United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-87/045
September 1987
&EPA Superfund
Record of Decision:
Montgomery Township,NJ
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TECHNICAL REPORT DATA
(Ptttu rtta /wmicriotu on tin nvtnt btfon eomplttuig)
. REPORT NO.
EPA/ROD/R02-87/045
3. RECIPIENT'S ACCESSION NO.
TITLE AND SUBTITLE
UPERFUND RECORD OP DECISION
Montgomery Township, NJ
First Remedial Action
7. AUTMOR(S)
s. REPORT OATI
September 29. 1987
8. PERFORMING ORGANIZATION COOC
8. PERFORMING ORGANIZATION REPORT NO
». PERFORMING ORGANIZATION NAME ANO ADDRESS
10. PROGRAM BLEMdNf NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OP REPORT ANO PERIOD COVERED
Pinal POn Ppnorfc
14. SPONSORING AGENCY CODE"
800/00
8. SUPPLEMENTARY NOTES
The Montgomery Township Housing Development (MTHD) is a 72-acre tract of land located
Ln Somerset County/ New Jersey. The housing development consists of 71 home sites. The
original potable water source for each home was a private well drawing from the
underlying aquifer. In 1978, the Borough of Rocky Hill, which is located near the site,
sampled ground water from the Borough well and found it to be contaminated with
trichloroethylene (TCE). Testing continued through 1983, and repeated evidence of TCE
contamination prompted the New Jersey Department of Environmental Protection (NJDEP) to
sample the MTHD well. Results indicated the presence of TCE and other volatile organics
in that and other surrounding wells. In 1981, 20 homes in the MTHD were connected to
the Elizabethtown Water Company water mains. To date, 38 residences have hooked up.
Due to the similarity of contaminants and the proximity of the MTHD and Rocky Hill
Municipal Well Superfund sites, a combined RI/FS is being performed. This ROD focuses
only on an alternate water supply for MTHD. The primary contaminant of concern is TCE,
with secondary contaminants being other volatile organics.
The selected first operable unit remedial action is to extend the Elizabethtown Water
Company distribution system to currently or potentially affected residents of MTHD. The
estimated capital cost of the alternative is $319,000, with no annual O&M.
7.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOBNTIPIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Montgomery Township, NJ
First Remedial Action
Contaminated Media: gw
Key contaminants: TCE, VOCs
8. DISTRIBUTION STATEMENT
19. SECURITY CLASS
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
DATE: September 16, 1987
SUBJECT- Record of-'Decision for /.Montgomery
: xownship Housing Development •^r--
FROM: Stephen D. Luftig, Director
Emergency & Remedial Response Division
TO: Christopher J. Daggett
Regional Administrator
Attached for your approval is the Record of Decision (ROD) for
the Montgomery Township Housing Development site in Montgomery
Township, Somerset County, New Jersey.
The selected remedy is a first operable unit for the site which
involves the provision of an alternate water supply for residents
with impacted or potentially threatened private wells. The
remedial investigation is continuing to identify the contaminant
source as well as the full extent of groundwater contamination.
These are intended to be addressed in the next operable unit for
the site and will be the subject of a subsequent ROD. The cost
for extending the water main and providing the residential
connections is approximately $320,000.
A public meeting to discuss the recommended alternative was
held on July 29, 1987. There was general agreement by the
public with the alternate water supply remedy. However, a few .
residents indicated a preference to continue using their own
wells, questioning the quality of the public supply, while
others expressed an interest in maintaining their wells for
non-potable purposes.
The ROD has been reviewed by the appropiate program offices
within Region II and the State of New Jersey, and their input
and comments are reflected in this document. In addition .a
letter from Commissioner Dewling of the Department of Environ-
mental Protection concurring'with the selected remedy is
attached.
If you have any questions, I would be happy to discuss them
at your convenience.
Attachments
REGION II FORM 132O-1 (0/80)
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DECLARATION STATEMENT
RECORD OF DECISION
Montgomery Township Housing Development
SITE NAME AND LOCATION
Montgomery Township Housing Development, Montgomery Township,
Somerset County, New Jersey
STATEMENT OF.PURPOSE
This decision document presents the selected remedial action
for the Montgomery Township Housing Development site, developed
in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300, November 20, 1985.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record and characterize
the area and evaluate the relative merits of remedial alternatives
for the Montgomery Township site:
- Draft Operable Unit Remedial Investigation Report, Montgomery
Township Housing Development, prepared by Woodward-Clyde
Consultants, July 1987
- Draft Operable Unit Feasibility Study Report, Montgomery
Township Housing Development, prepared by Woodward-Clyde
Consultants, July 1987
- Proposed Remedial Action Plan, Montgomery Township Housing
Development, July 1987
- The attached Decision Summary for the Montgomery Township
Housing Development site
- The attached Responsiveness Summary for the site, which
incorporates public comments received
- Staff summaries and recommendations
DESCRIPTION OF SELECTED REMEDY (Alternate Water Supply Operable
Unit)
The remedial alternative presented in this document is the first
operable unit of a permanent remedy for the Montgomery Township
site. It will provide a permanent and reliable solution for the
prevention of health risks to area residents associated with
exposure to contaminated groundwater. The alternative selected
involves extension of the Elizabethtown Water Company Distribution
System which presently services a portion of the development.
Service connections would be provided to all residents currently
utilizing contaminated or potentially threatened wells.
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-2-
Implementation of this alternative will necessitate the sealing
of affected individual wells. The contaminant plume and source
or sources of contamination will be addressed in a subsequent
Record of Decision.
DECLARATIONS
Consistent with the Comprehensive Environmental Response Comp-
ensation, and Liability Act, as amended, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective of
human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for
this action, and is cost-effective.
The State of New Jersey has been consulted and agrees with the
selected remedy, as is documented in the attached letter of
concurrence.
I have also determined that the actions being taken at the
Montgomery Township Housing Development site are appropriate
when balanced against the availability of Superfund monies for
use at other sites.
j
Date Chritopher J.yiJaggett
inis
19.
Regional Adminstrator
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Decision Summary
Montgomery Township Housing Development Site
SITE LOCATION AND DESCRIPTION
Montgomery Township Housing Development (MTHD) is a 72-acre
tract of land in Montgomery Township, Somerset County, New
Jersey. The development is located east of Route 206, north of
Route 518, west of the Millstone River, and south of Beden .
Brook and Montgomery Road (see Figure 1, shaded area).
Properties along Montgomery Road, the northern border of the
site, are wooded or agricultural lots. An industrial research
facility is also located in this area. To the southwest are
two shopping centers and an office center. The Borough of
Rocky Hill (population 960) which is primarily residential, is
located to the south. The homes on the end of Cleveland Circle
are bordered to the east by the Millstone River, which parallels
the Delaware and Raritan Canal.
The housing development consists of 71 home sites, each of approx-
imately one acre. The homes are situated on Montgomery Road,
Sycamore Lane, Robin Drive, Oxford Circle, and Cleveland Circle.
The original potable water source for each home was a private
well drawing from the aquifer in the Brunswick formation.
In 1986, the study area was expanded to include six additional
residences beyond the boundaries of the MTHD. Ground water
investigations have included the wells of residences along
Canal Road, east of the Delaware and Raritan Canal, north of
Montgomery Road, and along Route 206, as well as some commercial
establishments along Routes 206 and 518.
The MTHD site lies within the 'piedmont Physiographic Province
and is underlain by bedrock of the Brunswick Formation covered
with a relatively thin (up to about 30 feet thick) layer of
unconsolidated sediments. The Brunswick Formation contains
the principal aquifer in the region. Ground water exists in a
number of water-bearing zones which are generally under unconfined
to semi-confined conditions. Intersecting vertical fractures have
resulted from jointing and provide the principal means of storage
and movement of ground water in the formation.
The ground water in the Brunswick Formation is extensively pumped
for domestic and industrial use. More than 90 wells are known
to exist within a one mile radius from the center of the study.
area. The total reported yields of the permitted water supply
wells is on the order of 2,000 gallons per minute (GPM).
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non-. »TUOT AMI « AISO
INCtUOCl MUOCNCf I ON
CANAL HOAO.
FIGURE 1
STUDY AREA
MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT
MONTGOMERY TOWNSHIP, NEW JER
ro
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-3-
Site History
Tax records and accompanying maps indicate that the housing
development site was privately owned and had been used for farm-
ing until 1961. There was no knowledge of any underground
tanks or landfill areas on the property at that time. Tri-State
Development Corporation purchased the land in 1961 and began
construction of 71 homes. The potable water source for all
homes was originally individual private wells. All homes
utilize septic systems.
In 1978, a study by Rutgers University of the Rocky Hill Borough
well revealed trichloroethene (TCE) contamination levels of
approximately 25 micrograms per liter (ug/1). Continued testing
of this water supply from 1978 to 1983 detected concentrations
of TCE ranging from about 50 to 200 ug/1.
Concern over ground water contamination in Rocky Hill led the
New Jersey Department of Environmental Protection (NJDEP) to
conduct initial sampling of commercial and domestic wells in
Montgomery Township from December 1979 to January 1980. Other
investigations performed prior to 1984 included sampling from
private wells, industrial water supply wells, soils, surface
waters and septic tanks. Further environmental investigations
continue through the present. Results indicate that approxi-
mately half of the private wells in the development are contam-
inated with TCE and other halogenated hydrocarbons, while the
remaining are threatened.
Figure 2 summarizes the results of investigations prior to the
initiation of the remedial investigation and feasibility study
(RI/FS) for the MTHD and the related Rocky Hill Municipal Well
(RHMW) site. Data shown are mean averages of TCE concentrations
found in domestic wells between 1979 and 1984. Residences at the
ends of Robin Drive, Oxford Circle and Cleveland Circle were
found to have the highest TCE 'concentrations, whereas lower TCE
concentrations were found in wells along Sycamore Lane. TCE
was not detected in any domestic wells on the northern part of
Montgomery Road, where it runs east-west. However, the data were
insufficient to adequately delineate a plume of contaminated
ground water. In general, TCE concentrations in individual wells
did not appear to vary significantly with time.
On August 21, 1980, Montgomery Township passed an ordinance author-
izing the water line extensions into the Sycamore Lane area and
assessment to the area homeowners for cost. In March 1981,
Elizabethtown Water Company water mains were installed in the
Montgomery Township Housing Development, and residents were
advised not to use well water. Initially, 20 homes elected
to hook up to the new water lines. To date, 38 residences have
hooked up. Residences connected to the Elizabethtown water supply
are shown in Figure 3.
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AVERAGE
TCE CONCENTRATIONS
GREATER THAN
190 ppb
100-149 ppb
SO-99 ppb
2S-49 ppb
2-24 ppb
NOT DETECTED
I < 2 ppb)
NO DATA
AVAILABLE
SOURCE:
MONTGOMERY TOWNSHIP TAX MAP.
1984 RAMP BY JACA AND NUS
FIGURE 2
AVERAGE TCE CONCENTRATIONS
1979-1985
MONTGOMERY TOWNSHIP HOUSING DEVE
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SOURCE:
C. SEARFOSS. HEALTH OFFICER
MONTGOMERY TOWNSHIP. '
LEGEND:
PUBLIC WATER
CONNECTIONS
FIGURE 3
RESIDENTS CONNECTED TO PUBLIC WATER
AS OF JUNE, 1987
MONTGOMERY, NEW JERSEY
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-6-
REMEDIAL ACTIONS
In 1984, the NJDEP entered into a Cooperative Agreement with
the United States Environmental Protection Agency (EPA) under
which it would perform the RI/FS for the Montgomery Township
Housing Development and the Rocky Hill Municipal Well sites.
Because of the proximity of the two sites and the similarity of
contaminants found, the RI/FS for the two sites is being per-
formed under one cooperative agreement. However, the MTHD/RHMW
RI/FS is not the subject of this Record of Decision (ROD).
This ROD relates to a discrete phase of the main study, the pro-
vision of an alternate water supply for the residents of the
MTHD.
In January 1986, NJDEP's Division of Water Resources placed a
restriction on future well drilling for water supply in the
area.
Phase 1 of the MTHD/RHMW remedial investigation was completed
in January 1987. This phase involved a geohydrologic inves-
tigation which included a geophysical survey, permeability test,
water level survey, and a pumping test. The objective of Phase 1
was to charactarize and determine the boundaries of the ground
water contaminant plume.
Scope of Groundwater Investigation
Twenty-six monitoring wells were installed in 13 clusters in
the MTHD/RHMW site area. Each cluster consists of one shallow
and one deep well. Wells were sampled in late November and
early December of 1986. Six wells were dry at the time of
sampling and, therefore, could not be sampled.
Thirty-five domestic wells were sampled in and around the
MTHD. These wells were included due to their proximity to
previously identified areas of contamination. Locations of all
domestic and monitoring wells are included in Figure 4.
Summary of Results
Results of the RI indicate that the MTHD/RHMW sites are under-
lain by a fractured-bedrock aquifer, which consists of an upper
unconfined section and a lower semi-confined section which are
hydraulically connected. A downward hydraulic gradient exists
between the two.
Deep ground water flow is generally toward the northeast and is
largely controlled by the vertical fractures. Shallow ground
water follows topographic features and discharges into surface
water bodies (i.e. Millstone River).
^N^«^^
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MW-50 AIRPORT
MW-4S AIRPORT
MW-4O AIRPORT
STUDY AREA ALSO INCLUDES
RESIDENCE ON CANAL ROAD.
LEGEND
STUDY AREA
FIGURE 4
DOMESTIC AND MONITORING
WELL LOCATIONS
A DOMESTIC WELL SAMPLED DURING STUDY
-18 • MONITORING WELL SAMPLED DURING STUDY
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-8-
Ground water samples from the 23 monitoring wells were collected
and analyzed in late 1986. The most common organic contaminant
found in these samples was trichloroethene (TCE) at levels
ranging up to 650 parts per billion. Other priority pollutant
organic compounds identified included: trans-1,2-dichloroethene,
tetrachloroethene, chloroform, diethylphthalate, chlordane and
phenols. Table 1 lists TCE concentrations detected in monitoring
wells sampled during the first phase of the RI/FS.
Several priority-pollutant metals were found in the first round
of monitoring well samples. Analyses of ground water have been
compared to drinking water standards to assist in summarizing
the data. With the exception of MW-3D, chromium is the only
priority-pollutant metal present in concentrations exceeding
the National Primary Drinking Water Regulation's (NPDWR). in
general, there is no apparent correlation between the contami-
nation levels of organic compounds and priority-pollutant
metals identified in the monitoring well samples.
Thirty-five domestic wells were also included in the first round
of sampling in June 1986. Again, the principal contaminant
detected was TCE, concentrations of which ranged from below
detectable levels to 340 ug/1. A total of 17 of the 35 wells
sampled were found to contain more than 4 ug/1 TCE, and nine of
those wells contained more than 50 ug/1. Table 2 lists TCE
concentrations for those residences which are not currently
connected to public water. (Note: The 340 ug/1 maximum concen-
tration mentioned above was detected in the well of a residence
already connected to the municipal water supply and so is not
listed in Table 2.) Results from this round of analysis are
consistent with previous investigations as also shown in Table 2.
The areas of highest TCE contamination found earlier (the end of
Oxford Circle, near the end of Robin Drive and Cleveland Circle)
are approximately the same as measured in this study.
Other priority-pollutant organic compounds of concern which were
detected include 1,1-dichloroethane, diethylphthalate and
bromodichloromethane.
Priority-pollutant metals (inorganics) were detected in a'number
of the domestic wells. The occurrence of inorganic contamination
is sporadic and does not appear to be related to the occurrence
of organic contamination. The wells do not appear to have any
consistent relationship with each other relative to metal con-
centrations .
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Table 1
TCE CONTENTS OF MONITORING WELLS
TCE Concentration
Well 11/18/86-11/21/86, 12/3/86-12/4/86
(ug/1)
MW-ID . ND
MW-IS ND
MW-2D 34
MW-2S ND
MW-3D ND
MW-3D dup. 13
MW-3S 320
MW-4D 240
MW-4D airport ND
MW-4S airport ND
MW-5D ND
MW-5D airport ND
MW-6D ND
MW-7D . 650
MW-7S 650
MW-9D 6.3
MW-9D dup. 6.3
MW-10D " ND
MW-11D ND
MW-11S ND
MW-13D ND
MW-13S ND
MW-14D , ND
MW-14S ND
MW-15D ND
ND: Not Detected at detection limit of 5 ug/1.
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Block
-10-
TABLE 2
MONTGOMERY RESIDENTS NOT CONNECTED TO
PUBLIC WATER AS OF 7 MAY 1987
Lot
TCE Concentration
ug/1
June 1986 Sampling Date
TCE Concentration
ug/1
Average 1979-1986
23001
23001
23001
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29002
29003
29003
29003
29003
29003
29003
29003
29003
29003
29003
29003
29003
29001
29001
29001
29001
20
27
28
1
3
4
5
6
7
8
12
13
14
15
16
17
18
19
24
28
37
40
43
2
3
4
5
6
7
8
10
11
12
13
18
2
3
5A
' 6A
1.9
60
140
58
18
64
72
3.9
46
ND
2.5
40/44 (duplicates)
35
3.8
ND
32
ND
ND
ND
ND
ND
1.
73
85
1.
58
ND
9.
18
35
39
23
• ND
ND
3.
29
237
11
41
31
3.
6.
