen cases studied, contamination of public water
supplies by synthetic organic compounds was not particularly suspected. The
thought that over twenty-five percent of these cases of ground-water contami-
nation were discovered accidentally is not a comforting one. Unfortunately,
no data were available on the frequency of negative test results which could
be used to estimate nation-wide trends in contamination.
Prevention of Ground Water Contamination
In few of the cases studied could a simple action have prevented aquifer
contamination, since the organics release was not usually confined to a single
point source. The cases with leaking buried solvent tanks, Vero Beach and the
Great Oaks Water Company, however, could have been easily prevented, if the
leaks had been detected either by some simple accounting of the amount of
solvent delivered, used, and stored or by occasional pressure tests on the
tank systems. The gasoline tank leak in Rockaway Township that spilled
thousands of gallons could also have been prevented by either of these methods.
The majority of the cases studied involved the use of thousands of gallons
of solvents/degreasers over a five to twenty,year period. Several of these
sites even halted most operations ten or more years ago, but the organics are
still present in ground water in high enough concentrations to cause concern.
Of equal concern is the length of time that people in some areas had been
-------
III-7
drinking organics-laden water. Avoiding problems of this magnitude would have
te'qUlffed a complete change-over in handling and disposal methods for chemicals
many years ago, rather than any simple preventative steps.
Actions Taken in Response to Contamination
Actions taken in response to the discovery of organic contaminants in
drinking water range from Glen Cove's closing wells to Rockaway Township's
installation of granular activated carbon adsorption contactors and a packed
tower aeration column. Table III-l displays the immediate, short-term, and
long-term actions taken by each system to provide high-quality drinking water
to their customers.
The typical response on the part of a water system was to confirm the
initial tests that showed the presence of organics, notify the appropriate.
state health or environmental agency, and close the wells showing any signifi-
cant amounts (with the definition of 'significant' varying from 0 to 75 ppb)
of contamination. The next step was usually to notify the public of the
problem and meet with county and state health, state environmental, and any
regional agencies with jurisdiction over water quality to plan a coordinated
response. By this time, the system might have had to purchase water (at rates
ranging from 2 to 5 times normal costs) from neighboring interconnected
systems, or implement water use restrictions.
In an ideal response, investigations to trace and control the source of
contamination would parallel studies of alternatives for supplying uncontami-
nated water. These alternatives would usually include drilling new wells or
providing treatment by carbon adsorption or an aeration technique. Two impor-
tant, factors enter this decision: the cost and availability of new well sites
-------
III-8
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III-9
and the required quality of the treated water. Since no single numbers, have
been widely accepted as reasonably safe and attainable levels of contamination,
systems often opted for the more certain choice: a new source of water. An
engineering contractor usually designed the treatment system or placed the new
wells. Except for the companies doing business in carbon systems, most
consultants have preferred aeration technologies when drinking, water treatment
is the chosen alternative. - . ' ;
The investigations into the source(s) of contamination usually involved
sampling private wells and drilling monitoring wells to determine the extent
and magnitude of organics in ground water., A consulting engineering firm was
often used for this step although .the. state agencies or EPA occasionally pro-
vided investigative teams. A scenario frequently observed was the investigator
tracing the contaminant plume toward a particular industrial sitej but not
being able to conclusively prove responsibility for the contamination. In
only three of the'fifteen cases studied did the suspected- culprit cooperate
willingly and aid on-site surface or drilling investigations to trace the
source. In a few cases no real progress has been made, but some progress has
been made in most cases, as shown in,the following table.
Investigations Investigations
Concluded Continuing
No Success in Tracing Sourcce -'...-.
One Source Suspected . 2 3
One Source Confirmed 4 -
More than One Source Suspected 2 4
More than One Source Confirmed
-------
Ill-10
Health Guidelines
The lack of detailed information on the health effects of organic chemicals
in drinking water and the corresponding lack of consistent guidelines were the
major problems faced -by the states and municipalities in dealing with ground-
water contamination cases. Only a few states, such as New York, have gone
beyond reviewing the array of health effects numbers published at one time or
another in the Federal Register. Table III-2 shows the variety of concen-
trations allowable at certain risk and exposure levels for trichloroethylene,
the organic most often detected and used as an indicator of contamination.
Not only do health officials have a lack of confidence in this type of risk
estimation, but they also have a variety of methods for applying the
information. Consequently, as shown in Table III-3, the maximum contaminant
levels recommended in state guidelines for trichloroethylene range from 0 to
75 ppb.
The implications of the uncertainties and inconsistencies in health guide-
lines for organic chemicals found in ground water are major. Most obviously,
customers of some water utilities are subject to higher toxic and carcinogenic
risks than others. Secondly, the health guideline levels greatly affect
actions taken and expenses incurred in protecting water quality. If all the
cases studied had been subject to a recommended TCE limit of 75 ppb, half would
not have had to take action besides closing a few wells, and five or six water
supply crises would have been averted (although public pressure might have
forced stricter measures). Thirdly, because of the uncertainties in health
guidelines and the possibility of a standard being set, water operators were
afraid to take assertive actions, and they were especially hesitant to install
engineering control technologies to reduce contaminant levels, for fear of
-------
Ill-11
TABLE 111-2
TOXICITY AND CARCINOGENIC. RISK GUIDELINES
FOR TRICHLOROETHYLENE
EPA Suggested No Adverse Reponse Levels (SNARLs)
Length of Exposure Concentration in Drinking Water tppb)
One-Day 2000
Ten-Day 200
Chronic " '' " 75 "
Drinking Water Exposure for Carcinogic Risk
Concentration in-Drinking Water Cug/1)
Projected Upper Limit National Academy EPA Carcinogen
Excess Lifetime Cancer Risk of Sciences (NAS) Assessment Group (CAG)
1 in 10,000 (10~4) .'' 450 280
1 in .100,000 (10"S) , ; 45 , :- , , 28 ;.
1 in 1,000,000 (10"S) " 4.5 '" 2.8
Assuming; Lifetime exposure (70 years) by 70 kg adult/ consumption' 6'f 2 litres
of water per day.
-------
111-12
TABLE 111-3
SUMMARY OF STATE GUIDELINES FOR
TRICHLOROETHYLENE IN DRINKING WATER
State
Massachusetts
New Jersey
New York
Pennsylvania
Florida
Indiana
Michigan
Minnesota
Arizona
California
Washington
Locatiorv
Bedford
Rockaway Township
S. Bunswick Township
Garden City Park WD
Glen Cove
Vestal
North Penn. Water
Authority
Vero Beach
Elkhart
Battle Creek
Petoskey
New Brighton
Tucson
Great Oaks Water
Company
Lakewood WD
Recommended Maximum
Contaminant Levels for TCE
75 ppb
any single VOC-50 ppb, total VOCs 100 ppb
33 ppb
any single VOC-50ppb, total VOCs 100 ppb
any single VOC-SOppb, total VOCs 100 ppb
any single VOC-SOppb, total VOCs 100 ppb
originally 4.5 ppb, now 75 ppb
0.00 ppm
originally 75 ppb, now 45 ppb
minimizing exposure suggested (0 ppb)
minimizing exposure suggested (20 ppb)
27 ppb
5 ppb
5 ppb
no guidelines, handled case-by-case
-------
111-13
over- or under-designing. The officials contacted were confident in the capa-
bility of treatment technologies to remove organics from drinking water, but
were uncertain about what removal efficiencies to specify.
In short, the lack of consistent health guidelines is the major obstacle
to state and municipal officials responding to organic contamination of' ground
water used as a drinking water source. Many different interpretations of
health effects information by state officials have confused local water systems
and caused great public concern. Section IV elaborates on the need for
additional health effects research.
-------
-------
IV. GROUND-WATER CONTAMINATION
' RESEARCH AND DEVELOPMENT
An important objective of this study was to identify research needs
relating to the detection and control of organics in ground water, particularly
in aquifers used for public water supplies. This section discusses research
needs either mentioned by the municipalities or state organizations or inferred
from the case studies. The discussion is organized into five technical and one
general area. The areas discussed are the following:
Analytical Procedures for Monitoring Contaminants
Determination of the Extent and Source of Contamination
' .'Engineering Control Technologies
Aquifer Management Technologies
Health Effects
Other Needs
These topics were defined to parallel the areas'addressed in EPA ground water
research plans.
ANALYTICAL PROCEDURES FOR MONITORING CONTAMINANTS
The analysis, of how the presence of organic contaminants in ground water
was actually detected in the cases studied, discussed on page III-5, provides
some interesting insights. Only one of the fifteen cases was detected through
a federal monitoring program, while six cases were detected either accidentally
or during voluntary (not required) testing for trihalomethanes. Many water
utility officials, especially in the Northeast, were in favor of broadening
mandatory testing programs for organics in ground water. 'These officials were
generally of the opinion that many of their neighboring systems had problems
with organics but either were afraid to test in the first place because of the
-------
IV-2
potential cost of treatment, or had tested and found, organics but chose not to
report the test results to the State water quality "agency or the public.
*'
The following breakdown shows the laboratories finally used for the major-
ity of the analytical work in each case:
Primary Laboratory
EPA
State
County
Private
Cases
2 -
6
2
5
15
The quality of EPA labwork was generally reported as quite good but delays
in performing analysis were common. As a result, if EPA labs were used, it
usually meant that no other alternatives were available or affordable. In
several cases, municipalities switched from public to private labs for faster
turn-around; The State laboratories were also reported to be consistently
competent, but in every case, personnel, equipment, or budgetary constraints
slowed response time and limited the number of analyses that could be per-
formed. At Battle Creek, for example, the state health department pould only
spare a dozen sample bottles every two weeks, so it took many months to deter-
mine how many private wells near the public wellfield were also contaminated.
Nassau County, New York was the only county studied with organics analysis
capability. Since more people live in Nassau County than in several states
and since ground water is relied upon almost exclusively for public supplies,
it is not surprising that the County Health Department has had the capacity
not only to handle virtually all the water quality testing, but to revise and
improve several EPA laboratory methods.
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IV-3
All but one of the water systems that turned to private labs for organics
analyses faulted the quality of at least one lab used. Especially in the cases
detected from 1978 to 1980, reproduceability of test results was poor. Analyz-
ing and reporting extremely low concentrations of organics was also a weak
area. Water systems often ended up "shopping around" to find good quality
analytical services at a reasonable cost. Fortunately, laboratories performing
organics analyses have improved over the past several years, and most of the
water systems are satisfied with the quality of recent test results. Split
samples are usually taken as a quality control measure. Sampling procedures
are not regarded as a technical weakness.
Monitoring of water supplies after an incident of contamination has been
discovered is generally not a problem area. Once the municipalities studied
detected the presence of organics in their water, frequent monitoring was
always instituted to maintain water quality. Three factors usually-influenced
the decision to monitor -frequently: the personal responsibilities felt by
water officials, recommendations from the state health agencies, or public
concern over the potential health hazards. '
In the areas of testing, sampling, and monitoring, several needs were
voiced. The first general request was for more funding for equipment and
qualified .personnel. The second set of requests was organized along more
technical lines, summarized in the following points.
A one-time nation-wide program of sampling finished ground water
for organics should be instituted, with priority given to water
systems located near large-scale users of industrial solvents.
Michigan, for .example, has begun a state-wide survey, beginning
with the most vulnerable systems in each district, with sampling
priorities set by the district engineers familiar with local
problems. The national monitoring surveys already performed
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IV-4
should be analyzed to isolate common factors involved in organic
contamination of ground water, so that priority sampling can
begin. .
Several water officials mentioned a need for revised sampling
and testing procedures to include more organics. Current standard
methods'are viewed as time-consuming and expensive, although
generally adequate, but they need to be simultaneously expanded
and streamlined.
The development of a general screening method for organics was
suggested as a valuable tool by the director of the Michigan
Department of Health laboratories arid others.
A frequently heard complaint concerned the reporting of trace
amounts of organics. EPA was requested to standardize a policy
regarding lower detectable limits to avoid reports of "suspected
trace amounts" of a particular contaminant that might not actually
be present, complicating investigative efforts and further
upsetting the public. Reports of organics present below detecta-
ble limits are felt to be unfairly slanted towards implying the
presence of a chemical. Research in this -area must be associated
with the health effects of various organics found in ground water.
The water utilities who -used private laboratories want to see
expanded laboratory certification programs. Even state labs could
often improve.quality assurance programs, although most appeared
to be very conscientious about professional standards.
Sampling procedures were reported as adequate in most cases,
but several officials thought that the "trace amounts" of chemi-
cals occasionally reported from analysis were due to cross-conta-
mination during sampling or to ubiquitous compounds present in
the laboratory.
Other minor problems with sampling, especially the difficulty
in sampling for volatile organics in deep wells, were brought up
as problems, some of. which could be remedied by well design.
Searching for abandoned wells was a problem in about a third of
the cases studied. The potential of abandoned wells as hidden
sources of contamination, as perforations through confining clay
beds, or as additional data sources for aquifer sampling was men-
tioned several times. The basins containing the Lakewood and
Great Oaks water systems, for example, are estimated to contain
over 5,000 and 9,000 wells, respectively, but no one knows the
exact numbers or locations. .
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IV-5
DETERMINATION OF THE EXTENT AND SOURCE OF CONTAMINATION
Several technical topics are addressed under the above heading, including
methods for determining the transport and fate of organic contaminants and
characterizing the hydrological/geological features of the saturated and
unsaturated zones. For purveyors of ground water, these topics are important
in both determining the local extent of contamination (necessary for choosing
locations for new wells) and for planning measures to-prevent the migration of
organics to other production wells. These topics are also critical in tracing
plumes of contaminants back to their sources.
As discussed earlier, most of the utilities studied had difficulties in
outlining the extent of contamination and tracing the source'. The cost of
putting down monitoring wells in some regions is very expensive, limiting the
number of data points available for decision-making. The relative lack of
information on the transport and fate of chemicals in the subsurface also
hindered investigations. Several utilities, such as the towns of Vestal and
Bedford, described their ground-water investigations as "basic" or "textbook,"
but most faced technical and/or budget constraints. In several cases, such as
Lakewood, Petoskey, and Lansdale (North Penn Water Authority), anomalies in
the local geology severely complicated efforts to outline the extent and trace
the source of organics contamination.
The municipalities studied usually had a ground-water consulting firm, or
occasionally the state water quality agency, conduct the actual investigations
to determine the extent and source of contamination, and therefore were not
directly involved in the technical aspects. Several general areas where the
utilities or their consultants did request more research and information are
summarized in the following points.
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IV-6
The most frequent request for research was on the transport,
detention, and degradation properties of various organic chemicals
in both the saturated and unsaturated zones. Existing information
is, at best, fragmentary, and predictions of the mobility and
transformation of organic contaminants in ground water are not
nearly as accurate as predictions for inorganic compounds.
Of .particular interest are the degradation products, in indus-
trial processes and subsurface, of ubiquitious organics such as
trichloroethylene and trichloroethane. Ground-water investigators
have a definite need for data relating organic compounds found in
low or trace concentrations to those found at higher concentra-
tions, especially to-confirm or deny conjectures that only one
source of contamination is involved.
Several ground-water specialists stressed a need to design sub-
surface sampling investigations around predictive ground-water
flow and transport models, rather than to apply models to existing
data. The consultants interviewed claimed they occasionally used
in-house models, but the time and expense involved in verifying
the predictive capabilities of most models were often better spent
on pump tests and other forms of data collection. No state agen-
cies involved in determining the extent and source of contaminants
in ground water reported using models to predict the behavior of
pollutants in ground water.
Both the parties conducting contamination source investigations
and the suspected contaminators asked for the development of
standard methods for monitoring well placement and sampling to
support or deny charges of polluting an aquifer. "Standard,
accepted practices" are required for credible data when munici-
palities have to go to court to recover damages from alleged
sources.
The capability to conclusively identify a compound found in
ground water as emanating from a particular source, by some type
of "chemical finger-printing" method, was one area of R&D
requested by a few organizations. No one knew much about the
technology, but most thought it would save investigative and
legal time and money, especially in cases such as the Tucson
Airport problem, where more than one source is now suspected.
ENGINEERING CONTROL TECHNOLOGIES
Although only one of the water utilities studied had implemented a"full-
scale treatment plant, most officials agreed that engineering control techno-
logies were fairly well advanced. In all the cases studied, treatment to
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IV-7
remove organic compounds from drinking water was at,least considered, and one
or two systems may yet install treatment plants. B,etween, the consulting
engineers and the lead agency handling each case, enough basic technical infor-
mation was usually available. These sources credited EPA for performing some
very useful research in the field.
By coincidence, at two of the cases studied EPA pilot projects are being
conducted. At Glen Cove, New York, pilot studies are being conducted at one
contaminated well to compare removal efficiences of resin and granular acti-
vated carbon adsorption and air-stripping techniques. Work is also .being
carried out to test regeneration methods and the effectiveness of regenerated
adsorption media. At the North Penn Water Authority in Lansdale, Pennsylvania,
a pilot study of in-well aeration techniques is in progress. The potential of
this technology was discovered when samples of organic-contaminated water were
air-lifted out of wells and found to have reduced levels of volatile organics.
Three types of comments were received about the state of research on engi-
neering control technologies. The first was a request for updated cost infor-
mation and the publication of more technical data on the major.methods of
removing organic solvents, mainly granular activated carbon (GAG) adsorption
and packed-tower aeration processes. The second request was for more field
work and demonstration projects on the techniques already proved in the
laboratory. This type of research is necessary to provide design information,
costing, and actual removal efficiencies under field conditions.
The third research-related request was for a decision on the levels of
contaminants allowable in drinking water so that design specifications can be
set. Engineers are afraid of under- or over-designing-treatment plants, in
the face of uncertainties about what level of organics removal must be
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IV-8
obtained to meet health standards. This belief is certainly one reason why
more water treatment systems have not been installed. The only beneficiaries
of this -uncertainty are lessors of temporary treatment systems.
To reiterate, local and state water officials feel that engineering control
technologies have been fairly well proven and only require updated process
costs and some field demonstrations. The majority of water system operators
contemplating treatment are leaning towards some type of packed-tower air-
stripping to remove volatile organic compounds. One significant problem is
the lack of solid standards or guidelines for organics, which hinder design
specifications. Overall, better dissemination of information on technical
research and on the GAG and aeration systems currently in use is needed.
AQUIFER MANAGEMENT TECHNOLOGIES
Several technical areas, categorized here as "aquifer management technolo-
gies" and separate from the treatment methods generally referred to as engi-
neering control technologies, were also discussed by the officials contacted
in the cases studies. Some type of aquifer management was considered in about
one third of the cases studied. The technologies discussed here deal with
aquifer rehabilitation or with shifting the plume or zone of contamination.
Aquifer rehabilitation, including restoration of both the saturated and
unsaturated zones, involves two technologies: either in-situ or surface treat-
ment of the contaminated water and purging the unsaturated area of contamina-
tion, combined with removal of the source of contamination. This type of
remedial action, although expensive, is sometimes necessary. The third techno-
logy under this category involves designing pumping patterns or injection
strategies to keep the contaminant plume away from production wells. In most
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IV -9
of the cases studied, the water utility pumped contaminated wells to'waste to
keep brganics from migrating to uncontaminated wells. " ..-....' ?:. :.--..
A definite need exists for research on aquifer rehabilitation"' technologies.
At ten of the sites studied, production wells are or were being pumped to- waste
(only three water,systems or industries treated the contaminated water before
discharge), but no plans for reinjection have been approved^ and no'work has
been planned 'to purge the unsaturated zone. The present literature reflects
only a recent interest in this' country in restoring water" quality in the'
aquifer, so specific needs cannot be 'easily addressed. Frbrrf'ther c'ases-studied,
only the general need for more research'on this' topic' can !be reported.' A major
reclamation project, however, is being planned at the Tucson Airport site that
should provide useful data. ' ' ' '>' ' .: ..,;. .:/. .. . -.,- .._ < -
As mentioned, two-thirds of the systems-studied" decided'to pump contami-
nated production or mentoring wells to wa'ste, usually to prevent 'migrataon of
the contaminant plume rather than to restore the aquifer'.- -''Plans to reinject
treated water were considered at four or five sites, but rej'ected by EPA or
the lead agency because of the fear of altering aquifer flow patterns'-and fur-
ther dispersing the contaminant plume. 'At Battle Creek a s;tudy'by USGS'
investigated the possibility of injecting water between the'city's well field
and the source of contamination to create a mounding effect to prevent :further
migration of contaminants toward the-well field; '.''
In summary, although decisions to pump contaminated wells"to waste are
rarely controversial since current practices are not'being changed- the-7 tied-
sions are often made after considerable'delay'and without sufficient informa-
tion. Few experts seem to have enough confidence in injection and'monitoring
techniques to reinject treated water. Enough interest has been expressed,
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IV-10
however, by the states and municipalities to justify increasing research on
aquifer management technologies beyond hazardous waste site cleanup and preven-
tion. Information on the costs of aquifer rehabilitation techniques relative
to other alternatives for restoring water supplies is especially needed.
HEALTH EFFECTS
More than any other area, health effects research was unanimously suggested
as the topic on which municipalities, states, and the Regions most desperately
need EPA assistance. Only the federal government, and possibly a few states,
have the capability to carry out the toxicity and carcinogenicity studies
required to provide the data for determining the relative hazards of various
contaminants at different levels of concentration. In making decisions about
ground water quality solely to protect public health, optimum choices simply
.cannot be made if the major criterion, is unknown.
First and foremost, water agencies need more information on the acute and
chronic health effects of the most common organic contaminants. Realizing that
some of this research is completed or in progress, the next need that must be
met is reporting the results on two levels. The major effort at distributing
health effects information should be concentrated on the usual technical
reports intended for scientists and health specialists to assist in their deci-
sion-making responsibilities. The second level of reported results needs to
be in a version that the general public can understand. The misinformation
and misconceptions common to most of the cases studied created many difficul-
ties for local officials who often were not able to explain to citizens what
the health effects of drinking contaminated water might be. In support of
regulatory development and to assist officials in the field, the completion of
-------
IV-11
health, effects research, especially on the organics"prevalent in ground water,
is essential. The need;to then provide understandable .information to the
public must be emphasized:' < ./ . . , ; ;-> ; ,-, -, ,
A somewhat surprising finding of'-this' study-is that'.the majority of .the
dozens of local and state water quality and health officials interviewed1were
in favor of nation-wide standards for the volatile organic compounds most fre-
quently encountered. In a dramatic turnabout since the proposal "'of .maxoLmum
contaminant levels for trihalom'ethanes, almost all those/involved in the case
studies favored standards for organics, for: several reasons. 'The two reasons
heard most often were to protect the' public'health as much' as possible, and to
finally be able to supply-'water designated as ''safe", by the^federal.government,
for the comfort-of water officials and especially to.'satisfy the public's
concerns. -.-.'iis- ....;.v; ...,. ,; ;..... ' , ( .-.... -.-;; t.,: ,..,-...
In about half of the cases studied, the existing SNARLs;-by. EPA- or the
estimated increased carcinogenic risk levels determined by. MAS were not under-
stood. The difference between the SNARLs and risk level numbers was one-of
the problems: many systems did not differentiate between the two .sets o,f num-
bers proposed for several organics, and even used them, interchangeably. In
the New Jersey cases, a wide, range of "health numbers"-were recommended to
different municipalities. In the-Elkhart,! case, every agency invoIved had their
own number, each of which had been published somewhere, for. .allowable .levels
of trichloroethylene in drinking water., It is. imperative that a .consistent
policy for carcinogenic risk assessment-be.developed -and that a consistent set
of health advisories on the most common organics be issued under this,policy.
Whether nation-wide maximum contaminant,levels (MCLs) are issued for
organic compounds in drinking water or not, recommended maximum contaminant
-------
IV-12
levels (RMCLs) and supporting Wealth effects information are necessary for
municipalities to plan a response to organic contamination in ground-water
supplies and for the states to provide a basis for regulatory decisions. The
fact that the need for consistent health effects information was the highest
priority request in the cases studied in this report must be underscored.
OTHER NEEDS
Across the technical areas discussed above, several general requests were
made related to EPA research and development. The three broad areas where
assistance would be helpful were in reducing the costs of dealing with organics
in ground water, disseminating more technical information, and in providing
more trained expertise. Advances in these general areas would improve overall
response to the ground-water contamination problem.
First of all, cheaper analytical methods, less costly drilling and moni-
toring techniques, and more efficient and economic treatment technologies are
items that everyone in the ground-water field would, of course, like to see.
The need for cheaper, more efficient methods is hard to dispute.
Equally important and more easily attainable is the goal of improving the
transfer of technical information. The major sources of technical information
on topics related to ground-water contamination, for the municipal water
systems studied, were the state health and environmental agencies, EPA program
staff, ground-water consultants, and technical journals and conferences. No
water officials contacted mentioned the EPA Clearinghouse for Ground Water
Models or the Ground Water Information Center as sources used for information.
One of the primary sources in EPA of technical and health effects information
was through the Office of Drinking Water's Criteria and Standards Division,
-------
IV-13
which was found helpful in several of the cases. Several ground-water consult-
ing firms have organized successful conferences to educate state and local
personnel about methods of detecting, monitoring, and resolving problems with
contamination of ground-water supplies. This type of conference seems highly
valuable, and EPA should consider supporting similar programs. However it is
accomplished, improving the transfer of technical information should be a high
priority.
Especially in the state agencies and Regional offices, the lack of quali-
fied personnel was identified as a common problem. The few-toxicologists and
hydrogeolegists employed by the health, water, and environmental agencies are -
spread very thinly. Where laboratory facilities for organics analysis are
available, qualified technicians often are not available, or are severely over-
loaded due to the drastic recent increases in sampling. Traditional engineer-
ing training in water and waste water treatment is proving to be insufficient
as new health hazards (carcinogens) are turning up in water sources formerly
considered pristine. Some type of updated training in the skills required to
deal with ground-water contamination would be an interim solution to a problem
that over time must be addressed on a broader scale.
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-------
V. CONCLUSIONS
The majority of effort in this .study was concentrated.,,qn .gathering, infor-
mation for detailed, studies of ground-water,,contamination cases. .The full
case studies should be a valuable resource for those, setting research,and pro-
gram priorities in the field of ground water. An analysis of; characteristics
,. common to most of the cases .provides insights about pptenfia^, £rends ;-in ground-
. . water .contamination.. ,.,,.,,,... ,.. .« ,--., .,...,
- ' - - ' - .'...-.. ..-,. ..:.....) .:,-. - ...,-..t..-4 .;.,'.>,.
Organic solvents were, by far, the most frequently, discovered contaminants,
, with trichloroethylene reported as the mos.t ubiquitous, organic, c.pmpoun'd . .
detected, appearing in eighty percent of the cases,,^TrichJLpro.et^y.lene is becom-
ing the indicator compound for monitoring and treating^organics j.n drinking
water. State, monitoring .programs and.testing initiated,by suspicions of con-
tamination from likely, sites, originally., led to., the, detection- of .the contami-
nants in the majority of contamination incidents studied,, .but ferity percent of
the ca^es were discovered accidentally or while .Resting for. trihalgmethanes.
In terms of Identifying high-priority sites, privatei .andj military aerospace
industries and airports were most frequently assppiate.d with ^organic ^contami-
nation incidents, followed, by landfills, and che.mical waste,handlers,,.rrelectronic
companies, and plating industries.. , Specific-.point-'Sources were u.sual.ly above
ground or ,buried solvent tanks, solvent baths,.or old,disposal.wells.or dump
areas. : .... ... ........ ; , . ... ,
The case studies explain, in detail, the specific,actions taken in
response to the detection of organic chemicals in drinking .water.supplies.