13
ND
ND
ND
9
6
9
9
8
7
^^^•^•"^^•.^•^^•^^^^^^^A
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-11-
Contaminant Plume
A summary of ground water TCE concentrations obtained during
the Round 1 sampling program is illustrated in Figure 5.
Although other organic contaminants have been detected in
monitoring and domestic wells/ TCE is considered the main
contaminant of concern in this discussion because it is the
consistently predominant site contaminant.
Observed TCE contamination appears to extend from the RHMW
approximately northward to Sycamore Lane, and from Route 206
eastward to the Millstone River. It is not known at this
time whether the plume continues east of the Millstone River,
but the absence of contamination in the Canal Road wells
indicates that it extends no farther east than Canal Road.
Figure 6 delineates an approximation of the TCE contaminant
plume based on mean averages of all available historical and.
recent data on ground water quality. Other organic contaminants
frequently encountered during Round I sampling are found
throughout the TCE plume, but they occur more sporadically
across the site.
The plume appears to have been in a steady state condition for
at least the last eight years (1979 to 1987). This may be due
to two conditions: (1) the source or sources of contamination
have been constant since 1979 or prior, or (2) the source or
sources of contamination are no longer present but the rate
of contaminant migration is so slow that the plume has not
yet been appreciably dispersed.
Based on the inferred direction of ground water flow and the
observed plume of TCE contamination, a region potentially
threatened by ground water contamination may be outlined
(Figure 7).
CURRENT SITE STATUS
Because of the potential health risks associated with the
exposure to contaminated ground water via ingestion, inhalation
or dermal (skin) absorption, an. "operable unit", or discrete
phase, of the Montgomery Township RI/FS was identified for more
immediate action. This operable unit involved the evaluation
of the need for, and implementation of, an alternate water supply
for those residences continuing to draw water from the contamin-
ated aquifer. This action is based on data accumulated prior
to and during the first phase of the MTHD/RHMW RI/FS. It is
this action which is the subject of this ROD.
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TmCHlOHOtTKUt COMCUmUTIOMt
IAMM.VTICAI. VAlUf (MOM W MUUNTM*tC«>
O MOT OiTiCTIO
HOI I
Hf MJ»f» »- I »08 LOCATIONS
O» MOhltOHIMG MILL* AND
OOMCiTIC Wf LIS
•HAOIMO Nirnf UNT» f RTIMION
Of UK*AH AKf AS.
toonct
UCGSMAT 1AMIMUTE UHIlt
NOCK V Hill OUAOAAMOU.
Nf w Jinuv. OATIO i»?o
FIGURE 5
TCE CONCENTRATIONS
ROUND ONE GROUND WATER SAMPLES
MTHD/RHMW
i
»-•
|VJ
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N
LEOINO
— MONITORING WELL LOCATION
" ~ tMO NUMBER
AVERAGE TCf CONCENTRATION 1ST*-IBM
N NOTOEUCTEO
r--3
i i
GDIS'—
100 4/1
I. TCi CONCENTRAT IONS AHf Mf AN AVERAOfS Of ALL
DATA IIS7S-1MSI FOR OOMEITIC. COMMERCIAL WATER
SUPPLY. AND DEEP MONIIONIMO WELLS.
t. DETECTION LIMITS KX* HISTOMICAL ANALYSES VANIf O
BETWEEN I ANDkUU/L.
J THI CONCENTDATION HiLDt AKE SHOWN ONLV TO AID
IN THE VISUALIZATION Of THE IHSTNISUTION Of TCf
ACROSS THE SITE. THE CONCENTRATION FIELDS AIM
INICNOCP TO ILLUSTRATE AREAS WHERE IT IS fRO-
•ARLE THAT GROUND WATER or THE INDICATED TCE
CONCENTRATION RANOE MAY ft ENCOUNTER!O AT
THE PRESENT TIME.
4. 0ATA FROM ROCK V MIL MUNICIPAL WILL NOT
INCLUDED ON THIS FIGURE.
»- ALTHOUGH THIS PLUMS IS BAWO ON ALL HISTORICAL
DATA. IT IS CONSISTENT WITH THf MOST RECENT 11 (Ml
ANALYTICAL DATA.
SOURCE;
USGS MAP 7 » MINUTE SERIES.
ROCHV HILL QUADRANGLE.
NEW JERSEY. OAK O IS7O
1000
MM FT
FIGURE 6
AVERAGE TCE CONCENTRATION IN DEEP
MONITORING AND WATER SUPPLY WELLS
MONTGOMERY TOWNSHIP, NEW JERSEY
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KNOWN I XTINT Of TNf TGI M.UMX
(Nff NMO DIMCTION* Of OMOUNO
AMA KTM f N tMLltTONf MViN AND
FIGURE
F THREATENED TCE CONTAMINATION
OF GROUND MATER
MONTGOMERY TOWNSHIP. NEU JERSEY
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-15-
Th e second phase of the MTHD/RHMW RI/FS is ongoing and includes
the installation of additional monitoring wells to better
define the contaminant plume north of Route 518 and along the
eastern boundary of the site along the Millstone River. Soil
borings and septic tank samples have been collected during
this phase to assist in identification of the source or'
sources of contamination. Possible remediation of the aquifer
will also be evaluated in a subsequent feasibility study.
Risk Assessment
The primary potential human health impact at the MTHD is the
exposure of residents to contaminated ground water. In
order to evaluate this public impact, a health assessment,
which evaluates risks to users as a result of the exposure,
was conducted. This assessment provides a quantitative estimate
of risk levels under existing conditions — that is, in the
absence of remedial action. This serves as a baseline against
which the need for remedial action is evaluated. Potential
increases or decreases in risks associated with each remedial
alternative considered are qualitatively compared to this baseline
Development of a list of indicator chemicals is the first
stage in the characterization of risk. Factors considered
include: maximum and mean concentrations of contaminants and
their comparison to standards, frequency of occurrence in
ground water samples, and carcinogenicity. Ten compounds were
ultimately selected and are listed in Table 3. Trichloroethene
is considered the main contaminant of concern based on the
above factors. Acute inhalation exposure to TCE causes
central nervous system depression. TCE is classified as a
probable human carcinogen.
Potential exposure pathways to humans from the use of contaminated
ground water include:
0 ingestion of ground water
0 inhalation of volatile chemicals released during water use
0 direct dermal contact with contaminated water
Persons at risk of exposure to the contaminants in ground
water include those still using contaminated or threatened
private potable wells in the MTHD. Census data indicate
that approximately 120 persons still use such wells.
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Table 3
COMPARISON OF SITE DATA WITH WATER QUALITY CRITERIA
Substance
Trichloroethene
Tetrachloroethene
Chlordane
Arsenic
Barium
Beryllium
Chromium
Lead
Nickel
Silver
Water
Quality
Criteria
1
1
0.5
50
1000
NA
50
50
NA
50
Monitor Hell Data Private Well Data
Max. Mean No. Detected Max. Mean No. Detected
650
43
1.3
93
1980
14
355
736
293
36
240
18
1.3
14
256
4.1
46
62
103
15
(8)
(5)
(1)
(11)
(24)
(15)
(15)
(15)
(6)
(7)
340
26
0.76
39
300
ND
117
2170
71
180
67
6.4
0.76
11
180
ND
14
116
18
21
(20)
(7)
(1)
(12) ,
i-
(35) °
(0)
(32)
(29)
(30)
(22)
NOTES: 1) All levels are expressed in ug/1 and are compiled from RI/FS data.
2) Criteria were developed in the RI/FS by a review of water quality guidelines and
regulations.
3) Mean values are calculated for the number of samples with detectable levels of
contaminants, (shown above as "No. Detected")
4) Private well data includes six residences with public water as their primary water source.
5) Blank contamination was present in some cj^mium, lead, nickel, and silver sample
analyses. This table uses all sample res^Bs, and includes some data that were negated
due to blank contamination. ^^
-------
-17-
Based on assumptions involving the estimated human dosage from
exposure and the fact that TCE, the primary contaminant of
concern, readily volatilizes into the atmosphere, the largest
dosage of the organic compounds has been estimated to be due
to inhalation, followed by ingestion and dermal absorption.
ENFORCEMENT ANALYSIS
Several.industrial and commercial establishments within the
site area are believed to be potential sources of contamination.
To date, however, evidence connecting CERCLA potentially
responsible parties (PRPs) to the contamination of the study
area has not been fully developed. Accordingly, PRP identific-
ation is an objective of the ongoing MTHD/RHMW RI. A more
detailed discussion of potential sources will be included in
a subsequent Record of Decision that addresses the MTHD/RHMW
sites.
COMMUNITY RELATIONS
Community relations activities for the MTHD site were initiated
by the NJDEP in 1985 with the development of a Community
Relations Plan.
A public meeting was held in January 1986 to present NJDEP's
plans for the RI/FS for the MTHD/RHMW sites.
On July 10, 1987, the RI/FS report for Phase 1 was made available
at five public information repositories to initiate a 30-day
public comment period. This period extended through August 14,
1987. On July 29, 1987, a public meeting was held to present
the results of Phase 1 of the MTHD/RHMW RI and water supply
alternatives including the preferred alternative to affected
residents of the MTHD.
A high level of concern exist^ among the affected MTHD residents.
Several issues were raised by residents during the course of the
remedial investigation, as well as at the most recent public
meeting. A responsiveness summary, which addresses the comments
and questions raised, is attached to this ROD.
EVALUATION OF ALTERNATIVES
This section describes remedial alternatives for the MTHD
that have been developed in order to meet the objectives of
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended (CERCLA); and the National
Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR §300.68.
-------
-18-
Three alternatives were specifically developed to address the
health risk: to those MTHD residents continuing to utilize con-
taminated or threatened private wells. These alternatives, as
well as a no-action alternative, were identified and evaluated
according to specific criteria required by CERCLA. The fol-
lowing evaluation criteria were applied to each alternative:
1) Effectiveness: -Protection of human health
and the environment
-Reduction of toxicity, mobility,
and volume
2) Implementability: -Technical feasibility
-Administrative feasibility
-Availability of resources
3) Cost Effectiveness: -Capital
-Operation and Maintenance
Table 4 provides a breakdown of all factors considered in the
evaluation of alternatives for remedial action. Of these
factors, only those relevant to the evaluation of remedial
alternatives for the MTHD operable unit were considered.
CERCLA requires that the recommended remedial alternative be
protective of human health and the environment, be cost effective,
and utilize permanent solutions and alternative treatment tech-
nologies to the maximum extent practicable. The proposed remedy
must also attain legally applicable or relevant and appropriate
standards, requirements, criteria, or limitations (ARARs) and
other to be considered guidanances and advisories that have
been identified for the site by various federal and state agencies
to protect public health and the environment.
ARARs and other to be considered criteria, advisories, and guidances
used in the evaluation of alternatives include:
8 New Jersey Maximum Contaminant Levels
- NJMCLs
0 Federal Maximum Contaminant Levels - MCLs
Drinking Water Health Advisories and reference levels for
carcinogens have been included as requirements that are not
enforceable but are still considered in the analysis of
remedial alternatives. Table 3 lists ARARs, advisories, or
State criteria, whichever is more stringent, for compounds of
concern at the MTHD site. ARARs, advisories, or criteria for
TCE have been exceeded at this site.
Initially, alternatives were considered and screened to narrow
the list of potential alternatives for further detailed analysis.
The three primary criteria listed above are identified by CERCLA
for use in justifying the elimination of an alternative from
further evaluation.
-------
Table 4. EVALUATION FACTORS FDR REMEDY SELECTION
EFFECTIVE*
Protect iveness
Reduction of
existing risks
Compliance with
sane ARARs
Compliance with
some criteria,
advisories/ and
guidances
Protection of
community and
workers during
remedial actions
Time until protec-
tion is achieved
Magnitude of
residual risk
Long-term
reliability
Compliance
with sane
ARARs or TBCs
Likelihood
of future
exposure to
residuals
Potential need
for replacement
1ESS
Reduction of
Toxicity,
Mobility,
or Volume
Immediate or
short-term
reduction in
toxic ity,
mobility, or
volume
Permanent and
significant
reduction in
toxic ity,
mobility, or
volume
Technical
Feasibility
Ability to
construct
technology
Short-term
reliability
of technology
Compliance
with some
ARARs
(primarily
action-
specific)
Ease of
undertaking
additional
remedial
action, if
necessary
Ability to
monitor
effectiveness
of remedy
Ability to
perform
operation &
maintenance
functions
IMPLEMENTABILITY
Admi nistrat ive
Feasibility
Ability to obtain
approvals frcm other
agencies
Likelihood of
favorable community
response
Need for coordination
with other agencies
Compliance with
seme location-
specific ARARs
Need to respond to
other sites (§104)
*
i
Availability
Availability of
treatment, storage,
and disposal ser-
vices and capacity
Availability of
necessary equipment
and specialists
COST
Capital and O&M
Development and
construction
costs
Operating costs
to implement
remedial action
Other capital,
and short-term
costs required
to complete
remedial action
Operation and
maintenance
costs, for
as long as
necessary
Costs of 5-year
reviews
Potential
future remedial
action costs
-------
-20-
Those alternatives whose costs far exceed the costs of other
alternatives considered and which do not provide substantially
greater protection or technical reliability were screened from
further consideration. Alternatives not considered appropriate
for implementation and a brief discussion of reason for their
exclusion are provided in Table 5.
The following text discusses each alternative considered with
regard to the three major categories: effectiveness, implemen-
tability, and cost. The evaluation criteria not discussed in
detail are either the same for all of the alternatives, or
considered not relevant to this evaluation. Table 6 lists
those four alternatives retained for more detailed analysis,
and summarizes the specific criteria considered below.
Alternative 1; No-Action
As required by the NCP, a no-action alternative has been
evaluated. Under this alternative, residents currently using
contaminated or threatened private wells would continue using
water drawn from the contaminated aquifer. A ground water
monitoring program would be implemented to allow periodic
reassessment of potential health impacts resulting from
continued use.
For costing purposes, the assumed timespan of long-term ground
water monitoring is 30 years. Residential well water would be
sampled and analyzed semi-annually for priority pollutant com-
pounds .
A detailed risk characterization associated with the no-action
alternative has been performed as part of the RI/FS. Except
for beryllium and nickel, maximum concentrations of the con-
taminants of concern (listed in Table 3) exceed the site-
specific criteria, as cited. In addition, mean concentrations
of trichloroethene, tetrachlor'oethene, arsenic, barium, and
lead exceed the criteria cited. Human exposure to these con-
taminants in ground water may lead to adverse health effects.
Therefore, the no-action alternative is not appropriate because
it would not provide protection to human health and the environment.
Annual cost for monitoring would be approximately $29,000
(see Table 6).
Alternative 2; Temporary Drinking Water
The use of a temporary drinking water source for potable water
(i.e. bottled water) is a potential alternative to be implemented
until such time that a permanent alternative water supply can
be provided for the MTHD residents or the contaminant plume
has been remediated. A range of two to twelve years has been
estimated as the length of time that MTHD residents will need
to use a temporary drinking water source.
i^iMiii^^^
-------
-21-
Table 5
SCREENED ALTERNATIVES
Alternative
Reason Screened
Temporary water provided
by taps on Elizabethtown
Water Company mains
Not as easily implementable as
bottled water alternative
Engineering and construction time
required before taps would be
available for use
Use of bottled water can begin
immediately
Individual Well Treatment
Air Stripping with
Granular Activated Carbon
Adsorption
High cost of implementation with-
out benefit of greater degree of
treatment than extension of
Elizabethtown supply or installa-
tion of a community well
Individual Well Treatment
Granular Activated Carbon
Adsorption
Excessively high operation and
maintenance costs (specifically
for carbon replacement) will be
required to ensure the effective
operation of this alternative.
Methylene chloride, a possible
ground water contaminant, is not
effectively removed by this
technology
-------
Table 6
REMEDIAL ALTERNATIVES
MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT
Remedial
Alternative
Capital Annual
Cost O&M Cost
Present
Worth Cost
Time To
Implement (yr)
Comments
1- No Action
2- Temporary
Drinking Water
3- Extension of
Elizabethtown
Water Co.
Supply System
4- New Community
Well with
Treatment
29,000
59,000
319,000
273,000
556,000
319,000
699,000 31,000
991,000
.-Does not address public
health concerns; cost
reflects 30 years of semi-
annual well monitoring.
0-6 mo. -Risks due to inhalation
and dermal contact
would remain.
1-2 yrs -Addresses public health
concerns
-Meets ARARs
-Technically feasibile
and environmentally
sound
2-4 yrs -Will meet NJ ground water
criteria
-Potential releases of
off-gas (treatment may
need to be provided)
-Time allowed for property
acquisition prior
to implementation
IVJ
to
i
*An individual well water treatment alternative was considered and rejected due to inordinate
cost.
*Alternatives 3 and 4 include sealing of abandoned wells.
*Present-worth costs are calculated using an interest rate of 10% and a project duration of 30
yea i
-------
-23-
Bottled water can be supplied through delivery to each of the
39 affected.homes. The average daily demand for each residence
was established for drinking and cooking purposes only. Tem-
porary supply to meet all domestic water needs is impractical
since a majority of bottled-water vendors supply five or six
gallon storage containers mounted on a free-standing dispenser
(i.e., bulk storage and dispensing facilities for purchased
water would be required for each residence). Therefore, under
Alternative 2, all other domestic water needs (i.e., sanitary,
bathing, washing, etc.) would continue to be met through the
existing contaminated well supplies.