Overall, most municipalities responded.fairly .well .to the, si-feuation,: ^d no
-------
V-2
major mistakes were made, but some problems were common. The most frequently
encountered problem was a lack of understandable information on the health
effects of the organic compounds detected. Decisions on water supply alterna-
tives and treatment options were very difficult to make without solid health
guidelines, so most systems simply closed the contaminated wells and looked
for new wells.
The second part of this study focussed on the research needs of states and
municipalities confronted with organic chemical contamination of ground-water
supplies. The research needs discussed by the water, environmental, and health
agencies were usually very general, but a few deficiencies in technical infor-
mation were commonly mentioned.
By far, the major obstacle in choosing alternative responses to the problem
of organics in ground water was the paucity of health effects information and
guidelines. Requests for increased research and dissemination of information
on the health effects of common organic compounds were virtually unanimous.
Testing, sampling, and monitoring were technical areas with fewer weaknesses.
Engineering control technologies for removing organics from drinking water were
considered to be fairly well advanced, although more field demonstrations wore
requested. Aquifer management techniques also need more refinement before
rehabilitation of aquifers will be commonly accepted. Few specific research
needs other than those discussed above were mentioned by the state and
municipal officials contacted.
Finally, the in-depth case studies, data on incidents of ground-water con-
tamination, and source lists of the persons contacted at the many agencies
involved in these cases provide a firm basis for further investigations. This
report is intended to provide insights about the common problems and research
-------
V-3
needs of states and municipalities dealing with ground-water contamination.
As Such, it presents the necessary information to examine particular aspects
of the problem in greater'detail.
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-------
APPENDICES
APPENDIX A: Initial Survey Results
APPENDIX B: Sample Interview.Questions
APPENDIX C: Complete Case Studies
Bedford, MA
Rockaway Township, NJ
South Brunswick, NJ
Garden City Park, NY
Glen Cove, NY
Vestal, NY
North Penn Water Authority, Lansdale, PA
Vero Beach, FL
Elkhart, IN
Battle Creek, MI
New Brighton, MN
Tucson, AZ
Great Oaks Water Company, San Jose, CA
Lakewood, WA
APPENDIX D: List of Contacts for Each Case
-------
-------
APPENDIX A'
INITIAL SURVEY RESULTS
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APPENDIX B
SAMPLE SURVEY QUESTIONS
A. GENERAL INFORMATION ABOUT CONTAMINATION PROBLEM
1. When was contamination discovered?
2. What contaminant levels are involved?
3. What is the likely source of contamination?
4. How extensive is ground-water contamination?
5. How many wells are currently or potentially affected?
6. What has been/is being done?
7. What was the chronology of' events and who has been involved?
Water utility
Municipal government
County health department
State health department
State EPA
Regional EPA
Industry
Consultants
-------
B-2
B. GENERAL INFORMATION ABOUT THE WATER SYSTEM
1. How many persons are served by the water system?
2. Is the system public or private?
3. What percent of supply is from ground water?
4. What treatment methods are used?
5. How many wells, what capacity?
6. What are total production capacity, average production, peak demand?
-------
B-3
C. DETECTION OF ORGANiCS
.1. How was the problem originally discovered?
2. When was the problem first suspected?
3: Who initiated testing for organics?
4. When was contamination by organics confirmed?
5. What organics were tested for?
6. What organics were detected, in what concentration, in how many wells?
7. How long might problem have existed?
8.. Are any other problems suspected?
9. Might nearby untested sites also be contaminated?
10. How much did testing cost?
11. Who bore the costs?
12. Did the required expense delay the decision to test?
13. Who performed the tests?
X
14. How were they selected?
15. Were the service, turn-around time, test quality, and reports
satisfactory?
16. How confident are you of the results?
-------
B-4
C. DETECTION OF ORGANICS (Continued) . ; ,
17. What local, state or regional organizations were involved in
detecting organics in the ground water, and what roles did they play?
18. Did any industry representatives or consultants become involved?
19. What action was initiated on the basis of test results?
20. What organizations were notified?
21. Was the public notified? How?
22.
Would better technical information, equipment, or training have been
helpful?
23.
In retrospect, what were the major problems in detecting organic
contamination? . . "
24. General comments.
-------
BrS
D. EVALUATING SCOPE OF CONTAMINATION PROBLEM- .
1. What actions were taken to determine the scope of the problem?
2. What testing or monitoring programs were considered?
3. If such programs were set up, give details on frequency, location,
etc. .
4. How far is the source of contamination from affected wells?
5. What is the soil type?
6. Do you have any indication that the contamination is spreading?
7. What is. the depth and areal extent of the aquifer?
8. How long has the source been contaminating ground water?
9. Are other wells threatened?
10. What other waste dumps, landfills, or industrial sites are nearby?
11. Do you expect any more of the same or other contamination to occur in
the future?
12. Who was contacted for assistance in this stage?
13. Who had responsibility for this stage?
14. .What local, state, or regional organizations became involved in
evaluating the scope of the contamination problem, and what roles did
they play?
-------
B-6
D. EVALUATING SCOPE OF CONTAMINATION PROBLEM (-Continued)
15. Did any industry representatives or consultants become involved?
16. What did follow-up testing and/or monitoring and/or other actions
cost?
17. Who bore the costs? . .
18. Did you feel sufficiently informed as to what to look for?
19. Were testing techniques, equipment, technical expertise, timing, or
costs constraints at this stage?
20. Was the public involved in evaluating the scope of contamination?
How?
21. Were government officials involved? How?
22. Do you feel the scope of the contamination problem was adequately
determined? With what certainty?
23. General comments. .. ''
-------
B-7
E. RESPONSE TO PROBLEM
1, What action was finally taken? -; -" -
2. What options were considered?
3. What factors seemed important?
\ \
4. What parties were consulted in arriving at a decision?
5. What other state, local, or regional organizations eventually became
involved in responding to the drinking water problem, and what roles
did they play?
6. Did any industry representatives or consultants become involved?
7. What health information was considered?
8. Were SNARLs used in choosing a response?
9. Were they understandable?
10. Did state or.municipality have any applicable regulations or
guidelines?
11.. Would regulations (MCLs) rather than guidelines (SNARLs) be helpful
in deciding on treatment?
12. How were potential changes in regulation considered?
13. Was the time frame of response critical?
14. What was the final cost of resolving the problem?
15. What alternatives for funding were examined?
-------
B-8
E. RESPONSE TO PROBLEM (Continued) .
16. Who bore the costs? , ' , .
17. Were technical expertise, treatment technologies, or information on
health effects constraints to decision-making?
18. Was the public involved in responding to the problem? How?
19. Were government officials involved? How?
20. Are you satisfied with the resolution of the problem?
21. In retrospect, where could more assistance have been helpful?
22. What were the major problems in responding to the problem?
23. General comments.
-------
APPENDIX C
CASE STUDY REPORTS
Case Page
BEDFORD, MASSACHUSETTS C-l
ROCKAWAY TOWNSHIP, NEW JERSEY C-7
SOUTH BRUNSWICK TOWNSHIP, NEW JERSEY C-18
GARDEN CITY PARK WATER DISTRICT, NEW YORK C-24
GLEN COVE, NEW YORK C-32
VESTAL, NEW YORK c-42
NORTH PENNSYLVANIA WATER AUTHORITY, LANSDALE, PA . C-48
VERO BEACH, FLORIDA c-55
ELKHART, INDIANA . c-61
BATTLE CREEK, MICHIGAN .,.. C-70
PETOSKEY, MICHIGAN . . . . : C-81
NEW. BRIGHTON, MINNESOTA '.'... C-88
TUCSON, ARIZONA c-97
GREAT OAKS WATER COMPANY, SAN JOSE, CALIFORNIA C-lll
LAKEWOOD, WASHINGTON c-121
FORMAT FOR CASE STUDY REPORTS
SUMMARY
BACKGROUND INFORMATION
DISCOVERY OF CONTAMINATION PROBLEM
ACTIONS TO PROTECT WATER QUALITY
CURRENT STATUS
INSTITUTIONAL INVOLVEMENT
HEALTH GUIDELINES
CONCLUSIONS
-------
C-ii
ABBREVIATIONS
DBCP: dibromochloropropane
DCE: dichloroethylene
DIPE: diisopropyl ether
GAG: granular activated carbon
MERL: EPA Municipal Environmental Research Laoratory
MTBE: methyl tertiary butyl ether
NAS: National Academy of Science
PCE: tetrachloroethylene
SNARL: "Suggested No Adverse Reaction Level"
TCA: trichloroethane
TCE: trichloroethylene
VOC: volatile organic compound
UNITS
gpra: gallons per minute
mgd: million gallons per day
mg/1: milligrams per liter
ppb: parts per billion
Vg/1: micrograms per liter (roughly equivalent to ppb)
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CASE STUDY REPORTS
TOWN OF BEDFORD
MASSACHUSETTS
SUMMARY
Over the past several years, the Town of Bedford has experienced a substan-
tial water supply shortage as local growth has surpassed the municipal water
system's capacity. The shortage was seriously compounded when two synthetic
organic compounds were accidentially discovered in the finished water. Four
of nine wells were found to be contaminated with trichloroethylene (500 ppb)
and trichloroethane as well as dioxane (2100 ppb). The State then recommended
closing the wells.
Bedford responded to the crisis in several other ways as well. Water use
bans, changes in water charge rate structure, and purchases of water from
neighboring systems were the short-term measures employed. Efforts directed
toward long-term resolution of the problem included acceleration of an ambit-
ious exploration and development program for new wells and investigations into
halting the discharge and leaching of contaminants from the industrial source.
Bedford is currently testing new wells but still will not be able to meet water
demands for several years.
BACKGROUND
The Town of Bedford supplies water to a residential population of approxi-
mately 11,000 residents and a total employment population of about 24,000.
Bedford's water comes from two sources: indigenous wells and external connec-
tions. Nine wells supplied about 75 percent of the town's water requirements,
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with the balance purchased from neighboring systems. Unfortunately, the four
wells that became contaminated with volatile organic chemicals provided almost
two-thirds of the indigenous supply. Average daily demands are about 1,75 MGD,
with correspondingly higher summer peaks.
DISCOVERY OF THE CONTAMINATION PROBLEM
The discovery of organic chemicals in Bedford's drinking water was com-
pletely accidental. In May 1978, an engineer who lived in Bedford tested his
water as preparation for a paper he was writing. Relatively high levels of
organics showed up in his test, so he called town officials. When the town
became aware of the problem, officials closed the wells and notified the state
Department of Environmental Quality Engineering (DEQE). DEQE tested the water
to confirm the presence of organics and agreed with the decision to close the
wells on June 2, 1978. Besides 500 ppb of trichloroethylene and 2100 ppb
dioxane, the DEQE analysis showed that dichloroethane, bromodichloromethane,
and traces of chloroform were present in four of Bedford's nine wells.
ACTIONS TO PROTECT WATER QUALITY
Massachusetts generally follows the EPA SNARLs for allowable levels of
organic contaminants in drinking water supplies. When dioxane was found, DEQE
called EPA for more information. EPA suggested a maximum contaminant level of
20 ppb for dioxane. Based on the guidelines, DEQE and the Board of Health
recommended closing well Nos. 3, 7, 8, and 9.
Besides closing the contaminated wells, Bedford took several other measures
to combat the problem. To reduce water consumption the town instituted water
bans such as those used previously during summer months. Bedford also changed
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the price structure for drinking water from, a flat rate to an ascending block
rate, which discourages use. -
To meet existing water demands Bedford made arrangements to purchase water
from several neighboring interconnected water systems. This solution is only
temporary because purchasing the water at retail is quite expensive ($1,400-
1,600/day) and several of the neighboring systems are experiencing water
quality problems themselves. ,
The Town of Bedford expects to spend $3 to 4 million on an exploration and
resource development program .to replace and expand the municipal water supply.
Another $1.2 million is expected to be spent on treatment and filtration to
remove iron and manganese. The long-term plan must now provide about 1 MGD to
meet current restricted demands and may have to provide, as much as another 4
MGD to meet expected 1990 demands. A study by Bedford's consulting engineers
has identified several potential sites for new wells. The two most promising
sites may provide enough water for short-term demands, but high levels of iron
and manganese have required expensive treatment technologies. The search for
new water supplies is continuing.
In the fall of 1978, Bedford contracted with a consulting firm, Camp,
Dresser, and McKee (COM), to determine the extent and magnitude of aquifer con-
tamination, pinpoint the source(s), and outline actions the town.could take.
Several of the industries suspected of causing the contamination also hired
their own consultants.
The COM report, which cost Bedford $130,000, recommended three general
courses of action: a-program to flush the..aquifer, investigations into treat-
ment methods, and development of alternative water supplies. A plan to pump
three contaminated wells to waste in the Shawsheen River was eventually
approved by the Massachusetts Department of Environmental Quality Engineering
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and EPA, but pumping has not yet started. Treatment methods to control the
levels of organics in drinking water have not been extensively investigated.
Developing alternative water supplies has been made a high priority, and a
major program in that area is continuing, as discussed previously.
Efforts to pinpoint the source('s) and define the extent of contamination
have had mixed results. The town and DEQE have been successful in isolating
several point sources. Programs of test well drilling and sampling have pro-
vided information to develop subsurface descriptions of lenses of contamina-
tion associated with various industrial sites. The source of dioxane was not
difficult to trace since only one firm in the watershed used the chemical. In
most cases, actions to prevent further contamination and continued monitoring
have generally been adopted, and litigation has been undertaken by the town
against the alleged contaminating companies to assign legal responsibility for
remedial measures. In a few other cases, multiple sources have confused the
situation and emphasized the vulnerability of the aquifer to accidental contam-
ination.
CURRENT STATUS
At present, Bedford is still involved in litigation against an allegea con-
taminator. The affected wells remain closed. A NPDES permit was received to
pump contaminated water to the Shawsheen River, but pumping operations have
not yet begun. The Shawsheen River well field has been rehabilitated to clean
out iron and manganese deposits, bringing the wells back up to original capac-
ity. At the Concord River site, three new wells have been drilled, but the
treatment plant to remove exessive levels of iron and manganese has not.been
completed.
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INSTITUTIONAL INVOLVEMENT
The Massachusetts Department of Environmental Quality Engineering, the
agency with primacy over drinking water in the state has been the nominal lead
agency in the Bedford case. DEQE has a good staff of hydrologists, geologists,
and engineers supplemented by a toxicologist and an analytical laboratory. A
recently approved bond issue has given DEQE $10 million for funding investiga-
tions and remedial actions at contamination sites. Financially, the state is
now very well equipped to deal with organics problems.
The Town of Bedford has also been very active in the contamination case,
assisting in the preliminary industrial survey and contracting with COM to
trace the sources of the volatile organics and dioxane. According to the
state, the Bedford case was fairly straightforward, but the town's budget
constraints hindered efforts to find and control the sources.
The other major actor in resolving Bedford's organics contamination prob-
lem was Camp, Dresser, and McKee, the town's water consultants. The only real
difficulty COM had during their sampling and monitoring well program was with
inconsistent analytical results from various labs. This situation changed as
the labs improved quality control, although some analytical testing was shifted
to the state labs.
HEALTH GUIDELINES
Although the Massachusetts Department of Health has some jurisdiction over
water systems, the Department of Environmental Quality Engineering has been
awarded primacy for the state's drinking water program and wields the overall
authority. As mentioned above, DEQE usually uses the EPA SNARLs as a basis for
allowable levels of organics in water supplies. At 75 ppb for trichloroethy-
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lene and somewhere between 300 and 1000 for trichloroethane, the SNARLs are
considerably higher than the health guidelines in most states.
A DEQE offical stated, however, that although the state has urged several
water systems to place previously-contaminated wells back into service, no
water utility is willing to take responsibility for pumping even relatively
low levels of organics into the water system. In more than one case, wells
with total organics levels below 10 ppb are still not being used.
CONCLUSIONS
Although the Bedford incident is presently considered to be a relatively
straightforward, basic case, in 1978 it was not viewed as such. At that time,,
few persons had had much experience in dealing with organics in ground water,
and no EPA guidelines were available. Where standard procedures for sampling.,
drilling, and analytical work are now generally accepted, little guidance was
then available. EPA's recommended techniques generally have been considered
as good in terms of quality control and legally-defensible data, but time
consuming.
Several technical and policy areas have remained as weak points. One tech-
nical problem is that while plenty of information was avilable on-trihalomet-
hane and volatile organic removal techniques, COM was unable to find any
methods for removing dioxane from water. Research to develop treatment techni-
ques for various classes of related compounds was suggested as one area where
EPA assistance is critical. Officials indicated there is a need for greater
consistency between regions in terms of acceptable aquifer cleanup techniques,
improved health effects information, and better coordination at the EPA
regional office, where frequent turnovers hindered progress in the Bedford
case.
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ROCKAWAY TOWNSHIP
MORRIS COUNTY, NEW JERSEY
SUMMARY
During their own testing in November 1979, Rockaway Township health offic-
ials discovered trichloroethylene-in the municipal water system. The contam-
ination was traced to one well, which was eventually pumped through aeration
to waste to keep the TCE from spreading to other nearby wells. When other
organics, namely diisopropyl ether and methyl tertiary butyl ether showed up
in the course of increased monitoring at the two remaining wells, a water
emergency was declared. Township officials then obtained an emergency appro-
priation to have carbon adsorption units installed. The adsorption units
removed most of the organics, but the granular activated carbon (GAG) had to
be replaced almost monthly, rather than every six to nine months as originally
estimated. Rockaway Township, therefore, designed and installed a packed
column air stripping unit that removes over ninety percent of the problem
organics. ' ' . - . . .
BACKGROUND
Rockaway Township is located along Interstate Route 80 in Morris County in
North Central North Jersey. The Township has a population of about 20,000
people, most of which is supplied potable water from municipal .water supply
systems. Approximately half of the Township population is served by a ground-
water supply system owned and operated by the Township. The remainder of the
population is served by water suppliers in adjoining municipalities or by indi-
vidual wells. A ban on new septic systems has effectively halted new construc-
tion in 'the Township.
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Rockaway's ground-water supply system consists of three wells, located
about 80 feet from each other as shown in Figure 1. The individual capacities
of the three wells are:
Well No. 4: 350 gpra
Well No. 6: 550 gpm
Well No. 7: 1,000 gpm
When the wells are pumping simultaneously, the combined capacity of the system
is about 2.0 mgd because of head constraints. Each well is approximately 100
to 200 feet deep and taps an unconsolidated, glacial deposit. Historically,
the Township's ground-water supply has exhibited very good quality and required
only disinfection prior to pumping into the distribution system.
DETECTION OF THE CONTAMINATION PROBLEM
In November 1979, trichloroethylene (TCE) was detected in Well Nos. 4 and
6. Township officials initiated the testing because of articles they had read
in professional journals warning of growing problems with synthetic organics in
ground-water supplies. The Health Department consequently sampled the finished
water and sent the samples to their contracting laboratory for a standard VOC
scan. Follow-up samples sent to the EPA labs at Edison, New Jersey confirmed
that both wells had consistently high levels of TCE: 50 to 100 ug/1 in Well
No. 4 and 170 to 220 ug/1 in Well No. 6. Both wells are located at the east
end of the well field, nearest to the suspected source of contamination, which
is about 1,600 feet east of the wells as shown on Figure 1.
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Approximate
Suspected Source
of Ice Contamination
7 /
Figure 1. Location of Rockway Wells.
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The New Jersey ,State Department of Environmental Protection (NJDEP) has
set "action levels" at 50 ppb for a single VOC and 100 ppb for total VOCs.
The New Jersey action levels are the same as those for New York. New York has
probably spent more time and money on investigating the effects of organics in
drinking water than any other state.
Below the action levels, no action is required on the part of the water
system. Above these levels, the system is required only to notify the NJDEP.
If VOC concentrations exceed the action levels, NJDEP will recommend whether
the water supply should be taken out of service, taking into consideration the
size and importance of the potential disruption in relation to the remainder
of a municipality's water supply.
ACTIONS TO PROTECT WATER QUALITY
.Since TCE levels in-Wells Nos. 4 and 6 were considerably higher than the
state's maximum recommended levels, township officials quickly took the two
wells out of service. The Health Department then began looking for the source
of contamination and researching the possible health effects of trichloroethy-
lene. At the same time, officials started inquiries into treatment methods
for removing the TCE.
EPA Region II was contacted for assistance, but was not able to offer much
help. Region II did eventually tell Township officials that the Rockaway con-
tamination problem would be put on the Superfund "Priority List" and therefore
be eligible for financial assistance, but this information was incorrect. The
Township also contacted EPA Region III officials who did provide an explana-
tion of applicable regulations and guidelines and useful information on trich-
loroethylene in drinking water.
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By early 1980, the Health Department had investigated testing laboratories
and had selected one of the less expensive labs to test the samples still being
collected. Continuing tests soon showed that contamination was spreading to
the remaining good well. To keep TCE levels low in Well No. 7y Well No. 6 was
pumped to waste in an adjacent brook, preventing the contaminant plume from
migrating westward. .
By the summer of 1980, water usage restrictions were in place and the
Health Department was engaged in discussions with the suspected industrial
source, a company that used TCE. The source initially suspected-was identi-
fied by the Health Department as about the only company in the Township that
used TCE. The plant site also was upgradient from the Township well field.
In cooperation with NJDEP, the Township convinced the suspect company to drill
five test wells, one of which was on the far side of the plant site from the
wells. This particular well showed the greatest levels of TCE, 'in effect
exonerating the company as the main source and leading the search beyond the
political border of Rockaway Township to another industrial site.
The site currently suspected is a federal facility built in the 1940s.
The federal facility is a factory which reached full production in the 1950s
and 1960s and used,TCE baths to clean parts used in fabricating rocket engines.
Since Rockaway Township has no jurisdiction,outside its political boundaries,
the matter has been turned over to the state for investigation'and enforcement.
Investigations into the source of TCE extended through the summer of 1980.
During this time the Township began to consider alternatives for dealing
with the TCE contamination problem; Three main alternatives were suggested:
drilling a new well in the western portion of the Township;
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purchasing water from the neighboring municipality of Dover; or
treating the contaminated wells.
The first option would have required several years to investigate potential
well sites and install a new well with sufficient capacity and quality. The
second option would have required a contract, possibly a long-term commitment,
to purchase water at a higher price than the Township could supply from their
wells. Interconnecting pipelines and meters would also have had to be con-
structed to implement this option. The treatment options considered included
both aeration and GAG adsorption.
As these alternatives were being considered, the Township began to receive
taste and odor complaints about its drinking water. In October 1980, the TCE
problem was compounded by the discovery of diisopropyl ether (DIPE) and methyl
tertiary butyl ether (MTBE) in Well No. 7 at concentrations of 70 to 100 ug/1
and 25 to 40 ug/1, respectively. The taste and odor threshold concentrations
for these compounds are between 5 and 15 ug/1, explaining the numerous com-
plaints from water customers.
The TCE problem became less important as the Health Department scrambled
to deal with the new crisis. At first, the Township had no idea where the
ethers were coming from. A Shell Oil Company gas station 1,500 feet upgrad-
ient soon became a prime suspect for two reasons. When Health Department
officials noticed a drilling rig onsite, they went to the station to ask why
Shell was drilling. While there, they spoke with police officers who mentioned
that they had staked out the station for several months to apprehend the cul-
prit Shell suspected of stealing 50 gallons of gasoline nightly. After at
least 6,000 gallons were lost, Shell began to suspect that a leaking tank was
the culprit. Shell notified the New Jersey Department of Environmental
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Protection (NJDEP) Spill Control group and began investigative drilling. NJDEP
reportedly failed to notify the Township or the Bureau of Potable Waters'
Groundwater Resource section. . , ,
The Township also had reason to suspect the gas station as the source of
/
the ethers due to some detective work at EPA headquarters. When-the Health
Department, baffled by the appearance of more organic contaminants, called the
head of the Criteria and Standards Division in the Office of Drinking Water
Supply (ODWS), he had his staff perform a literature search on the two
ethers. This effort turned up the fact that the methyl tertiary butyl ether
was a proprietary gasoline additive used only by Shell. Throughout their
efforts .to resolve the various contamination problems^
Township officials have stated that ODWS was extremely responsive.
Shell drilled about fifteen monitoring wells to determine the extent of
aquifer contamination. Faced with their own information and evidence gathered
by the NJDEP Groundwater Monitoring and Enforcement group, Shell-agreed to pay
for the hydrogeological work.
Meanwhile, although little health information on the new contaminants was
available, the Mayor declared a water emergency when the ethers were discovered
and went immediately to the Township Council with the engineering and health
staff for an emergency appropriation of funds to install a treatment system.
At that time residents were advised not to drink the water and were instructed
where to obtain water for drinking. The Township was very' prompt and open in
notifying the public. Health Department staff spent the weekend following the
announcement at a phone bank, answering more than 1,000 calls per day for
several days. .
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The Township had already discussed GAG adsorption with the Calgon Corpora-
tion. When the water emergency was declared, officials had little choice but
to choose a GAG adsorption system as the optimum treatment method for a range
of organics and as the most expedient solution to the problem. After some
negotiations with Calgon, the Township was able to purchase (rather than make
the usual leasing arrangement) a GAG system on very advantageous terms. Within
three weeks, two 20,000 Ib. GAG contactor tanks were installed and the system
was put on line. The system cost was estimated at $200,000.
Based on the TCE levels initially detected in the wells, the carbon was
expected to last six to eight months before regeneration was necessary. After
three months of operation, however, the DIPE concentration in the contactor
effluent was 14 ug/1, MTBE was at 23 ug/1, and TCE was not detected. With the
ethers "saturating" the carbon and breaking through earlier than expected, it
became necessary for the township to replace the carbon every two months,
rather than every six or nine months. By the end of 1981, the carbon was being
replaced at a rate of about once every four to six weeks, at a cost of $32,000
per change. The Township negotiated, with Shell to pay for the carbon.
Because of the replacement expenses due to the quick breakthrough of the
ether compounds, the Township began to investigate aeration techniques as
pretreatment to the GAG adsorption system. Officials at ODWS suggested they
contact the EPA Cincinnati Municipal Environmental Research Laboratory (MERL)
for help in conducting pilot studies. Pilot-scale tests were conducted at the
well site using a packed-column aeration process, and test results indicated
that adequate removal of organics could be achieved using aeration. Shell
sent an engineer to help design a treatment installation and agreed to pay for
an aeration facility. 'Consequently, a packed column was fabricated on
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site and put on line in December 1981 at a reported cost of $375,000 for the
1.7 mgd tower.
CURRENT STATUS
Currently, both aeration and GAG adsorption are used for VOC removal. As
expected, the life of the carbon has been prolonged by reducing the influent
ether levels to the GAG contactors. Removal efficiencies for DIPE have usually
been greater than 99 percent, while about 95 percent of the MTBE and virtually
all of the TCE are removed. At the time of this report (November 1982) the
carbon on line when the aeration system was installed is still in place. The
raw water still is pumped through the packed column to the contactor tanks and
then to the distribution system, but Township and Shell officials feel the
adsorption step is unnecessary at this point and are considering taking the
tanks off. line. . The Township will maintain the capacity to bring carbon
adsorption back on-line quickly in anticipation of the arrival of the major
part of the ether plume.
The cost of service to water customers has increased from $0.27/thousand
gallons to $0.48/thousand gallons with the addition of GAG treatment and
aeration. This figure is estimated to drop to $0.40/thousand gallons after
the well pumps are restaged.
INSTITUTIONAL INVOLVEMENT
The Township Engineer and Rockaway Township Health Department organized
and carried out a response to the contamination problems with the help of
several other agencies. The Township, however, took the lead in dealing with
trichloroethylene and ethers in their drinking water. For a relatively small
body with no previous experience with similar problems, the Health Department
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and others played an extremely active role in researching the situation and
evaluating alternative solutions. Although officials felt they were often in
over their heads and had to operate continually in crisis mode, their
responses were rapid, and little effort was spared to protect public health.
Briefly, the roles taken by other agencies in the Rockaway Township ground
water contamination case were as follows:
U.S. Environmental Protection Agency (EPA). At least four
groups in EPA were involved in the Rockaway Township case.
Region II and Region III were both contacted for assistance, but
Region III was more helpful, even though New Jersey is located in
Region II. The experiences of other regions indicate that this
might simply have been the result of contacting the wrong person
at Region II, or that Region III has had more experience in
dealing with this type of problem since state programs in Region
III are not as established as those of, for example, New York.
The Office of Drinking Water Supply in Washington, and partic-
ularly Dr. Cotruvo, was credited with being very helpful in pro-
viding information on the contaminants detected in the Township's
water. Similarly, researchers at the Municipal Environmental
Research Laboratory were quick to provide technical assistance in
evaluating and testing various organics removal techniques.
New Jersey Department of Environmental Protection (NJDEP).
Three sections of DEP had some involvement in the Rockaway
Township case. Most helpful was the Groundwater Monitoring and
Enforcement group, who came out and helped trace the gasoline
spill. This group's work established the evidence used to prove.
that Shell was unquestionably the source of ethers in Rockaway
water. The State's Bureau of Potable Water followed the Rockaway
Township incident, but did not actually become involved except to
verify one set of test results. The Spill Control group at NJDEP
apparently made a major blunder in not notifying the Township or
state ground water group of the Shell gasoline leak.
New Jersey State Health Department. Rockaway Township
officials stated that the state toxicologist was very helpful in
supplying and interpreting health information. The toxicolo-
gist 's quick response was appreciated since the Township was
under fire to explain the health hazards associated with TCE and
the ethers to the public.
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HEALTH GUIDELINES -
The health guidelines for drinking water quality recommended by the State
of New Jersey (a maximum of 50 ppb of any one organic or 100 ppb of 'totaT
prganics) have already been outlined. The guidelines parallel those drawn up
by the New York State Department of Health. Some other municipalities in New
Jersey have reportedly been given different- recommended "maximum .contaminant
levels, however, so the health guidelines do not appear t6 be: firmly-estab-
lished. .-'.' ''-.." '.-.- i ...
CONCLUSIONS
Rockaway Township officials eventually handled their organics contamination
problem very, well. With a minimum of outside assistance, the Township removed
the immediate health hazard, tracked down the sources of contamination,
designed and installed two treatment systems, -and negotiated ah agreement for
one responsible party to pay for treatment. Health Department'officials
believe that the state and federal agencies should act only as technical and
scientific resources whenever the local government has enough resources to
take the lead.
In agreement with this view point, the local officials feel!that their big-
gest weakness in dealing with .the prganics contamination was a lack of informa-
tion oft health effects. They call for some useful, consistent numbers to guide
them in protecting public health. Township officials believe that testing and
reporting requirements would turn up quite a few local water systems with
organics- levels in the 25-50 ppb range, as well ,as some-wells with over 50 ppb
which have not been tested thus, far because of the desire to avoid the poten-
tial long-term costs of having to... treat contaminated water.
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SOUTH BRUNSWICK TOWNSHIP
MIDDLESEX COUNTY, NEW JERSEY
SUMMARY
The accidental discovery of trichloroethane in a South Brunswick Township
water well in 1977 began one of the first cases of organics contamination in
New Jersey public water supplies. South Brunswick Township Well No. 11, which
supplied one-third of the Water Department's capacity, was closed when tests
showed 400 to 500 ppb of trichloroethane (TCA).
The Township responded by hiring a ground-water consulting firm to trace
the source of contamination. Geraghty & Miller drilled a series of monitoring
wells that traced the contaminant plume towards an IBM plant. When notified,
IBM voluntarily drilled their own wells, installed an air-stripping tower, and
began pumping out the contaminated water. After two summers of dangerously
low water supplies, South Brunswick eventually installed a new well to restores
capacity. The Township also began pumping Well No. 11 to the sewer system and
cut back on nearby pumpage to prevent further migration of the plume. IBM ha,si
reimbursed the Township $1 million for expenses incurred.
BACKGROUND
South Brunswick Township is located in Middlesex County, New Jersey, at
the south end of the New York-Newark-Elizabeth sprawl. When the contamination
incident was discovered, the Township Water Department was supplying water to
about 18,000 persons with three wells. The Township wells are screened from
about 80 to 100 feet and tap the lower, but not completely confined, aquifer.
Average demands are about 2.5 MGD, with summer peaks near 4.25 MGD. Several
heavy manufacturing and chemical industries are located in the Township.
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DISCOVERY OF THE CONTAMINATION PROBLEM ;:i
In September of 1977, the New Jersey-Department of Environmental Protec-
tion XNJDEP) tested South Brunswick's water as part of a state-wide program.
No organics were detected at that time.. In'December, a local-company that had
found trichloroethylene (TCE) in.chlorine gas cylinders it used'warned other
chlorine users to check their supplies. When the South Brunswick-water was
sampled, the analysis confirmed that both finished and raw water had TCE.'
Since this result was highly curious, another, analysis was run that showed
that the organic detected-was actually 400 ppb of trichloroethane (JTCA), not
TCE, and that the chlorine feeder had nothing to do with the newly.Adetected
chemicals.. Levels of tetrachloroethylene near 150 ppb'were, found.later.
ACTIONS TO PROTECT WATER QUALITY
The first step taken by the Township was to close the-contaminated ,well.
Four hundred parts per billion of trichloroethane was riot a borderline case in
terms of health guidelines, so officials acted quickly to remove Well No. 11
from service. A new well at the other end of the township was not completed
until two years later, so South Brunswick experienced;several water crises
during the summers. One of the two remaining wells also went out of service
periodically for repairs, .further complicating matters. Fortunately,, the
Township has 5.5 million gallons of storage (more than a .peak day's demand)
which helped a great deal during the shortage.
The second step taken by the Township was to hire a giroundTwater rconsul-
tant, Geraghty & Miller, Geraghty & Miller performed a two-phase investiga-
tion, including studying potential sources, sampling .existing wells, and
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drilling monitoring wells. The final report indicated that the TCA plume
extended from an IBM facility seven-tenths of a mile to South Brunswick Well
No. 11.
On the basis of this information, the Township went to IBM and negotiated
a plan of action. IBM did more work to define the plume and drilled seven pro-
duction wells off-site to pump out the contaminated water. The point source
on IBM property was found to be a leaking buried tank. Geraghty & Miller
estimated 500 to 1000 gallons of TCA had leaked. About 1 MGD of contaminated
ground water is now being drawn out of the aquifer and pumped through an air-
stripping tower. The treated water is discharged to a ditch or sprayed on a
field to recharge the aquifer. Plans for injection wells are under considera-
tion to recharge the aquifer and create a mounding effect which should halt the
spread of contaminated ground water toward South Brunswick wells.1
One year after the problem was discovered, monitoring wells indicated that:
the plume was mig'rating toward the remaining two South Brunswick wells. Well
No. 11 was reactivated and pumped to the sewage system to halt the spread.
When the new well came on line a year later, the Township switched one of the
original wells to back-up capacity to reduce withdrawals near the contaminated
zone. Well No. 11 is being pumped to waste at 0.85 MGD, which is upsetting
local officials who are sensitive to the fact that their aquifer is threatened
not only by organics and salt water intrusion but also by oversubscription.
CURRENT STATUS
For the short term, at least, the South Brunswick Township Water Department
is in a relatively comfortable position. With the new well, they have ample
capacity even if a third of their supply is lost. Moreover, as a result of
various ground-water investigations, there are now almost 300 monitoring wells
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in the Township, about one per acre. This measure of security and the "early-
warning" wells drilled by IBM around the South Brunswick production wells have
taken the pressure off the Township. IBM has also followed through on their
"good-neighbor" policy and reimbursed South Brunswick for roughly $1 million.
Besides the multi-million dollar five-year abatement program at the South
Brunswick facility, IBM put in monitoring wells at all their manufacturing
facilities nationwide. Several other problem sites were discovered.. IBM has
a highly-trained crew assigned to work on contamination incidents, and a South
Brunswick officials says that IBM now has the best analytical laboratory in
the State of New Jersey.
Another industrial source was discovered, during the ground-water investiga-
tions in South Brunswick. A contaminated plume from this source was heading
for Well No. 12. The industry, Mideast Aluminum, put in their own monitoring
wells and eventually began pumping out the contaminated water and running it
through aeration. The plume has retreated and now is confined under the plant.
Although the immediate supply problems have been resolved, the long-term
security of the South Brunswick water supply remains uncertain due to potential
contamination from unknown sites, salt water intrusion, and over-subscription.
INSTITUTIONAL INVOLVEMENT
Five years ago, even in New Jersey, water authorities had not had much
experience with organic chemicals in ground-water supplies. Since the discov-
ery of the South Brunswick case, much knowledge has been gained about organic
contamination of drinking water, but the first few cases were definitely learn-
ing experiences.
South Brunswick Township handled the situation well, especially in negoti-
ating with IBM rather than threatening legal action. Township officials empha-
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C-22
sized the fact that cooperative efforts were much more productive than antagon-
istic efforts. Fortunately, the Township was able to bear the financial burden
until reimbursed by IBM.
IBM, in this case as in others cooperated completely with efforts to solve
the contamination problem, although they never .actually admitted complicity in
the contamination problem. Their nation-wide program to investigate ground-
water contamination associated with their manufacturing operations is an
example to other chemical users and producers.
»
The New Jersey Department of Environmental Protection (NJDEP) did not pro-
vide any financial assistance to South Brunswick, but did offer help with any
litigation the Township should undertake. The state geologist was very help-
ful in advising on hydrogeologic investigations. The local Board of Health
never really became involved.
EPA provided some technical assistance to the Township. Cincinnati Labor-'
atory personnel set up their portable pilot plant at the contaminated South
Brunswick well. Several treatment technologies, including granular activated
carbon and resin adsorption as well as aeration, were demonstrated.
HEALTH GUIDELINES
The New Jersey Department of Environmental Protection set a recommended
maximum of 33 ppb for trichloroethane in South Brunswick drinking water. The
source of this number remains a mystery, especially since neighboring Rocky
Hill was told that 100 ppb was acceptable and since 50 ppb of any single
organic was suggested to Rockaway Township. Standard State of New Jersey
policy limits any single organic to 50 ppb and total organics to 100 ppb.
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C-23
CONCLUSIONS
The cooperation between IBM and the township has led to a satisfactory
solution to the problem of contaminated ground water. The threat to public
health was removed soon after it was discovered, a new water source was
located, and efforts continue to clean up the aquifer. The Township is content
with the resolution of the problem and now has quite a few defenses to warn of
\
future contamination incidents.
Township officials maintain that their biggest problem in the TCA case was
with testing. For quite a while they could riot find three labs to agree on
the contents of the same sample. This situation has improved greatly since
1977.
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C-24
GARDEN CITY PARK WATER DISTRICT,
NEW YORK
SUMMARY
The Garden City Park Water District was notified by the Nassau County
Health Department in late 1977 that tetrachloroethylene had been found in the
water supply. One well was closed in November of that year when two successive
tests showed contaminant levels of 76 and 84 ug/1. Since one-fourth of the
water system was already restricted due to excessive levels of nitrates, the
tetrachloroethylene problem became very serious when two more wells had to be
closed in April and June of 1981. As short-term measures, the Water District
purchased water from neighboring systems and imposed sprinkling restrictions.
Conservation efforts and the addition of a new well allowed Garden City Park
to operate through the summer of 1982 without purchasing water. Plans to blend
water from different wells to allowable nitrate levels and to start a pilot
plant for organic removal testing have been approved by the Health Department
to restore short-term capacity, but long-term plans to meet water demands are
uncertain.
BACKGROUND
The Garden City Park Water District serves a population of about 24,000 in
a three mile square area located in the southwestern portion of the Town of
North Hempstead, Nassau County, New York. Formerly a dairy-farming region,
the service area is now largely residential, with some light industry and
commercial establishments. The Water District is served by the Nassau County
public sewer system.
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C-25
At the time the organic problem was discovered, the Water District had nine
Wells scattered throughout the service area. A new well came on line in early
1982. All wells but Nos. 1 and 2 pump directly into the distribution system
after chlorination and treatment with caustic soda. Well No. 6 also has poly-
phosphate added. Well No. 9 is equipped with a nitrate treatment plant con-
sisting of an ion exchange resin bed which is continuously regenerated through
a closed loop, using salt as the regenerate. Mechanical problems have kept the
equipment out of service several times. Waste brine and rinse water are dis-
charged to the county sewer system, a procedure approved by special permit.
Because of high operating costs, this well is used only during peak periods.
Total well capacity was about 14.5 mgd before the organics problem was dis-
covered, with over a third of that restricted due to nitrates. The Water Dis-
trict operates 2.5 million gallons of elevated storage to handle peak demands.
Peak summer demands are near 6.4 mgd, with average winter demands only 2.2 mgd.
DISCOVERY OF THE CONTAMINATION PROBLEM
Between 1975 and 1977, the US EPA conducted surveys to characterize the
organic chemical contamination of the nations' drinking water systems. Alerted
by the preliminary reports on these surveys and the discovery of contaminated
wells near the Grumman Aerospace Corporation facility in Bethpage, the New York
State Department of'Health organized a cooperative effort with Nassau County
officials to sample and analyze water from community wells. Beginning in 1976,
wells were tested for six synthetic organic chemicals: 1,1,2-trichloroethy-
lene, trifluorotrichloroethane, tetrachloroethylene, chloroform, carbon tetra-
chloride, and 1,1,1-trichloroethane. By the end of April 1978, 372 community
water system wells had been tested: tetrachloroethylene and 1,1,2-trichloro-
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C-26
ethylene were found in 15 percent and 13 percent, respectively, of those
sampled.
' Tetrachloroethylene was found in Garden City Park Water District's Well No.
5 in November 1977 during the initial testing program. State Health Depart-
ment guidelines limit any single organic contaminant to 50 ug/1, and total con-
taminants to 100 ug/1. Concentrations of 76 and 84 ug/1 were detected, so the
Water District complied with Nassau County's request to remove the well from
service. The Nassau County Health Department (NCHD) requires annual testing
for the six compounds .listed in the paragraph above and requires notification
if the individual maximum contaminant levels (50 ug/1) are exceeded. Testing
at Garden City Park in 1981 showed levels of tetrachloroethylene over 50 ug/1
in well No. 4. £fter well No. 4 was taken out of service, levels of tetra-
chloroethylene in nearby well No. 6 climbed rapidly until that well also had
to be closed. One set of tests was performed by the NCHD, and the other by
the Water District's consultants, Holzmacher, McLendon, & Murrell, P.C.
(H2M). After these wells were closed, the Water District was left with only
3,680 gpm of unrestricted capacity, only about three-quarters of the capacity
necessary for a peak day, even at 100% operation.
ACTIONS TO PROTECT WATER QUALITY
The immediate action taken by the Water District to protect their customers
from the health hazards of contaminated water was in all cases to close the
wells classified as "restricted". The Nassau County Health Department has
drawn up a comprehensive "Policy Statement on Use of Public Supply Wells Con-
taminated by Organic Chemicals" that explains testing, monitoring and reporting
requirements and water quality guidelines. Details of this document are dis-
cussed in the Glen Cove case study.
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C-27
The Water Districts' consulting engineers, H2M, have made several sugges-
tions for improving both the short-terra and long-term available supply. The
short-term options proposed relate principally to blending well water of
acceptable quality with well water which exceeds standards to deliver a product
water to the distribution network that meets the applicable standards or guide-
lines. The County has approved the blending technique for reducing nitrate
levels, and a project to blend wells 1 and 2 into the 1.5 million gallon tank
at the well site is nearing completion. The County has restated its opposition
to blending to reduce organic levels, taking the position that there is no
"safe" level of a carcinogen in a water supply and proposing conservation mea-
sures and the purchase of water before organic-contaminated water is used for
drinking. In 1981, the Water District purchased 142 million gallons from the
neighboring'Albertson Water District, one of six interconnected systems.
H2M has "also suggested several long-term programsto remedy the curtailed
supply of water, -agreeing that expected growth in consumption as well as cur-
rent demands must be met. The consultants approach the long term objectives
in two ways: installing a new water supply, or treating water at an existing
well(s). The Health Department has urged Garden City Park to "vigorously pur-
sue selection of a site for a new well", but recognizes the lack of an ideal
location for a new well. Any new wells would have to be drilled in the north
end of the Water District to avoid the contamination problems apparent in wells
in other locations. Tapping a different aquifer may provide a solution. The
minimum short-term resolution to the water supply shortage was estimated by
H2M to cost $355,000, with the full program to increase supply estimated at
$1,530,000.
With nitrate levels apparently declining and organic levels increasing,
H2M suggests that treatment methods should focus on organics removal. They
-------
C-28
mention that carbon adsorption, synthetic resin adsorption, and air stripping
have been used to control tetrachloroethylene, and propose a countercurrent
packed tower air stripper as the most cost-effective technology. The Health
Department agreed with H2M that Garden City Park should set up a pilot plant
at Well No. 6 to test removal efficiences and to develop design parameters for
that well and another potential site. H2M has decided that they have enough
technical information.to design and install a packed tower air-stripping plant
without setting up a pilot plant, and plan a 1200 gpm (1.7 mgd) installation
at well No. 6.
The restored capacity from Well No. 6 should meet short-term needs but not
long-term demands. The Water District has contracted with a private firm,
Ecolotrol, to plan a pilot biological denitrification plant on Well No. 1 or
2. The Water District believes that enough of the organics might be removed
by the plant to meet both the nitrate standard and the tetrachloroethylene
guideline. If so, a 2.5 mgd biological denitrification plant may be installed
to meet long-term water demands.
CURRENT STATUS
The County Health Department has recently begun drilling monitoring wells
to identify the source(s) of the organics discovered in Garden City Park Water
District wells five years ago. Several landfills are suspected, but none have
been positively linked to the tetrachloroethylene in Water District wells.
Conservation measures will be in effect to reduce water demands until the
air-stripping plant is installed. The plant is expected to be completed in
late 1983. In the summer of 1983, work should begin on the biological denitri'
fication pilot plant designed by Ecolotrol. In the meantime, Water District
-------
C-29
officals are still investigating the possibility of using wells with tetra-
chlorpethylene levels slightly over the 50,ppb'Health Department guideline.
INSTITUTIONAL INVOLVEMENT
the organizations involved in the Garden City Park organics contamination
problem are the following:
Garden City Park Water District
Nassau County Department of Health
New York State Department of Health
New York State Department of Environmental,Conservation
u.s. EPA .- , - --:-
Holzmacher, McLendon and Murrell, P.C. (H2M)
Ecolotrol ,
The Garden City Park Water District is directed by a Board of Commissioners
and operated by the office of the Supertendent. The Water District relies on
the County for health information and on a private consulting firm, H2M, for
technical and planning expertise.
The Nassau County Department of Health administers the basic State programs
in addition to programs initiated by the County. The Department of Health is
a large organization with a relatively large staff assigned to drinking water
problems. The County Health Department has its own laboratory and specialists
to carry out programs that most other municipalities would have to relegate to
state authorities. Since Nassau County was the location of New York State's
first detected cases of organics contamination in ground water, the Department
of Health has extensive experience in dealing with contamination problems.
.The New York State Department of Health is the organization that carried
out the first studies of organics in ground-water supplies on Long Island.
The State Department of Health has been involved in the Garden City Park case
only indirectly, through the County Department of Health. The State developed
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C-30
the Interim Guidelines that address organic contamination and has analyzed the
available medical and technical information to assist the counties with ques-
tioliS bn health effects and treatment alternatives. A summary of information,
as well as the results of several organics surveys, is presented in an excel-
lent comprehensive report entitled "Organic Chemicals and Drinking Water",
revised in April 1981.
The Department of Environmental Conservation and EPA were not active in the
Garden City park organics case. The Water District's consulting engineers,
H2M, have played a major role in evaluating alternatives to secure a sufficient
water supply and in planning treatment methods. Ecolotrol has been involved
with the specialized planning for a biological denitrification pilot plant.
HEALTH GUIDELINES
The Nassau County Department of Health administers the state health guide-
lines and regulations affecting community and non-community water supplies.
The New York State Department of Health Interim Guidelines for organic chem-
icals specify that the level of benzene or of vinyl chloride shall not exceed
5 ug/1 and that the level of any other single synthetic organic chemical con-
taminant shall not exceed 50 ug/1. Ground-water source community systems are
required to monitor eighteen organic constituents, including six halogenated
organics: 1,1,2-trichloroethylene, trifluorotrichloroethane, tetrachloroethy-
lene, chloroform, carbon tetrachloride, and 1,1,1-trichloroethane.
The Interim Guidelines were adopted by the State Department of Health on
January 13, 1977 and modified on February 25, 1980 as a direct consequence of
detecting these organic contaminants in ground water. Concerns raised over
the hazards associated with long-term consumption of these potential carcin-
ogens prompted the State to take action.
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C-31
CONCLUSIONS :
The Garden City Park case involved only a few government organizations,
biit Still touched on many technical topics. Although the County is drilling
several monitoring wells, no real progress has been made in conclusively ident-
ifying the source of contamination. Conservation measures, more so than water
purchases, were credited with avoiding severe water shortages when wells were
closed. Finally and perhaps most importantly, the consulting engineers hired
by the Water District had enough confidence in their own expertise and informa-
tion from other projects to proceed with installing a full-scale packed column
air stripper to remove the tetrachloroethylene found in ground-water supplies.
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C-32
CITY OF GLEN COVE
NASSAU COUNTY, NEW YORK
SUMMARY
The Nassau County Health Department (NCHD) tested the City of Glen Cove's
Water in the summer of 1977 for organic compounds. Their analysis indicated
that four of Glen Cove's wells contained trichloroethylene (TCE) and tetra-
chloroethylene above New York.State's maximum allowable limits of 50 ug/1 for
any one organic contaminant and a total allowable limit of 100 ug/1 for all
such compounds. The Health Department subsequently restricted the use of
those wells.
The City, faced with the loss of half of its water supply, was forced to
purchase water from neighboring systems as well as to implement conservation
measures that summer. One of two wells being developed at the time the con-
tamination was discovered was-then put on line, allowing water demands to be
met. To further augment their'reduced supply, the City retained an engineer-
ing consulting firm to study the situation. The firm found that no existing
treatment technology was capable of treating large volumes of water containing
trichloroethylene and tetrachloroethylene and helped the City secure an EPA
research grant to test several possible treatment methods with pilot studies
at one well field. The first two phases of this study are complete, and the
third phase is currently in progress.
BACKGROUND
The City of Glen Cove is located in northern Nassau County, New York on
Long Island Sound. The City supplies water to a population of about 27,000
with an average demand of 4.14 mgd and a peak demand of 7.72 mgd in 1981.
-------
C-33
When the organics problem was first noticed in 1977, the City was operating
seven wells drawing from intervals between 160 and 300 feet deep. The only
treatment applied to the raw water is chlorination, with polyphosphate and
sodium hydroxide added as corrosion control agents. Glen Cove is mainly a
residential area, with some light industry and commercial establishments in
the center of town.
DISCOVERY OF THE CONTAMINATION PROBLEM
Organic chemical contamination of the ground water in Nassau County was
first discovered in October 1975 at two Grumman Aerospace Corporation wells in
Bethpage, thirteen miles from Glen Cove. This discovery by the State Health
Department and the detection of VOCs in eleven adjacent public and industrial
wells led to the establishment of an extensive program to sample all public
wells.
Sampling for volatile halogenated organic chemicals began in late 1976 in
southeastern Nassau County. At that time, samples from public wells were
routinely tested for eight such compounds: trichloroethylene, tetrachloro-
ethylene, trifluorotrichloroethane, 1,1,1-trichloroethane, chloroform, bromo-
dichloromethane, carbon tetrachloride, and 1,1,2-trichloroethane. Limited
testing for vinyl chloride, 1,2-dichloroethylene, methylene chloride, bromo-
form and the non-halogenated compounds benzene and toluene was also carried
out. The samples collected were analyzed by the U.S. EPA, New York State
Department of Health, Nassau County Department of Health, and various
consultants' laboratories.
In early 1977, the State Health Department developed "interim guidelines"
to assist the Department in evaluating data and controlling the use of public
-------
C-34
supply wells. The guidelines limited vinyl chloride to 5 ug/1 (micrograms
per liter), other organic chemicals to 50 ug/1, and the combined level of all
Organic chemicals to 100 ug/1. These guidelines were based on a toxicological
study in progress by the National Academy of Science which relied primarily on
extrapolation of animal data and were predicated on a lifetime human exposure
(70 years) to drinking water (2 liters/day) which would cause one additional
cancer death per year.in 100,000 to one million persons.
The Nassau County Department of Health sampled the Glen Cove municipal
wells in the summer of 1977. Four wells (Numbers 22, 1-S, 20, and 21) were
placed in the "restricted" category and closed due to organic contamination,
mainly by trichloroethylene (as high as 300 ug/1) and tetrachloroethylene (as
high as 375 ug/1).
ACTIONS TO PROTECT WATER QUALITY
The decision to close the contaminated wells was the first action taken to
protect public health. The Nassau County guidelines for organics in drinking
water are very clear and detailed, so closing the wells was not an arbitrary
decision.
Faced with the loss of about half of the municipal water supply capacity,
Glen Cove also had to implement conservation measures and purchase water. The
City entered into contracts with the Sea Cliff Water Division to supply 0.70
mgd and with the Locust Valley Water District for 0.25 mgd to meet the summer
demand in 1977. Conservation measures were credited with significantly
reducing demand and minimizing the shortage.
By the summer of 1978, two factors, the closing of a industrial customer
with a water demand of 1 mgd and the opening of a new 2 mgd well, allowed even
-------
C-35
summer demands to be met, although another smaller well (No. 2-S) was closed
in August 1978 due to measured tetrachloroethylene concentrations in consecu-
tive satoples of 73 and 84 ug/1.
Two efforts initiated in 1977 and 1978 were directed towards ensuring the
long-term availability of safe drinking water. Beginning in 1977, the Nassau
County Health Department began investigations into the source(s) of Glen Cove's
organic contamination problem. One study was conducted to identify local
industries that used the halogenated organic solvents. Another study surveyed
residences and commercial establishments, such as dry cleaners, to update
knowledge of organic chemical usage and disposal practices in the vicinity of
the contaminated wells. The other main line of investigation concentrated on
methods of treating the water, rather than on isolating the source. The City
and their consulting engineers entered into discussions with U.S. EPA that
resulted in a research grant to test several possible treatment methods at the
Glen Cove site.
The first study to identify sources of contamination was carried out by
NCHD in June to December 1977. Over one hundred inspections/surveys were made
of commercial/industrial sites near the Carney Street and Seamens Road well
fields. This study concluded that no waste disposal practices were found at
that time which could account for the extent of contamination at the Carney
Street or Seamans Road wells. The contamination problem was therefore attri-
buted, to past disposal practices, perhaps as recent as the early 1970s. The
Health Department recommended exploring the feasibility of purging the contam-
inated ground water as well as changing water supply practices. The difficul-
ties in testing for dichloromethane, a suspected contaminant, were noted.
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C-36
The second study by the Nassau County Health Department was conducted to
find the source of contamination of the Seamen Road wells. This study looked
more closely at drycleaners and unsewered residences in the area, as well as
several commercial buildings and a distant (2,000 feet from wells) landfill.
The NCHD concluded that the one remaining drycleaner was a potential source and
ordered several changes at the facility. The report also recommended connect-
ing all unsewered residences and continuing the investigation with subsurface
exploration techniques. Finally, the Health Department proposed a specific
program of observation well construction and sampling. No hydrologic/geologic
studies of this type have been carried out to date.