Based on an assumed domestic water demand of one gallon per
day per person, the estimated demand for drinking and cooking
purposes would be met using bottled water with free-standing
cold water cooler/dispensers. Water would be delivered in 11
five-gallon containers to each home every three weeks. It is
estimated that each water delivery for 39 residences would
consist of 2,145 gallons of water, or 429 five-gallon bottles.
The provision of a temporary water supply to meet drinking and
cooking needs would reduce health risks resulting from the in-
gestion of contaminated well water. However, risks associated
with airborne and dermal exposure would continue. The magnitude
of the health risk from inhalation and dermal absorption is
expected to be comparatively small for a two-year implementation
period and would increase proportionately with increased time
of exposure.
Supplying temporary drinking and cooking water from a local
bottled water company is easily and immediately implementable.
The annual cost of supplying 39 residences with bottled water
includes an annual rental charge of $6,000 for the free-standing
dispensers, and a water charge of $53,000 for a total of
$59,000 per year. Implementation of this alternative necess-
itates future action.
Alternative 3; Elizabethtown Water Company Service Connections
and Water-Main Extension (Public Water Supply)
Elizabethtown Water Company is currently supplying water to
38 of the 77 residences in the MTHD study area.
The Elizabethtown Water Company's existing water distribution
system for the MTHD is shown in Figure 8. Addressing the
problem of the contaminated residential wells by replacement
with a public water supply would require the extension of the
Elizabethtown water supply service system.
-------
ro
•8"W
6
PROPOSED WATER MAINS
EXISTING WATER MAINS
• ISOLATION VALVE
0 HYDRANT
I 1/2" BO.
BLOWOFF
BO
FIGURE 8
EUZABETHTOWN WATER COMPANY
WATER DISTRIBUTION SYSTEM
-------
-25-
The facilities to extend the Elizabethtown water system, also
shown in Figure 8, include approximately 4,000 feet of water
main and 39 service connections. The location of water mains
and appurtenances for the water service would be finalized
during the design phase.
The implementation of this alternative would necessitate aban-
donment and sealing of the individual residential wells in
accordance with State of New Jersey Standard Specifications for
Sealing of Abandoned Wells.
Extension of the existing system is a technically feasible and
readily implementable alternative and the most cost-effective
alternative considered. The capital cost for expanding the
Elizabethtown water company system is estimated at $319,000.
The physical expansion of these facilities could be implemented
in six to nine months including design, approval, and construc-
tion of the system. Six additional months are necessary for
administrative purposes, such as securing contracts.
Implementation of this alternative would completely eliminate
risk due to exposure to contaminated ground water of residents
using the aquifer for dringking water. It is a viable alter-
native and represents a permanent solution for providing a drink-
ing water source that meets all criteria for the protection of
human health. The Elizabethtown water supply is a reliable
water source. The NJDEP Division of Water Resources has
confirmed that this water company is in compliance with the
Safe Drinking Water Act (SDWA) requirements. The water supply
is monitored regularly for a list of compounds, as mandated by
the SDWA.
Alternative 4 New Centralized Community Well with Well
Water Treatment
Under this alternative a new dommunity well would be installed
on a purchased parcel of land within the MTHD or the surround-
ing area. A treatment system of sufficient capacity to meet
the combined water demand of the 39 residential households
would be constructed to treat the well water to a level that
meets applicable criteria. The treatment facility components,
shown in Figure 9/ are described below.
The community well treatment system would be comprised of an
air stripping system, in conjunction with a ground water
activated carbon absorption system. Contaminated water would
be brought into contact with air to vaporize the volatile
compounds, which would then be removed with the exhaust air.
The water would then be pumped through activated carbon car-
tridges for removal of those contaminants that are not removed
by air stripping.
-------
AIR EXHAUST
WATER FROM RESIDENTIAL WELL
RECYCLE
RAW/PROCESS
STORAGE
PACKED
TOWER
BLOWER
GAC CARTRIDGES
uv
DISINFECTION
at
TO DISTRIBUTION
SAMPLE TAPS FOR GAC FILTER
MONITORING AND MAINTENANCE
FIGURE 9
INDIVIDUAL WELL TREATMENT
AIR STRIPPING WITH
GRANULAR ACTIVATED CARBON ADSORPT
-------
-27-
Raw and tr««M;.«d water storage would be required to provide a
buffer forf||t;uctuating demand throughout the day. The commun-
ity well s£«tem would require a distribution network system
to collect~and transport the water to the individual residences.
Distribution pumps with recycle and distribution piping would
be used for this purpose. Disinfection would be provided by
chlorination to ensure residual disinfection throughout the
distribution system. A standby generator would be included in
case of power failure.
Like Alternative 3, the .implementation of this alternative
would result in the abandonment and sealing of the individual
residential wells in accordance with State of New Jersey
Standard Specification for Sealing of Abandoned Wells.
The reliability of the selected treatment is based on the
existing water quality and contaminants presently identified.
Possible future variations of contaminant levels or newly
identified contaminant parameters could adversely affect
reliability,.and may require the upgrading of the treatment
system.
Based on the individual contaminant levels found in the ground
water to date, the water treatment systems described for Alter-
native 4 would meet all federal and state requirements for
organics. However, pilot testing would be required to determine
whether standards for metals would be met. If not, an appropriate
treatment system for metals removal, based upon levels detected
in the well, may need to be designed and evaluated. Continued
monitoring of contaminant levels would be necessary to ensure
that water quality meets appropriate requirements.
Air emissions for any of the treatment systems considered would
be evaluated and treated to meet any ARARs.
Design and construction of the planned treatment system could
be implemented within twelve months. Implementation of the
centralized treatment system would also require time for
property acquisition and associated contracts.
From an administrative standpoint, this alternative would not
be as easily implemented as the ocher alternatives discussed
herein. The establishment of the facility could take from a few
months to over a year, based upon the cooperation of the resi-
dents, and the proposed owner (town or county). The time
required to complete any necessary pilot studies, studies,
design, construction and start-up of the treatment system
would be likely longer than that for Alternative 3, especially
since additional land would have to be acquired.
-------
-28-
The capita&cost for this alternative, $699,000, is the highest
of all considered alternatives. Annual costs of operatio'n and
maintenance'include costs for carbon disposal and replacement
(see Table 6).
SELECTED REMEDY
After review and evaluation of the remedial alternatives
discussed in the feasibility study and consideration of the
evaluation criteria under each alternative, EPA and NJDEP
presented Alternative 3 to the public as the preferred alter-
native for the MTHD site. During the public meeting held on
July 29, 1987, concern was expressed regarding the quality of
the Elizabethtown water supply. However, EPA and NJDEP have
confirmed that this water supply is consistently in compliance
with state and federal water quality standards.
Alternative 3 represents the first operable unit of a permanent
remedy for the MTHD/RHMW sites. Identification of sources of
contamination and possible remediation of the ground water
plume will be addressed in a subsequent Record of Decision
for the MTHD/RHMW sites.
The extension of the Elizabethtown water supply system best
meets all evaluation criteria, as previously described here.
Specifically, this alternative will best meet the objectives
of CERCLA in that it is protective of human health, is cost
effective, will provide a permanent solution to potential
exposure to ground water contaminants by residents of the
MTHD, and attains ARARs or criteria.
Implementation of Alternative 3 will effectively remove the
risk of exposure to contaminants, and thus also remove poten-
tial health risks of those MTHD residents currently using the
contaminated water supply.
t
Alternative 3 represents the most cost effective of all alter-
natives considered. In addition, Alternative 3 represents a
permanent solution to the problem of potential exposure of
MTHD residents to contaminated ground water. Administratively,
Alternative 3 is the most easily implementable, when viewed
over the long term, as compared to the other alternatives
(see Table 5). It i-s also technically feasible.
Implementation of Alternative 3 is consistent with all ARARs
and criteria. Specifically, the Safe Drinking Water Act
(SDWA), as amended in 1984, established the basis for the
development of the New Jersey Maximum Contaminant Levels and
the Federal Maximum Contaminant Levels which were used as
ARARs and criteria for the MTHD site. Implementation of an
extension of the Elizabethtown water distribution system
would meet these criteria and so ensure compliance with the
SDWA.
-------
Montgomery Township Housing Development
Montgomery Township
Somerset County, New Jersey
Responsiveness Summary
This community relations Responsiveness Summary is divided into the
following sections:
Section I Overview - This section discusses the New Jersey Department
of Environmental Protection's (DEP) and the United States
Environmental Protection Agency's (EPA) preferred alternative
for remedial action, and likely public reaction to this
alternative.
Section II Background on Community Involvement and Concerns - This
. section provides a brief history of community interest and
concerns raised during remedial planning activities at the
Montgomery Township Housing Development (MTHD) sit*.
Section III Summary of Major Comments Received During the Public Comment
Period and the DEP/EPA Responses to the Comments - Both
written and oral comments are categorized by relevant
topics. DEP/EPA responses to these major comments are also
provided.
*
Section IV Remaining Concerns - This section describes remaining
community concerns that DEP/EPA should be aware of in
conducting the remedial design and remedial action at the
MTHD site.
In addition to the above sections, Attachment A (included as part of this
Responsiveness Summary) identifies the community relations activities
conducted by DEP and EPA during remedial response activities at the MTHD
site.
I. OVERVIEW . ' .
The alternative selected in the Record of Decision (ROD), which
addresses the private potable well contamination in the MTHD, involves
supplying a public water supply system to those residents whose wells
are threatened or contaminated and permanently sealing the wells. The
existing Ellzabethtown Water Company water distribution system will be
extended to replace use of these private wells.
Judging from the comments received during the public comment period,
the residents and Montgomery Township officials appreciate DEP/EPA's
efforts to mitigate the MTHD contamination but are concerned about the
quality of the Ellzabethtown Water Company supply. Several residents
also expressed reservations regarding the sealing of private wells.
Additionally, the Township and a number of residents felt that a marked
inequity exists with respect to payments and reimbursements from the
New Jersey Spill Compensation Fund and the Comprehensive Environmental
Response Compensation and Liability Act (CERCLA or Superfund) for past
actions taken to provide a safe water supply to residents.
-------
Thes* eincttrns have been addressed both In the July 29, 1987 public
meetinglpttd within this Responsiveness Summary. It is hoped that these
effort*"vill result in increased community support for the water hookup
program.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Community interest in the MTHD evolved as information on the
contamination became available. The contamination was first discovered
in the Borough of Rocky Hill during a 1978-1979 water quality study
being conducted by Rutgers University. Soon afterward, the problem was
also recognized in the MTHD and by 1980, a citizens' committee had
formed within the community to address the problem. The committee
gathered information, produced newsletters and a petition for clean
water, coordinated meetings, and helped to organize a sampling plan.
Interest in the organized committee waned over the next three years but
community interest continued.
• m
The major concerns expressed at the January 14, 1986 public meeting and
throughout the RI/FS process, and how DEP/EPA addressed these concerns
are described below:
1) Concern was expressed regarding property damage related to site
activities.
Response; DEF/EPA made assurances that any damage would be repaired
(including any necessary landscaping) and that this would be ensured
through Access Agreements.
2) A number of residents complained that they had not received first
round sampling results for their wells. A few residents who later
received sampling results were confused as to their content and
meaning.
Response; Those residents who called before results had been
approved through the DEP Quality Assurance program were told that
results would be transmitted, when finalized, through the municipal
health officer. They were also told to contact DEP by a specified date
If they had not received them. Further follow-up contacts were made by
DEP's Bureau of Community Relations to the DEP Bureau of Safe Drinking
Water, the Montgomery Township Department of Health and the Franklin
Township Health Department (some samples were also taken in Franklin
Township) to ensure that the proper information was sent. Follow-up
calls were made by DEP to clarify and explain results to residents with
questions.
3) Concern was expressed regarding both payments for past actions and
the possibility of mandatory hookups to the Elizabethtown Water
Company supply.
Response; See Section 3, "Concern Regarding Hookup to Elizabethtown
Water Company Supply" and "Reimbursement for Past Actions" for detailed
responses to these concerns.
-------
III. SUMMARY OF PUBLIC COMMENTS DURING THE JULY 15 - AUGUST 14, 1987 COMMENT
PERIOD
Concern Regarding Hookup to Elizabethtown Water Company Supply
1) An inquiry was made as to whether the Ellzabethtown Water Company
supply is periodically tested and if it is known to contain the
contaminants of concern. Several comments were made regarding the
poor quality of the Elizabethtown water sources, specifically the
Delaware and Raritan Canal and whether those sources are tested.
A resident stated that the Ellzabethtown Water Company, when
asked, could not guarantee their supply was of better quality Chan
her home-filtered water. A request was made for "proof" that the
Elizabethtown water quality would be maintained.
Response; The water that Elizabethtown Water Company supplies to its
customers is sampled on a regular basis to assure that State and
Federal drinking water quality requirements are met. This supply has
consistantly been in compliance with these requirements and sample
results for recent analyses are included in the MTHD Operable Unit
Remedial Investigation/Feasibility Study (RI/FS) for private potable
wells (hereinafter referred to as the "MTHD RI/FS report"). This
sampling includes the following:
— Hazardous Contaminants (including trichloroethene and methylene
chloride) as specified in the New Jersey Safe Drinking Water Act
(commonly known as "A-280") - on a six' month interval.
*
Volatile Organic Scan (including trichloroethene) - on a monthly
basis. (This is done voluntarily by Eliabethtown, it is not a
State requirement.)
Organic Pesticides - required to sample once every three years.
— Trlhalomethanes - voluntarily on a monthly basis. State requires
quarterly sampling.
Inorganics (including lead and chromium) - required on a one year
interval.
— Coliform Bacteria - ten samples per day. Requirment varies by
population served.
Turbidity - required on a daily basis
Radionucleids - required once every four years.
While regular sampling indicates that the public water supply is of
good drinking quality, sampling of the ground water entering homes in
the MTHD have consistently shown evidence of contamination. Levels of
trichloroethene have been found in private wells in concentrations of
340 parts per billion (ppb), well over the present drinking water
quality requirements of 5 ppb.
In contrast to the assurances provided regarding the public water
supply quality, few similar assurances exist regarding the
effectiveness of a home-filter unit.
-------
2) A representative of Security and Safety Systems (a distributor of
residential water filter systems) suggested that the FS include a
listing of chemicals that are likely to be regulated under "A-280"
in the future (according to a report issued by Congressman
Christopher Smith).
Response; The MTHD RI/FS report has included in its analyses,
chemicals which are likely to be regulated for drinking water supplies
in the near future. DEP/EPA consider the inclusion of any more
preliminary findings to be premature at this time. In March 1987, the
New .Jersey Drinking Water Quality Institute, which consists of members
of the .government, research and private sectors, released new
recommended maximum contaminant levels for drinking water regulated
under the New Jersey Safe Drinking Water Act. Once adopted in a
regulation, Elizabethtown Water Company will be required to meet these
levels. In the meantime, it can be noted that based on recent data,
the Elizabethtown Water supply currently meets these proposed levels.
« ,
3) One resident noted that with hookup to the Elizabethtown system,
there is no control over costs, as there is with a private well.
Response; Elizabethtown Water Company rates are regulated by the New
Jersey Board of Public Utilities (BPU). If a rate increase Is deemed
necessary by Elizabethtown,- they must file a rate-case petition. The
BPU has 10 months in which to act on the request. During this time,
the BPU forwards the petition to the New Jersey Department of the
Public Advocate, the agency charged with defending the public's point
of view. In addition, a public hearing, which ^s announced in local
newspapers, Is held by the BPU.
A) A resident submitted a written comment which expressed concerns
about the health effects of trihalomethanes (THMs) that are
created through chlorination of a public water supply (See
Attachment B).
i
Response; Trihalomethanes (THMs) are a class of chemicals consisting
of three halogens (either chlorine, bromine or iodine) around a methane
base. Common THMs are chloroform, bromodichloromethane,
dlbromochloromethane and tribromomethane. These compounds are largely
formed when selected organic materials in the water are combined with
chlorine, which is introduced to kill harmful microorganisms. The
recommended chlorination practice is to add a minimum of 1 parts per
million (ppm) chlorine to the water and maintain a residual amount of
at least 0.2 ppm as the water enters the distribution system.
Potential risks from THMs are being addressed by EPA, by requiring that
total average THMs are. below 100 ppb in drinking water. This
requirement is similar to the 5 ppb requirement for tricholorethene.
This level is currently being reviewed by a subcommittee of the New,
Jersey Drinking Water Quality Institute, as well as by EPA. If levels
below 100 ppb are determined to be appropriate, new regulations would
be issued accordingly.
-------
In response to the concern regarding THMs, Elizabethtown Water Company
carefully regulates the amount of chlorine used for disinfection. As a
result* THM levels are consistently below 20 ppb, which are the lowest
levels of any major New Jersey water company.
The choice currently being made by the concerned resident is to start
with water from a severly contaminated aquifer and take on the
responsibilities and associated risks of treating the water to potable
levels. DEP/EPA feel that a more prudent action may be to start with
water from an approved potable source and make the choice to treat the
water in some personally acceptable manner. In this way the
consequences of a home treatment system failure would not be one of
drinking contaminated water.
Well Sealing and Hookups
1) A resident expressed concern that the "bad" wells had not been
sealed which he felt affected the movement of contaminated ground
water through the community. Another resident questioned why his
well should be sealed if it's clean. Furthermore, because some
residents have residential filters, there was resistance to a
mandatory hookup. There was also an allegation made that th«
public water supply alternative had already been selected. A
resident questioned why DEP was discussing leaving a few private
wells unsealed for monitoring purposes.