In an effort to treat the contaminated water, rather than to find the
source, the City retained the consulting engineering firm of Nebolsine Kohlmann
Ruggiero Engineers, P.C. (NKRE) to design a feasible and economical treatment
system. Through consultation with the U.S.-EPA's Drinking Water Research
Division, Municipal Environmental Research Laboratory (MERL), Cincinnati, it
was determined that no existing treatment technology was capable of treating
large volumes of water containing these organic contaminants. After prelim-
inary tests of the Carney Street wells, discussions and negotiations between
the City, NKRE, and the U.S. EPA resulted in a research grant (later a cooper-
ative agreement) funded by the U.S. EPA to test several possible treatment
methods at the Glen Cove site.
Phase I of the pilot project, begun in March 1979, tested counter-current
diffused aeration and adsorption using resins. Phase II of the project began
at the conclusion of Phase I, after modifications to the pilot plant equipment
(including changes in resin-testing column size, installation of activated
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C-37
carbon towers, adaptations for a larger steam supply, and installation of a
packed aeration tower and a cooling tower for air stripping) were completed.
Tile data developed during the two phases of testing showed that the most
efficient system to reduce organic contamination to low levels was one using
aeration followed by adsorption on resin. This approach allows treatment by
aeration to efficiently strip all contaminants, significantly lowering the
well water contamination levels, and then polishes the water with resin,
thereby reducing regeneration requirements and extending the length of service
time for the resins. The pilot project has shown that the target contaminant
level is an important consideration in interpreting the data or determining
the cost of treatment, and the effluent -quality mandated affects the design
parameters, length of service time for adsorbents and the overall system costs.
Phase III of the pilot project is in progress. The following table shows the
estimated cost ranges for the"three systems tested:
ESTIMATED COSTS FOR FULL-SCALE INSTALLATION
(Thousands of Dollars)
System Capital Costs
Diffused Aeration 228-471
Packed Column
Aeration
Resin
477-684
308-953
Annual Operating Costs
122-342
($0.19-0.33/thousand gallons)
130-378
($0.21-0.36/thousand gallons)
77-228
($0.12-0.22/thousand gallons)
CURRENT STATUS
According to the Health Department, the Glen Cove site is no longer con-
sidered a "hotspot" in terms of organic contamination. Since new wells have
come on line, the present capacity is sufficient to meet water demands, and
-------
" ""'* » '. ', !
little, further action is planned. The City and NKRE are examining the possi-
4f ; ' ?.. ;,
" ° ' **'* !
bility'pf getting a grant for a demonstration plant based on pilot project
'_,: f. : . '' ' * v "'.., ',.
results, but the outcome of their efforts is uncertain. Glen Cove does not
seem interested in following up on the problem, as long as immediate water
demands can be met.
INSTITUTIONAL INVOLVEMENT
The Nassau County Health Department has been the lead agency in dealing
with volatile organics in the Glen Cove water supply. The Health Department,
mostly through the Bureau of Public Water Supply, initiated the organics test-
ing program in 1977 that discovered the problems with Glen Cove's drinking
water. NCHD is responsible for administering the New York State Health Depart-
ment Guidelines for organics in drinking water. In that capacity, the depart-
ment classified Glen Cove wells into "restricted," "reserve," and "unre-
stricted" categories, with specific suggestions to the City as to approved use
of each category.
The Nassau County Health Department also planned and carried out two resi-
dential/industrial surveys in the Glen Cove area, in an inconclusive effort to
find sources of contamination. With a complete laboratory facility capable of
testing for volatile halogenated and non-halogenated compounds, the Department
offers strong technical support to testing and monitoring programs. In addi-
tion to providing technical assistance, NCHD reviews proposed alternatives for
alleviating water shortages due to organic contamination.
Since the County has had over a dozen water systems with serious organics
problems, the large staff and years of experience that NCHD can apply to cases
of drinking water contamination is a definite advantage. Several other organ-
izations that have been involved to a lesser extent in the Glen Cove case:
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C-39
U.S. Environmental Protection Agency (EPA). The federal
government has been involved only in two aspects of the Glen Cove
contamination problem. EPA research into the health effects of
various organics was used by the New York State Health Department
to set the guidelines used by Nassau County to recommend.that
wells be closed. EPA is also involved in funding the pilot tests
at Glen Cove to compare and establish design ^parameters for '-
aeration, resin adsorption, and granular activated carbon adsorp-
tion treatment techniques.
New York State Health Department. The State Health Depart-
ment has been involved in the Glen Cove case' only indirectly.
The State, however, deserves mention for'its studies of organics
and drinking water. At present, the NYSHD guidelines on organics
in drinking water are being reviewed. Recommendations on stan-
dards for organics, rather than the present guidelines, are
expected to be proposed in late 1982.
New York Department of Environmental Conservation. The .
Department of Environmental Conservation has responsibility in
New York under the State Pollution Discharge Elimination System
and Water Classification System to protect tjie water resources of
the state, including ground water. DEC has conducted a state-
wide survey of organic chemical use, storage and disposal which
has been used in Nassau County to identify potential sources of
ground water contamination.
City of Glen Cove. The City of Glen Cove has played a rather
passive role in resolving the problem of organics in its drinking
water supply. Officials stated that once new wells restored the
City's capacity to meet immediate demands, it reportedly became
someone else's responsibility to investigate the source and extent
of contamination. Consequently, Glen Cove now has no major plans
to investigate the problem. Their consulting engineers are con-
cluding the pilot tests at a Glen Cove well site, but unless
federal money becomes available, no further action is .expected.
HEALTH GUIDELINES
The State of New York first announced guidelines for synthetic organic
chemicals in public water supplies in January 1977. These guidelines specify
that the level of benzene or vinyl chloride shall not exceed 5 ug/1, that the
level of any other single synthetic organic chemical shall not exceed 50 ug/1,
and the combined total for such contaminants shall not exceed 100 ug/1. The
State Health Department has extensively researched methods of estimating .risks
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C-40
from organic chemicals and has reviewed many strategies for managing synthetic
organic contaminants in drinking water, but has kept the 50 ug/1 guideline for
single synthetic organics. By Health Department references, 50 ug/1 corre-
sponds to a wide range of risk levels, as shown in the following table for some
common organics.
MAS PROJECTED LIFETIME CANCER RISKS FOR
INDICATED DRINKING WATER CONCENTRATIONS
Concentrations Corresponding to Risk Levels
Compound
Carbon Tetrachloride
Chloroform
Dibromoethane
Tetrachloroethylene
Trichloroethane
Trichloroethylene
Vinyl Chloride
1 x 10
-4
1 x 10
-5
1 x 10
-6
450.0
29.0
48.0
220.0
46.0
460.0
110.0
45.0
2.9
4.8
22.0
4.6
46.0
11.0
4.5
0.29
0.48
2.20
0.46
4.6
1.10
(all concentrations in.parts-per-billion)
Note that the risk levels for the "allowable" 50 ug/1 of trichloroethane and
the "allowable" 5 ug/1 of vinyl chloride differ by one and a half orders of
magnitude. Despite this apparent inconsistency, the State of New York has the
most extensive program for dealing with origanic chemicals in drinking water
i
of any state investigated in this survey. The Nassau County Policy
Statement on Use of Public Supply Wells Contaminated by Organic Chemicals
is one of the most comprehensive documents on the subject produced by county
government.
CONCLUSIONS
The Glen Cove contamination case differs from most others examined in
several respects. First, the presence of organics was detected and a response
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C-41
was made under a well-funded, well-organized County Health Department program.
Second, no hydrogeological study was made to determine the source of contamina^
tion. This kept Glen Cove from finding a responsible (i.e., liable) party and
from being certain of halting the source of contamination. Third, a pilot pro-
ject has generated quite a bit of information on treatment technologies that
can be extremely useful to Glen Cove or other water systems with similar prob-
lems. The value of this data should not be overlooked.
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VESTAL
NEW YORK
SUMMARY
Random sampling of New York water supplies by the State Health Department
discovered high levels of trichloroethane in a well operated by the Town of
Vestal Water District No. 1. The state came back and sampled all of Vestal's
wells and found another, in District No. 4, contaminated with trichloroethane
and tetrachloroethylene. Both wells were shut down in the spring of 1980.
District No. 4 faced a water shortage that summer and installed a portable
granular activated carbon unit on the contaminated well until a new well came
on line. The State assisted in tracking down the suspected source of contam-
ination, a chemical company less than 300 feet from the well. The Town of
Vestal and the State are currently involved in litigation against the company.
Water District No. 1 experienced-no major supply disruptions, but it was
feared that the contamination would spread to the two remaining wells in the
district. The well is now pumped to waste to prevent migration of the organ-
ics, and a private contractor is performing a study to pinpoint the source.
EPA recently sent investigators to the site to evaluate the case for Superfund
assistance.
BACKGROUND
The Town of Vestal is located in Broome County in south-central New York
State. Vestal supplies water to 27,300 persons, including 11,000 at the State
University at Binghampton. The water system is divided into nine Water Dis-
tricts, supplied by a total of eight wells. The wells tap into a moderately
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vulnerable aquifer at about 140 feet. The deep bed of gravel below the soil
level allows rapid percolation.
DISCOVERY OF THE CONTAMINATION PROBLEM
In 1978, through one of the national water supply sampling programs, EPA
randomly selected a Vestal well, No. 1-1, for organics analysis. The samples
were delivered to the Cincinnati lab where they set on a shelf, unrefrigerated,
for a year or two. When the samples were tested, some organics were detected,
but although the results were published, they were dismissed as inaccurate
because of poor handling procedures. In the spring of 1980, the New York State
Department of Environmental Conservation (DEC) sampled ground water at nearby
Endicott and, on a fluke, collected a sample from a Vestal well.
The results of organics analysis on that sample from Well No. 1-1 showed
over 1500 ppb of 1,1,1 trichloroethane. The state came back and resampled all
Vestal wells. This confirmation round of testing confirmed, the results in
. , . * < ' O
Well No. 1-1 and also revealed that Water District No. 4 well No.' 2 had 300
ppb of 1,1,1 trichloroethane and tetrachloroethylene.
ACTIONS TO PROTECT WATER QUALITY
The first step taken to protect water quality was to close the contaminated
wells. State Department of Health guidelines are quite specific in recommend-
ing that water with greater than 50 ppb of a single organic (except vinyl
chloride, which has a 5 ppb limit) or 100 ppb of total organics should not be
used for drinking.
The two wells were contaminated by different sources. Well No. 1-1 was
pumped to waste in the Susquehanna River to prevent the spread of contamina-
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tion to the other two wells in District 1, located about 1500 feet downgrad-
ient. Levels of contamination have dropped from 1700 ppb to about 200 ppb.
The Town hired a local consultant to trace the source of contamination in
District 1. So far, a considerable amount of drilling- and many flow tests have
determined the general direction of plume travel, but no source has been defin-
itely identified. Vestal requested assistance from DEC for further investiga-
tions. EPA contractors were recently sent to the site to evaluate the case
for Superfund aid. The EPA team reportedly copied the existing documentation
in Town files and did no on-site investigations. Vestal has spent over
$100,000 investigating the source of contamination.
Closing Well No. 4-2 severely restricted water supplies in that district
of the Vestal water system. The Town put a portable GAG unit on the well to
help meet summer water demands. When a well aready under construction came on
line, No. 4-2 was taken off GAG and pumped to the Susquehanna. Trichloroethane
levels have dropped from 200 ppb down to 50 or 100 ppb.
The DEC came in to trace the source of contamination in Well No. 4-2, cur-
iously enough with State Department of Transportation funding. An obvious
source, a chemical company located 370 feet from the well, was soon identified.
Apparently the company had obtained a permit from DEC to rinse chemical barrels
on a gravel pad behind the building. The Town of Vestal and the New York
Attorney General are currently involved in litigation, against the company.
CURRENT STATUS
Investigations in Vestal District No. 1 are still continuing while the
resolution of the problem in District No. 4 is somewhere in the court system.
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The Town is running out of money to finance further investigations and must
find either the responsible party or another funding source. Even if Vestal
is approved for Superfund monies, the funding probably will not be available
for a year or two. .
INSTITUTIONAL INVOLVEMENT -
The roles of the various agencies involved in the ground-water contamina-
tion cases at Vestal have already been outlined. The Town of Vestal has played
an active role in finding alternate sources of drinking water and in tracing
the sources of contamination. The current town engineer was hired just two
months before the contamination was detected, but he and his staff responded
well at the time and have gone ahead in making contingency plans in case the
problem worsens. Extensive research and several national ground-water confer-
ences have provided useful information for making .decisions on treatment and
other technical responses.
The New York State Departments of Healtn and Environmental Conservation
assisted in testing well water and tracing the sources of organics. New York
has,a fairly well established state program for dealing with organic contamina-
tion, described in the Glen Cove case study.
EPA Region II has been involved indirectly. The regional office provided
some health information to the town, through DEC, and the hazardous waste sites
branch recently sent in a team of contractors to briefly investigate the case
for Superfund consideration. .
Several other organizations have been involved peripherally. Roy Martin
Consultants and other local firms have assisted in placing the new wells and
tracing the sources of contamination, especially in Well No. 1-1. Calgon and
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the American Water Works Associaion have provided information on treatment
alternatives. The local media was involved in the case, but reportedly criti-
cized the water officials rather than distributing the few known facts of the
problem. The County Health Department also hindered the investigation by the
Town of Vestal. Finally, a local citizen and student group organized to lobby
for no allowable levels of contamination has generated some political pressure.
HEALTH GUIDELINES
The New York State guidelines recommending less than 50 mg/1 of any single
organic chemical and less than 100 mg/1 for total organics are described in
detail in the case study of Glen Cove. Although the New York program for
organics in drinking water is one of the country's most established, questions
as to what levels of various organics will be acceptable in even the near
future complicate decision-making. Water officials do not seem to have much
confidence in the permanence of these guidelines and hesitate to take actions
based solely on the present numbers. For example, a treatment plant cannot be
designed without performance specifications, and the fear of designing an
installation and then having the applicable standard change is a very real
i
problem.
CONCLUSIONS
After a slow start in detecting the trichloroethane and tetrachloroethylene
problems in Vestal drinking water, due in part to handling delays at EPA's busy
Cincinnati labs, the town acted decisively in removing the contaminated wells
from service. Fortunately, a new well was already being developed that was
capable of replacing the closed wells. Vestal and the Department of Environ-
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mental Conservation then proceeded with efforts to find the sources of organ-
ics. One source has been found and the Town is continuing its search for the
other.
As in many other cases, the lack of understandable information on the
health, effects of the synthetic organics was a major problem in responding to
the situation. Town officials felt that there were not enough regulations or
standards as to what levels of contamination were "safe," "acceptable," or
"allowed" in drinking water. Vestal could have contracted to have a treatment
system installed, if. necessary, but not with assurances that the system would
both meet any applicable standards and protect,, public health as much as
feasible. A related problem was in dealing with the media, which soon became
a major source of irritation. The Town simply did^not have the answers about
the potential health hazards that the newspapers wanted, and the media saw
this weakness as a cover-up.
- Another problem is the cost of investigative efforts. Vestal has spent
over $100,000 in one district and is already running out of funds to continue
work. The possibility of Superfund monies becoming available would be helpful,
but a lack of information surrounding EPA's evaluations and the delays expected
before funds are actually committed have kept local officals cautious about
depending on government aid.
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NORTH PENNSYLVANIA WATER AUTHORITY
LANSDALE, PENNSYLVANIA
SUMMARY
In response to requests by water customers, the North Pennsylanvla Water
Authority (NPWA) tested its wells in 1979 for organic chemicals. Of the
system's 51 wells, seven were found to have trichloroethylene and one had
tetrachloroethylene, or perchloroethylene (PCE). All eight wells were closed,
effectively reducing the system's supply by about one-third.
The NPWA's short-term response was to purchase water from a neighboring
water company and to increase pumpage from the remaining wells to make up for
lost capacity. The Water Authority then worked with EPA Region III and the
Pennsylvania Department of Environmental Resources (DER) to trace the source
of contamination. This task proved to be difficult due to aquifer heterogene-
ities and the large number of potential sources soon discovered. Eventually,
only one well was definitely tied to a single source of contamination. A
number of local industries have contributed to finding and halting sources of
contamination.
The NPWA began treating some well water with granular activated carbon
adsorption in 1981. Other treatment technologies, including an in-well aera-
tion project, are also being tested.
BACKGROUND
The North Pennsylvania Water Authority is the major water utility for
eastern Montgomery County, located in southeastern Pennsylvania. NPWA is a
non-profit utility, governed by an elected Board of Directors, serving seven
townships and municipalities. The Authority has 51 wells capable of supplying
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5.2 MGD, but usually only 30 to 35 wells are required to be in service. The
production wells are scattered all over the service area. Some, of the very
old wells are in the shallow aquifer at about 120 feet, while the new wells,
generally in the lower aquifer, are as deep as 300 feet.
DISCOVERY OF THE CONTAMINATION PROBLEM
When a very large trichloroethylene (TCE) spill in nearby Collegeville
contaminated the local water supply, officials at the North Pennsylvania Water
Authority became curious about the quality of their own water sources. In
July 1979, the Authority tested the water and found levels of, TCE from 1 to
400 ppb in seven wells. One other well showed significant levels of perchloro-
ethylene. Other chlorinated hydrocarbons such as 1,1,1 trichloroethane and
cis-1,2 dichloroethylene were also detected in smaller amounts.
nated wells were scattered at various locations around the" service area.
The contami-
ACTIONS TO PROTECT WATER QUALITY
The eight wells found to be contaminated were immediately closed down.
The Water Authority referred to the NAS 1 in 106 increased cancer risk level
of 4.5 ppb for TCE in taking this action, although the State of Pennsylvania
does not yet have primacy under the Safe Drinking Water Act and had no official
response levels for organics in water supplies. About one-third of the NPWA
supply capacity was lost when the wells were closed, although the difference
was quickly made up by purchasing water from the neighboring Keystone Water
Company. Keystone gets its water from a surface source, and complaints about
taste and odor problems as well as questions about the wisdom of exchanging
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TCE risks for THM risks often associated with surface water supplies have
caused NPWA officials to minimize use of Keystone water.
The Pennsylvania Department of Environmental Resources and EPA Region III
became involved in tracing the sources of volatile organics and in evaluating
treatment alternatives. NPWA, with DER and EPA assistance, has put quite a
bit of effort into locating the sources of contamination. Although the old
industrial area in the middle of Lansdale had several suspected sources, a
newly developed area with more recent activity was picked first for pump tests
and periodic sampling to isolate sources of organics. Deep industrial wells
and more shallow monitoring wells were used to define the contaminant plumes.
NPWA carried out investigations through the summer of 1982, and a group of
industries with potential TCE problems, organized as the North Penn Water
Resources Group, sponsored investigations in 1982. The Water Authority and
EPA have stressed a positive .approach to resolving the organics problem,
rather than threatening the industries with legal action, and have received
excellent cooperation from the industries.
Only one contaminated well was definitely linked to a single industrial
source. Another well was found to be contaminated by six different sources.
The multitude of sources and fractured rock geology made investigations diffi-
cult, especially in downtown Lansdale. Several clean-up actions were taken on
industrial sites found to be contaminated by organics used as solvents or
degreasers. One very heavily contaminated site was excavated and the dirt
hauled away. At several sites, the contaminated soil was dug up and spread
over the ground to volatize the synthetic organics present. Other industries
improved chemical drum storage facilities, replaced leaking TCE tanks, or
installed other measures to control organic discharges.
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In,the meantime, efforts, were underway to treat the contaminated well
water. Shortly .after the wells were originally closed, .several were put back
on line and pumped to the wastewater treatment plant to prevent localized TCE
plumes from spreading to clean wells. In November 1981, a 100 gpm granular
Motivated carbon plant was installed at one well, at a cost of $70,000, to
return a portion of that well's capacity to service. Officials from the EPA
Municipal Environmental Research Lab in Cincinnati tested the effectiveness of
their portable packed aeration tower on one well in 1982. The Water Authority
and EPA have also entered into a cooperative agreement for $90,000 to test new
in-well aeration techniques. This two-year project is in the preliminary
stages of design, although laboratory facilities with a gas chromatograph have
already been installed for organics analysis. Operating expenses for the lab
are estimated at $70,000 per year. North Perm's total costs thus far have
totalled over $500,000, and average water bills have increased by $0.50 per
month. -. . ,
CURRENT STATUS
Recently, some previously-closed wells have been put back on line to reduce
the amount of water purchased from the Keystone Water Company, Although the
4.5 ppb risk level was originally discussed, DER is now speaking in terms of
75 ppb, the number used as the long-term Suggested No Adverse Response Level,
as an acceptable level for TCE. NPWA has only put wells back on line with TCE
levels,less than 5 or 10 ppb.
INSTITUTIONAL INVOLVEMENT
The Water Authority, Department of Environmental Resources, and EPA worked
together on most aspects of the contamination problem around Lansdale.
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Although DER was inundated with requests for assistance with chemical contami-
nation incidents in 1979, the Department still managed to respond to North
Penn's contamination problem. Several EPA officials from the Region III office
and the MERL center in Cincinnati provided assistance in several stages of
tracing and controlling organics in the drinking water supply. Both EPA and
the American Water Works Association provided research grants to test VOC
removal techniques. .
The North Penn Water Resources Group, the organization of industries formed
to deal with the TCE problem, has been very cooperative in allowing and assist-
ing investigations on and off plant sites. Most, if not all, of these firms
have probably contributed to ground-water contamination in the area, but the
group still deserves credit for facilitating investigations. The success of
this positive effort is largely due to NPWA's decision to emphasize cleanup
efforts rather than determination of culpability.
Several engineering and ground-water consulting firms have been involved
in the North Penn case. Until the Water Authority equipped its own labora-
tory, a private lab was also used for organics analyses.
HEALTH GUIDELINES
As mentioned previously, the State of Pennsylvania has not been given pri-
macy under the Safe Drinking Water Act and therefore has no program to deal
with organic chemicals in drinking water supplies. For lack of better informa-
tion, the Department of Environmental Regulation initially proposed the NAS
10"6 increased cancer risk level of 4.5 ppb for TCE. Now the DER is using
the Suggested No Adverse Response Level (SNARL) of 75 ppb for chronic exposure
to TCE.
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CONCLUSIONS
Several aspects of the North Penn Water Authority case,are fairly unusual.
First of all, the utility was fortunate that lost production capacity could be
made up easily, even if at considerable expense, considering the prevalence of
ebtttaMination sites throughout the service area. Second, the lack of a state
drinking water program eliminated one agency usually,involved in ground-water
cases. Finally, the degree of cooperation between the Water Authority and the
group of local industries using TCE has rarely-been observed elsewhere.
Several aspects of the North Penn case are common to many other cases.
The public "outrage" and intense media coverage hindered careful, deliberate
response to the problem. In retrospect, NPWA officials feel that the decision
to install a GAG adsorption plant as small as 100 gpm may have been too hasty.
The major shortcoming that kept the public upset and complicated planning was
the lack of understandable, consistent information on the health effects of
organics in drinking water.
Informing the public about the detection of potential carcinogens in their
drinking water caused an "incredible amount of panic." With several sets of
health numbers for TCE being tossed around, and no solid information that the
public could relate to, confusion was rampant. Local officials needed one
"official" number for acceptable levels of TCE both to calm the public and to
use as a goal in designing water treatment methods. The Water Authority has
made great efforts to keep the media informed of progress in the case, and the
initial furor has largely ceased.
Local officials also mentioned a need for more technical information.
Improved knowledge of the transport of chemicals through soil, rock, and the
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C-54
water table is needed to better predict leaching, subsurface travel, and reten-
tion of various organic compounds. More information on'site cleanup proced-
ures, such as the relative merits of landfill disposal, impermeable liners,
forced leaching, soil aeration, etc.. was requested.
Finally, in another health-related topic, the tradeoffs in abandoning a
ground-water supply contaminated with low levels of TCE for a surface water
source contaminated with trihalomethanes need to be evaluated. The lack of a
consistent basis for making this type of comparison has long been a problem.
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VERO BEACH
FLORIDA
SUMMARY
Trichloroethylene and related volatile organics were accidentally disco'v-
ired in Vero Beach's drinking water when the water supply was tested for tri-
halomethanes in 1978. The City traced the contaminants back to ,one well near
the airport. After the well was closed, an investigation around,the airport
'area revealed that Piper Aircraft had a buried tank of TCE that was leaking.
Once the suspected source was identified, test holes .were drilled around
the tank that confirmed that very high levels of TCE were present. After dis-
cussions between the City, Piper, and Florida Department of Environmental Regu-
lation (DER), a dewatering well was drilled to prevent the acquifer contamina-
tion from spreading to other wells. After a major delay, a NPDES permit was
finally, approved to discharge the water from this well to a canal.
Vero Beach never experienced a serious water shortage because of the closed
"well, but new wells have since been drilled to supplement the City's supply.
Local officials feel that they and Piper could have handled the problem as well
and much more rapidly without interference from the State and EPA.
BACKGROUND
The City of Vero Beach is located on the Atlantic coast of central Florida.
The City supplies water to about 21,000 customers at a normal rate of 7 to 8
MGD. About twenty relatively shallow wells are used by the. City. The combina-
tion of very sandy soil and a high water table make ground-water supplies very
vulnerable to contamination from surface spills as well as intrusion by salt
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C-56
water if wells are pumped at high rates. Vero Beach treats its water with
coarse filtration and a lime softening process before distribution.
DISCOVERY OF THE CONTAMINATION PROBLEM
In 1978, a researcher for the Harper-Branch Research Foundation tested
Vero Beach's finished water for trihalomethanes. The results of that analysis
showed that very low levels of total trihalomethanes were present, but that
another halogenated organic, trichloroethylene, was present at a level of 68
ppb. The city backtracked through the water distribution system and found
that one well, production well No. 15 located on Vero Beach Airport property,
was the source of TCE in the drinking water system.
ACTIONS TO PROTECT WATER QUALITY
The concentration of TCE in the contaminated well was 900 ppb. Based on
health information from Harper-Branch and the Water Department, Vero Beach
decided to close down the well.
With the immediate threat to drinking water quality removed, the City
began looking at potential sources of contamination on the airport grounds.
Very quickly they learned that Piper Aircraft had a buried tank for TCE.
Piper pressure-tested the tank and found a leak in a corroded below-ground
pipe fitting. After Piper drained the tank to prevent any more of the solvent
from leaking out, shallow (12-15 feet deep) well points were put down around
the tank to determine the extent of contamination. High levels of TCE were
found to be fairly widespread, indicating that the tank had been leaking for
some time.
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After discussions with Florida DER and the City's consulting engineers, Gee
& Jenson, Piper drilled a 60 foot deep interceptor well near the tank site.
Samples from that well had over 10,000 ppb of trichloroethylene. The City
applied to the state for a NPDES permit to pump the well to waste in a nearby
drainage canal to prevent the spread of contamination to other wells. The
State approved of the pumping plan, but EPA refused the permit until a base-
line study of the discharge area was completed, since the effects of TCE
getting into the salt water environment were unknown. The study cost Vero
Beach quite a bit and the delay allowed the contaminant to migrate further.
In February 1982, after more than a year's delay, the Florida Department
of Environmental Regulation authorized emergency pumping of the Piper well,
with some treatment, because the contamination had spread to other wells.
Eventually a consent agreement was developed by EPA and DER, requiring an
analysis of the results of the treatment process used before discharging 'the
contaminated water, an evaluation of other treatment alternatives, establish-
ment of a monitoring program, and a hydrological evaluation. The NPDES permit
was finally approved with Piper Aircraft listed as the discharger.
Piper had put in water lines from the purge well to the canal and had Gee
& Jensen design a treatment method. Gee and Jensen settled on an aeration
technique through spray nozzles to remove the volatile TCE. In reviewing
alternate treatment techniques, the following options and cost estimates were
considered:
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Treatment Technology ' Estimated Cost
Air Stripping
(a) upgrade spray discharge system $ 9,500
(b) design aeration tower $ 26,400-52,800
Synthetic Resin Adsorption $ 62,000
Steam Stripping $350,000
Solvent Extraction $555,000
Activated Carbon Adsorption $810,000
Levels of trichloroethylene in the Piper well were around 7000 to 8000 ppb in
August 1981 and have declined to 400 ppb fourteen months later. The air
stripping process currently in use has approximately a 70 percent removal
efficiency. About 0.25 MGD is being pumped from Piper's purge well. TCE
levels at the end of the discharge spillway were less than 3 ppb.
At the time that the organic contamination was discovered, Vero Beach was
in the process of drilling two new production wells. While the City never
experienced serious water supply disruptions, a total of eight wells have
since been drilled to satisfy current demand as well as projections of future
growth. There are some problems with drilling in the area 'in that isolated
spots of contamination by various chemicals are occasionally encountered.
CURRENT STATUS
At present, levels of trichloroethylene in the abandoned Vero Beach produc-
tion well are down to trace amounts. Apparently, the contaminant plume has
moved past that well and the purge well is preventing the residual contamina-
tion at the tank site from migrating towards the production well. City wells
are still being monitored for organics and Gee & Jensen are still sampling and
testing water at several points from the purge well, through the spray nozzle
discharge, and down the canal. Trichloroethylene levels a short distance down
the canal from the discharge spillway are below the detectable limit.
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INSTITUTIONAL INVOLVEMENT ,
The City of Vero Beach and Piper Aircraft, in a rare example of government/
business cooperation, worked together to resolve the problem. Once it became
clear that Piper was at fault, the company became very cooperative in cleaning
lip the spill. Technical assistance from the Harper-Branch Research Foundation,
a private, non-profit organization, was instrumental in detecting the original
problem and carrying out the response. Harper-Branch was generally in charge
of testing and monitoring programs. The City's consulting engineers, Gee &
Jensen, designed and tested the treatment method for discharged water. The
State of Florida became involved only in approving a permit to discharge purged
water to the drainage canal. The state DER tentatively approved the NPDES per-
mit, but EPA Region IV officials became quite upset at the request and orgin-
ally would not allow a discharge of TCE greater than 0 ppb. The agreement
finally worked out with DER allowed up to 1000 ppb of trichloroethylene to be
present in canal water several hundred meters downstream from the discharge
spillway.
HEALTH GUIDELINES
The Department of Environmental Regulation finally imposed a maximum allow-
able level for TCE in drinking water of 0.00 mg/1. In response to earlier
requests from Vero Beach, the DER merely sent the City a copy of a Federal
Register which discussed EPA's approach to setting health standards. Appar-
ently., DER later adopted the policy of limiting public exposure to potential
.carcinogens as much as possible.
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CONCLUSIONS
The case of organic contamination in ground water at Vero Beach is somewhat
unusual ih that the City and the organization that caused the contamination
worked together to resolve the problem, without assistance from the state
health" and enviromental agencies or EPA. In fact, Vero Beach officials claim
they could have resolved the problem equally as well and much more rapidly
without the state and EPA becoming involved. Frequent and confusing personnel
turnovers at the EPA Region IV office and the lack of knowledge about the
effects of TCE in a saltwater environment were sources of irritation to local
officials. Although individual contacts proved helpful, the slow pace of
bureaucratic response was difficult for local officals, highly concerned with
a potentially serious ground-water problem, to understand.
A major reason for the Region's slow response was the lack of information
available on the environmental and health effects of trichloroethylene and the
other organics present in the ground water. Region IV simply had not had much
experience with this type of problem. The NPDES process also seems inadequate
for emergency pumping to purge aquifers of contaminants. The dichotomy
between justifying industrial discharges versus efforts to prevent the spread
of potential carcinogens to public wells should be recognized.
The testing, monitoring, and treatment design aspects of the Vero Beach
case were handled competently by a private research foundation and the City's
consulting engineering firm. The state agencies involved, however, were not
able to provide useful information to the City, partly due to their relative
inexperience with the health effects and control methods associated with
organic chemicals in ground-water supplies.
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ELKHART WATER WORKS
ELKHART, INDIANA
SUMMARY
The Elkhart Water Works was one of a thousand community water supplies
sampled by EPA in a nation-wide ground-water program concluded in 1982. In
April 1981 Elkhart was told that 94 ppb of trichloroethylene had been found in
the city's finished water. Followup well-by-well sampling resulted in several
wells being closed, leaving Elkhart with insufficient capacity for a normal
summer. . ' . ' .
More well tests, samples from observation wells drilled by the Water Works
for EPA, and a study by the Water Works' consulting engineers.outlined the con-
taminant plume and suspected sources by the Spring of 1982. At present, two
interceptor wells between the sources and the main well field are being pumped
to waste to purge the aquifer and keep the contaminants from migrating into
the well field's*zone of influence. No significant change in contaminant
levels has been observed, and Water Works officials are planning another study
to conclusively identify the source so remedial actions can be taken.
BACKGROUND
The Elkhart Water Works is a public utility, managed by a board of trustees
under the Indiana Public Service Commission, that supplies the majority of
water consumed in Elkhart, Indiana. The Water Works has 12,600 accounts for
approximately 36,000 people in this city of 41,000. The remainder of the popu-
lation is served by private or subdivision wells.
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Elkhart's water supply comes from three well fields. The North Main Street
Well Field has 15 wells, each with an average depth of over 50 feet and rated
at dbbtlt 1 mgd each. The Bower Street Well Field on the west side of town has
two wells 70 feet deep and one well 135 feet deep, with a total design capacity
of 4.5 mgd. The newest supply, the South Well Field, was put into service in
1966. South Well Field has three wells, each 100 feet deep with a combined
design capacity of 3 mgd. Several of Elkhart's wells have been placed on
reserve, due to high iron levels or other problems. With all wells pumping,
maximum capacity is near 20 mgd, three-quarters of which is from the North
Main Street Well Field. Peak demands at North Main Street are in the range of
12 to 14 mgd, with off-season lows near 5 mgd. The Water Works operates a 6.5
million gallon storage system, with 2.5 million gallons of that total elevated.
The United States Geological Survey completed a three-year study of north-
western 'Elkhart County in 1981 to define the general flow and quality .of water
in the outwash system, to determine if a proposed well field near the Municipal
Airport (northwest of the city) would draw leachate from an industrial land-
fill, and to define the areal extent of ground-water contamination at an east-
side industrial park and landfill. The hydrologic portion of the study
reported that the outwash aquifers underlying the region are mainly composed
of sand and gravel and are separated by a thick silt and clay bed. The satu-
rated thickness of these deposits averages 175 feet and ranges from 85 to 500
feet. Under most of Elkhart, the silt and clay bed confines the underlying
aquifer. Average hydraulic conductivities of the sand, and the sand and
gravel, are 80 and 400 feet per day, respectively. Regional ground-water flow
is toward the St. Joseph River. The sand and gravel soil has been described
as "highly vulnerable."
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The USGS investigation discovered that ground-water quality had, as
expected, been degraded in some areas near Elkhart by liquid and solid waste
disposal practices. Volatile organic compounds have been detected in residen-
tial wells near an industrial area in east Elkhart. The landfill on the north-
w§St Side was closed because leachate penetrated the shallow aquifer, uncon-
fined at that point.
DISCOVERY OF THE CONTAMINATION PROBLEM
Through preliminary reports of the USGS study described above, Elkhart
officials had reason to suspect volatile organics might be present in drinking
water. In April 1981 EPA Region V notified the Water Works that Elkhart was
on the list of 1,000 community water systems due to be tested for organics.
When test results came back in May, EPA informed Elkhart that the finished
water from the North Main Street plant contained 94 ppb of trichloroethylene.
More samples .were then taken to confirm early tests. The results of these
follow-up analyses showed 57 ppb in the finished water and 270 ppb in the most
heavily contaminated well, Well E. As much as 880 ppb of trichloroethylene
has been detected in observation holes and closed production wells since.
. " /
ACTION TO PROTECT WATER.QUALITY
In Elkhart, as in most cities faced with organics in their drinking water
supplies, the short-term action taken to protect water quality was to close
contaminated wells. Here, however, confusion over the allowable levels of TCE
made the decision to close wells less clear-cut. The Indiana State Board of
.Health (ISBH) thought that 75 ppb (EPA's Suggested No Adverse Response Level)
was allowable while EPA wavered between 45 and 4.5 ppb (the National Academy of
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Science estimated 1 in 106 and 1 in 107 increased cancer risk levels).
When the contamination problem was discovered, the Water Works took a conserva-
tive approach and immediately closed down the wells that showed significant
amounts of TCE. In May 1981 water from one well contained 270 ppb TCE, so the
definition of 'significant' was not critical. Since then, wells with as low
as 17 ppb TCE have been closed to keep the quality of the finished water as
high as possible. Water from the North Main Street plant now contains less
than 1.5 ppb, but officials are not certain that they could always meet an EPA
standard of 4.5 ppb for trichloroethylene.
One month after trichloroethylene was discovered in water from the North
Main Street plant, the Water Works, under the supervision of an EPA Region V
hydrologist, drilled five 2-inch observation holes generally upgradient of the
well field. These 30 feet deep holes were to determine the direction the con-
tamination was coming from. Test results in early July showed high contamina-
tion levels (several hundred parts per billion of TCE) in observation wells
east of the well field. The observation holes and production wells continued
to be sampled every two weeks to provide data for planning further efforts.
After EPA's initial involvement, the Indiana State Board of Health took
over as the nominal lead government agency. The ISBH continued sampling and
organized several meetings with the agencies and suspected industrial sources
involved.
In the spring of 1982, the water utility hired Canonie Environmental to
determine the extent of the trichloroethylene contamination. Under Canonie's
supervision, the Water Works drilled eighteen more observation wells. Most of
the wells were east of the North Main Street plant, around the suspected indus-
trial sources. The suspected sources, the Excel and DuraKool companies, both
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used TCE in plating operations. Canonie sampled all the wells installed up to
that point in March and was able to outline the areal extent of the plume
faltly Conclusively, since the wells were relatively close together. Begin-
ning in May 1982, all water samples were sent to a private lab, since the ISBH
lab cduld not provide the rapid turnaround time required.
At the conclusion of their study, Canonie presented several alternatives
to the Water Works Board. One alternative was to install a north-south slurry
wall between the source and well field, a four hundred foot'long barrier
extending south to Christiana Creek. On the east side of the slurry wall,
interceptor wells would be placed to draw out the contaminated water. A second
alternative was to install interceptor wells on the western edge of the indus-
trial sites, irrigate to leach out the organics, and pump the interceptors to
waste in the creek.
The Board, in consultation with EPA, the State, and the companies, decided
to put two interceptor wells on the western edge of the DuraKool property.
' When Elkhart went to install the wells, however, DuraKool would not let any
drilling take place until the Water Works released DuraKool from any liability
in the contamination case. Water Works officials balked at this request and
placed, the wells directly across North Main Street on the eastern edge of the
North Main well field.
After protracted negotiations, the Water Works obtained a NPDES permit
from the State to discharge water from the interceptor wells to Christiana
Creek. The state allowed discharges containing up to 500 ppb of trichloro-
ethylene on the condition that some progress towards reducing these levels be
made within nine months. The utility began pumping to the Creek in August
1982, at a rate of about 4 mgd. Some field tests of simple air-stripping
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methods, such as discharging the contaminated water through perforated plastic
pipe, have been shown to reduce TCE concentrations in the effluent by as much
as 40 percent, but the outfall presently runs directly into the Creek. The
concentration of TCE in the effluent has varied around 300 ppb.
the State Board of Health has strongly recommended that the source of con-
tamination be |ocated and removed. The ISBH told Elkhart that they should
consider air stripper and granular activated carbon treatment methods, as well.
Elkhart experimented with rudimentary air-stripping, as described above, and
contacted Calgon for information on portable GAG units, should the need arise.
The state itself has become involved in on-site inspections and soil sampling
on Excel and DuraKool property.
CURRENT STATUS
The Elkhart Water Works is now. assuming that some remedial action must be
taken, since concentrations of TCE' in the interceptor wells have not, declined..
One factor that may force action is the ISBH NPDES permit, which requires
Elkhart to show in early 1983 that effluent levels in water pumped to
Christiana Creek have declined. The. Board of Health has warned as recently as
October 1982 that it objectives in the Elkhart case are to:
1) determine the extent of the contamination problem;
2) determine the need for emergency remedial actions;
3) identify the responsible parties;
4) solicit proposals for permanently remedying the situation;
5) work out a plan with the parties involved to pay for remedial action;
and
6) begin remedial actions as soon as possible.
The Water Works has asked Canonie Environmental to submit a proposal for
more work to pinpoint the source(s) of contamination. At the same time,
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Elkhart is looking for more witnesses employed by the companies suspected of
dumping the chemicals. The water utility has spent about $150,000 thus far on
the problem and, in the absence of government funding, must find the source of
contamination to shift liability and the costs of clean-up to that party.
Comprehensive on-site clean-up efforts could easily cost several million
dollars. In the meantime, Elkhart is spending $1,200-1,400 per month on
electricity to pump the interceptor wells, and $1,500 per month on laboratory
fees.
Despite local efforts, the water supply for Elkhart is still restricted.
If the summer of 1983 is accompanied by normal water demands, the Water Works
will be very hard-pressed to meet those demands. One option for increasing
water supply is to accelerate existing plans for the new well field on the
northwest side of the city, but officials are still uncertain whether demands
could be met.
INSTITUTIONAL INVOLVEMENT.
A number of parties were involved in different aspects of the Elkhart
ground-water contamination case. The USGS was one of the first agenices to
become involved, when their investigation of ground water in Elkhart County
discovered two areas where waste disposal practices had contaminated ground
water. A national EPA survey of community water systems then detected the
prganics in the North Main Street well field.
After EPA's initial involvement, the City Water works and the Indiana State
Board of Health directed efforts to find the source and to prevent the further
spread of contamination. The ISBH dealt with the suspected industries very
firmly and has insisted the industries take major actions soon to resolve the
problem. The Water Works capably managed the initial investigation and hired
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a ground-water consulting firm, Canonie Environmental, to trace the source and
to present alternatives to the state for securing a safe water supply.
HEALTH GUIDELINES
The Indiana State Board of Health generally passes on EPA information with-
out much interpretation. In the Elkhart case, the ISBH was initially recom-
mending a maximum allowable level of 75 ppb for TCE (the level of the EPA SNARL
for chronic exposure) but has reportedly been suggesting a limit of 45 ppb (the
concentration at which the NAS estimates a 1 in 10s increased cancer risk).
The confusion surrounding the meanings of these items and what is truly "safe"
has. complicated the decision-making process immensely.
CONCLUSIONS
The case of organic contamination at the North Main Street well field in
Elkhart has been a troublesome one. Although the wells found to be contami-
nated were immediately closed, and finished water quality (averaging 1-2 ppb
TCE) is now being very carefully monitored, several problems still exist.
Ground-water investigations have not yet conclusively implicated the suspected
industrial sources. One of the sources has closed down local operations and
may be hard to prosecute. Success in pumping out the contaminated zone of the
aquifer to waste has been slow and it appears it will take quite a while to
reduce TCE levels in local ground water. The City's capacity to supply water
remains drastically reduced and next summer could bring dangerously low water
levels. On top of these problems, the Water Works is running out of money to
continue investigations.
Water Works officials feel that they should not be responsible for paying
for investigative and remedial actions and would like to see the state or
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federal government assist financially,. Technical assistance requested on the
case was for more health effects information, improved subsurface monitoring
methods, and research on aquifer management technologies to direct the move-
ment of the contaminant plume away from the remaining production wells.
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CITY OF BATTLE CREEK
MICHIGAN
SUMMARY
In 1981 sampling of private wells near a Battle Creek landfill accidentally
Uncovered the presence of organic contaminants in the municipal water system.
After the city notified the state of the problem, the Department of Natural
Resources applied to EPA for assistance. While EPA conducted a preliminary
investigation, the city pumped the two most heavily contaminated wells to
waste. Eighteen of thirty municipal wells eventually had to be closed, in
accordance with Michigan Department of Public Health recommendations that no
organics-contaminated water be supplied to the public. The County Health
Department found that over 80 private wells between the public wellfield and
the suspected industrial sources were significantly contaminated by as many as
seven volatile organic chemicals.
The wells pumping to waste were shut down recently when a USGS report
showed that increased pumpage was drawing contaminated ground water toward the
wellfield. Meanwhile the demand for municipal water has increased due to the
discovery of various organics in several cereal manufacturers' wells (and the
subsequent closures of the wells), which has heightened the severity of the
water supply shortage. Efforts to supplement the water supply through treat-
ment or alternate sources have been of secondary importance relative to locat-
ing the source(s) of contamination and establishing legal liability. The situ-
ation at Battle Creek remains one of the potentially most serious organics con-
tamination cases in the Midwest.
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BACKGROUND
The City of Battle Creek owns.and operates one wellfield located in the
northwest portion of the City. The Verona wellfield supplies water to the
City of Battle Creek, an industrial park, and parts of four townships. The
total population served is slightly over 50,000 persons. Several major break-
fast cereal maufacturers also obtain their potable and production water from
the city system. These manufacturers and other industries are located south
of the wellfield, beginning several hundred yards down the valley. A railroad
yard crosses northeast through the industrial complex to the wellfield.
Between the wellfield and the industrial complex lies a residential section of.
100 to 150 older homes. These residences obtain water from .relatively shallow
private wells. ..,'.' - . -...-.
The Verona wellfield, which borders on the Battle Creek River, has four
production wells on the west side of the river and 30 on the east (see Figure
BC1). Most of the municipal wells tap the Marshall sandstone formation at
depths of 100 to 160 feet. Residential wells in the area generally tap the
upper Marshall formation and the overlying glacial deposits, .only 20 to 60
feet deep. Some of the municipal wells drawing from the Marshall formation
are capable of yielding several thousand gallons per minute. Battle Creek had
thirteen wells that could consistently yield 1,000 gpm each. These and other
...wells can be pumped at high rates without significant drawdown. Depending on
seasonal demand, pumping from the Verona field ranges from 7,000 to 12,000
gpm. The annual average is .about 9,000 gpm. Of this total, about 5,000 to
6,000 gpm is currently pumped to just two industries.
Ground water in the immediate area generally flows towards Battle Creek
River, except, at Verona wellfield where flow is towards the production wells
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C-72
being pumped. At peak summer periods (when withdrawals are as. high as 12,000
gpnO, water is drawn to the wellfield from several thousand feet away. During
these periods, water is drawn to the wellfield from strata underlying the
industrial sites. In winter, when withdrawals are normally 7,000 gpm, the
Zone of influence is smaller, and the east-west divide between water flowing
to the wellfield and water under the industrial sites flowing to the river
shifts northward, reducing the movement of water under the industrial sites to
the wellfield.
DISCOVERY OF THE CONTAMINATION PROBLEM
In August 1981, the Calhoun County Health Department took water samples
from residences with private wells in the northwest part of the city. The
sampling was undertaken in response to complaints of taste and odor problems
in wells near the Cereal City Landfill, 'several miles from the Verona well-
field. When the test results came back from the state labs, county officials
notified one residence, a rectory, that volatile organic chemicals had been
discovered in the well water and that the residence should consider hooking up
to city water. The minister informed the county that his .water was not from a
well, but from the municipal system.
The health department took more samples to confirm the preliminary find-
ings. When the results showed that low levels of organics were indeed present
in municipal water, they notified the city of the problem. The city immedi-
ately began testing through the distribution system and at the Verona wells.
These September 1981 tests showed that ten wells had some degree of organics
contamination. Plant tap water contained 10 ppb of cis-1,2 dichloroethylene,
4 ppb of trichloroethylene, and smaller amounts, of dichloroethane, perchloro-
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C-73
ethylene, and trichloroethane. Individual well samples showed levels as high
as 12 ppb for dichloroethane, 91 ppb for trichloroethane, 66 ppb for dichloro-
ethylene, 26 ppb for trichloroethylene, and 44 ppb for perchloroethylene.
ACTIONS TO PROTECT WATER QUALITY
The position of the State of Michigan .Director'of'Public Health is that
every effort should be made to limit the amounts of organics in drinking water.
Consequently, the ten Battle Creek wells that showed any contamination (over 1
ppb, defined for these purposes as the detectable limit) were closed. The
Director's position was formalized in a December 1981 letter that presented
the state policy on organics and public health. In that letter, the director
underscores the frustration of having to make such an important decision on
the basis of incomplete information, and opts for the most;conservative choice.
Besides closing the contaminated wells, other short-term responses to the
discovery of organics in Battle Creek's water included continued weekly testing
of city wells, initiation of a program by the county to sample nearby private
wells, and notification of the public about the organics problem and associated
health risks. Since levels of contamination appeared highest in wells on the
southeastern edge of the wellfield, city and state officials assumed the con-
tamination was moving from the southeast towards the northwest. To keep the
contamination.from spreading further into the wellfield, the two most heavily
contaminated wells, Nos. 32 and 35, were pumped to waste in the river. Contin-
ued monitoring has led to eight more wells being closed, leaving only twelve
wells (capable of 9,150 gpm, less than half of the city's previous production
capacity) in service.
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Simultaneous testing by the Calhoun County Health Department began turning
up private wells south of the wellfield with organics contamination. The
following table compares levels in public wells with levels in private wells
for the seven organic chemicals detected. Since laboratory limitations (all
MAXIMUM LEVELS OF ORGANIC CHEMICALS
IN WELL WATER
Contaminant
Concentration in
City Wells (30)
(ppb)
Concentration in
Private Wells (over 100)
(ppb)
perchloroethylene
trichloroethylene
cis-1,2 dichloroethylene
1,1 dichloroethylene
1,1,1 trichloroethane
1,1 dichloroethane
1,2 dichloroethane
44
34
79
5
99
12
3
230
657
3,900
38
43
149
325
organics tests for the city and county were run by the State Department of
a
Public Health) allowed the county to test only a dozen or so wells at any one
time, it took several months to find that a large number of wells were
seriously contaminated. One year later, some wells still had not been tested.
The County has developed' three form letters to notify residents with con-
taminated wells; these explain that the well water should not be used for
drinking, should not be used for cooking or drinking, or should not be used
for bathing, cooking, or drinking, depending on the degree of contamination.
In all cases, private well owners are now told where they can pick up city
water for household use. One of the companies suspected of causing the ground-
water problem has agreed to buy $5000 worth of bottled water for residents with
contaminated wells.
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In November 1981, the Michigan Department of Natural Resources (DNR) pre-
pared an emergency action plan to obtain EPA assistance on the suspected con-
tamination sites. The plan contained a site summary, site status, and emer-
gency action plan. In late December EPA agreed to provide a response to the
tiMR plan. ' , ,
, The first, phase of the EPA response was handled by a Technical Assistance
Team (TAT) from EPA's contractor, Ecology & Environment,, Inc. The TAT drilled
15 wells near the wellfield and both upgradient and downgradient from the sus-
pected sources. Water and soil samples were collected and analyzed. The
l
results of the TAT .investigation indicated that three sites could have contri-
buted to the organics problem in Battle Creek .ground water; an industrial sol-
I
vent reclamation facility that handled large quantities of the; substances in
question, a railroad yard and former maintenance facilities where degreasers
were used, and a landfill located one mile south of the wellfield. The TAT
study was limited to a $25,000 budget but was sufficient to place Battle Creek
on the Superfund national priority list, allowing EPA to provide additional
assistance. . . .
By February 1982, the agencies involved in the Battle Creek case had been
organized into a Task Force under the guidance of the state Department of
Public Health (DPH) Regional Engineer's office. The following organizations
are represented on the Task Force:
Michigan Department of Public Health (DPH) .
, Michigan Department of Natural Resources (DNR)
U.S. Geological Survey (USGS)
U.S. EPA, Region V, Office of Superfund
Calhoun County Health Department.
City of Battle Creek
Kellogg Company .
General Foods Corporation (Post)
Ralston Purina Company
Michigan Department of Commerce
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The Task Force was set up to coordinate activities directed towards defining
the source and extent of the problem and, subsequently, controlling the con-
tamination problem.
The cereal companies are on the Task Force because of their concerns about
using contaminated water in their manufacturing processes. Several of the
cereal companies' wells showed low levels of organics. To keep their product
as "wholesome" as possible, they switched over to city water in February 1982.
The increased demand severely taxed the already reduced capacity of the Battle
Creek system. In the previous year, the City had completed a new $4.5 million
high capacity pumping station that was to provide enough capacity for an esti-
mated 20 years of local growth. When Kellogg and General Foods switched to
city water, they increased base demand by 4,000 to 5,000 gpm, roughly doubling
the amount of water the City had to supply. The capacity deemed sufficient
for 20 years of growth was used up in one month. Besides straining the City s
water supply capacity, the increased pumpage drew more water from the contami-
nation zone towards the wellfield.
In the summer, while the DNR and EPA were concluding site investigations,
the City of Battle Creek contracted with USGS for some ground-water modeling
studies of the six by six square mile area around the wellfield. The $32,000
study concluded that shifting pumpage patterns would not prevent migration of
contaminants toward the Verona field. In fact, simulations showed that with-
drawing 2,000 gpm at Well Nos. 32 and 35 near the south edge of the field was
compounding rather than alleviating migration towards wells. Battle Creek,
therefore, stopped pumping the wells to waste in August 1982.
The City also began designing an additional high service system to supply
customers. The USGS report was relied upon to provide the background basin
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C-77
information required to place additional high-capacity city wells. In other
efforts, the County represented the townships in, negotiations with the Depart-
'-- ' . '-' ' f, i '. >
rtient of Commerce to secure funding to extend City water mains to the affected
private homes.
In the fall of 1982, the City and a national ground-water consulting firm
sponsored a conference in Battle Creek on volatile organic compounds in ground
water., Over sixty state and local government and industry representatives
attended. All reports indicated that the conference was highly successful in
providing technical information and a basic education in ground-water contami-
nation.
CURRENT STATUS
In October 1982, EPA Region V Superfund officials met with the three sus-
pect companies to work out a plan of remedial.action. By the end of November,
EPA wanted the companies, singly or collectively, to agree to take responsibil-
ity for further efforts, to undertake a feasibility study, and to outline the
scope of work for permanent remedial measures. The companies suspected of
causing the organics contamination are not expected to comply willingly, since
none have been proven guilty of contaminating Battle Creek's drinking water.
The Michigan DNR and EPA are handling negotiations with' the suspect com-
panies. The two agencies are also expected to begin evaluating treatment
alternatives. The Michigan DPH is keeping a close watch on the situation and
searching for more health information. Ca'lhoun County is negotiating with the
State Department of Commerce to extend water mains to the owners of contami-
nated private wells. The county Health Department is also still sampling pre-
viously untested private wells. The next steps in resolving the Battle Creek
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water crisis will depend on the outcome of additional hydrogeological investi-
gations by the EPA Field Investigation Team and legal discussions.
INSTITUTIONAL INVOLVEMENT
the lead agency in the Battle Creek organics case has been the Michigan
Department of Public Health. Officials in the DPH office of Water Supply
direct the Task Force.of local, county, and state government and industry
representatives. Since the discovery of organics in drinking water supplies
for Battle Creek and several other municipalities, DPH has initiated a state-
wide sampling program for public water systems. The laboratory in Lansing is
the only DPH facility in the state capable of testing for halogenated and nori-
halogenated organic compounds. Severe budget cutbacks in Michigan have forced
all of the state's branch labs to close.