Response; It is DEP/EPA's responsibility to protect residents from
the fluctuations of contaminants in ground water, and to ensure that
future homeowners do not drink contaminated water. As the MTHD RI/FS
report indicates, contaminant levels can change with time and
location. Sealing of the private wells provides a uniform solution and
assurance that present or future public health will not be threatened
by this supply. The MTHD RI/FS attempts to specifically focus
attention on the fact that several residents are using contaminated
water, and provide a program to correct this situation. Sealing of the
newly closed wells was included in some of the alternatives (including
the selected alternative). Reasons for permanently sealing the wells
include:
An unsealed well could provide a conduit for further vertical
migration of contamination either from the surface or, from
subsurface layers.
State law stipulates that abandoned wells must be sealed.
Incidential contact with contaminated water could occur with these
unsecured wells.
A new homeowner could unknowingly reconnect the well and start
drinking contaminated water.
-------
Improper plumbing could lead to a cross connection between the
veil and the public water supply, resulting in contamination of
the public water supply.
The decision to seal these 39 wells at this time was based on the ease
with which this could be carried out under this program. Sealing of
other abandoned wells in the site area are not being addressed here,
but will be included within the main study.
Private wells which have not yet been sealed have probably not exerted
a great Heal of influence on movement of contamination through the
aquifer in the short-term, although there is certainly some effect on
ground water flow. Sealing of the wells is nonetheless deslreable
regardless of these facts.
Wells left unsealed for monitoring purposes only would allow us to
track the flow and levels of contamination and to predict and avoid any
unforeseen public health or environmental threats.
With respect to residential filters; because the design and maintenance
of individual household filters are critical to their performance,
DEP/EPA cannot readily ensure the reliability of the treated supply.
The public water supply alternative, or any other alternative, had not
been selected prior to the issuance of the ROD and this Responsiveness
Summary which incorporates public comments. Statements made at the
July 29, 1987 public meeting regarding the public water supply
alternative were based on DEP/EPA's preferred alternative as
recommended to the public.
2) A resident asked if the wells could be uncapped once sealed if the
aquifer were ever again deemed potable.
Response; A well is sealed by removing the pump and filling the well
with a cement slurry. This is an Irreversible process and is done to
assure that the aquifer is not used while it is contaminated. As a
result, the well could not be reused at a future date.
Other Proposed Alternatives
1) A resident suggested that we explore the possibility of the MTHD
connecting to the Rocky Hill Municipal Well which is being treated
to meet drinking water quality standards. The Township Health
Officer questioned whether the Rocky Hill treatment system was
adequate for heavy metals.
Response; The most efficient way to provide water to the MTHD from
the Rocky Hill Municipal Wellfield would be to disconnect the tie-in to
Ellzabethtown water at the intersection of Route 206 and Sycamore Lane,
and connect to a Rocky Hill municipal water main on Montgomery Road.
It should be noted here that as with Elizabethtown water, Rocky Hill
water is regularly tested for both organic and inorganic contaminants.
The following concerns were raised when DEP/EPA considered this
suggestion:
-------
a) The Borough of Rocky Hill must first agree to such a connection.
b) An adequate supply must be available from the existing facility.
c) Limitations may exist because of franchises held by Elizabethtovn
Water Company.
d) Billing and water line maintenance would have to be addressed in
some manner.
Subsequent contact with Mayor Raymond Whitlock of Rocky Hill indicated
that he did not initially object to DEP/EPA's exploring the possibility
of such a program. He noted however that actual approval would have to
be gained from the city council when details of the plan were fully
developed.
Both Mayor Whitlock and the Rocky Hill Borough Water Superintendent
agreed that the system would probably be capable of handling the
additional demand at the current usage rates. However, it was noted
that significant portions of Rocky Hill are as yet undeveloped and any
commitment to supply MTHD with water would impact future development
plans.
According to the Board of Public Utilities, although Ellzabethtown
Water Company maintains a franchise to supply water in the area,
alternative supply sources can be developed. The MTHD water mains,
however, are under the control of Elizabethtown Water. If an agency
other than Elizabethtown Water were to use these mains, they would have
to assume control of the distribution system. Such an arrangement,
which could be fairly simple or fairly complex (and expensive), could
only be determined following a thorough review of the contract
documents between Montgomery Township and Elizabethtown Water. It
should be noted that the likely outcome of this review is that control
can be shifted with only minor efforts.
Billing and water system maintenance could be handled by either
Montgomery Township, Rocky Hill Borough, or Elizabethtown water under a
variety of procedures. As compared to the other groups, Montgomery
Township would probably be inappropriate for this task, since they do
not customarily perform these functions. Rocky Hill would probably be
capable of performing these functions, though they would have to act in
the function of a utility with regard to sampling and accounting.
Likewise they would have to assume added maintenance tasks. The
complications would be minimized if Elizabethtown Water were to retain
billing and maintenance responsibilities, and operate under a bulk sale
agreement with Rocky Hill.
In summary, water can possibly be obtained from Rocky Hill We11fieId
only for the present time. The optimal mechanism by which this would
be done is by Elizabethtown Water buying water in bulk from Rocky Hill
and distributing it to the housing development. Other methods would
face several potential obstacles. Because the Elizabethtown water
supply is of good drinking water quality, is the readily available
water supply, and is a more reliable, long term water supply, an
-------
alternative supply is not warranted under this program. It is
recommended that any discussion between Elizabethtown Water Company,
Rocky Hill, and Montgomery Township be pursued further outside the
realm of this program.
2) A proposal was made by a Township Committeeman to combine the
alternative to connect to available water mains with the home air-
stripping alternative, applying the latter to the four residences
on Montgomery Road who do not have available mains. This would
avoid the substantial costs involved in providing a water main to
connect these four residences to the Elizabethtown supply. He
further suggested that the savings may be applicable to the
remaining homes thereby allowing households to continue using
private wells with filter systems.
Response; This hybrid alternative is described in Attachment C. The
c,ost estimates for this alternative are $266,000 capital costs and
$11,000 for annual costs. The net present cost of this alternative is
$369,696 (@ 10Z for 30 years) compared to complete public water supply
connection costs of $319,000. (See Item 2 in"Costs of Alternatives"
for discussion of possible tax impacts). Since the accuracy of the
cost estimate is limited, DEP/EPA do not consider the difference in
estimated system costs of less than 302 to be significant. Therefore,
a comparison is made based on technical parameters only.
Because of the relative ease of implementation and relative permanence
of the remedy, the public water connection alternative is the selected
alternative. *
3) The Security and Safety Systems representative also requested that
other new technologies be evaluated in the final MTHD FS report.
Information he has submitted to DEP/EPA is included in Attachment
D. These technologies may be applicable as an exclusive
alternative, or as a means of providing water prior to the
implementation of other remedial programs.
Response; Attachment D is a proposal for a carbon adsorption home
filtration unit. The use of this unit In remediating the potable well
contamination was considered, and the following points were noted:
a) The unit only addresses water ingestion and does not address
Inhalation threats associated with bathing. The RI/FS has
identified this as a significant threat.
b) Though the unit is capable of removing trlchloroethene, which
is the major contaminant, it does not address other less
prevalent potential problems, Including biological buildup
and contamination by methylene chloride and metals. (It
should be noted that the activated carbon units discussed in
the MTHD RI/FS also do not address methylene chloride and
metals, though the public water connection alternative does
address this point.)
-------
c) The only information regarding trichloroethene removal is a
calculation of total loading for a 34 ppb influent in a
family unit. No data is presented for a concentration closer
to the levels found on site (160 ppb or 0.16 mg/1 average).
If the total loading value presented of 102.1 mg is used,
approximately a two month unit life would be expected as an
average. (102.1 mgfO.16 mg/1 T 12 I/day - 53 days). This is
significantly below the one year figure presented in the
proposal. This factor results in a potential for proposed
costs to be underestimated, since both filter replacement and
analysis would be performed more frequently.
The proposed home filtration system (for drinking and cooking uses) is
not recommended as part of this program. At best, the proposed unit
would be only as protective as the bottled water alternative, and this
alternative was eliminated from consideration in the FS because it
failed to effectively limit inhalation risks. Those factors listed in
points b) and c) above could be addressed with added monitoring and
maintainance, but with resultant increased costs.
Reimbursement for Past Actions
1) Township officials expressed concern over the inequities of
reimbursements to residents (See Attachment E). A number of
residents have not been paid for hookups to the Elizabethtown
supply or for assessments for the installation of a water line.
The Health Officer further stated that the Township Committee
would probably take these apparent inequities into consideration
when addressing their plans to pass an ordinance condemning the
wells. The Township Committeeman suggested that the cost of the
existing water mains be factored into the alternatives.
One resident stated that the starting point for the cleanup
program should be 1979 when the contamination was first discovered
and cleanup costs should, include any cleanup actions taken from
that date.
Response; Several claims related to MTHD have been filed under a
State program intended to remediate a variety of problems at hazardous
waste sites (New Jersey Spill Compensation and Control Act, otherwise
kncwn as Spill Fund). These claims are currently being handled on an
individual basis, with roughly half already processed. The law
governing this program is explicit in defining filing requirements and
the approval of claims is entirely dependent on the limitations of this
law.
As a matter of EPA policy, Superfund is not used for reimbursement
programs under the conditions addressed at MTHD. The fact that the
obligation of municipal funds occurred prior to the enactment of the
Superfund law passed December 11, 1980, raises an issue regarding State
credits under CERCLA. Under section 104(c)(5) of CERCLA (Attachment
F), the State is eligible for a credit for response actions that
-------
10
occurred before December 11, 1980 taken by a political subdivision.
This granting of credit could conceivably be passed on to Montgomery
Township. EPA and DEP are currently discussing the applicability and
mechanics of such a program and will continue to pursue it to
resolution.
Costs of Alternatives
1) There was general consensus among residents and officials that
some of the estimated costs for the alternatives may be inaccurate
and highly inflated.
Response; The costs presented are higher than may have been
anticipated for the following reasons:
a) Contamination levels used for system design are the average
site contaminants found in recent private and monitoring well
samples (160 ppb). Due to the highly variable nature of the
ground water sample results, it is necessary to use these
levels to safely size treatment systems.
b) Analysis procedures required under this program are both more
expensive and more frequent than those customarily seen by
residents. As an example, the monitoring for individual
activated carbon units is on a 30-day schedule at a cost of
$750 per sampling event. Due to the highly variable nature
of the contamination, a frequent sampling program is
necessary.
c) Miscellaneous items such as bacterial buildup and winterizing
of outdoor equipment are also addressed in the alternatives,
resulting In increased cost estimates.
Further details of the cost elements are discussed in the body of the
RI/FS report.
2) A resident suggested that we factor Into our cost analysis the 66%
State or Federal tax on the 4,000-foot water line.
Response; The additional project costs resulting from Elizabethtown
Water potentially being taxed for the value of the new main have not
been incorporated. This is because of the liklihood that these costs
would be addressed outside of this program. The table below shows the
potential impact of this tax.
-------
11
Present Worth
Alternative
Bottled Water
Public Water
Home Air
Capital Cost
-
458,425
1,255,000
Annual Cost
59,000
-
105,000
(Rounded)
556,200
458,400
2,244,800
Stripping
«
Home Carbon 559^000 378,000 4,122,400
New Community 699,000 31,000 991,200
Well (Assumes
Well Operated
by Township)
Hybrid System 266,000 ' 11,000 369,700
The only shift in ranking of systems occurs between the complete public
water connection and the hybrid system, but the resulting variation is
still within the accuracies of the estimate (30Z).
Responsible Parties
1) The Township Committeeman asked if DEP/EPA is focusing in on a
responsible party and if so, will they be responsible for the
costs incurred? ,
Response; A prime objective in any Superfund remedial action is
identification of a responsible party or parties. The Superfund law
mandates that any or all identified responsbile parties pay all costs
associated with the cleanup process (including costs of the RI/FS).
Should a responsible party choose not to pay the incurred costs, the
law allows EPA to sue that party for up to three times the cleanup
costs.
DEP/EPA are continuing to narrow the list of potential responsible
parties through the more comprehensive* ongoing RI/FS being conducted
for both the Rocky Hill Municipal Wellfield and MTHD sites.
Decision Process
1) A resident asked what the mechanism was for selecting the remedial
alternative. After being told that the Regional Administrator
makes the final decision, he asked why a referendum could not be
held instead of a "czar" making the decision.
Response; The Superfund community relations program is very specific
in its requirements for citizen input into the cleanup process in order
to meet the mandates of the law. As is evident in the ROD and this
Responsiveness Summary, the mechanism for selecting the remedial action
-------
12
alternative is relatively complex. The Superfund law and the
accompanying regulations listed in the National Contingency Plan
clearly outline the process by which a Superfund cleanup is conducted,
including the alternative selection process.
Public input does indeed play an important role in this process. The
public's concerns are solicited throughout the RI/FS process. These
concerns are addressed in the Responsiveness Summary and are presented
to the Regional Administrator prior to final selection of a remedial
alternative.
The ROD is based on months of research, data gathering, analyses, and
alternative reviews by a number of geologists, hydrogeologists,
engineers, toxicologists, attorneys, etc. and each document of the
Rl/FS and ROD goes through several drafts before reaching the Regional
Administrator.
Thus, the ROD actually represents the concerted efforts of DEP, EPA and
the affected communities.
Aquifer Contamination
1) A resident had not heard prior to this public meeting that metals
contamination was a concern. She asked what levels of heavy
metals contamination were found.
Response; The metals contamination found randomly in the area is not
necessarily part of the groundwater plume. Of jrhe 35 private wells
recently sampled for inorganics, the following materials were found in
excess of standards:
Chromium (50 ppb drinking water standard) - in one well at
117 ppb.
Lead (50 ppb drinking water standard) - in four wells at
levels of 91, 143, 740, and 2,170 ppb.
i
2) A resident asked how many wells have gone "bad" since the study
started in the area.
Response; A comparison of 1986 data with previous data for changes
in trichloroethene detection was made. Of 29 homes that had both a
1986 sample and a sample prior to 1986, four homes showed a newly
detected presence of trichloroethene while one home where
trlchlorothene was previously detected, was clean. The four homes with
recent detections were on Sycamore Lane and Montgomery Road, along the
northern edges of the identified plume.
3) A resident asked what are the odds that the aquifer will be clean
in ten years.
-------
13
Response; Because the source is not yet known, it is impossible to
predict whether, or how long it will be until all of the contaminants
have traveled through the aquifer. The source may, in fact, no longer
be discharging contaminants. The more comprehensive, ongoing RI/FS
will address the contamination of the aquifer as a whole. The present
MTHD RI/FS addresses only the private potable wells.
IV. REMAINING PUBLIC CONCERNS
The community will be awaiting the results of the more comprehensive
RI/FS for MTHD and RHMW. This will address their concerns regarding
the identification of responsible parties and the long-term cleanup of
the aquifer.
DEP/EFA are confident that the July 29, 1987 public meeting regarding
the MTHD RI/FS and this Responsiveness Summary will help to foster
further public acceptance of the public water supply hookup and private
well sealing decision.
-------
ATTACHMENT A
Summary of
Community Relations Activities
-------
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
AT
MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT
Community Relations activities conducted at the MTHD site to date include
the following:
A Community Relations Plan was prepared (June, 1985).
Municipal officials were contacted to advise them of a contract award
to conduct the RI/FS for the MTHD and the Rocky Hill Municipal
Wellfield sites (August, 1985).
An informational flyer was distributed to homes in the MTHD regarding
the RI/FS and planned activities (November,'1985).
DEP held a briefing for municipal officials (November 14, 1985).
—• Notices were sent to those listed on the Contacts list of the Community
Relations Plan and press releases were sent to the media announcing the
January .14, 1986 and July 29, 1987 public meetings (December 1985 &
July 1987). .
— A public meeting was held at the Montgomery Township Municipal Building
to discuss the initiation of the RI/FS. Approximately 35 people
attended including citizens, local officials and media representatives
(January 14, 1986).
The Operable Unit MTHD RI/FS report was placed in repository for public
review and comment at four locations: the Montgomery Township
Municipal Building, the Mary Jacobs Library in Rocky Hill, the Somerset
County Library Main Branch and DEP in Trenton. The public comment
period was from July 15, 1987 to August 14, 1987.
— A public meeting was held at the Montgomery Township Municipal Building
to 'discuss the completion of the Operable Unit RI/FS for Private
Potable Wells. Approximately 35 people attended including citizens,
local officials and media representatives (July 29, 1987).
— Telephone contact and written correspondence was maintained between DEP
and municipal officials and the press (ongoing throughout RI/FS).
-------
ATTACHMENT B
Letter from Resident
Regarding Trihalomethanes
-------
RECEIVED
AUG 1 3 1987,%
<* EiWronmtntrf fotatfw
W««r team
August "• 1987
Jan Gajewski
167 Montgomery Road
Skillaan, KJ 08558
Jeffrey Folaer, Senior Area Coordinator
f(J Department of Environmental Protection
* • * " • • -\
401 Bast State Street ' 1 ' • REC'O
C'v'
Trenton, MJ 08625 ;. t c;.,,c.
Dear Sir:
As a resident of Montgomery Road I wish to TO ice my concern over the
mandatory hookup to Elizabethtown public water proposed by the New Jersey
Department of Environmental Protection for homes in the Montgomery Road
Sycamore Lane area.