Several of the agencies in the Task Force have been more heavily involved
in tracing the source of contamination and assuring a high quality drinking
water product than others. The roles of the major agencies have been as
follows:
Michigan Department of Natural Resources.
The DNR has been the primary state agency involved with site
surveys, hydrogeological investigations, and industrial discus-
sions to find the source of and clean up the assorted organics in
ground water. DNR has a drilling rig and a hydro/geo staff cap-
able of aquifer studies, but again, budget cutbacks have slowed
responses to water quality problems.
U.S. Geological Survey .
The study USGS performed for the City was quick and thorough. In
the course of the study, the USGS determined ground water flow
patterns and rates and made suggestions on pumpage patterns to
minimize drawing contaminated water to the Verona wellfield.
Several dozen observation wells drilled by USGS (in addition to
wells drilled by the EPA TAT) are still available for sampling to
monitor the position of the contamination plume over time.
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U.S. EPA
EPA Region V has been a major participant in resolving the problem
at Battle Creek, mainly through their Superfund Office. The
Technical Assistant Team study, completed last spring, and the
Field Investigation Team work, still in progress, are .the two main
efforts to determine the source(s) and extent of the organics in
ground water. The Office of Superfund is also involved in
negotiations with the suspected sources to set up and ascertain
funding guarantees for remedial actions on the industrial sites
and possibly at the City wellfield.
Calhoun County Health Department
The County Health Department has worked closely with DPH to
sample private wells that might be contaminated by organic com-
pounds, jSince August 1981, the county has tested over 120 wells,
mostly in the residential area south of the Verona wellfield.
About two-thirds of the wells tested have proven to be contami-
nated with at least one of the compounds previously mentioned.
The Health Department would like to do more sampling, but this
effort is constrained by limited laboratory capacity at Michigan
DPH. . ' . .
City of Battle Creek
The City has been involved in most of the work done so far to
find the source of and a solution for the contamination problem,
and has worked especially closely with DPH. EPA and Michigan DNR
have been working more closely with each other, rather than with
the city, although the Task Force has been effective in bridging
communications gaps between the agencies.
Battle Creek has not had to spend a large amount of the Water
Department budget on the organics problem, but the situation has
been very time-consuming. Since the state lab has provided all
the analytical work, the US6S project and small changes in the
water system have been the only direct expenses incurred. Still,
the organics problem is using enough resources to require rate
increases in the near future, especially if the City has to pay
for new wells or major system upgrading.
HEALTH GUIDELINES
As discussed earlier, Michigan has no "action levels," per se, for respond-
ing to organics in drinking water. Instead, the Department of Public Health
considers each case individually and makes, recommendations to limit human
exposure to potential carcinogens as much as possible. In the case of Battle
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Creek, every well that showed contamination by organics was closed, since some
of the lost capacity could be made up by increasing pumpage from other wells.,
It is doubtful, however, that normal summer demands can be met by the existing
number of wells. In other organics cases in Michigan, such as Petoskey, sole
supplies have not been closed since alternative sources were not available.
Department of Public Health officials would welcome more information on
the health risks associated with various organics in drinking water, but
express hesitation at accepting a federal standard, preferring to have more
discretion in protecting water quality.
CONCLUSIONS
The Task Force members are proceeding relatively smoothly towards resolving
the problems of various organics in Battle Creek wells. Several strengths and
weaknesses in response to the problem are noted below:
Qualified, concerned assistance was available to the City from
the State of Michigan.
Some communication lapses between agencies hindered progress,
but formation of the Task Force improved coordination.
Severe State budget cutbacks have limited organics analysis
capabilities. Private wells that may be severely contaminated
still have not yet been tested.
« With seven VOCs present in Battle Creek wells and three sources
suspected, investigative efforts have become very complicated.
An educational conference on volatile organics in ground water
was sponsored by a private ground-water consulting firm. Many
local, state, and industry representatives attended and spoke
very highly of the value of this type of meeting.
Delays in Superfund investigative efforts have mildly frus-
trated local officals who need a solution to their problem soon.
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CITY OF PETOSKEY
MICHIGAN
SUMMARY
During testing for trihalomethanes in the City of Petoskey's water supply,
tirichloroethylene and cis-1,2 dichloroethylene were found at concentrations of
45 ppb and 20 ppb, respectively. Since the city has only one well, located on
the Lake Michigan shoreline, the source could not be closed down. The State
Department of Public Health and Department of Natural Resources have been
following the case closely since 1981 to isolate the source of contamination
and locate a new water supply. At present, contaminant levels have declined
somewhat but well drilling has not yet found a new supply capable of sustain-
ing the pumping rate required.
BACKGROUND -
The City of Petoskey is a small .community located on the Lake Michigan
shore in the Northwestern Lower Peninsula. The entire water supply for the
City comes from one large infiltration well 50 feet from the Little Traverse
Bay shoreline; a cone-shaped pit about 36 feet wide and 17 feet deep. The
well is capable of providing 3,000 gpm (4.3 mgd) without noticeable drawdown.
Average daily demands are about 1.4 mgd, with summer peaks (due to resort
customers) near 2.1 mgd. The raw water is fairly soft and low in iron, as
might be expected of lake water. Chlorination and fluoridation are the only
treatments applied to the raw water before it is pumped into the distribution
system.
One well has provided a sufficient supply of water for the 10,000 persons
served in the City and parts of adjacent townships. For the past several
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years, however, the Michigan Department of Public Health (DPH) has been urging
the city to install another well because of the vulnerability of the pit well
in the City and because state policy recommends at least two sources of water
to maintain a reliable supply. Petoskey has directed a ground-water consultant
to begin looking for a suitable location for a new well.
DISCOVERY OF THE CONTAMINATION PROBLEM
On August 12, 1981 a water sample was collected from the Petoskey water
system for trihaloraethane (THM) analysis. The sample was collected by DPH in
response to an inquiry by the local health department director. Although the
finished water received chlorination, it had not been sampled previously
because the source was technically defined as ground water and the water
system was small enough to be excluded from EPA monitoring requirements.
As expected', the THM levels were low. The analysis performed by the state
laboratory, however, showed the presence of two other" organic compounds, tri-
chloroethylene (TCE) at 12 ppb and dichloroethylene at 7 ppb. DPH notified
the city manager and water superintendent of the sampling results and the
significance of the organic compounds. Five more samples were collected at
various points in the water system in early September. The table below shows
the results of the analysis of those samples.
Compound
cis-1,2 dichloroethylene
trichloroethylene
1,1 dichloroethylene
DPW
Garage
11
19
ND
City
Hall
23
38
ND
Lockwood
Hospital
21
35
ND
Plant Tap Plant Tap
(New Pump) (Old Pump
7 27
12 45
ND >1
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C-83
All samples showed the presence of some THMs, but total trihalomethanes were
at levels of 18 ppb or less. The results of the plant tap sample from the old
pump station were confirmed using mass spectroscopy. Selected samples were
analyzed using a full VOC scan. No other organics showed up at significant
levels, although low concentrations of phallates were noted. Continued
testing over the past year has indicated that organics levels are declining
slightly.
ACTIONS TO PROTECT WATER QUALITY
The normal response in Michigan to detection of organic contaminants in a
public well is to close down the well. The State has no "action levels" set
for organics, but suggests that the levels of organic chemicals in drinking
water be limited as much as possible. In some cases, wells showing 1 ppb of
TCE have been closed. At Petoskey, the city only has one well, and the pre-
sence of 20 ppb of TCE in the water system was deemed less hazardous to public
health than closing down the City's entire water supply. No other water sys-
tems are close enough to Petoskey to make an intersystem connection feasible.
City officials met with their consulting engineers and the local health
officer on September 16, 1982 to discuss a response to the problem. They
decided it was necessary to inform the public of the presence of the organics
in drinking water and issued a press release explaining what was known about
the problem. Continued sampling was planned, including raw water samples and
plant tap samples to ensure that contamination was not being introduced by the
chlorine or fluorine feed systems. The City used an independent laboratory
for their followup analyses.
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O84
Results of additional testing showed that levels of trichloroethylene and
dichloroethylene were consistently twice as high in samples from the old pump
station as from the new pump stations. The intakes for each station are only
several feet apart in the well. The majority of pumpage has since been shifted
to the new pump station to lower the amounts of organics sent to the distribu-
tion system.
At the September meeting, the City also authorized their engineers to pro-
ceed with developing specifications for a test well located 1/2 mile southwest
of the City. The proposed site for the new water source had been reviewed and
approved for test well drilling. A 2" hole drilled on that site hit an aquifer
at 240 feet that appeared to have sufficient quantity. The severe winter
slowed drilling operations, so it was not until March 1982 that a 6" test well
was completed. Test pumping showed that nitrates were consistently present.
«
The results of several analyses indicated that 6 to 7 mg/1 of nitrates were
present, uncomfortably close to the drinking water, standard of 10 mg/1.
Because of the nitrate problem, the search for a new city well was expanded
to several other sites, and some test holes were drilled. No other location,
however, has proved to yield as high a flow rate of water as the first, and
the city is uncertain about what to do next.
Shortly after the contamination problem was discovered, the Michigan
Department of Natural Resources (DNR) became involved in investigating the
source of the organics. A site visit to a small manufacturing firm 500 feet
from the well and subsequent soil samples at that site tentatively implicated
that firm as the source. The DNR sent in a drilling crew to establish ground
water flows and outline the contamination zone. In drilling six monitoring
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C-85
wells, three different ground-water flow directions were noted. Although water
levels were the same in all wells, it was very difficult to pump much water out
of the rock for analysis. In short, investigative efforts have been stymied by
unusual hydrogeologic conditions along the shoreline.
the above ground investigations by DNR on the plant site have been more
successful. In the spring of 1982, officials from the DNR field office came
on site and had barrels of hazardous wastes removed. An area of contaminated
soil was also excavated. The excavation was covered with an impermeable liner
and then backfilled. The purpose of the liner is to prevent more substances
from leaching into the ground-water table. The owners of the manufacturing
plant have been cooperative in assisting cleanup efforts.
CURRENT STATUS
Presently, the City of Petoskey is still trying to find a satisfactory site
for a new> secure well. The city and state have spent over $200,000 thus far
on the case. The Michigan Department of Public Health is still assisting the
City in finding a new source, and has recently met with the City's engineers
to authorize more test wells. The Petoskey City Council has been under pres-
sure from the press and the public to show progress in resolving the contamina-
tion problem. Finally, DNR has slackened efforts to trace the source of con-
tamination through hydrogeologic studies. Thus far, the state has not been
able to make a solid case against the suspected source.
INSTITUTIONAL INVOLVEMENTS
As in most cases, institutional response to the detection of organics in
Petoskey's well was focused in two areas. The Michigan Department of Public
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C-86
Health had been urging Petoskey to find a new well, and accelerated efforts to
find a new drinking water source once the old well was found to be contami-
nated. The Department of Natural Resources directed efforts to find and con-
trol the source of contamination, including drilling monitoring wells near the
production well and suspected source and conducting a hazardous waste excava-
tion and removal project on the industrial sites.
HEALTH GUIDELINES
The Director of Public Health in Michigan recommends that public exposure
to potential carcinogens be limited as much as possible, promoting a no-thres-
hold-level policy. In a situation such as that at Battle Creek, where lost
water production from contaminated wells can be mostly made up by increasing
pumpage from clear wells, this policy means that any well showing organics
contamination should be closed. At Petoskey, however, where the City depends
on one well for its entire water supply, the potential hazards of closing that
well are greater than the risks associated with keeping the well open. The
only option in this case was to notify the public and accelerate the search
for alternate supplies.
CONCLUSIONS
The Petoskey case was the only situation studied in which a well defined
as contaminated was still being used. Present trichloroethylene levels are
around 20 ppb, a concentration that would be quite acceptable in New York,
where the state guidelines limit a single VOC to 50 ppb. Local and state
officials expressed a need for more health effects information to get a better
idea of the health risks faced by Petoskey residents.
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C-87
Another stumbling block in resolving the Petoskey case was the difficulty
with drilling and monitoring along the lakefront. The shallow rock and unusual
hydrology have stalled efforts to trace the trichloroethylene and dichloroethy-
lene found in the City's well back to the source. Although responsibility has
not been proven, the industry suspected of being the source has cooperated with
surface cleanup plans.
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O88
NEW BRIGHTON
MINNESOTA
SUMMARY
In July 1981, the City of New Brighton was notified by the Minnesota
Department of Health that trichloroethylene and other, related organic solvents
had been identified in most of the city's wells. The city discontinued use of
the most heavily contaminated wells and increased pumpage from the uncontami-
nated wells, supplemented as needed by water from mildly contaminated wells.
The public was notified of the problem and sprinkling restrictions were
announced to keep demand down during peak-use summer months. ...A request for
Superfund assistance in developing new water supplies was turned down, but the
city began a program of recompleting wells in deeper intervals anyway, at a
fairly large expense. At present, the previously "clean" wells are picking up
traces of contamination, but the newly-completed wells- appear free of organics,
and should be able to meet immediate demands. Efforts to trace the source of
contamination have centered around the Twin City Army Ammunition Plant, and
the Army has begun on-site investigations.
BACKGROUND
The City of New Brighton is a suburb on the north side of Minneapolis,
Minnesota. The Department of Public Works has a total of eight fairly deep
(around 400 feet) wells serving 23,500 of the city's residents. At the time
organic contamination was discovered, average daily demand was about 2.5 MGD
with summer peaks running around 6 to 7 MGD. Only six of the eight wells were
on line at that time, since one well was down for repairs and the oldest well
was used only as a standby supply.
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C-89
DISCOVERY OF THE CONTAMINATION PROBLEM
By early 1981, the Minnesota Pollution Control Agency (MPCA) had set up a
strike force unit to identify and investigate hazardous waste dump sites.
Acting on a tip about past disposal practices at the Twin Cities Army Aramuni-
tibn Plant (referred to as the "arsenal"), MPCA sampled private wells around
the arsenal in July. When a variety of organic chemicals in well water were
identified in this testing, the Pollution Control Agency immediately notified
the Minnesota Department of Health (MDH), the agency with jurisdiction over
public water supplies.
The Department of Health sampled public wells in the area and discovered
the contamination to be fairly widespread. The water supplies for the City of
New Brighton, two other municipalities, the arsenal and a trailer park were
found to be contaminated, as were several hundred private wells near the
arsenal. Trichloroethylene, trichloroethane, dichloroethylene, and dichloro-
ethane were the contaminants detected most frequently. Of the New Brighton
wells, four had TCE concentrations between 150 and 200 ppb, two had concen-
trations from 5 to 10 ppb, and two wells showed no traces of contamination.
One of the originally uncontaminated wells has since shown 20-30 ppb of TCE,
leaving the city with only one clean well.
ACTIONS TO PROTECT WATER QUALITY
The Department of Health took a second set of samples tp confirm the
initial results and notified New Brighton. In discussions with the city, MDH
interpreted the health risks of the moderately high levels of organics found
in the city wells and outlined possible options to reduce the risk to public
health. The Department of Health used both the EPA Suggested No Adverse
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C-90
Response Levels (SNARLS) and the HAS increased cancer risk estimates in
explaining the situation to city officials. Minnesota had not had a similar
case of gross contamination by VOCs before, but the state reacted quickly in
setting a zero-exposure goal to reduce exposure to potential carcinogens as
mtlch as possible.
The short-term control method was to close the most heavily contaminated
wells. The City established a pumping scheme to bring contaminated wells on
line only when water demands required, in reverse order by the degree of con-
tamination. This temporary solution a-llowed base (winter) demands to be met,
but still meant that contaminated wells would have to be used in the summer.
The other immediate action taken was to notify the public of the problem. The
City hand-delivered letters to all its customers explaining the problem and
possible health effects. Shortly thereafter, the press and television media
grabbed the story and put out enough misinformation to make it difficult for
the City and MDH to keep the situation under control.
The State outlined three long-term control options that New Brighton could
take, basically treatment to remove the organics, new well construction to find
an uncontaminated source, or connection to an adjacent municipal water system.
Since the adjacent system, the City of Minneapolis, had a history of taste and
odor complaints with its surface water system, and since treatment was not
thought to be .a complete solution, the City opted for a well construction
program.
With the assistance of the Pollution Control Agency, New Brighton applied
to EPA for Superfund money to recomplete two existing wells into deeper, clean
formations, at a cost of $500,000. The November 1981 application for funds to
develop an alternative source by deepening existing fcells was denied because
-------
C-91
the site did not meet criteria for .an immediate removal. An EPA Technical
Assistance Team and a Field Investigation Team have studied the site.
The City proceeded without EPA assistance to have the two most heavily con-
taminated wells recompleted in a deeper (1000 feet) aquifer in September 1981.
The State required strict quality control measures, including special casing,
to eliminate the possiblity of contaminants migrating to previously-clean zones
along the well bore. Cross-contamination of clean aquifers by aquifers carry-
ing organic chemicals is often a major concern when monitoring or production
wells are drilled through more than one aquifer. One of the two recompleted
wells came on line in the summer of 1982 and the other was to follow shortly.
In the. meantime, the City imposed and enforced strict sprinkling bans to keep
summer demands low. On five occasions, water emergencies were declared.
Samples taken in the distribution system when the city was forced to put a
contaminated well on line occasionally reached 10 to 15 ppb of trichloroethy-
lene.
The Minnesota Pollution Control Agency has been the agency most involved
in tracing the source of contamination and has been following an investigation
program estimated to cost over $500,000. The MPCA sampled local wells and
found that high concentrations of organics were present in wells on one side
of the arsenal (the side nearest the New Brighton well field) and that no
organics were present in wells on the other three sides. With some EPA
Superfund money for off-site well drilling, MPCA defined the extent of contami-
nation more closely. These data and information on TCE and solvents use at
the arsenal were used to persuade the Army to do an on-site study. Officials
at the arsenal originally balked, but became cooperative after political
pressure was applied by the local Congressional delegation. Monitoring wells
-------
C-92
have now been drilled in Phase I of the Installation Restoration Program
sponsored by the Department of Defense.
EPA offered the assistance of a Field Investigation Team in January 1982.
The FIT examined four other potential sources of contamination between New
Brighton and the arsenal, drilled and sampled eighteen monitoring wells,
sampled 150 existing wells surrounding the arsenal, and started a surface-water
sampling program. The investigation showed that the direction of ground-water
flow was from the arsenal toward New Brighton and that the zone of contamina-
tion was highest on the downgradient side of the facility. One other site, a
solvent recycler, had high levels of organics nearby, and the owner has begun
investigations on-site in response to a request by MPCA.
CURRENT STATUS
Efforts are currently proceeding on two fronts in the New Brighton case.
The Minnesota Department of Health is still working with the City to develop
alternative sources of drinking water. Towards that end, the second of two
recompleted wells is expected to come on line soon and a new drilling program
is planned. By the summer of 1983, the City hopes to drill three new deep
wells, bringing the total of good wells to six, capable of meeting even summer
demands. Voters in New Brighton passed a $2.6 million bond issue for further
well construction in the November 1982 election. MDH performed the background
work and well site surveys required to locate the new wells.
In terms of tracing the source, the Minnesota Pollution Control Agency is
continuing to gather evidence on the source of the organics showing up in
local wells. The DPH is engaged in discussions with the arsenal to determine
culpability and work out some cleanup agreement.
-------
C-93
INSTITUTIONAL INVOLVEMENT
The agencies involved in resolving the organics problem are split into' two
groups. On one side, the City of New Brighton and Minnesota Department of
Health have the goal of protecting the public health by providing safe drink-
ing water. Working in complementary fields, the Minnesota Pollution Control
Agency and EPA are charged with removing the threat to health by identifying
and halting the -source of contamination.
The City of New Brighton is handling the problem internally, without hir-
ing a consulting engineering firm. Good communication with the state agencies
has allowed the City to make reasonably informed decisions, and the City has
made strong efforts to protect the quality of water distributed to its resi-
dents. The City and DPH originally shared organics analyses expenses, but New
Brighton now contracts with a private lab.
The state agencies are facing budget reductions but still have been respon-
sive to New Brighton's problems. The Department of Health is the lead agency
on drinking water quality issues. MDH has a capable but small staff knowledge-
able about organics and ground water. With the discovery of several organic
problems in state ground water, however, the Department is being severely taxed
to respond and cannot handle much more. Laboratory capacity is especially
limited. MDH has contacted EPA Region V several times for information but has
generally relied on internal resources.
The Minnesota Pollution Control Agency has been the lead agency involved
in determining the extent and source of the north Minneapolis area organics
problem. Relations between MPCA and MDH are reported to be good. Since the
Pollution Control Agency also has a fairly limited budget, agency policy has
been generally to identify the party responsible for contamination incidents
-------
C-94
and turn over further investigations and expenses to the responsible party.
MPCA has spent many weeks preparing requests for EPA to provide assistance in
emergency and remedial measures.
EPA involvement in the New Brighton case has mainly been through the
Reglbn V office, except for headquarters involvement in Superfund decisions.
State officials say that the Region V office has been very helpful in respond-
ing to the New Brighton area problem. EPA headquarters has been reportedly
less helpful in supplying information.
HEALTH GUIDELINES
The Minnesota Department of Health reportedly uses a 1 in 10s increased
cancer risk level concentration of 27 ppb as the guideline for trichloroethy-
lene. TCE is usually used as the indicator organic. The EPA Cancer Assessment
Group (GAG) did estimate that a 1 in 10s increased risk would be associated
with 20 ppb, but no other health department interviewed used the GAG figures
to set guidelines and no other department mentioned a 27 ppb guideline. The
source, therefore, of the health guideline numbers reported for Minnesota is
uncertain.
CONCLUSIONS
The main points of the New Brighton case of ground-water contamination by
organic solvents can be summarized as follows:
Widespread contamination, potentially a very serious problem.
* Department of Defense involvement slowed response.
State performed reasonably well but has no established program.
0 Lack of health information is a problem.
-------
C-95
Media involvement complicated the situation.
No EPA funds for immediate removals, although some Superfund
money has been made available.
State officials believe that the whole investigation around .the Twin City
Army Ammunition Plant was hampered by the fact that the arsenal is a federal
facility and that EPA was very leery of getting involved in a conflict with
the Department of Defense. According to the National Contingency Plan,
Defense is responsible for dealing with hazardous waste problems on their own
property, but responsibility for off-site migration of contaminants seems to
be an unresolved issue. The Army apparently took the position in this case
that their responsibility ended at their property boundary. Although another
small source may have contributed to the problem of organic chemicals in the
local ground water, it does appear that the arsenal was the primary source.
This premise has not been proven absolutely, given the difficulties in tracing
subsurface flows of chemicals that are becoming fairly ubiquitous.
Another difficulty faced by state officials was in obtaining a commitment
from EPA to spend Superfund monies on remedial or emergency actions. The
Pollution Control Agency has submitted at least three applications for long-
term relief, emergency actions (planned removal request), and initial remedial
measures, none of which have been approved. DCA officials have not understood
why the decisions have been made against them. Along the same lines, the state
has wondered why EPA has been so hesitant in the New Brighton case to fund
alternative water supplies.
An issue related to Superfund decisions is the lack of health effects
information or standards for organics in drinking water. On one side of this
problem, the City was unable to convince the media that the levels of organics
-------
C-9.6
present were not extremely hazardous. On the other hand, the state was unable
to convince EPA that TCE levels varying from 1 to 150 ppb were serious enough
to require emergency action to supply an alternate water supply. The lack of
a "hard" number on which to base decisions on protecting public health also
makes it difficult to recover damages from polluters.
Overall, some measure of certainty in response would have been helpful in
resolving several aspects of the New Brighton case. It was difficult to decide
on closing wells without solid health guidelines. Quite a bit of effort was
expended to obtain EPA Superfund assistance without knowing whether such
assistance would be forthcoming. The responsibility of the Army in cleaning up
the organics problem is still under negotiation. The failure of all parties
involved to coordinate a broad investigation of the total area of contamina-
tion, now estimated to be 18 square miles, was also due to uncertainties about
funding and each party's degree of responsibility, although the State was in
favor of such a study. The delays caused by these uncertainties have caused
the health risk to remain and have allowed the organic plume to migrate
further, contaminating another New Brighton well and placing the water supply
of the next municipality downgradient in jeopardy.
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C-97
CITY OF TUCSON
PIMA COUNTY, ARIZONA
SUMMARY
Prompted by a state-wide surface impoundment study, EPA undertook a field
investigation of certain uncontrolled hazardous waste sites in Arizona early
in 1981. The investigation of the Hughes facility, the number one potential
source of contamination, near Tucson Airport revealed the presence of various
contaminants in wells at and near the facility. The results of further sampl-
ing showed 77 ppb of trichloroethylene in one Tucson Water Department well,
leading to the closure of that well. Continued monitoring has revealed
organic contaminants in eight other public wells, five of which have been
closed. Tucson's water production capacity has not yet been significantly
affected.
Soil borings and downgradient monitoring wells have been used to verify
suspected disposal areas and determine migration of the contamination plume.
Preliminary government efforts were concentrated on plume identification and
waste.stream/source studies on the assumption that a detailed hydrogeologic
study contracted by Hughes would be available, but Hughes refused to release
the report until the summer of 1982. Some activity on treatment research and
clean-up alternatives has begun since the Air Force announced a $3 million
commitment to treat water from the contaminated wells. Previous estimates of
total clean-up costs ranged up to $20 million. The ongoing search to
positively identify contamination sites has been expanded from just the Hughes
facility to the Tucson Airport area as a whole.
-------
C-98
BACKGROUND
The City of Tucson Water Department is one of the largest public water
suppliers in the state. Tucson Water operates over 240 wells, with the number
in service at any one time dependent upon demand. The annual average demand
is about 70 mgd, with winter lows of 50 mgd and summer peaks near 150 mgd.
The City of Tucson only consumes about 15 percent of the base demand. Seventy
percent is used for irrigation and the remainder is consumed in copper mining
operations south of the city.
A typical Tucson water well is about 800 feet deep. The upper regional
aquifer begins 100 to 150 feet below ground level ,and is roughly 100 feet
thick. A tight clay zone separates the upper aquifer from the lower, another
100 feet down. Most wells are screened at both intervals, but the majority of
water produced is from the upper zone since the lower zone is less permeable.
Tucson water-well fields are -scattered over a large part of the Tucson Basin.
Tucson International Airport is located about five miles south of the
center of the city. U.S. Air Force Plant No. 44, operated by Hughes Aircraft,,
Missile Systems Group, is on the south edge of airport property about one mile
east of Nogales Highway. The facility is spread over approximately two square
miles. Of nearly a hundred structures, the main building (#801) is the source
of most of the liquid effluents and general industrial wastes. Various metal
finishing and electroplating operations are performed in this building and
others.
Land use near the Hughes facility is principally medium to heavy industrial
manufacturing sparsely situated on large parcels of extremely flat, arid land.
The area immediately surrounding the airport to the south and west was
reportedly used- by up to six aircraft manufacturing and retrofitting operations
from World War II to the Korean War. Approximately one mile west of Building
-------
C-99
801 and one-half mile from currently-used wastewater impoundments-, low-income
single family residences border Nogales Highway. Trailers and small mobile
home pS£ks are common along Nogales Highway, south of the airport. Most of
these residences rely on deep 200-600 foot municipal and domestic wells
drilled adjacent to the highway.
DISCOVERY OF THE CONTAMINATION PROBLEM
In December 1979, the Arizona Department of Health Services (ADHS) com-
pleted a state-wide assessment of surface impoundment sites. Along with eval-
uating the potential for ground-water pollution by percolation and infiltration
from surface waste impoundments in the state, the report ranked the major sites
for further investigation. Air Force Plant No. 44, operated by Hughes
Aircraft, was highest on the list, having reportedly caused the contamination
of.nearby wells with chromium, cadmium, and arsenic. Tucson Water Depart-
ment's Well SC-7, located about one mile west of the Hughes facility, had
exceeded the EPA Drinking Water Standard for chromium on at least three
occasions since 1975.