Through its past actions the HJDEP has made available to residents
t
in the area an alternative to private well water in the form of Elizabethtown
public water* Each resident has made a conscious decision as to the best
source of water. I am one of several residents who has chosen activated
charcoal filtered private well water. This source of water has been shown
to contain no detectable organic contaminants per analysis of Princeton
Testing Laboratory, P.O. Box 3108, Princeton, JQ 08540. In mandating hookup
to Elizabethtown public water the State will be forcing me to ingest chlorine
disinfected water against my better judgement. Recent epidemiologic studies,
such as the one enclosed, have demonstrated health risks which have resulted
-------
from drinking chlorinated water which meets present standards. Numerous
researchers hare docunented the increased mutagenicity of chlorinated water
via standard Ames test*. Present studies of chlorinated water are quite
reminiscent of asbestos research during the 1950's. In mandating public
water the State is assuming a custodial role with all the responsibilities
which this implies. I urge the New Jersey Department of Environmental
Protection to consider the long term consequences of its decision,
Sincerely
f ^ X"9
Jan Gajewsfci
-------
1982.
s lot
'nn«.
69.
Journal of the National
Cancer Institute
December 1981
Volume 67
Number 6
STACKS
^^w-J&sag^ssS^**'^ t-ry^-nrt^ ^
SSW8§5S^W
V'.:ra&*te*£&'£ ?3rfEm::
U.S DEPARTMENT OF HEALTH AND HUMAN SERVICES Publ.c Heaitn Service National Instrtutes of Health
-------
_M
Journal of the National
Cancer Institute
October1981
Volume 67
Number 4
THE JOURNAL of the National Cancer Institute
solicits manuscripts on original observations in
laboratory and clinical research Crom all scientists, A
manuscript is considered (or publication with the
understanding that it has not been published previously
and is submitted exclusively to the Journal. Opinions
expressed by the authors are not necessarily those o(
th* publisher or its editors.
THE JOURNAL is published monthly (two volumes a
year). The Secretary of Health and Human Services
has determined that the publication of this periodical
is necessary in the transaction o( the public business
required by law of this Department.
AJUONOGRAPH SERIES covering proceedings of
scientific meetings pertaining to cancer is also
published. These books may be purchased from the
Superintendent of Documents. Series subscriptions are
not available and monographs are not included in a
subscription to the Journal.
THE JOURNAL is for sale by the Superintendent of
Documents. U.S. Government Printing Office, Washing-
ton. D.C 20402. Price per copy. $6.00. Subscription
price for (wo volumes per year in the United States.
{65.00: foreign. $81.25. Payment is required in advance,
arid check or money order should be made payable to
the Superintendent of Documents.
All inquiries regarding purchase of subscriptions or
depository library distribution, including inquiries
about missing issues and change of address, should be
addressed to the Government Printing Office. The
Government Printing Office requires payment in
advance on all orders. Inquiries regarding missing
issues or change of address (or official subscriptions,
should be addressed to the Editorial Office. Room
850. Westwood Building. 5333 Westbard Avenue,
Bethesda. Md. 20016.
VINCENT T. DEVITA. JR., Director,
National Cancer Institute
BOARD OF EDITORS
JOHN L. ZIICLER. Editor in Chief
ELIZABETH K. WEISBI.-RGER. Assistant Editor
in Chief
STUART A. AARONSON. Associate Editor
MARV A. FINK. Associate Editor
JANET w.,HARTLEY. Associate Editor
DONALD HENSON, Associate Editor
RONALD 8. HERBERMAN. Associate Editor
GEORGE s. JOHNSON. Associate Editor
KURT w. KOHN. Associate Editor
ARTHUR s. LEVINE. Associate Editor
JOHN j. Mi'LMHiLL. Associate Editor
ALAN s. RABSON Associate Editor
RICHARD M SIMON. Associate Editor
EDITORIAL STAFF
EDWIN A. HAi'CH. .Managing Editor
PAMELA T ALLEN. Assistant Managing
Editor
FLORENCE i GREGORic. Afonograp/i Editor
Editors: DOROTHY D KATZ. MERCEDES B. LA CHARITY.
JOAN O'BRIEN RODRIGUEZ. CONSTANCE R. STONESTREET.
and ANNA B WITTIG
JNCI iNIH Publication \o 82-13)
U.S DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
National institutes of Health
-------
gpidemiologic Study of Drinking Water Chlorination and
; Wisconsin Female Cancer Mortality
1.2
B. Young,3 Marty 8. Kanarak,3 and Anattaslot A. TtltlU 4
—Th* association between gastrointestinal, urinary
brain, lung, and breast cancer mortality and drinking water
tffnciomethane exposure, as estimated by average daily chlorine
: 0osng* of w-t*r •ourc* 20 ***** P**1- wa> Investigated for
Wisconsin white females by use of a death certificate-based
jg^a-CL.'irol study design. A total of 8.029 cancer deaths and
1.029 controls (noncancer deaths) matched on county of resi-
jgnce. year of death, and age were taken from mortality records
0126 counties for the years 1972-77. Data on characteristics and
fitment of municipal water supplied to the residences of cases
tnd controls were obtained from questionnaires sent to the water
wpsrintendents of the 202 waterworks associated with the
asmple. By the'use of logistic regression analysis, odds ratios for
ilta-specific cancer death associated with high, medium, and low
chlorine-dosed water as compared to unchlorinated water expo-
sure were determined: the control variables were urbaniclty,
marital status, and occupation. With the exception of cancer of
0M colon, no anatomic cancer site was significantly associated
with any chlorine dose exposure category. For colon cancer,
Odds rstios of 1.51 [95* confidence interval (Ct)« 1.08-2.14], 1.53
(95% 01 = 1.08-2.00). ane V53 (95% Cl«1.11-2.11) were obtained
JOT high-, medium-, and low-dose Chlorination, respectively
K>£0.02). For colon cancer cases and controls exposed to water
Sources affected by rural runoff, odds ratios of 3.30 (95% Cl =
1.45-7.48). 3.60 (95* 01 = 1.57-6.26), and 2.74 (95% Cl = 1.10-
6.88) were observed for high, medium, and low chlorine dosages
20 years past (P<0.025> —JNCI 1981; 67:1191-1198.
Acute chloroform exposure has been known to cause
necrosis of liver, kidney, and central nervous system
tissue since the 1940's, which dates to the era of
chloroform anesthesia (1). Due to its toxic effects,
chloroform was banned from use in medicinal prepa-
rations, and occupational standards were established
(2). Widespread exposure to low levels of chloroform
and other trihalomethanes* became apparent, however,
when nationwide water surveys found these com*
pounds to be pervasive in municipal water supplies
disinfected with chlorine (3). Chloroform concentra-
tions were found to greatly exceed those of any organic
contaminant, including industrial pollutants. With
repeated findings tha: chloroform is carcinogenic under
bioassay conditions in rodents (4) and that other
trihalomethanes are rr.utagenic (2), the chronic, low-
dose exposure of a targe proportion of the population
to trihalomethanes via chlorinated drinking water as-
sumed additional importance and necessitated assess-
ment of human cancer risk.
A number of epu:-r.iologic studies have been con-
which examine -.he relationship between drink-
vater variable.- ihat crudely reflect THM ex-
lire and cancer ru-rulny or incidence (5-10). Sig-
nificantly higher cancer mortality rates for various
anatomic sites (gastrointestinal, urinary tract, lung)
have been found in geographic areas supplied with
chlorinated surface water (6, 7), prechlorinated water
(8), and water with recently measured high THM levels
(9). In a case-control study of seven New York counties,
excess gastrointestinal, urinary tract, and lung cancer
deaths were associated with presumed use of both
chlorinated surface and chlorinated ground water (10).
In general, these studies have been considered incon-
clusive as a result of the lack of concurrence of the
anatomic cancer sites associated with higher risk.
However, many o'f these studies were preliminary in
intent and were not designed to assess THM exposure
per se. From the consideration that an oncogenic
effect appears to be associated with probable exposure
to trihalomethanes, further investigation incorporating
more exposure specificity was a major aim of this study.
Trihalomethanes are thought to result from a halo-
form-type reaction of chlorine with naturally occurring
organics in water (11). Whereas trihalomethanes are
rarely detectable in unchlorinated water, THM con-.
centration in chlorinated water is a function of the
amount of chlorine added* concentration of organic
precursor, pH, water temperature, and water purifica-
tion procedures (12-15). Historical data for most of,
these parameters were available from Wisconsin water-
works records. Consequently, the case-control study
ABBREVIATIONS usiD: C]-confidence interval: 1CDA*> International
Classification of Diseases adapted for use in the United Stairs (8th
revision); THM = trihalomethane.
1 Received December 2. 1980; revised June 19. 1981; accepted JuK
21. 1981.
1 Supported by Environmental Protection Agency contract
C2769NAEX and by grants from the University of Wisconsin
Graduate School and from ihe Wisconsin Clinical Cancer Center.
Cancer Control Program.
1 Department of Preventive Medicine. University of Wisconsin. 504
North Walnut Si., Madison, Wis. 53706.
4 Department of Bioiiatisncs Harvard School of Public Health.
and Sidney Farber Cancer Institute. Boston. Mass. 02215.
1 We thank Dr. Ray Nashold (Director of Health Statistics.
Wisconsin Department of Health and Social Sen tecs i (or providing
the mortality data used in this study and Mr. Kevin Kessler iBuirju
of Water Quality. Wisconsin Department of Natural Resources- lor
assisting in the gathering of exposure data.
' CH(R)i where R represents chlorine, bromine, or iodine or
combinations thereof: th« major trihalomethanes in drinking water
are chloroform, bromodichloromethane. dibromochloromeihane. and
tribromomethane (bromoformi
1191
JNCl. VOL 67. NO. 6 DECEMBER !JSi
-------
TI92 Young, Ktnarti
reported here examines the risk of site-specific female
cancer death associated with THM exposure, as esti-
mated by chlorine dose of water supply 20 years past
and other water factors known to affect THM levels.
METHODS
Study design.—A death certificate-based case-control
study design was used in which the characteristics of
water supplied to the last residence of the cases (female
cancer deaths) are compared to the characteristics of
water supplied to the controls (female noncancer deaths).
Inherent in this design were the assumptions that cases
and controls were exposed to the water supply associ-
ated with the "usual place of residence" recorded on
the death certificate for 13-20 years before death snd
thai this *ater source provided most of the water
consumed daily. These tenets were maximized by the
imposition of two sample renr.aions. First, males were
eliminated from the sample, ror this cohort of dece-
dents (death years 1972-77), males were likely to have
experienced more residential mobility before their last
residence. Furthermore, males of this era were more
likely to h2ve been employed outside the home than
were females and thus to have had significant exposure
to water other than the home supply on a daily basis.
Second, only counties with 10-year population in-
creases due to immigration of 10% or less over the past
two decades with both chlorinated and unchlorinated
water supplies were considered as sources of cases and
controls.
Sample of cases and consols.—Cases were defined
as all white female deaths that occurred 1972-77 within
the 28 study counties due 10 malignant neoplasms of
the following sites: esophagus, stomach, colon, rectum,
liver and intrahepatic bile ducts, pancreas, urinary
bladder, kidney, lung, breast and brain (see table 1 for
ICDA codes). Due to the lack of racial heterogeneity in
most of Wisconsin, only v r.ite female deaths were
included. Gastrointestinal and urinary tract cancer sites
were chosen on the basis of experimental animal
studies and clinical reports, which suggest kidney and
liver as target organs and ecological studies that link
treated water with gastrointestinal and urinary cancer
mortality (I, 4, 5). Lung cancer in females has been
linked to treated water in both ecological and case-
control studies (9, 10). In addition, the lung is a
biologically plausible target organ, since it is a major
excretory route of ingested chloroform (16} and a site of
considerable enzymatic metabolism of toxic compounds
(17}. Brain cancer is included on the basis of the
relationship with THM exposure found in the eco-
logical study by Cantor et a! 9) and of the clinical
findings that link chloroforrr exposure to brain lesions
(/). Breast cancer was origin..!! included as a control
site, because most current!* htid risk factors for this
site are of a genetic or hormon.il nature, and environ-
mental factors have not beer. implicated. Findings from
metabolic and animal studio ':•. >wever. give no justifi-
cation for precluding breav .-• target tissue. To the
JNCl. VOL. 67, NO 6. DECEMBER -
contrary, mammary tumors seen in mice exposed to
chloroform (4) and findings from a metabolic study
suggestive of a positive relationship between arrutfL J
adipose tissue and ingested chloroform retenti^H^
posed some biological rationale (or investigation J
this site.
All deaths meeting the case criteria were taken from
computer tapes of abstracted death certificates provided
by the Wisconsin Department of Health and Social
Services, Bureau of Health Statistics. A noncancer
death was then matched to each case on the basis of
sex, race, year of death, county of residence, and nearest
birth date (day, mo, yr).
The sample distribution by cause of death is pre-
sented in table 1. Several points are worthy of note. For
most controls (71%), the cause of death was categorized
as circulatory system disorders. There is some indication
from animal studies that chloroform can induce heart
and blood vessel lesions (/, 4). This possibility would
tend to reduce differences in mortality associated with
THM exposure. Similarly, since chloroform exposure
is associated with liver and kidney necrosis in humans
and experimental animals, control deaths due to liver
and kidney disorders may also tend to reduce a
relationship between cancer death and THM exposure.
A small percentage (1%) of the controls died due to
infective and parasitic diseases. Some of these deaths
may be related to waterborne infectious agents present
in unchlorinated water. A positive relationship with
unchlorinated water for these controls would thus have
the effect of overestimating a positive relatio;
between cancer death and chlorinated water. Due t1
small numbers of relevant controls, however, the
tential effect would be slight.
Exposure data.—Water source for each decedent was
assigned on the basis of the water facility, if any, that
served the population within the boundaries of the
city, village, or town listed on die death certificate as
the usual place of residence. Residences not served by
private or municipal waterworks were considered to
have individual wells. In addition, residences served by
waterworks constructed more recently than 1970 were
considered to have an individual well water source,
since the exposure of interest would have been before
the operation of these waterworks. Water treatment and
characteristics for each of the 202 different water
sources that had served ihe sample were then gathered
and linked to the decedents.
Type of water source (surface or ground), depth of
ground source in feet, and use of purification proce-
dures (coagulation, sedimentation, and filtration i were
obtained from the 1970 Wisconsin Waterworks Surve\
report (based on data for 1960-65). More detailed
information on prechlorination and'or postchlorina-
tion dosages used over the past 20 years (average daih
dose in ppm; and the occurrence of several environ-
mental factors influencing organic content of raw
water (rural runoff, industrial discharge, air pollution.
and water with taste or color) were ascertained from a
mail-bark questionnaire sent to each
water supe
-------
WtUr Chlorlnatlon and Ctnetr Mortality 1193
TABLE 1.—Sampit distribution by cautt of deatit'
^*
Cause of death
"cancer, 50.000
No. of Percent
deaths of deaths
6.900
10.086
90
13.840
12.460
2.922
756
1.217
1.139
2.596
7.428
43
63
<1
86
78
18
5
8
7
16
46
' Sample consisted of 16,058 Wisconsin female deaths. 1972-77
* Population category was from the 1960 U.S. census.
JNCI. VOL. 67. NO 6. DECEMBER 1981
-------
1184 Young, Kanarek, and T«latl»
TABU 3. — Distribution of sample fry Marine dote categories'
Category (chloriaa doM)
None
Low (0.01-0.99 ppm)
Medium (1.00-1.70 ppm)*
High (1.71-7.00 ppm)
Sample, «« 16.058
No. of Percent
deaths of deaths
3.598 22.40
1.340 8.34
8.603 63.67
2.617 16.67
Waterworks
No. report-
ing. M* 202
96
66
26
26
ifi
* Wiiconain female deaths. 1972-77.
* The numerous recipient* of Milwaukee city water con-
tributed heavily to this category. The chosen cut-points, however.
maximized water source variability (No. of waterworks) within
each category and provided reasonable dosage ranges.
DATA ANALYSIS
For analysis with each individual decedent as the
unit of observation, each case or control was assigned
the appropriate value for 1) water variables, based on
the water source for the residence, and 2) control
variable^, based on death certificate and census data.
Cut-points for high, medium, and low average daily
chlorine dose categories were established, which created
exposure categories of reasonable dosage ranges and of
adequate numbers of waterworks and decedents. The
distribution by sample decedents and by waterworks is
given in table 3.
The site-specific cancer risk associated with water
supply was estimated by the analysis of several sta-
tistical models in which logistic regression was per-
formed separately on each cancer site subsample and
the corresponding set of matched controls (see ap-
pendix). The distinct advantage of this technique lay
in its ability to account for factors that may confound
the association of interest and to allow for the influence
of factors related to the strength of the association (25).
Thus when variables for potential confounders were
included in the logistic regression model, the estimated
value of the regression coefficient for si;
cancer death in relation to chlorine dosef
estimate of the log odds ratio associated
exposure) is considered to be adjusted for the~oth
variables in the model (26). e
A computer program capable of multinominal lo~j
tic regression was used which computed maxirnu
likelihood estimates of the regression coefficients. Lo
likelihood ratios which approximate a *: disiributicf
were used to assess the significance of the resultan
odds ratios (27). Standard errors of the paraniete
estimates, computed by the program from the inverter
matrix of the second derivatives of the log-likelihooc
function, were used to construct 95% confidence in
tervals (27, 28).
RESULTS
Analysis of Site-Specific Cancer Risk of
Chlorinated Water
Table 4 presents the results from the analysis of the
basic model which estimates the relative risk of site-
specific cancer death for exposure 20 years past to
high, medium, and low chlorine doses as compared to
no chlorination, while urbanicity, marital status, and
site-specific high risk occupation are controlled for. i
Only colon cancer death showed a significant (/><0.05) j
association with chlorine dose. No other cancer site
risk was found to even approach significance,
exception of brain cancer death in areas
chlorine-dosed water (/*=0.09).
For these two sites, chlorine dose 10 years past was
also used as the exposure variable to allow for a shorter
latent period. Positive odds ratios for colon cancer were
found for the more recent chlorine dose, but they were
not significant (P-0.09). (See table b.)
For brain cancer death, odds ratios for categories of
total chlorine dose 10 years past were similar to those
of the 20 years-past variable, and they. were of no
TABLE 4.—Odds ratios of rite-specific cancer death associated u-ith chlorinated water exposure SO yearn past*
Chlorine dose category
Cancer site
(No. of deaths)
High
Medium
Low
No. of Odds
deaths ratio
(95% CD
No. of Odds
deaths ratio
(95% CD
No. of Odds
deaths ratio
None?
No. of
(95% CD deaths
Esophagus(194)
Stomach (914)
Colon (3502)
Rectum • 3 yr (1976-78) of breast cancer mortality were analyzed.
«°
. d
JNC1. VOL. 67. NO. 6. DECEMBER I98f
-------
Water Chlorlnatlon and Cancer Mortality 1195
TABLE 6.—-Odd* ratio* of colon and brain cancer death associated with chlorinated u deaths n£ P (f
Low
)5%CI) No-°( M** P
None:
No. of
(95% CI) deaths
Controlled for rural run-
off (2.776)
Stratified for rural runoff
Not exposed (766)
Exposed (2.010)
Controlled for water
source depth and
purification
510 1.58 0.03 (1.06-2.40) 1,618 1.56 0.03 (1.05-2.34) 356 1 44 0.03 (1.01-2.07) 292
27
483
483
1.37 0.40 (0.60-3.12) 205 1.28 0.40 (0.73-2.25) 27?
3.30 0.003 (1.45-7.48) 1,413 3.60 0.002 (1.57-8.26) 78
135 0.13 (0.91-2.00) 256
2.T4 0.025 (1.10-6.88) 36
3.43 0.003 (1.48-7.96) 1.413 3.68 0.003 (1.56-870) 78 2.?4 0.015 (1.20-7.24) 36
' Sample included municipal water recipients only. Ratios are relative to no chlorinaiion: con:-3.' ariables were urbanicity and
status: Wisconsin female deaths 1972-77.
•na^tol
JSCJ VOL. 67. NO. 6. DECEMBER 19*1
-------
1196 . Young. Kanartk, and Tilatls
dosed water. For the subsample exposed to rural
runoff, odds ratios of 3.50, 3.60. and 2.74 were found
(/»<().003) for the high-, medium-, and low-dose cate-
gories, respectively. Variables for water source depth
and purification were then added to the basic model.
As seen in the table; these variables somewhat increased
the odds ratios.
For completeness, the entire sample was analyzed
under this model, with private well users coded zero for
chlorination, rural runoff, and water purification and
assigned to the less than 250-fooi well-depth category.
Neither the odds ratios nor the significance levels
differed appreciably.
In the comparison of the results of various models,
the risk of colon cancer associated with any dose
category of chlorinated water is over twice as. great for
water affected by rural runoff. In contrast, odds ratios
are fairly constant over chlorine dose categories under
any particular model. Thus it appears that organic
precursor content of chlorinated water is more im-
portant in regard to dose-response considerations.
«
DfSCUSSfcN
The major finding of this investigation is that death
due to colon cancer for females is significantly associ-
ated with exposure to water that was disinfected with
low, medium, or high daily chlorine doses for at least
20 years. The validity of the models used in this in-
vestigation must be scrutinized to generalize the study
results or to infer risk in a meaningful way.
Misclassification error, a major problem in retro-
spective studies where past exposure must be traced or
estimated, is of compounded concern in death certifi-
cate case-control studies, where the effect is also
vulnerable. The potential for exposure misclassifica-
tion arises from unknown water exposure histories,
other than that source associated with the residence
recorded on the death certificate, and from the ability
of the exposure variables used to differentiate among
high, medium, and low THM exposure by the cases
and controls. For the first limitation, migration from
areas of low THM water concentration to areas of high
THM concentration and the converse have the effect of
damping a measurable relationship. Such effects were
researched by Polissar (30). who showed quantitative
loss in sensitivity of cancer risk estimates to be propor-
tional to the latent period and size of the geographic
area that encompasses the exposure. The long latent
period assumed for colon cancer and the rather small
geographic boundaries of waterworks thus tend to
reduce the degree of risk discernible in this study.
However, Polissar points out that since mobility is age-
dependent, diseases with a higher incidence among
older age groups are more likely to occur near the
location of the environmental "cause."
Since the measure of effect in this study is mortality
rather than incidence, migration during the interval
between cancer diagnosis and death musi also be
considered. For females, the 5-year survival rate for
JNCl. VOL. 61. NO. 6. DECEMBER 1981
colon cancer is approximately 46% (31). During this
period, the cancer diagnosis may influence a '
to migrate and possibly introduce bias. If t
trend toward migration to more urban areas
tend to chlorinate) for proximity to medical care as an
example, a spurious association between chlorine-
treated water and cancer death would result. Three
aspects of this study presumably minimize this possi-
bility. First, only counties with low migration rates
were considered as sample sources. However, this does
not preclude intracounty migration. Next, migration
due to cancer diagnosis would be less likely for married
females, since (for this cohort of decedents) the spouse's
occupational status would weigh against a move re-
quiring a job change late in life. Finally, urbanicm
was always included as a control variable in the
analysis.
A second major source of exposure misclassification
lies in the use of water variables as surrogates for
ingested trihalomethanes. While chlorine dose and
organic contamination may adequately reflect the THM
level of water at the time of treatment, several factors
not measured in this study may be of greater impor-
tance in the determination of an individual's ingested
THM dose. Differences in THM concentrations at
home water taps due to continued THM formation
along the water distribution system, the amount of
water ingested daily from the home water tap, signifi-
cant ingestion from water sources other than the one
supplied to the home, and past use of chlorof
containing cough syrups or other preparation
account for considerable dose variation amon_
dividuals with the same water supply. Use of surro-
gates has been reported to result in loss of power and
underestimation of the true relative risk proportional
to the strength of the association (31).
Another shortcoming due to the death certificate-
based study design is the uncerumty of accurate effect
classification. A recent study of death certificate ac-
curacy showed that malignant neoplasms were under-
reported by approximately 10%, and vascular diseases
overreported by 10% (33). From the assumption that
misclassification with respect to exposure is indepen-
dent of misclassification of effect, the net result is again
power reduction, with a measured relative risk in the
same direction as that, of the true relative risk, but
reduced in magnitude, according to Gladen and Rogan
(32).
The major sources of misclassification error in this
study are not likely to explain the significant finding*
for colon cancer. Also, there is evidence that misclas-
sificau'on has the effect of both underestimating the
true risk and obscuring a dose-response relationship.
However, in view of the lack of evidence for a dose-
response relationship, possible :oniounding factors are
of greater concern. While it would have been unlikeh
for unknown colon cancer risk factors to be correlated
with the amount of chlorine add*-;: to the water su
it is possible for such factors :_• be associated
living in an area supplied w:ih chlorinated
t--
^K*TM^^"*^^""**'^^'"™" ., . -.»—- --~ ;; • _ , _4 ;^ '~.\:-* '• .>»•'•. <*
-------
Exposures to other environmental contaminants, life-
nyle (acton, and ethnic susceptibilities are all sources
of possible contribution to risk error through con-
founding. In summary, the findings of this investiga-
tion must be coruajfaed inconclusive, due to the
possible underestimation- of risk associated with mis-
classification error and possible spurious contribution
to the study findings from unknown colon cancer risk
factors.
The results of this investigation do not significantly
implicate any other gastrointestinal, urinary tract, lung,
brain, or breast cancer risk for Wisconsin females. Two
points in this regard must be noted. First, in view of the
decreased power and probable underestimation of risk
inherent in the study design used, it is not possible to
generalize the Wisconsin results by summarily dis-
missing exposure association with other sites. Second,
carcinogenic organotropism is exceedingly complex; a
variety of exposure and coexposure conditions that
vary by geographic area may impact on the nature and
magnitude of measurable population effects. There is,
for example,, evidence that activation of chloroform,
tissue binding, and subsequent lesions are affected by a
variety of compounds and conditions [such as DDT,
benzo[a]pyrene, polybrominated biphenyls, chlordecone
(Kepone), and protein deficiency] to which the popula-
tion is differentially exposed (34-37).
While we stress both the modest risk and the
preliminary nature of this study and similar studies (5),
the excess colon cancer mortality associated with chlo-
rinated water is provocative. At present, there are few
clues to the etiology of this major cancer. The high
rate of colon cancer among the more economically
developed nations has focused attention on the high-
fat, low-fiber diet of these nations in contrast to the
diet of nations with lower rates. Evidence from epi-
demiologic studies examining these possible diet risk
factors, however, has been largely inconclusive; a recent
editorial by Graham et al. (38) stressed the need to
pursue new colon cancer hypotheses. As several authors
have noted (39, 40), there are a number of potentially
important correlates of industrial development in addi-
tion to high-fat diet. Those factors of special relevance
to the findings of this investigation include water
chlorination and environmental dispersion of the in-
dustrial spillage, leachates, and refuse of advanced
nations. Clearly, drinking water exposure deserves
attention in future epidemiologic studies of colon
cancer.
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(34) MCLEAN PE. The effect of protein deficiency and microsomal
enzyme induction by DOT and phenobarbitone on the acute
toxicity of chloroform and a pyrrolizidine alkaloid retrorsine.
Br J Exp Pathoi 1970, 51:317-321.
(31) KLL'WE WM, HOOK JB. Polybrominated biphenyl-induced po-
teniiation of chloroform toxicity. Toxicol Appl Pharmacol
1978; 45:861-869.
(.?.*> M'wirr 'VR. MIYAJINA H. COTE MC, Pi** GL. Acute alien-
lion of chloroform-induced hepato and nephroioxicity by
Mirex and Kepone. Toxicol Appl Pharmacol 1979; 48.509-
527.
(37) CAUL ID. Dotneu. HM, JENNM M. WILLIAMS DC. Effect of
chloroform ingestion on some carcinogen metabolizing en-
zyme systems in rats. Bull Environ Coniam Toxicol 1979; 23:
112-116.
(38) GMHAM S% HAENSZEL W, BOCK FG, LYON JL. Need to pursue
• ' new leads in the epidemiology of colorectal cancer. JNCJ
1979; 63:879-881.
(39) HICCINSON J. Etiological factors in gastrointestinal cancer in
man. J Nail Cancer Insi 1966; 37:527-545.
(40) GRAHAM S. DAVAL H. SWANSON M. MITTELMAN A. WILKINSON
G. Diet in the epidemiology of cancer of the colon and
rectum. JNC1 1978: 61:709-714.
APPENDIX: LOGISTIC MODEL- ESTIMATIO
ODDS RATIO OF CANCER DEATH AND
CHLORINE LEVEL EXPOSURE
Log
ffl
[*<
x chlorine dose)
P(no chlorination)
P(x chlorine dose I D=*l, V, C, W)
log odds cases
'P(no chlorinationI D-l, V, C, W)
, ,, . P(x chlorine dose I D-0, V, c w\
log odds controls = s; r:—: :—r-= :— -I
/•(nochlonnatjonl Z)=0, V, C W?
log odds ratio
log odds cases
S '
log odds controls
AWJ
-[a + 0 (0) + yV + oC
log odds rauo=£,
where x = high, medium, or low dose; £)=cancer death
(yes = l, no = 0); V- matching variables, age in years
percent county chlorine exposure; C=comrol vari-
ables — 1] marital status (married= 1, not married = 0), 2)
high-risk occupation (yes=l, no = 0), and 3) urbanicity
«2.500=1, 2,501-5.000=2. 5.001-10,000=3. 10,001-
20,000 = 4, 20,001-50,000=5, >50,000=6); and W=cx.
planatory water variables — 1) rural runoff (yes = J,
no=0), 2) purification (yes = l, no=0), and S) source
depth (surface source = 1, wells <250 feet » 2, wells
251-500 feet = 3, wells >500 feet = 4).
I MA
i
JNCJ. VOL 67. NO 6. DECEMBER 1981
-------
ATTACHMENT C
Description of Hybrid Alternative
(This alternative has been Identified as Alternative 5
in keeping with the RI/FS numbering system.)
-------
ALTERNATIVE DESCRIPTION
Alternative S
This alternative is a hybrid of alternatives .2 and 3A.
Eliz'-abethtown Water Company's supply system will be hooked-up to
homes, on streets where the company's distribution lines are
already in place/ including homes on Sycamore Lane/ Robin Drive/
Oxford Circle/ and Cleveland Circle. The four homes on
Montgomery Road will remain on their wells/ however a well
treatment system/ such as that described in Alternative 3A with
afr-stripping and activated carbon adsorption, will be provided
for each of these homes.
ALTERNATIVE EVALUATION
Public Health Evaluation
Alternative 5. For the 35 residents who wilJ. be hooked-up
to the Elizabethtown Water Company supply system, health effects
will be the same as those described for Alternative 2, in that
ARARs will be met or exceeded based on available data. The
individual well treatment system, proposed for each of the four
remaining residents will meet the ARARs for the organic
contaminants provided the system is well monitored and
maintained. There is no guarantee/ however/ that heavy metals
will be removed to a level that will meet the ARARs.
Environmental Assessment
Alternative 5. Although the off-gas from the air-stripping
column will contain the stripped volatile organics/
-------
concentrations from these units is expected to be minimal when
dispersed to the open air, therefore the environmental impact of
the off-gas from the four columns is minimal. Activated carbon
replacement will be handled by the vendor, and disposal or
regeneration will be conducted off-site.
Assessment of Technical Feasibility
Alternative 5. Extension of the Elizabethtown Water Company
supply system can be easily implemented since, for this
alternative/ the water mains are already in place. Installation
of individual well treatment, for the four residents on Montgomery
Road will be implemented using well established technologies.
Like Alternative 4, the reliability of the treatment systems is
based on existing water quality and contaminants identified.
Possible future variations of contaminant levels or newly
identified contaminant parameters could adversely affect the
reliability.
The capital cost for this alternative is $266,000, as
presented in Table 5-3. The annual O&M cost, associated with
sampling and maintenance of the individual well treatment
\
systems, is $11,000.
-------
TABLE 5-5. CAPITAL AND O&M COSTS "HYBIRD" ELIZABETHTOWN
WATER ^ INDIVIDUAL TREATMENT SYSTEMS - ALTERNATIVE 5
Cost Item «y Cost, $ '
Ex'tejjtion of Elizabethtown Water
Valves (4) 11,000
"Well Sealing 35,000
Service Connections 46/000
Pavement Repair 5,000
Subtotal 97,000
_ Engineering and Contingencies (25%) 24,000
Subtotal ' 121,000
Individual Well Treatment - 4 residences 102,000
(See Table 1-1 for details)
- Analytical (startup) 2,000
- Engineering & Contingencies (40%) 41,000
Subtotal 145,000
TOTAL CAPITAL COST "$266,000
Annual O&M For Well Treatment
- 4 Residences $11,000
(See Table 1-1 for details)
Does not include tax impacts. ~~"
-------
ATTACHMENT D
Letter from Security & Safety Systems Representative
Regarding Activated Carbon Adsorption
-------
Security & Safety Systems AU6 101987
MKOOTHAL
74 MKMttMO OMV«
SMUMAM.MJM9S*
(201)874-5018
July 31,1987
Mr. Douglas E. Seely
Senior Projtet Scientist
Me teal f and Eddy, Inc.
P.O. Box 4043
Uoburn, Mass. 01388-4043
Dear Douglas I
This letter is in response to our discussion following
the documtntation and present ion of the Montgomery Township
Remedial Investigation/Feasibility Study of 39 private
contaminated wells.
Enclosed per your request are copies of the result* of
extensive EPA 601 it 604 protocol testing and information
reflecting over * 10 million of product development and
reseach. The technical feasibility and economic viability
of the methods we recommend are well documented in detailed
EPA reports, major Educational Institutional Studies,
Private Industry research, Independent Laboratory testing,
and by many Environmental Engineering Consultants.
This information scientifically substantiates the
superior performance capabilities of solid carbon block
filtration over less sophisticated activated granular carbon
filters. Clearly, the two most important state-of-the-art
breakthroughs ares
The ability of SOLID CARBON BLOCK technology to
remove over 100* of the EPA 128 priority pollutants.
(No other filter technology can effectively remove
more than 40 of the 83 toxic chemicals required by
the EPA under the 1986 Safe Water Act guidelines)
Solid Carbon Block construction provides a major
safety advantage because EVERY DROP OF WATER passes
through the carbon and is filtered. (Granular
activated Carbon filter dependability is often
plagued with channeling and frequently deteriorates
rapidly in use with no indication that they are
performing poorly and/or are no longer effective)
-------
Other outstanding performance benefits of SOLID CARBON
BLOCK point-of-use -filtration includes
water quality remedial technology available!