On the basis of the ADHS study, EPA Region IX selected the Hughes facility
for further investigation under the Uncontrolled Hazardous Waste Site Investi-
gation Program. An extensive amount of background information was gathered
before EPA's Field Investigation Team went on site on March 5, 1981 to collect
water samples and examine the facility. This information included well logs,
previous ground-water quality analyses, aerial photographs, and other official
documents relating to the plant's operation. A special effort was made to
analyze historical chemical usage and waste disposal practices.
-------
C-100
EPA's consultants conducting the on-site investigation (Ecology and Envir-
onment, Inc.) found three Hughes wells contaminated with trichloroethylene;
one as high as 4,600 ppb. At the same time, Tucson Water Well SC-7, on the
far side of Nogales Highway and one mile west of the most heavily contaminated
Hughes well, yielded 77 ppb TCE. These samples were taken during the first
week of March 1981. The test results came back two months later. Since the
state had no action levels for VOCs, they and Tucson officials spent several
days looking for references. The same action levels used by the State of
California were adopted temporarily and SC-7 was closed on May 12.
A follow-up investigation May 26-28 involved gathering some on-site soil
samples and samples from previously inaccessible Hughes wells in addition to
ten municipal and private wells north and west of the facility. One additional
Tucson well (C-62) was found to be contaminated and subsequently closed on
June 29. The presence of TCE and chromium in wells operated by Hughes was
confirmed (as high as 13,000 ppb TCE) at that time. As more wells have been
sampled in successively wider circles, water from four more Tucson wells has
been found to contain significant amounts (over 5 ppb) of TCE and have been
closed. The most recent closure of an active well was November 1981, but test-
ing has continued. All of the wells contaminated lie in a swath stretching to
the northwest from the Hughes facility, although it is unlikely that Hughes is
the only source responsible.
ACTIONS TO PROTECT DRINKING WATER QUALITY
As discussed above, Arizona had no policy for dealing with volatile
organics in ground water in 1981. Historically, Tucson has had very good
-------
C-101
water from deep, ancient aquifers. EPA had even used Tucson water as a base-
line for naturally-occurring organics, so officials were caught off-guard when
a serious contamination problem was discovered. '
The state tentatively established an action level of 5 ppb for trichloro-
ethylene, the same level suggested by the State of California. Five parts per
billion is roughly the NAS' 1 in 10s increased cancer risk level; the concen-
tration at which one additional case of cancer per million people consuming 2
liters of water per day over a 70 year lifetime may be expected. Six Tucson
water wells were taken out of service for exceeding this guideline. ADHS
released the final Guidelines for TCE in Public Water Supplies in March
1982, discussed later in this case study.
After the analytical results from water and soil samples taken by E&E
during the May follow-up investigation were reviewed/ some long-term planning
began. 'In September 1981 interagency meetings were held to define the scope,
tasks, and.areas of responsibility for investigating and removing the threat
to Tucson's water. Ecology and Environment's Interim Composite Report on
Intergovernmental Agency Activities, submitted to EPA Region IX, contains a
framework of tasks and subtasks, reproduced here as Exhibit 1, and a chronology
of major investigative events, reproduced here as Exhibit 2. These exhibits
outline each study activity, agency responsible, and planned and actual dates
of accomplishment. The government agencies most heavily involved in planning
and carrying out the work plan have been:
U.S. Environmental Protection Agency (EPA)
-- Region IX, San Francisco
-- Ecology and Environment, Inc.
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C-102
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C-104-
:TARLE 2.1 CHRONOLOGY OF MAJOR INVESTIGATIVE EVENTS
DATE
ACTIVITY DESCRIPTION
AGENCY PARTICIPATION
3/3 - 5/31
4/15/81
5/26 - 28/81
5/18/81
7/17-11/2/81
7/17/81-
4/8/82
9/8-10/81
9/22-23/81
11/81
1/12-31/32
1/25-2/8/82
Site inspection of Hughes' Aircraft/USAF Plant # 44;
11 water samples collected from onsite and offsite
municipal, industrial, and private wells
Draft preliminary site inspection report submitted
to Hughes Aircraft Co..for comment
Followup investigation of Tucson Airport area; 14
water samples collected from onsite and offsite
wells; onsite wellsresampled plus Credit Union well
and Hughes Hell #2; 3 soil samples collected from
former waste water impoundments; .ADHS collects
duplicates of offsite wells
HAC critique of draft preliminary report received
and draft report revised; .report released 6/29/81
A total of 93 water samples from 52 municipal and
private wells. Sample collection dates 7/17, 7/20,
8/3, 8/11, 8/12, 8/24, 9/2, 9/16, 9/30, 11/2.
Distribution system sampling (ave. 7 samples/sel)
Shallow soil.borings; 22 samples collected in
areas selected by ADHS in over 8 sections rang-
ing from drainage ditches south of Irvington Road
to various areas on HAC property. Report
TSC14-2(81)177 issued by EPA on 1/8/82
Inter-agency coordination meetings; develop con-
ceptual tasks and assign responsibilities;
establish reporting framework
Well Inventoryi historical water quality data
search; water level measurements
6 soil borings to 150' in five separate locations
(TAA fire fighting training area, HAC FACO dump,
HAC abandoned metal precipitate pits, HAC aban-
donned wastewater impoundment,.TAA landfill )j
115 samples collected
Tucson Airport Authority welV'tflO aquifer test;
abandoned well reactivated, pumped for 2 weeks,
and periodically sampled. Duplicate samples
collected for ADHS BWQ and EPA/E&E by TW; 15
sets of samples collected.
EPA/E&E; TW
EPA
EPA/E&E; TW; ADHS
EPA/E&E
ADHS BWC; ADHS BWQ
TW; ADHS BWQ
.ADHS/BWC; EPA; EPA/E&E
EPA: EPA/E&E; ADHS; AzAG;
TW; flzDWR
DWR; TW
ADHS BWC
TW; EPA/E&E
-------
C-105
DATE
ACTIVITY DESCRIPTION
AGENCY PARTICIPATION
3/P-5/8?
3/15-18/82
3/15/82
t/13-6/1/82
i/10-14/82
71/82
1/82
Tucson Airport Authority wells tfl.and #5 aquifer
tests; abandoned wells reactivated, pumped 1-2 days
each; 7 samples collected at TAA #1; 9 samples
collected at TAA'#5 plus blank from distribution
system.
Attempted monitoring well installation; revised
scope of work resulted in collection of 3 water
samples and 8 soil samples collected from 3 lo-
cations (TAA landfill, drainage ditch at entrance
to Tucson Aviation Center off Nogales Highway,
drainage ditch immediately south of Warner Prop. Co.
Tucson Aviation Ctr.)
RCRA 3007 information requests sent to Airport Area
industries for waste practice investigation; re-
sponses received circa 4/10/82
Aquifer testing; B-102, SC-7, B-85, B-101, B-87,
C-64, C-62, B-103 '
ntermediate depth soil borings; 59 samples-
ollected in 23 soiling borings at a depth
f approximately 15 feet; 5 general areas
elected on basis of historical alleged
ources of disposal.
ughes Aircraft/Hargis & Montgomery hydrogeological
tudy made available to EPA
5 monitoring wells scheduled for installation;
Coordination with San Xavier Indain Reservation
Gates Learjet,- and Hughes Aircraft. Phase II
monitoring wells pending results..
TW; EPA/E&E; EPA
ADHS/BWC; EPA; CPA/E&E
EPA
TW
EPA/E&E
EPA
EPA; EPA/E&E
FP?/F*F' r Enviroental Protection Agency, Region IX, San Francisco, CA
^ A°-°9y & EnVir°nment' Inc. Field Investigation Team
" £H20na Apartment of Health Services/Bureau of Waste Control
°f HeaUh S-V>C"/B-eau of Water Quality
.
DWR - Arizona Department of Water Resources
AzAG - Arizona 'Attorney General
-------
C-106
Arizona Department of Health Services (ADHS)
-- Bureau of Water Quality
Bureau of Waste !Control
City of Tucson Water Department
Arizona Department of Water.Resources
CURRENT STATUS
Since June 1982, developments have occurred on several fronts. Hughes
finally released the hydrogeologic report prepared by their consultants, after
EPA negotiated and filed suit for the information. EPA directed the construc-
tion of five monitoring wells on Indian land west of Nogales Highway. The
county health department became active in the case. The major development was
announced by the Air Force in October. In a lengthy press release, the Air
Force stated its intention to spend $3 mill-ion under its Installation
Restoration Program (IRP) to clean up the Tucson aquifer. Previous estimates
a
of the cost of clean-up had ranged up to $20 million.
After major negotiations, the Air Force committed itself to a plan to pump
contaminated ground water to a treatment plant capable of removing the subject
organics. One and a half million dollars has been allocated for redesigning
and replacing pumps and pipes and making other alterations at Hughes' treat-
ment plant to allow pumping at 450 gpm. Another $1.2 million has been allo-
cated for drilling 15 reclamation wells "spread strategically within the zone
of contamination." The cost of booster pumps and 35,000 feet of pipelines are
included in that figure. The final $300,000 has been approved for designing' &
treatment system. These remedial actions are to be implemented when EPA's
efforts to define the extent of the contamination plume are complete. EPA has
already spent over $500,000 on the case.
-------
0107
In the same press release, the Air Force verified that contamination
migrating off-site had forced Tucson to close Well SC-7. The Air Force was
not involved in early discussions on the contamination problem but has now
stated that "the contaminants .. . were used by Hughes in it's operations at the
plant (and) percolated through the soil from waste treatment ponds."
INSTITUTIONAL INVOLVEMENT
The responsibilities and participation of the major government agencies
involved in the Tucson ground water problem have been as follows:
U.S. Environmental Protection Agency (EPA). EPA has been
directly involved in every step of detecting and resolving the
problem. The state-wide surface impoundment assessment by ADHS
that uncovered the problem was largely funded by EPA, as is ADHS
itself. EPA's uncontrolled hazardous waste site program was
responsible for confirming the presence of TCE and other
contaminants. Region IX personnel and their main contractor.
Ecology and Environment, Inc., haye been heavily involved in
hydrogeological studies, waste stream/source analysis, plume
identification and treatment/clean-up research.
Arizona Department of Health Services (ADHS). Despite
budget cutbacks and organizational changes, ADHS has played a
major role in the Tucson case. ADHS is the regulatory agency
with primary responsibility for ground-water protection, safe
drinking water and control of hazardous wastes in Arizona.
Therefore, when the contamination problem was discovered, EPA
reportedly asked ADHS to take the lead in the case, also for the
purpose of avoiding intergovernmental conflicts. Since then,
ADHS has coordinated all local, state, and federal TCE-related
activities.
This responsibility has been a major drain oh health department
resources. Since the state had no contingency plan for dealing
with a ground-water contamination incident as serious as that
discovered in Tucson, funding and manpower had to be borrowed
from existing programs, causing other services to be cut back.
Reorganizations have shifted responsibility back and forth
between safe drinking water, hazardous waste, and ground-water
protection (a group that was scheduled to be phased out in 1981)
programs. A special group was recently set up to manage the
continuing investigations and implementation of remedial actions
-------
C-108
in the TCE problem areas as well as to oversee the utilization of
monies obtained under the CERCLA and Arizona's Water Quality
Assurance Revolving Fund (WQARF).
The Water Quality Assurance Revolving Fund is Arizona's version
of Superfund, set up by the state legislature in response to the
discovery of trichloroethylene and other contaminants in Tucson
area wells. The monies in the WQARF can be used to assist in the
clean-up or removal of contaminants from ground water or as state
matching funds against federal remedial actions related to ground-^
water problems. The WQARF was funded to $500,000 in 1982, with
half of that, the maximum allowable for one site, already
committed to the Tucson case.
City of Tucson Water Department. Tucson Water, the agency
most directly affected by the discovery of organics in the Tucson
aquifer, had not only the funding but the technical expertise to
respond to the problem. Since the water department still had
ample capacity after the well closings, it was in no hurry to
resolve the contamination problem if in doing so, water
department funds would be expended. On the contrary, Tucson
Water chose to limit.their involvement and see if a federal or
state source could be found to fund investigative and remedial
actions. Tucson Water expenditures on the case were generally
related to pump tests and sample collection. Although the State
had to struggle to come up with $50,000 for emergency drilling,
Tucson Water reportedly had several times 'that amount available
in one of several program budgets.
These facts are not intended in any way to put the blame on
Tucson Water for not responding as quickly as possible, but to
point out a dilemma that is not unique to this case. As long as
the water system could still meet demand and as long as no
immediate threat to other wells was obvious, there was no
incentive for the department to rush in and spend their own money
when other funding sources could be exploited. Some
clarification of EPA policy on reimbursement for funds already
expended might have speeded the department's response.
Pima County Health Department. In the summer of 1982, the
county health department became involved in the organics issue
since it was brought up as a highly publicized, politicized
health hazard. Pima County began an extensive search for private
wells near the airport that had not yet been tested and handled
sample collection for the state.
The county went one step further due to the interest aroused by
publicity on the case. At a public hearing in September 1982,
monitoring requirements for all public and semi-public water
systems in the county were proposed. In the form of a County
Ordinance, this proposal would require annual testing by each
-------
C-109
system for volatile organics. In addition to the cost burden on
small system operators (some of which supply only 5 to 10
customers), enforcement of the ordinance would be difficult.
Arizona Department of Water Resouces (ADWR) . The Department
of Water Resources is another agency involved in the coordination
and planning of meetings. As the state agency responsible for
keeping track of the quantity of water resources, ADWR assisted
the overall effort by conducting a well inventory and providing
historical water quality data and water level measurements.
Drilling logs and well specifications have also been helpful in
developing an idea of the previously-unstudied hydrogeology of
many problem areas.
HEALTH GUIDELINES
As previously discussed, the health hazards posed by organic chemicals
found in Tucson's water forced ADHS to adopt temporary guidelines for TCE which
were finalized in March 1982. ADHS is currently re-evaluating the guidelines
issued in March to address the issue of TCE risk relative to other hazards,
such as the trihaloraethanes prevalent in surface-water" supplies near Phoenix.
CONCLUSIONS
As might be expected of a "potentially disastrous" contamination problem
involving a large number of actors, the response to trichloroethylene and
other organics detected in wells near Hughes has not proceeded perfectly.
Some difficulties raised by officials involved in the investigation are noted
below:
Hughes' refusal to release the hydrogeological information
collected by their consultant, Hargis and Montgomery, slowed
investigative efforts, reduced the possibility of a coordinated
response, and caused undue friction.
-------
C-110
The uncertainties and time involved in getting the Tucson
Airport Area on EPA's Interim Priority Superfund (CERCLA) List
delayed investigative efforts and caused several steps of the
workplan to be eliminated due to funding constraints.
* Tucson Water Department had the necessary resources but
expended no great effort in response because it hoped to obtain
EPA funds.
ADHS was caught unprepared and had to fight budget cutbacks,
public pressure, and a lack of technical expertise to respond.
These problems served to slow but not stop progress on the case. In the end,
the Air Force came through with funding from a Department of Defense IRP grant.
This and Superfund monies have caused Hughes and the government health agencies
to increase their respective levels of effort towards resolving the problem.
Several other difficulties unrelated to the amount of money spent in Tucson
remain. Health effects information on the contaminants detected is incomplete
and not easily understood by the public. In a state such as Arizona, the
health department does not have the resources required to conduct health
research and must depend on the federal government. Similarly, many states do
not have the expertise required to set guidelines or regulations for carcino-
gens and again must rely on more capable agencies, although even EPA has yet
to decide on regulations for some synthetic organic compounds.
Another weakness is in knowledge of the transport and decomposition of
organics in the soil and ground-water environments. Local officials did not
have much faith in the ability of existing models to predict plume movement.
Some type of chemical finger-printing was also mentioned as a technology that
would help to positively identify sources of contamination.
-------
C-11,1
GREAT OAKS WATER COMPANY,
SAN JOSE, CALIFORNIA
SUMMARY
The Great Oaks Water Company (GOWC) in San Jose was notified by Fairchild
in December 1981 that trichloroethane had been found in wells on Fairchild's
plant site. A nearby GOWC well was then tested for volatile organics. When
the test results showed the well water was contaminated by 5,700 ppb of, tri-
chloroethane, the well was taken out of service. Fairchild, GOWC, and the
half-dozen agencies with jurisdiction over health and water issues then began
meeting to determine the extent of contamination and resolve the problem.
Soil borings and monitoring wells have outlined the area of contamination
around a leaking waste solvent tank on Fairchild property, and the firm has
been pumping the contaminated GOWC well through carbon-packed bottles to waste
to keep the trichloroethane from migrating to other wells. The water company
had enough capacity to meet demands during the relatively cool summer of 1982
but is concerned about other down-gradient wells becoming contaminated. Great
Oaks is also concerned about its reputation and solvency in the face of several
lawsuits alleging damages to public health.
BACKGROUND
The Great Oaks Water Company is an investor-owned utility regulated by the
California Public Utilities Commission. The company was founded in 1959 to
provide water to an unserviced area in South San Jose, and has grown rapidly
with the development of the local electronics industry; now serving an esti-
mated 70,000 persons through 16,000 connections. GOWC prides itself on pro-
-------
C-112
viding excellent service to the community at very reasonable rates, arrived at
through careful planning and budgeting.
Before the contamination problem was discovered, GOWG was operating 13
wells. An average daily demand would be about 10-12 mgd, with summer peaks as
high as 19 mgd. The water company has a 1.5 million gallon elevated storage
tank for peak leveling and fire protection, but the widely dispersed wells
pump directly into the distribution system so localized pressure drops can
occur when a well is taken out of service.
DISCOVERY OF CONTAMINATION
In November of 1981, a Fairchild crew noticed discolored soil and smelled
solvent fumes while excavating near the south-west corner of the South San Jose
plant for a new underground storage tank. Fairchild did some soil borings and
tested an on-site well shortly thereafter to determine the source of the
apparent leak. Great Oaks Water Company officials noticed the drilling activ
ity, since the plant site was directly across the street from their offices,
but knew nothing of the problem until Fairchild informed them on December 4
that trichloroethane had been found in a Fairchild well one hundred feet from
the plant. Since the notification was given late on a Friday afternoon, the
President of GOWC wasn't able to contact state officials for advice on how to
proceed until the following Monday. On that day, Fairchild1s consultants
(EMCON) tested GOWC Well No. 13 and the domestic water supply in the Fairchild
plant. The plant's water showed only 0.7 ppb of trichloroethane, but Well No.
13 showed 5,700 ppb of trichloroethane.
At this point it is interesting to note that in 1980 the State Department
of Health Services had conducted a study of volatile halocarbon contamination
-------
C-113
in four ground-water basins. Trichloroethylene and tetrachloroethylene were
chosen as indicators of contamination because of their widespread use and dis-
persion's ease and sensitivity of analysis, environmental persistence (resis-
tence to degradation) and high mobility. Of 183 wells sampled in the Santa
dlaM Valley, only three wells showed any traces of TCE or PCE contamination
.and none of these tested over 1.0 ppb. Great Oaks Water Company Well No. 13
was sampled and scheduled for TCE/PCE and purgeable organics analysis, but the
sample was apparently lost, as no results were ever reported. Results for
Well No. 13 could have either alerted officials to the contamination problem
considerably earlier or established a base date at which the contaminant plume
had not reached the well.
ACTIONS TO PROTECT WATER QUALITY
Closing the contaminated well was the. first short-term step in protecting
the quality of water delivered to Great Oaks' customers. Since the concentra-
tion of trichloroethane in Well No. 13 was almost twenty times as high as
California's 'Action Level' (discussed later), the need for this action was
not questioned. Organizing working groups to trace the source and to plan
remedial actions was another effort undertaken shortly after the contamination
was discovered.
Beginning in December 1981, the water and health agencies with either
responsibility for or an interest in the problem began meeting at least every
other week. The purpose of the meetings was to plan monitoring and long-term
clean-up actions, as well as to report individual progress. At first, some
officials were confident that the entire problem would be resolved within
three months, but more cautious voices have proved correct as no comprehensive
-------
C-114
plan for remedial action has emerged as of eleven months after the leak was
discovered. The organizations usually represented at the meetings have been
the Great Oaks Water Company, Fairchild, the Santa Clara County Health Depart-
ment, the Santa Clara Valley Water District, the Regional Water.Quality Control
Board, the State Department of Health Services, and various consultants.
When the contamination problem was discovered, Fairchild's consultant was
EMCON. EMCON drilled about eight monitoring wells on-site in an initial
attempt to define the area of contamination. After it became apparent that
the scope of the problem was expanding, Woodward-Clyde Consultants were com-
missioned by Fairchild to define the plume and suggest clean-up measures.
Also in early 1982, Fairchild paid to have one GOWC well (No. 4) deepened to
increase production capacity, at a cost of about $30,000.
Woodward-Clyde took soil borings or drilled monitoring wells at 23 loca-
tions on Fairchild property and constructed another 19 monitoring wells down-
gradient from the property. Eight private wells in the area were also sampled.
In January Woodward-Clyde had decided that Well No. 13 had to be pumped to
waste to halt the spread of the plume to other wells, and later set up a row
of monitoring wells as an early-warning system for other GOWC production wells.
Their report "Hydrogeologic Studies at Fairchild Camera and Instrument Corpora-
tion, MOS Facility" was finished in May 1982 and reportedly cost Fairchild
about $500,000. The Woodward-Clyde report seemed to explain the hydrogeologic
characteristics of the region and define the areal extent of the TCA plume
fairly well, but no suggestions were made for cleaning-up the source. The
report apparently did include a contingency plan for responding if the tri-
chloroethane moved past the contaminated GOWC well.
-------
C-115
Fairchild designed and had installed an unusual system for removing the
trichloroethane from Well No. 13 water before pumping it to waste. The con-
taminated well is now pumped through isolated GOWC lines to a filtration system
on the Fairchild site. About 1,700 gpm of contaminated water is pumped through
750 to 800 individual carbon bottles connected in parallel, each tank treating
slightly more than 2 gpm. The Regional Water Quality Control Board has
approved a maximum effluent1 concentration of 30 ppb for water dumped to a storm
drain on-site. Fairchild also had several large carbon contactor tanks
installed in June and July of 1982 to remove or'ganics from water pumped from a
purge well near the leak site. Because of very high influent concentrations
(over 10,000 ppb), the tanks are currently treating only a tenth of their
total design capacity of 2,000 gpm. Fairchild is reportedly spending $5,000
to $6,000 per day on carbon replacement alone.
At present, after extensive evaluation, Fairchild has selected another con-
sulting firm, Canonie Environmental, to continue working on the aquifer contam-
ination problem. Fairchild has been thinking recently about removing the
organics from contaminated water by an air-stripper process, but nobody seems
to know what levels of trichloroethane are safe in air. The Air Resources
Control Board would have responsibility for the necessary emissions standards,
but the characteristics of the substance and the legal definition of "source"
are still uncertain. The questions associated with transferring a potential
carcinogen from one medium to another have yet to be resolved.
CURRENT STATUS
At present, the extent of trichloroethane in South San Jose ground water
has been fairly well defined. Great Oaks water supplies are sufficient for
-------
C-116
the short-terra, and it appears that Fairchild will be involved in cleaning up
the contamination. GOWC has probably the most-often tested water in the
country, with Fairchild and IBM running organic analyses weekly. IBM has been
spending about $6 to 8 thousand per month on testing and GOWC has been spending
ail eqtial amount. Fairchild's expenses have been even higher. The overall
situation seems fairly well in hand, but some problems remain.
Some local residents are dissatisfied with official responses to the
problem. Articles in the local press (viewed as "sensationalist reporting" by
local officials) have aroused public interest in the trichloroethane problem
to a "hysterical" pitch. One point of contention is that Fairchild did not
notify the public of the trichloroethane leak until after a newspaper printed
the story a month after Well No. 13 was closed. Local and state officials
maintain that notification was postponed while the extent of the health hazard
was being studied, and that the contaminated well had been closed down immedi-
ately regardless of notification. One lawsuit has been filed over this
alleged negligence.
Another point of contention is the failure of state and local government
to set standards for organic chemicals and to follow through on enforcement of
these standards. A class action suit has been filed by 150 people against the
Regional Water Quality Control Board, the State Department of Health Services,
the City of San Jose, the Santa Clara Valley Water District and others alleg-
ing negligence in protecting public health.
Most recently, in May 1982, a multi-million dollar lawsuit was filed by
eight South San Jose couples claiming,they have been harmed by the contamina-
tion. Led by a mother of a child with a congenital birth defect, the group
brought suit against Fairchild and GOWC. Prompted by public outcry, the State
Department of Health Services announced in late September a study to investi-
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gate possible links between the contaminated well and birth defects in one
neighborhood. The study, which could cost up to $100,000, should be concluded
by September 1983. , ,
iNltltUTIONAL INVOLVEMENT
Several of the mild organizational conflicts and the perceived lack of
progress encountered in responding to the organics problem in Great Oaks Water
Company wells were due to the myriad of overlapping jurisdictions in the State
of California, The following summary attempts to explain the mandate and
involvement of each organization:
Regional Water Quality Control Board (RWQCB). The RWQCB was
officially the lead agency in the Great Oaks case. As the agency
with overall responsibility for water quality in the state, the
RWQCB was looked to for direction. Unfortunately, for some
reason, the Board was slow to "react to the problem in South San
Jose, and several of the other agencies became frustrated at
constant delays. Relations were smoothed out somewhat in the
work groups.
State Department of Health Services (DHS). California DHS
is charged with protecting the health of the public and therefore
has jurisdiction over public water supply wfells. Two DHS groups
the Sanitary Engineering Branch and the Hazardous Waste Manage- '
ment Division have been involved in the Great Oaks case The
primary role of DHS has been in administering drinking water
standards and monitoring requirements. DHS has also provided
information on the health effects of various organics found in
water systems. Of the state agencies, DHS is probably best
equipped to serve as a clearinghouse for health information. The
Department doesn t have a toxicologist or a huge staff, but they
do try to keep abreast of developments in health research and
occasionally go to EPA for assistance in answering complicated
requests.
Santa Clara Valley Water District (SCVWD). The SCVWD is in
charge of water conservation and flood control in the Valley
The Water District operates surface reservoirs and artificial
recharge basins as the local agency for surface and ground-water
supplies. Although the SCVWD does have ordinance and revenue
S^r'x." Usually relies on the less-cumbersome authority of the
KWQOB when enforcement actions are necessary. In the GOWC case
the^Water District sits in on meetings and reviews proposals for
exploration and remedial measures. As the custodian of all well
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logs in the Valley and the body most familiar with ground-water
flows, the SCVWD must approve any well drilling activity. In
this capacity, the Water District rejected a plan to pump out,
clean-up, and reinject contaminated water on the grounds that
until the contamination area was defined, changes in flow
patterns might disperse the plume.
Santa Clara County Health Department (SCCHD). In
California, the County Health Departments are responsible for
enforcing SDWA monitoring requirements and water quality stan-
dards for small, semi-private and private water systems. When
Fairchild announced it had discovered the trichloroethane prob-
lem, it was the Santa Clara County Health Department that checked
the nearby small community systems for organic contamination.
Over a hundred samples were taken, but no nearby wells were found
to be contaminated. The County is quite concerned about the
threats posed to over 5,000 private wells. The SCCHD role in the
Great Oaks case has been to supplement the State Health Depart-
ment by taking responsibility for the small community systems, as
well as to participate in the planning meetings with the rest of
the agencies.