* Majof* drinking water problems are solved immediately!
* L»»» expensive and healthier than bottled water!
* Convenient because safe water is always available!
* Eliminates costly and unnecessary filtration at
public water processing plants!
* Removes the unpleasant smell, taste and harm-full side
a-f-fects o-f Chi or i nation at the point-of-use!
* Filters can be easily replaced on a controlled basis!
« Eliminates individual Risk in sitiuations o-f common
water contamination!
Equally important, Security and Sa-fety Systems is a
full service company. We provide water quality testing and
monitoring, use only the most effective state-of-the-art
solid block carbon filter technology, utilize experienced
and licensed trades people for installation and service. Our
water treatment systems are backed with a manufacturing five
Yr. warranty and 100X customer satisfaction guarantee.
WATER QUALITY TESTING is conducted by our firm through
Aqua Associates Inc. and *AA LABS, Inc. Both firms are a
N.J. State Certified water chemistry specialists.
Costs range from * 45.00 to * 75..00-* 100.00*
SOLID CARBON BLOCK Water Treatment System point-of-use
technology manufactured exclusively by the Amway Corporation
is configured to meet the specific needs of each situation.
« 500 Gal. Family Model cost * 295.00
100 Gal. Compact ,Model cost * 99.93
INSTALLATION & MAINTENANCE is provided by several local
contractors (incl'd Jefferson Plumbing of Princeton). We
replace the solid block filters on a scheduled and routine
basis. This is done to insure proper working conditions and
avoid the concern of neglect on the part of the system user.
We accomplish this by registering each unit on a computer,
periodic water meter readings, scheduled water testing
cycles and/or any reasonable specific arrangements to comply
wi th regulat ions.
ft Installation per unit cost * 50.00
Maintenance call cost * 25.00
-------
SECURITY & SAFETY SYSTEMS is an Approved contractor
with tht state of New Jersey.
The following analysis reflects our order of magnitude
estimate w&Uie cost of both the short term and long term
benefit* tifzTFncluding solid block filtration in Alternative
i in litu Wf"* 130,000 for only 2 years of bottled water.
Equipment Investment*
39 Family 900 Gal. Models cost * 12,000
39 Compact 100 Gal. Models cost 3,900
78 2nd year (annual) filter replacements 780
Installation and Maintenance
39 Family 500 Gal. Models * 3,000
39 Compact 100 Gal. Models * 2,000
* Equipment cost includes 5 year warranty
\Je look forward in assisting Woodward Clyde, Me teal f
and Eddy, Inc., the N.J. DEP, the EPA, the township of
Montgomery and the Elizebethtown Water Co. in their efforts
to assure everyone who lives and works in Montgomery
Township that their water can be healthier and better
tasting that ever!
We offer our help in communicating and demonstrating the
opportunity for- your neighbors to be fully aware of and
protected with the best state-of-the-art now available in
the form of solid block carbon filtration systems.
We appreciate the opportunity to be considered in your
evaluation of experienced contractors who can effectively,
professionally, economically and immediately respond to the
water treatment problems you are working hard to resolve !
Sincerelyj
Warren Tunkel
President
CC!
Edward Putnam
Robert Gaibrois
Kevin M Psarianos
harley Seafass
Jeffrey Folmer
-------
£R
a AMWAY Water Treatment
s Pesticides and Herbicides:
JOT, DBCR malathion, and a
ral contaminants.
/es Industrial Chemicals:
exachioroethane, and many more
jis.
joves Chlorine and THMs:
.nd its THM by-products out of the
ire suspected cancer-causing asents.
removes Other Contaminants:
:>estos, precipitated heavy metals, sedi-
id scale.
faster
i, juice, ice cubes, and soup have a better
J no unusual odors.
Simple to Use:
Fits any standard
water faucet or
taps into your cold
water line. Use on-
the-counter or un-
der-the-sink.
Simple to Install:
No special tools
needed. Just fol-
low the step-by-
step instructions.
Large Capacity.
The averase family
can expect each filter
cartridge to last
about one year. It de-
pends upon how
much water you use
and the quality of
your water.
Replacement Filter
Cartridge:
No need to send the
entire unit back to the
factory for a new fil-
ter. Simply remove
the filter cartridge and insert a new one.
Nf W "CONCENTRIC RING"
FILTER DESIGN-EXCLUSIVEiyAMWAY
In addition to the advantages already mentioned,
Amway's unique "second generation" filter design
provides extra benefits:
• Five-stage filtration re-
duces sedimentary dog-|
gins, traps particles as
small as 0.2 microns
(1 /300th the diameter
of a human hair)
• Up to 25% greater ini-
tial flow rate
• Higher flow rate
throughout filter life
• More even water distri-
bution throughout filter
• New harder outer layer helps reduce acciden-
tal damage, increase durability. *
• Improved carbon block matrix allows more ef-
fective removal of hard-to-absorb chemicals
such as chloroform.
The Best Service:
If you have any problems installing or using your
System, simply call the toll-free Hot Line listed in
your Owner's Manual.
The Amway Satisfaction Guarantee:
If, after a reasonable time, you decide you're not
satisfied with your AMWAY Water Treatment Sys-
tem, you're entitled to a replacement, a full refund,
or full credit toward the purchase of another
AMWAV product.
PURE AND SIMPLE
c
74 RICHMOND DR.
S*H ? I'SW. N.J, 08558
Printed in U.S.A. T-SA-955-H 530587 SA-4616
-------
This giyes trie
.£ i
t* '
- *•.-..•
ai+J---!**--****^^^ :^;v-. -."
&*-:$$&&£A>2-!'f
iwaterteJ
r • Frank Nosek ^ -.' -iv- -. •:
9^^^^^^^^^-y^^^':~^-'•••;:.^;".>1 -;:-w:- •.•;•-' Tm^w. --.Vt?..• / ^
.A'/^yy^«*^j^ab^^agteafc^&^a^ >w^rtri<^i;«1^«UMuS*?e;-v4?>-- '-"'
\- -
Frank Nosek gets tap water directly from the city,
but It is often cloudy and brown. "Installing an
AMWAY® Water Treatment System turned our water
clearer, cleaner, and more appetizing. I really believe.
It encourages my family to drink more water." <
Frank likes the AMWAY Water Treatment System.
He's hooked It up to his kitchen tap and refrigerator
cold water dispenser. "It doesn't take up a lot of room
in our small kitchen, and It's movable if we move."
Frank especially likes the fact that his AMWAY Water
Treatment System gets results. "I tried one of those
filters you put on the end of the faucet. It didn't work.
- • * . •
even though ttiad to replace the filter every couple of:
months. With my AMWAV Water Treatment System, I
only have to replace the filter once a year." .
Frank believes that pollutants dont do your body
any good. So when his Amway distributor showed
Frank an Amway video, he quickly decided to buy. "I
knew our water didn't toofc good. The video made me
that much more aware of how many other things
might be In our water. 1 realized,the AMWAY Water
Treatment System would help me take better care of
my family and myself." :
' '
COM (201) 874-5018
-------
/?u/ft Mars/i, Onsfetf, Michigan
(201)874-5018
W TUNKKU
T4 BtCMMONO OMIVC
. NJ oessa
Security & Safety Systems
RCSIDCNTIAI.. COMMERCE
MECHCATIONAL VEHKLCS
"The AMWAY® Water Treatment
System took the harsh taste out of our well
water and gave it a nice, fresh-water taste,"
soys Ruth Marsh. "I really notice the
difference!"
The AMWAY Water Treatment System
effectively removes more than 100 E.P.A.
priority pollutants. It will improve the taste
and smell of your water, while it effectively
removes any chlorine, pesticides, industrial
chemicals, and other contaminants which
might be in your water. And it's small
enough to fit under your sink or on your
kitchen counter.
"I was hesitant to drink much water. I
feel a lot more comfortable drinking it now
with our AMWAY Water Treatment System,"
Ruth Marsh says.
If you want to assure good-tasting,
clean water for your family, ask an Amway
distributor to show you the easily installed
AMWAY Water Treatment System.
OperolionQl, moinlenonce. ono re-
placement requirements are essential
(or the product to perform as
advertised.
ecopvrigm Amwoy Corporation.
Ada.MIU.SA. 1987
All Rights Reserved
-------
The AM WAY® Water Treatment System
Versus Competitive Units
Comparison 1
One way to see how well a water filter works is to measure the Trihalomethanes (THMs) removed over the
rated filter life of the unit. The graphs below show the superior capacity of the AMWAY Water Treatment
System to several competitive water filters in removing THMs over the rated filter lives of the units depicted.
Rated filter lives of the competitive units depicted below vary.
tan
SugulllV
J-
h
Hurtoy Turn 4 Country
CulllganS8-2
Filter FrwhFM
AMF«C
-------
Comparison!
In general, the more carton a water filter has in relation to the amount of water it filters, the more efficient that
filter will be over its rated life. The graph below shows the superior capacity of the AMWAY Water Treatment
System to several competitive filters over the rated lives of filters.
ijipiv^Af^V^ &.»:'.< 'i^v-i -
E^m^^c.^
4l*a^^ .'• yi^ v
n?. ••••->".:..!
..':-;.<.'-s»'c4"i^ *»t-1-^ -.IwiV :'~ •'-•.'.:*:..•< y'•"••'':*-t.:>;iir«..r.^-!>: T;j.-'..iV;y-"^- ;-isf £.••;"• •• .'?.•.-'fi*.- •• ••: •
££J'!yV'^:*£«T'--«'.;'';: •-..-•":-"^-'r:':'>r'' ::--".^::''.V--':'J's-i>tr;.\.''*.'';..'X.'!'.".". -»•'"' •'••Vi'.'V;^'.'*': '•••"; "•-.•' '
Information for AMWAY Water Treatment System was generated in Amway Laboratories as described on the
reverse side.
Information on the competitive units was obtained from a report prepared for the Office of Drinking Water,
U.S. Environmental Protection Agency, Washington, D.C., July 1,1980. The Report is publicly available and
is entitled "Development of Basic Data and Knowledge Regarding Organic Removal Capabilities of Com-
mercially Available Home Water Treatment Units Utilizing Activated Carbon: Phase 1 and 2." The data for the
competitive filters obtained from the Report was based on a series of studies. The graphs depict the average
of the results of those studies.
\
CCopyr4gmAnmtyCorpar«lon.U.S>.1965.MIRIghalteMrvM.PrlnMlnaSX L-1371-SAC 530690
-------
CHEMICALS AND
YOUR WATER
THE FACTS
Man's use of chemicals dra-
matically affects the quality
of our water!
.Pesticides and Herbicides
They protect crops and in-
crease our food supply. But in
the past, toxic chemicals like
DDT and DBCP have mixed with
irrisation water and permeated
the soil. Many of these chemi-
cals have been banned since
1975, but because of their re-
sistance to decay, they con-
tinue to be found in sediments.
FACT: Traces of pesticides
thought to cause cancer
have been reported in
aquifers that serve the
Miami, Florida area.
FACT: A1974 study of dis-
solved residues of DDT
and dieldrin in surface,
subsurface, and finished
drinking water in Iowa
showed contamination in
every major watershed in
the state.
Industrial Chemicals
They increase the efficiency of
manufactures and are used in
the creation of products. More
than 100,000 chemical com-
pounds have been developed,
and each year an estimated
500-1000 more are introduced.
But chemicals like PCB, PBB, and
dioxin have been disposed of
in ponds, landfills, and la-
Soons. In the past, many of
these chemical dumps were
not properly lined and because
these chemicals have been
used for generations and be-
cause chemicals move slowly
in the earth, the problems may
have originated 20 or 30 years
ago.
FACT: A recent United States
Environmental Protection
Agency (EPA) survey of
176,647 industrial waste
impoundments showed
that 95% of the sites were
not being monitored for
groundwater contamina-
tion and that 70% of the
impoundments were
unlined.
FACT: In January 1980,39
public wells-serving
400,000 people in 12 cities
in the San Gabriel Valley,
California-were closed be-
cause of high levels of
trichloroethylene (TCE), an
industrial solvent. Similar
contamination and well
closings have occurred in
New York, New Jersey,
Pennsylvania, Connecticut,
Massachusetts, and Maine.
Chlorine
It's used to eliminate bacteria in
many municipal water systems.
But recent studies show that
chlorine reacts with organic
material in water to form chem-
icals called Trihalomethanes
(THMS).
FACT: The EPA reports that
THMs are not considered
dangerous at low levels
found in most municipal
water systems. But THMs
are suspected cancer-
causing agents!
FACT: In 1980, the U.S. Gov-
ernment's Council on Envi-
ronmental Quality
reported that chlorine
added to water increased
the risk of urinary-tract
and gastrointestinal
cancer.
Other Contaminants
What else is in the water? As-
bestos; heavy metals like lead,
cadmium, chromium, and zinc,-
sediments,- dirt; and scale.
FACT: Evidence suggests that
asbestos is a significant
contaminant in a number
of water supplies in the
United States. In Canada,
chrysotile asbestos was
identified as a major form
present in drinking water.
Age-standardized mortal-
ity rates for gastrointes-
tinal cancers were
calculated for 71 munici-
palities between 1966 and
1976. The results for two
cities with the highest as-
bestos concentrations
were compared with the
weighted average for 52
localities where the con-
centration did not differ
significantly from zero.
Relatively higher mortality
rates for stomach cancer
were recorded in both
sexes in one of the cities
and in males in the other
city. The death rate due to
cancer of the large intes-
tine also markedly in-
creased for males in the
first city.
-------
WHAT CAN
YOU
Once a groundwater supply is
contaminated, it can take gener-
ations to clean it up. That's not
immediate enough when the
public's health is threatened.
And though government, in-
dustry, and municipalities are
doing a better job, many of us
want the best possible water
now-not sometime off in the
future.
It's up to each of us to take re-
sponsibility for the quality of
our water, individuals have
been trying several alternatives
to clean up the water they per-
sonally use. Various methods
achieve various results.
TRADITIONAL METHODS OF TREATING WATER
Method
Spring water
Bottled water
Well water
Distilled water
Boiled water
Water
Softeners
Advantage*
• Generally free of chlorine and
THMS.
• Depends upon the source and
treatment method used by
the manufacturer.
• May or may not contain
chlorine and THMs-whether
local authorities require
chlorine treatment of water.
• Significantly reduced chlorine
and THMs.
• May contain less chlorine and
toxic chemicals than unboiled
water.
• Improve water for laundry
and battling.
Disadvantages
• Threat of chemical contamination exists-
spring water is only as safe as its source.
• Could become expensive.
• Agricultural contamination and other
toxic chemicals can infiltrate well
water.
• Free of trace minerals that are essential
to good health.
• Cannot remove most toxic chemicals-it's
hardly better than tap water.
« Do not remove toxic chemicals.
Filtered Water can be a good solution. How good depends upon the method used
FILTERED WATER METHODS FOR TREATING WATER
Method
Advantage*
Disadvantages
Reverse • Removes chlorine, THMs,
osmosis and many industrial »
filter compounds.
• Removes minerals, which are essential
good health.
• Some contaminants may concentrate
certain units as they pass through the
filter-increasing potential hazards.
• Slow and wasteful-up to 20 gallons
of water to get 1 gallon of
treated water.
Granular • Removes chlorine, THMs,
activated char- and toxic chemicals.
coal filter • Leaves minerals.
• Most units have a pre-filter
that removes rust and large
particles.
• Performance can vary greatly depend!
ing on the quantity and quality of
activated carbon and the design pera
meters of the unit such as flow rate,
prevention of channeling, etc.
Pressed • Removes chlorine, THMS,
carbon and toxic chemicals.
block filter • Leaves minerals.
• Pre-filter takes out large
particles and inner carbon
block removes smaller
particles.
• An efficient system-because
the filtering block is solid,
every drop of water passes
through the carbon and is
filtered.
Of all the methods for use on drinkable water, it's clear that a very effective system is
pressed cartoon block filter.
-------
The AMWAY® Water Treatment System effectively removes impurities from water including over
100 EPA priority pollutants such as organic contaminants, pesticides and trihaiomethanes.
Acenaphtnene
Acenaphthytene
Aldrin
Anthracene
Benzene
Benzidine
Benzo[a]anthracene
Benzo[a]pvrene
Benzo[b]fluoranthene
Benz0[ghi]perylene
Benzo(k]fluoranthene
alpha-BHC
teta-BHC
delta-BHC
gamma-BHC (Undane)
Bis (2-chloroethoxy) methane
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bromodichloromethane
Bromoform
4-Bromophenyl phenyi ether
Butyl Benzyl phthalate
Carbon tetrachloride
Chlordane (technical mix.)
para-Chloro-me£a-cresol
Chlorobenzene
2-Chloroethyl vinyl ether
Chloroform
2-Chloronaphttialene
2-Chlorophenol
4-Chlorophenyl phenyi ether
Chrysene
4,4-DDD
4,4-DDE
4,4'-DDT
Di-n-butyl phthalate
Dt-n-octyt phthalate
Dibenzo[a,h]anthracene
Dibrornochtorornethane
1,2-Dtehlorbbenzene
1,3-Otohlorobenzene
1,4-Dichtorobenzene
3,3'-Dichlorobenzidine
1,1-Dichloroethane
1,2-Dichloroethane
1,1 -Dichloroethylene
frans-1,2-Dichloroethylene
2,4-Dichlorophenol
1,2-Oichloropropane
1,3-Dichloropropene (trans)
Dieldrin
Diethyl phthalate
Dimethyl phthalate
2,4-Dimethylphenol
4,6-Dinitro-ortfJo-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
a/pna-Endosulfan
tefa-Endosulfan
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Ethylbenzene
Ruoranthene
Fluorene
Heptachlor
Heptachlor epoxide
Hexachlorobenzene
Hexachlorobutadiene
Hexachtorocydopentadiene
Hexachloroethane
Isophorone
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
A/-Nitrosodi-n-propylamine
/V-Nitrosodiphenylamine
PCB-1016(Aroclor1016)
PCB-1221 (Arodor 1221)
PCB-1232 (Arodor 1232)
PCB-1242 (Arodor 1242)
PCB-1248 (Arodor 1248)
PCB-1254 (Arodor 1254)
PCB-1260 (Arodor 1260)
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
TCDD (2,3,7,8-Tetrachloro-
dibenzo-para-dioxin)
1,1,2,2-Tetrachloroethane
1,1,2,2-Tetrachloroethene
Toluene
Toxaphene
1,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
2,4,6-Trichlorophenol
-------
AMWAY Water Treatment System Effectively Removes Precipitated Heavy Metals.