Great Oaks Water Company (GOWC). As discussed earlier, the
GOWC is a medium-sized investor-owned utility. As such, the
Water Company is subject to Public Utilities Commission rules and
must meet all the same Health Department water quality standards
as the public (municipal) water systems. A major difference is
that a private utility isn't eligible for public grant money for
defining and cleaning up a contamination problem.
U.S. Environmental Protection Agency (EPA). The Region IX
EPA office in San Francisco and the headquarters Office of Drink-
ing Water, Criteria and Standards Division have been involved in
the Great Oaks case. Region IX has had little to do with the
case except to answer occasional questions from DHS. Region IX
has not assisted the local agencies. The director of the
Criteria and Standards Division of the Office of Drinking Water
at headquarters and his staff have reportedly been helpful in
supplying health information.
Consulting Firms. At least four consulting firms have been
working on various aspects of ground-water contamination in the
Great Oaks Water Company service area. Fairchild has had EMCON,
Woodward-Clyde Consultants, and Canonie Environmental working oix-
and off-site. IBM has hired Brown & Caldwell as part of their
rapid response to a potential contamination problem near their
facility. .'.,.' :
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HEALTH GUIDELINES -.-.>..
The California Department of Health Services has recommended a set of
Action Levels" for organic chemical compounds found in domestic water sup-
plies. These guidelines are essentially the EPA SNARLs. The Action Levels
ar6 generally set at the carcinogenic risk levels where a 1 in 1,000,000 excess
lifetime cancer risk is estimated, although some variances up to the 1 in
100,000 risk level are allowed if alternate water supplies are not available.
DHS plans to expand the list of Action Levels as more information becomes
available from EPA or as major incidents of contamination force the issue.
CONCLUSIONS
In addition to complaints from consumers and lawsuits over past practices,
the problem presently affecting local officials is that nothing has been done
to clean up the source or the aquifer and no actions have been approved for the
near future. This concerns water and health officials who are worried about
continuing contamination and the potential of the contamination plume spread-
ing to other wells. They believe that the difficulties caused by the involve-
ment of so many agencies, the defensive attitude of the industrial source, and
the failure of the lead agency to act decisively have slowed responses to the
problem to the point that no resolution is in sight, a far cry from early
predictions that the problem could be cleared up in three months.
According to most officials interviewed, the major weaknesses in dealing
with the trichloroethane problem were related to health information and guide-
lines. The need for EPA to continue research on the health effects of organics
and to then promulgate standards (rather than loose guidelines) based on that
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health information and an assessment of risks was voiced frequently. Other
topics suggested for research were the detention and transport of organic
chemicals in the subsurface and ground-water environments. Less expensive
testing and monitoring techniques were also called for, but the major area
where EPA assistance was thought necessary was in performing health research,
distributing health effects information in a form understandable by the public,
and establishing enforceable standards.
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LAKEWOOD WATER DISTRICT
PIERCE COUNTY, WASHINGTON
SUMMARY
The Tacoma-Pierce County Health Department (TPCHD) and the State Department
of Social and Health Services (DSHS) conducted a survey of surface and ground-
water quality in late 1980. Traces of organic chemicals appeared in a sample
taken from a Lakewood Water District well. Followup sampling by DSHS and EPA
Region X confirmed that relatively high levels of 1,2 trans-dichloroethylene,
trichloro.ethy lene, and tetrachloroethylene were present in two adjacent
Lakew.ood wells.
EPA took the lead in a two-phase approach to the problem. The first phase
consisted of an immediate 'health response (closing the contaminated wells) and
I
planning meetings with the agencies involved to coordinate efforts in determin-
ing the extent of contamination. In the second phase, the EPA, state and local
health departments, state Department of Ecology, Lakewood Water District, and
the Air Force met to identify the source and discuss corrective actions.
The Water District lost about one-tenth of its production capacity when
the two wells were closed in August 1981. In addition to problems with low
water pressure in that corner of the District, summer demands were difficult
to meet, so sprinkling restrictions had to be implemented. .A new, deeper well
was drilled to augment water supplies, but that effort only produced a dry
hole. The Water District and other local agencies have admitted that nothing
could have been done without EPA1s technical and financial assistance, but are
disappointed at the slow pace of progress in the case.
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BACKGROUND
Pierce County is located at the southeastern end of Puget Sound in western
Washington State. It is roughly 1,790 square miles in area and extends from
Puget Sound to the crest of the Cascade Mountains Range, a distance of about
75 Biles. Most of the County's 501,000 people live in central Pierce County,
primarily in the cities of Tacoma and Puyallup and the unincorporated areas
surrounding Tacoma, including Lakewood.
The highest density residential and commercial growth has occurred in
central Pierce County, primarily in the area south of the City of Puyallup and
in the communities of Lakewood, Parkland and Spanaway, all south of Tacoma.
Developmental pressures in the Lakewood area have been heightened by the
expanded use of nearby McChord Air Force Base and Fort Lewis since World War
II. Nearly all growth in unincorporated Pierce County has occurred without
'the benefit of public"sewer systems. Community storm water drainage systems
are also virtually absent outside of cities, making storm water injection
through drain wells commonplace in many areas. Only one major protected
surface-water source exists in the county, that serving the majority of needs?
for the City of Tacoma. Drinking water for most areas of developing Pierce
County has been supplied by many small public and private water systems
tapping underlying ground-water aquifers.
The geology of the Pierce County area is an important factor in ground-
water studies. The region is crossed by several well-defined channels cut by
glacial meltwater streams which left substantial deposits of coarse sands and
gravel known as the Steilacoom gravels. Several of these channels are the
ancestral tributaries of the Lakewood area drainage basin known as Clover and
Chambers Creek. Due to the high velocity and erosional effects of these
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meltwater streams, and to glacial anomalies in the local geology, the normally
protective glacial till layers are absent in some areas, permitting rapid
recharge through the overlying highly permeable Steilacoom gravels. The uncon-
solidated glacial drift and alluvium underlying the area contain aquifers of
very high porosity and permeability that yield high flow rates of water. The
highly permeable gravels and steep gradient make rapid transport of ground-
water contaminants a serious problem.
The Lakewood Water District draws all of its water from these highly per-
meable aquifers, using 25 wells screened at intervals varying from 110 to 800
feet deep. The Water District serves over 40,000 persons in a twenty square
mile area southwest of Tacoma. Wide variations in demand are due primarily to
lawn sprinkling in this mostly-residential area: average demands are near 6
mgd,.with summer averages of 15 to 18 mgd and the peak 1982 demand at 22 mgd.
Most of the Lakewood wells are pumped directly into the distribution sys-
tem,,, although the Water District does have a small amount of storage capacity.
Some of the wells receive chlorination, and all are sampled weekly for
bacteria, a concern in this unsewered area.
DISCOVERY OF THE CONTAMINATION PROBLEM
In response to growing concerns about the effects of rapid development on
ground-water quality, DSHS directed a study 'in 1980 to investigate the extent
of aquifer contamination in the Clover Creek-Chambers Creek Basin. The study
was designed to document ground-water quality, identify any trends in ground-
water quality related to development, and recommend areas for further study.
The analysis of existing data showed that a significant problem did exist
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and recommended a. comprehensive survey of water quality be made as soon as
possible.
ThS comprehensive survey began in November 1980 and .was concluded in
February 1981. The Department of Social and Health Services performed the
survey, with the aid of the Tacoma-Pierce County Health Department. EPA agreed
to assist by running organics analyses on 24 samples collected throughout the
basin. Lakewood Water District Well No. H-l was selected for analysis partly
to satisfy geographical diversity and partly for its proximity to McChord Air
Force Base.
The results of the February tests came back later in the spring, showing
that 1,2 trans-dichloroethylene, trichloroethylene, and tetrachloroethylene
were present in Well No. H-l. Follow-up sampling by EPA and DSHS in July and
August confirmed that H-l and H-2, a nearby well in the same production zone,
were both contaminated. The the results of those tests were as follows:
HIGHER LEVELS OF CONTAMINANTS DETECTED
(ppb)
Well #1 Well #2
1,2 trans-dichloroethylene 37 138
trichloroethylene 7 18
tetrachloroethylene 29 138
ACTIONS TO PROTECT WATER QUALITY
Since the levels of contamination in both wells exceeded the NAS contami-
nant level for a 1 in 100,000 increased cancer risk by as much as 600 percent,
immediate action was necessary. The following account of responses to the
discovery of VOC contamination is taken partly from a paper presented at the
AWWA 1982 Annual Meeting by William A. Mullen (Region X Drinking Water Program
Chief) and others. '
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The Water District, State Departments of Health and Ecology, Tacoma-Pierce
County Health Department, EPA, and the U.S. Air Force formed a work group to
deVelbp and implement an action plan. The action plan was broken down into
three phases: removing the health threat, determining the source of contamina-
tldfi*. and taking remedial measures to restore,or replace Lakewood's water
supply.
In the first phase, concurrent with the planning process, several actions
were taken immediately. The Water District voluntarily removed the wells from
service in mid-August and notified its customers regarding the problem. A
sampling program was begun to assure that contaminated water had been flushed
from the system, and nearby homeowners with private wells were urged to contact
the Tacoma-Pierce County Health Department so that sampling could be arranged.
Those Wells, along with other public water supply wells in the area, were
sampled by EPA to ensure that any public health threat had been eliminated.
Wells on McChord Air Force Base were sampled jointly by EPA and the Air Force. <
In the second phase of the EPA investigation, beginning in November 1981,
a number of monitoring wells were drilled to determine the source of contamina-
tion. Ten shallow (28 to 35 feet) interactive wells were drilled by EPA from
November to February around the contaminated Lakewood wells. These wells,
drilled at a total cost of about $10,000, showed some contamination in the
upper aquifer, but at concentrations an order of magnitude lower than those in
H-l and H-2. Pump testing of the two Lakewood wells, however, showed there
was some interconnection, possibly through a poorly-cased well bore, between
the two aquifers.
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In January 1982 the hypothesis that the upper aquifer was the carrier of
contamination was abandoned, and efforts were concentrated on the lower
aquifer. By this time the Water District was becoming frustrated with the
apparent lack of progress and therefore contracted for a deep multilevel well
near H-2 with their own money, rather than waiting for authorization through
EPA and EPA's contractor, Ecology and Environment (E&E), Inc. EPA provided
technical assistance on this well and did the testing, which showed the
highest contamination at a depth of 90 feet.
The information gathered from the multilevel well was used to design a
deeper drilling program. Beginning in June 1982, a series of deep holes have
been drilled around H-l and H-2 in an effort to trace the flow of contaminants
in the deeper aquifer (below 90 feet). A cable tool rig has been used for
these test holes because it is much more controllable and provides better
samples than an air rotary rig. The seventh deep well has just, been completed,
and EPA officials expect the next well to confirm their suspicions that the
contaminant plume is flowing from a source in the direction of nearby McChord
Air Force Base. To date, only about $36,000 has been spent on the 10 shallow
wells, one multilevel well, and seven deep monitoring wells.
As the above activities were proceeding, the Air Force carried out some
investigations on-base. The Air Force and EPA checked the eight wells on
McChord Air Force Base after organics were discovered in H-l and H-2, but
found only trace levels. In addition, quarterly surface-water sampling has
not shown organics concentrations higher than allowed by the Base's NPDES
discharge permit. Most other investigations on the Base have been related to
the Air Force's Installation Restoration Program.
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The Installation Restoration Program (IRP) is essentially the Air Force's
version of Superfund. IRP is a four-phase program targeted at identification
of potential waste storage areas through to the final restoration of any dump
sites which may require clean-up. Phase I, a detailed analysis of records,
including a history of operations, the geological and hydrological conditions
which may contribute to migration of pollutants off installations, and a search
of ecological files for evidence of any environmental effects resulting from
contamination, was completed by CH2M and Hill in July 1982 and made public.
Phase II, a field survey of the installation, consisting of soil and water
sampling to confirm the presence of specific migrating pollutants, was begun
shortly thereafter by JRB Associates. The first two phases are estimated -to
cost the Air Force $370,000. Phase III and IV, containment and remedial
actions, will depend on the findings of Phase II. Based on preliminary
findings, the Headquarters Air Force Engineering and Services Center program
directors have moved McChord from below number fifty to about number twelve on
"the list" of installation priority sites. Some of these actions were accele-
rated when a local congressman, in his efforts to find a culprit in the
Lakewood incident, initiated a congressional investigation into the case last
spring.
CURRENT STATUS
The second of three phases to resolve the Lakewood problem is currently in
progress. The immediate health hazard has been removed, and EPA is optimistic
that drilling efforts in October and November will all but pin down the source
of contamination. Phase three, remedial action to ensure that Lakewood Water
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District has a safe long-term supply, will likely take quite a while, based on
the quantity of VOCs already pulled out of the- production wells and the fact
that increasing concentrations have been reported in some wells.
INSTITUTIONAL INVOLVEMENT
At least a half dozen organizations have been directly involved in resolv-
ing the problem of organic compounds in Lakewood Water District's ground-water
supply. The 'round-table' approach, to planning and decision-making has
attempted to take advantage of expertise held by each group. The following
briefly describes the role of each organization in the Lakewood case.
U.S. Environmental Protection Agency (EPA). The Drinking
Water Programs Branch of EPA's Region X in Seattle has been the
lead agency in coordinating a response to the Lakewood contamina-
tion problem. Other agencies have stated that they simply could
not have handled the problem without technical and financial
assistance from EPA. In terms of technical assistance, EPA.or
EPA's contractor ran the organics analyses that originally-
discovered the problem, performed further sampling in confirma-
tion, drilled the shallow monitoring wells, supervised the multi-
level well, and is now drilling a series of deep wells that are
expected to pinpoint the source of contamination. Since the
state and county have no capacity for laboratory analyses of
organics, EPA has generally been responsible for all testing.
For technical information, EPA officials in Seattle have con-
tacted EPA headquarters, various consulting firms with experience
in hydrogeology, and personal sources at other Regional Offices.
For health information, the Seattle office has usually turned to
the Office of Drinking Water at headquarters in Washington, D.C.
Professional journals and water industry conferences have also
been credited as valuable sources of information for those
organizations with enough personnel and resources to keep up with
current events.
State Department of Social and Health Services (DSHS). The
Department of Social and Health Services is responsible for the
quality of water distributed to the public. In this capacity, it
deals with water utilities on sampling and compliance require-
ments and provides information on treatment. Although DSHS is
the primary health agency in the State of Washington, it has not
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established a program to deal with contamination of ground-water
sources and has no plans to establish any guidelines for organics
in drinking water. In the absence of any state program for
responding to VOC contamination, DSHS has handled each incident
individually, referring to the EPA Office of Drinking Water's
"Guidelines in Response to Contamination Detected in Groundwater
Supply Survey" and to other agencies for suggestions on how to
proceed.
The Department of Social and Health Services is handicapped in
dealing with problems such as organics in the Lakewood wells for
several reasons. First of all, there seems to be some confusion
at the state level as to who exactly is responsible for this new
type of problem. Some coordination in the roles of DSHS and the
Department of Ecology would be helpful. Secondly, the state has
been hardhit by budget cuts and has not looked favorably on
expanding health service related activities. Finally, DSHS has a
shortage of personnel qualified'to deal with organics or ground
water. The civil engineers traditionally concerned with conven-
tional water or wastewater treatment just have not been trained
in hydrogeology or toxicology, and the state has no lab space for
organics analysis.
Department of Ecology (DoE) . The State of Washington
Department of Ecology is more concerned with the resource aspects
of ground-water contamination than the health effects. In the
Lakewood case, DoE' was involved in the debate over local growth
and land use planning that "prompted the DSHS study ('with the
cooperation of DoE and Tacoma-Pierce County Health Department) of
ground-water quality. Because of jurisdictional conflicts,
including one over the Commencement Bay Superfund site, and the
commitment of a large share of resources elsewhere, DoE has not
played a major role in the Lakewood contamination problem. The
Department of Ecology has,.however, assisted in the initial
ground-water basin study and in surface surveys of potential
sources of organic contaminants.
Tacoma-Pierce County Health Department (TPCHD) . Under an
agreement with DSHS, the local health department has responsibil-
ity over some small water and sewer systems. Without the finan-
cial or technical resources to do any complicated testing, how-
ever, the Tacoma-Pierce County Health Department has been unable
to take much responsibility over ground-water issues.
The Health Department has been heavily involved in several
aspects of the Lakewood case. The TPCHD helped the State select
well sites for sampling in the initial ground-water basin study.
Health Department officials urged DSHS to recommend closing the
Lakewood Water District's contaminated wells early, after the
first round of testing. More recently, the department has been
conducting historical surveys into the use and disposal of
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organic compounds in the Tacoma-Pierce County area. This
information is being used to gain insight as to potential con-
tamination sites as well as to aid in the development of a com-
prehensive land use policy.
Since the Tacoma-Pierce'County Health Department could not afford *
to do any drilling or even organics scans, they credit EPA for
making any progress in the case possible. At the same time,
TPCHD was mildly critical of the slowness of response and several
lapses in communications between themselves and the federal
organizations.
\
United States Air Force (USAF). The Air Force and Army have
maintained large installations south of Tacoma since before World
War II. McChord Air Force Base property, beginning several
hundred yards from the contaminated Lakewood wells, consists of
over 1,000 acres on which live about 6,500 people associated with
the Base's flying mission.
McChord Air Force Base was the immediate suspect when the tri-
chloroethylene, tetrachloroethylene, and dichloroethylene (com-
pounds often associated with aircraft-type degreasers) were dis-
covered at H-l and H-2. As of September 1982, no evidence has
conclusively implicated or exonerated the Air Force as the source
of the volatile organics. Under the USAF Installation Restora-
tion Project (described previously), Base personnel and their
consultants carried out an extensive study of organics use and
disposal practices.
Lakewood Water District. The Lakewood Water District's main
concern in the organics contamination case has been with finding ,
a suitable location for a new production well. After extensive
studies, one deep well was drilled a mile downgradient of the
contaminated wells. Continuous monitoring showed no detectable
organics as drilling passed through the aquifer level contami-
nated at Well No.s H-l and H-2. Lakewood has not taken a signi-
ficant role in tracing the source of contamination.
HEALTH GUIDELINES
As mentioned earlier, the State of Washington has not set guidelines for
f
volatile organics in drinking water. The EPA SNARLs are therefore the only
real guidance the health agencies have in responding to cases of contamina-
tion. The obvious difficulty with this approach is that the SNARLs document
can be interpreted in many ways. Lakewood Wells H-l and H-2 contained over
200 ppb of each of the organics detected, well over the maximum recommended
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concentrations other states suggest (usually on the order of 5 to 50 ppb).
For this reason the health agencies were unanimous in recommending that the
wells be taken out of service.
If circumstances had differed, the response might have been less predict-
able. An EPA official in Seattle thought a standard should be set at a risk
level between I/10s and 1/107 excess cases of cancer, roughly equivalent
to a TCE level between 4.5 and 0.45 ppb. An Air Force'official said he would
be concerned if over 10 ppb of TCE showed up in his wells, a risk level between
1/105 and 1/106. Most state guidelines recommend using water with no more
than 5 to 50 ppb of TCE, depending on the availability of alternate supplies.
The Lakewood Water District Superintendent did not seem to think that a 1 in
4,000 risk level of excess lifetime cancer risks was excessive., All parties
involved called for someone, usually an agency with higher authority, to set
I
some defensible guidelines.
CONCLUSIONS
The response to the discovery of trichloroethylene, tetrachloroethylene,
and dichloroethylene in Lakewood Water District wells was slowed by a lack of
financial resources, little previous experience with VOCs in ground water, and
the regional attitude that resource contamination is an East Coast problem,
not a Washington problem. Overall, the organizations - involved were fairly
well organized and responded to the best of their abilities. Several
weaknesses, however, were highlighted by officials working on the case:
Health effects information still contains lots of unknowns and
needs to be improved;
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Some type of public education effort would be helpful to
explain the magnitude of risks in understandable terms;
Streamlined funding and response mechanisms would eliminate
frustration over delays perceived by the public as
unresponsiveness to the problem;
A clearinghouse for information on treatment options and other
technical aspects should be set up and publicized;
A lack of qualified hydrologist/geologist professionals
requires present staff to be spread thin at times;
Some type of inhouse or external peer review process for study
plans would help if the response was rapid;
Some standard well placement and monitoring procedures would be
a good fallback;
Communication between the levels of government involved in
organics contamination cases needs to be improved;
The federal government needs to recognize that in most cases,
local governments cannot shoulder this type of burden.
To reiterates better health information and clear guidelines are the two most
critical areas where research efforts should be concentrated. Other areas
where assistance would be helpful are drilling and monitoring, and hydrogeo-
logical investigations, in general.
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APPENDIX D
LIST OF CONTACTS
GROUND-WATER CASE STUDIES
PHONE INTERVIEWS
Bedford, Massachusetts
EPA Region I - Eliot Thomas
Town of Bedford - Steve Daly, Town,Administrator
Massachusetts Water Pollution Control Office
Massachusetts Department of Environmental
Quality Engineering - Jerry McCall
Camp, Dresser, McKee - Donna D'Amore
Garden City Park, New York
Water District Superintendent - John Mirando
Assistant Superintendent - John Guarino
Nassau County Health Department - Frank Padar
N.C.H.D. Bureau of Water Supply -
Michael Alarcon, Director
New York Bureau of Public Water Supply
Protection - John Orndorff, Director
Vestal, New York
Town Engineer - Tom Goettle
Consultant - Ray or John Martin
New York Department of Environmental
Conservation - Mike Marchie
New York Department of Health - Jim McCarthy
New York Bureau of Public Water Supply
Protection - John Orndorff, Director
(617) 223-6688
(617) 275-1111
(617) 292-5500
(617) 742-5151
(516) 746-3194
(516) 746-3194
(516) 535-3324
(516) 535-3323
(518) 474-5577
(607) 748-1514
(607) 724-3226
(518) 474-5577
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D-2
PHONE INTERVIEWS (Continued)
North Pennsylvania Water Authority, Pennsylvania
North Pennsylvania Water Authority -
Harry Borchers, Executive Manager
North Pennsylvania Water Authority -
Judy Wright
EPA Region III - Bob Ranowski, Karen Dewald
Vero Beach, Florida
Lab Supervisor - John TenEyck
EPA Region IV - Mark McClanahan, Toxicologist
Florida Department of Environmental
Regulation - Glen Dykes
(also William Bostwick, Fred Huttner,
Mickey Bryant)
(215) 855-3617
(215) 885-3617
(215) 597-9873
(305) 562-5124
(404) 881-3781
(904) 488-3601
Harper-Branch Research Foundation - Dr. Tsen Wang -(305) 567-7196
New Brighton, Minnesota
City Engineer - Les Proper
.Minnesota Department of Health - Gary Englund,
Chief, Water Supply Section
Minnesota Department of Health - Dick Clark,
Supervisor, Engineering Unit
Minnesota Pollution Control Agency - Steve Lee
Petoskey, Michigan
City Manager - Steven Hoffner
Public Works Superintendent - Frank McCune
MDPH - District Engineer - Tim Benton
MDPH - Public Water Supply Division
Jim Cleland
Michigan Department of Natural Resources -
Dan Cummins, Geologist
Petoskey Water Superintendent - Pete Adams
District Health Office - Dr. Brian Young
(612) 633-1533
(612) 296-5330
(612) 623-5227
(612) 297-2720
(616) 347-4105
(616) 347-4105
(517) 373-1376
(517) 373-1376
(517) 373-2508
(616) 347-5550
(616) 347-6014
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D-3
PHONE INTERVIEWS (Continued)
- South Brunswick, New Jersey
Public Works - Larry Merk
Township Health Officer - Robert Harris
IBM " Chaim Luria
New Jersey DEP Geologist - Bill Altoff
New Jersey Bureau of Potable Water -
Barker Hamill
Geraghty-Miller - Erhardt Werth
SITE VISITS
Glen Cove, New York
Director, Public Works - Joe Hurley
Superintendent - Anthony Caruso
Nassau County Department of Health - Don Myott,
Frank Padar
Nassau County Bureau of Water Supply -
Mike Alarcon
New York Bureau of Public Water Supply
Protection - John Orndorff, Director
Nebolsine, Kohlmann, Ruggiero Engineers -
Dominic Ruggiero
Rockaway Township, New Jersey
Health Department - Richard Christie
. Township Engineer - Ron McKinnon
Water Superintendent - Donald Tyrone
Township Attorney - Rich Sirota
New Jersey DEP - Joe McKulka
New Jersey Bureau of Potable Water -Barker Hamill
(201) 329-4000
(201) 329-4000
(201) 329-7704
(609) 292-0668
(609) 292-5550
(516) 921-6060
(516) 676-2000
(516) 676-2000
(516) 535-3323
(516) 535-3324
(518) 474-5577
(212) 695-6800
(201) 627-7200
(201) 627-7200
(201) 627-7200
(201) 539-1313
(609) 292-0577
(609) 292-5550
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D-4
SITE VISITS (Continued)
Elkhart, Indiana
Water Works Manager - Mike Terlep
State Board of Health - Arnold Viere
- Jim Traylor
(219) 295-2400
(317) 633-0210
City Engineer - Bruce Carter
EPA Region V - Michael Strimbu
Canonie Environmental - Roberto 'Rob1 Weiss Malik
Battle Creek, Michigan
Michigan DPH - Water Supply Division - Jim Cleland
Michigan DPH - District Engineer - Rick Wirsing
Michigan DNR - Bill Iverson, Section Chief
EPA Region V - Steve Ostrodka
City Utilities Engineer - Larry Osborn
Calhoun County Health Department - Ted Havens
Lakewood, Washington
EPA Region X - Bill Mullen, Section Chief
EPA Region X - Fred Wolfe, Hydrologist
Washington Department of Social and Health
Services - Bob James
Tacoma-Pierce County Health Department -
Derek Sandison
Lakewood Water District, Superintendent -
Wayne Dunbar
Washington Department of Ecology - Jim Oberlander,
Will Abercrombie
(219) 295-2400
(313) 886-6202
(219) 926-8651
(517) 373-1376
(517) 373-1376
(517) 373-8147
(321) 886-7571
(616) 966-3421
(616) 966-1241
(206) 442-4092
(206) 442-0691
(206) 464-7671
(206) 588-4423
United States Air Force -
Captain Lindsay Waterhouse
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D-5
SITE VISITS (Continued)
San Jose, California
Great Oaks Water Co. - Ken Krajeyski
Regional Water Quality Control Board -
Peter Johnson
Santa Clara County Health Department -
Steve Brooks
Santa Clara Valley Water District - Tom Iwamura
Fairchild - Larry Amen
California Health Department (DHS),
Engineer - Cliff Bowen
EPA Region IX - Nate Lau, California
Tucson, Arizona
Water Department - Tom Jefferson
Water Department - Bruce Johnson,
Chief Hydrolegist
City of Tucson - T.J. Harrison, Attorney
EPA Region IX - George Wilson, Arizona
EPA Region IX - Harry Seraydarian, Toxics
Division
Arizona Department of Health Services -
Pamela Beilke, DEH
Arizona Department of Water Resources -
Ed Nemecek
(408) 227-9540
(415) 464-4270
(408) 279-6060
(408) 265-2600
(415) 962-5011
(415) 540-2153
(415) 974-
(602) 791-4761
(602) 791-4761
(602) 791-4221
(415) 974-8274
(415) 974-7460
(602) 255-1134
Consultant - Ecology & Environment - Dave Buecker (415) 777-2811
United States Air Force - Charles Alfred,
Environmental Program Manager
Hughes Aircraft - Donald Ellerman, Legal Counsel
- Edward K. Spaulding, Manager,
Environmental Health and Safety
Wright-Patterson
Air Force Base
(602) 746-6000
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