Certain metals do not dissolve in water—they are suspended In it. These metals are called
"precipitated heavy metals." The AMWAY Water Treatment System effectively removes
precipitated heavy metals. There are many different types and some are listed below. The System
also removes over 99% of asbestos, sediment, and scale.
Iron Oxide
Copper Oxide
Zinc Oxide
Barium Sulfate
Cadmium Oxide
Lead Carbonate
Silver Chloride
Chromium Oxide
Manganese Oxide
Nickel Oxide
The AMWAY Water Treatment System effectively removes from water other non-priority pollu-
tants including gasoline, kerosene, EOB, OBCP, aldicarb and 13 other organic compounds.
A I _ _ l_ I . J .A ^K. . • _ . .__ . _
Alachlor
Aldicarb (Temik)
Atrazine
Chlorpyrifos
1,2-Dibromoethane (EDB)
Guthion
Hydrocarbons*
Malathion
4,4'-Dibromo-1,1 '-biphenyl Methoxychlor
(PBB)
Parathion
TCDF (2,3,7,8-Tetrachloro-
dibenzo furan)
1,2,3-Trichloropropane
Xylene
"includes the components of gasoline.
Kerosene and diesel fuel.
1,2-Dibromo-3-chloropropane Strychnine
(DBCP)
-------
The cross-section of the AMWAY Water Treatment System gives you a closer look at the unit itself. The
five-stage filter is an extremely effective way to treat water. And the durable, high-impact housing
assures its quality for years to come. The AMWAY Water Treatment System Is intended for use with
cold, oactertotoslcaHy suitable (potable) drinking water only.
High-impact
Polymer Housing
Exterior Netting
Porous Polymer
Center Core
Untreated Water in
Treated Water Out
NEW CONCENTRIC RING
FILTER DESIGN AND CARBON
BLOCK MATRIX... Exclusively Amway
In addition to the advantages already men-
tioned, Amway's unique "second genera-
tion" filter provides extra benefits:
• Traps particles as small as 0.2 microns (1 /300th the dia-
meter of a human hair) with less sedimentary clogging..
Outer Non-Woven
Pre-Fitter
Inner Non-woven
Pre-Fiiter
Outer Pressed
(Coarse) Carton
Filter
Inner Pressed
(Fine) Caroon Filter
• More effective removal of hard-to-absorb
chemicals such as chloroform.
• More durable construction reduces acci-
dental damage.
• More even water distribution throughout filter.
• Up to 25% sreater initial flow rate.
• Higher flow rate throughout filter life.
Auxiliary Faucet kit it includes 4
noie drilled into your countertop.
: sink with tne faucet All the tuO-
:re it's out o' the way The filter
Any do-it-yourselfer can nook up tne auxiliary Faucet to tne filter hous-
ing and cold water (me Each auxiliary faucet kit includes a seif-pierc-
ms saddle valve mat makes addms your AMWAY water Treatment
System simple Full instructions snow how and wnere to add tuoms,
the valve, and the faucet connections.
you don t nave to send your entire unit oack to tne factory for a new
Mter Simply remove tne filter cartndse and insert a new one
Tne average family can expect each filter cartridge to last aoout one
year Of course,« depends upon now mucn water you actually use for
cooking and drinking it also depends upon tne quauty of your water
-------
THE AMWAY
WATER TREATMENT SYSTEM!
Yes, you < in do something about the ccf
water. Us
the
lizes a prised carbon block filter in this;
effective
the A/w
Improves Taste:
Coffee, tea, iuice, ice cubes, and soup have
iiuvor anc ;,u unusual odors.
Effectively Removes Pesticides and He
Filters chemicals like DDT, DBCR maiathion,
of other agricultural contaminants.
Effectively Removes Industrial Chemica
FiltersJO, PBB^Hexachioroethane, and ma
dustrial chemicals.
Effectively Removes Chlorine and THMs:
Takes chlorine and its THM by-products out
water-one of these (chloroform) is a suspe
cer-causing agent.
Effectively Removes Other Contaminan
Filters asbestos; precipitated heavy metals,
dirt, and scale.
Simple to Use:
Fits any standard water faucet or taps into .
water line. Use on-the-counter or under-the-
!inants?in your
:m! Arr\waVuti-
xtremely
tages of
11:
needed Just follow the steo-by-step
:amiiy can expea each filter cartridge to
year.
pon how much water you use and the
ur water.
Filter Cartridge:
:nd the entire unit back to the factory for
,,'Simply remove the filter cartridge and in-
e.
iny problems installing or using your Sys-
the toll-free, Hot Line listed in your
nual.
The Amway Customer Satis
Anytime you buy an Amway Water Treatment prodi
right to use it for 120 days from date of purchase to
is satisfactory and mat you want to keep it. If you
tory, return it to the Amway distributor from whom yi
distributor will offer you the choice of replacement
credit toward the purchase of another Amway distributed
refund of the full purchase price.
Guarantee.
>t apply to products which have been intentionally
iess: if, after you have decided to keep me prod-
it give the services you expected, please contact
•ay Corporation. We will extend every effort to
m accordance with the terms of me Satisfaction
Tht fastest, easiest way to put your new AMWAy water Treatment Sys-
tem into serwce i» by connecting it to an Existing Faucet Merely set me
Wter housing on me countertoo and connect tne oxiai-iine tuoing ana
divener to me kitcnen faucet' installation is mat simpie-and so i
necting ana moving tne unit snouia you want to use it eisewner*.
you can emoy tne convenience of installing your AMWAV Water Treat- For a more finisneo ioo«. ask'-.
ment System to an Ensting Faucet, Out store me nousing under me nandsome auniiary faucet r >,
sink your kn includes a countertoo sieeve to oass me tuomg from your O' reoiace your spray noz: •
aucet 'cr.i£ nousin; oe^ow tne sink Drill a one-men noie in tne coun- ing 15 connected oe'ow mr -.
:•. —:c 'o' !"< siteve or add it m piac< of ycur sorav nozzle The rest .li-..'?'".0- >ts.rejVi.:^:.tJ
-------
TABLE 4-1. TREATABILITY INDICATORS FOR CONTAMINANTS IN
MONTGOMERY TOWNSHIP HOUSING DEVELOPMENT RESIDENTIAL WELLS
Contaminant
Carbon Requirement
Henry's Law . . Mg Contaminant
Constant @ 10°CU' Adsorbed/gm Carbon
Trichloroethene
1 , 1 , 1 -Tr ichloroethane
1 , 1 -D ichloroethane
1 ,2-Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dichloroethene
Tetrachloroethene
Methylene Chloride
Ethylbenzene
Carbon Tetrachloride
Toluene
Chloroform
1 ,2-Dichlorobenzene
336
223
140
30.4
709
91.7<«>
564
140<3>
350<3>
720
154
97
37.1
0.39
2.5
1.8
3.6
4.9
3.0
50
1.3<5>
53
11
26
2.6
129
(1) M.C. Kavanaugh, R. Trussel, 1980.
(2) EPA, carbon adsorption isotherms for toxic organics, EPA-600/8-80-023,
April 1980, unless otherwise noted.
(3) Nyer, Groundwater Treatment Technology, (20°C).
(4) Metcalf & Eddy Data Base.
(5) Based on available data, this compound is not readily adsorbed onto
activated carbon (Becker, 1978; Metcalf & Eddy, 1987; Calgon, 1987).
•COM000050
-------
4/25 Page 1
tavey Wat*r Tre*t»enfr Systeai
Otstrlbutor/Custcoar Information Packet
This dbcuaent ts to help understand the principles behind the *m»ay water
Tra«ta«nt Systta and tt\a el alas documantttlon ttsttng that vas don*.
Traa-teant Syttan ts • point of us* tratar filter
pr*SMd carbon block t*chnology. Th* prassad carbon block Is Mda by
caprasstng vary fln*ly dlvldad activated carbon Into • porous block. Th*
water Is forced through tho.subalcron per* structure by water pressure.
» . "
The filter cartridge consists of three stages. The first ts • synthetic,
non^oven febrlc that acts as • pre- filter. Th* next ts the pressed carbon
block where organic centealnants and sub««!cron partlculates are removed. The
final stage ts e sintered polyethylene core that acts as a support Mdle for
the carbon block.
-------
4/29
Included In this packet" ar« the follcwlngj
1. Claims platform
2. Product specifications
3. Qualifications for us*
4. Abstracts of the ttst protocols and results
fcr ess.4: s!e!a»
3. Am»ay Water Treatment System Brochure
6. Anvay Water Treatment System C»ners Manual
-------
4/23 »aga 3
Ctatn Plctf
1, -Effectively removes Impurltlat from vatar,. Including ovar 100 EPA priority
pollutants such u organic contaminants, pesticides and trlhalom«than*s.
2* Effectively rtmovas pr»c!pltat«d Navy natal s, asbastot, t»d!m»nt, dirt
and
3. RatnOvaS STapdfa t**Mt«
4, Raoovts chlertn*.
9* CMS not ramova banaf Ida! alnarals and fluorlda.
6. Iftpreves vatar t»st« and odor.
7. iBprovas tasta of eoffa*. taa. Jut CM, lea oibas and sous.
;.
8. Fits standard vatar faucets.
9* Easily replaceable fitter cartridge.
10. VIII traat tno'ugh drinking and cooking vatar for ttie avaraga family for
one year*
-------
Page 4
Specifications
1. Housings Height -.13 1/2" nominal. Diameter - 6 31/32" nominal.
Constructed of durable, high Impact, Noryl plastic. /*.'^ ,»,-v»v. -
2. Filter block: Three-stage, pressed activated carbon block cartridge.
3. Materials! Water contact surfaces made with F.D.A.-epproved mattrials.
*
4. Flow rattt 0.72 to 0.98 gallons per minute at 60 pst of Mater pressure
with a new filter. (Flow rate will vary directly with water pressure and
tine filter has been In service.)
S. Filter life: The fitter Is designed to serve the average fan My fcr ore
year. Filter life will vary with the amount of use and the quality of the
Influent water.
,-.
6.* Installation: The filter can either be Installed en an existing faucet
via • dual line dlverter or plumbed In using a self piercing saddle valve
end an auxiliary faucet.
-------
4/29
Qualifications for Us*
Tht following qualifications for UM of tht Airway Water Traatnant Systam should
b« nottdi
*
1. Tho Mway Watar Traatnant Systam Is daslgnad for usa only with cold
potabla vatar«
r»
2. 80 NOT u«« vfth vans or tot watar.
S« Curing normal oparatlon, If tha tytta* has not baan usad for savaral
hours* run vatar through ttia unit for ona to two ailnutas prior to usa.
4. Tht fMtar eartrfdga should ba raplaead at laast onea • yaar. In araas of
vary poor vatar quality* uora fraquant raplaeanant «ay ba naadad* A drop
Ir. tha flow rata fs • good Indication that tha ftltar Is filling up with
contaminants and naads to ba raplaead. Hewavar, avan If vatar flow rata
It not affactad. aftar • yaar of oparatton, tha flltar should still ba
raplaead to assura adaquata filtration of til eontaalnants.
-------
Abstracts
Tha accompanying Abstracts ara oreaniiad as fotlewss
1. Claim.
2. introduction
3. Analytical Precadura
4. Rtsuits
-------
Abstract!
1. Effectively removes Impurities from vater. Including ever 100 EPA priority
pollutants such a* organic contaminants, pesticides, and trlhal.cmethan«s.
Introductloas * .
TMs claim vas documented In three sections! 1) Removal of Solubla, Organic
EPA Priority Pollutants} 2) Removal of Intelubla, Organic EPA Priority
Pollutants} and 3) Removal of Trthalomethanes. The flltars vtra tastad ov«r
thalr ratad Ufa, and to an additional 90S to Insura • margin of safaty.
Analytical Procadur* * Solubla Organlest
•
« »
Tha EPA organic priority pollutants vere saparatad Into tuo groups classified
as soluble and Insolubla. Tha dafInltlon of selubla vas basad on gattlng
•aasurabla quantities of the compounds Into solution vlthln the taat
constraints. Compounds not Mating this cr I tar I a vere run undar the Insolubla
protocol. Tha organic priority pollutants «ara addad to veter In a sarlas of
200 gallon tanks and raclrculatad vhen not being pumped through tha flltar.
Tha flltars vara tastad In duplicate. Tha Influant to, and affluent from, aach
of tha flltars vas sampled at 1, 5, 90, and 190 gallons and then at 100 gallon
Intervals to measure tha actual quantity of organic material gattlng to tha
flltar. This provided an analysis from aach tank of spjked water used
throughout tha test.
All samples vara taken according to EPA-protocols and vere analysed by EPA
method 624 and 001 (purgeables) or 629 (base/neutrals and acids). The memoes
use GC/MS detection and quantltatlon. One modification to the methods *as tha
use of tha Tracer /Ha11 detector In place of the GC/MS for the purgeablas.
•
Duplicate samples fre* tvo sample points vere analyzed by an outside test
agency for confirmation.
Result** •
•
listed belov art tha compounds tasted, the detection limit for each compound,
tha measured average Influent, tha affluent at rated Ufa and 90S beyond, and
the calculated total loading on .the filter. The measured average Influent la
an average of the Influent concentrations determined at aach sample point. The
calculated total loading Is the summation of tha Influent concentrations times
the gallons of water passed at that concentration.
-------
4/29
Me
'Detection Av
. . .limit In
£cs2fiu&d JLfiJU^ c p
CMorobenzene
1 ,2,4-Tr Ich I orebenzene
1,2-0!chloroethane
1,1,1-TrIchloroethtnel
1.1.2,2-
Tetrach 1 oroethane2
fili (2-Chloreethyl)
•ther
2-Ch 1 oronapfctha 1 ene
2,4,3-TrIehlorophenel
part-chloro-iMta-cresol
2-CMcropnenol
«
1 ,3-0 1 eh I or obenzene
1 ,4-OtehIorobenzene
1 ,1-Olchloroethy lene
1 ,2-l£ftaa-0 ! eh I ero-
ethylene
2.4-Dlchlcrophenol
1 ,2-0!chlorepropane»
1 ,3-Dlchloropr9«ylt«*3
2. 4-OImethyl phenol
2,4-01 nttrotol uene
2.6-OInltrotoluene
FI uoranthene
0.1
*
0.1
0.1
0.1
0.1
0.3
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1
0.1
0.1
0.1
O.t
O.t
O.t
1.0
O.t
asured
crag* Effluent
ifluent 1 rated
iiviBHelp ^a-^^^^.*^.^ta^fc^»^»^^
*
52
8
81
11
7
7
19
84
96
18
29
67 •
*
25
78
1
11
49
14
168
3
93
lit
34
^OL
«jOl»
-------
4/29
Page 9
Measured
4-CMeroph«ny!
phtnyi *th«r
4-8remoph«nyl
phtnyl «th«r
C2-Qtl(
tsepropyl) «th«r
(2*Chlerp»
•thexy)
Qemofoni
Tr I ch I orof I uorcnethan*
0 1 ch I orobr OBom«tfi«n«
Ch I eredl broBOMth«n«3
Htxach I crobuttd I «n«
Hexachlorocyclo-
* Isophoron*
Naphtha I «nt
Nltrob«nzai*
2-N1troph«nel
4<-N!trophanol
2.4-Otnltrophtnol
4,6-OInltro-fl-cr«tol
j-Nl trosod I pht ny I an I m
Nnttehlerophtnol
Pht no I
Butyl otnzyl phthalat*
Ol-fl-oetyl phthalatt
Detection
Halt
0.2
0.1
0.2
0.3
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.2
0.2
1.0
0.1
0.1
0.2
0.1
Average
Influent
56
33
105
91
6
3
31
168
20
43
104 "•
33
111
78
127
32
77
72
45
31
66
12
Effluent
6 rated
J!f«(p5fei
<*
OL
«•
OL
•
-------
Paga 10
*aasurad
OatactIon Avaraga Effluant Effluant Calcutatad
Unit Inf luant t ratad « SCI t*- Total
Ot*a-butyl phthalata
0lathyI phthalata
Dlmathyl phthaltti
Acanaphthylana
Anthracana
Flvorana
Phananthrana
Pyrana
Tatrach1eroathyIana2
TrIchIoroathyIan*
Dlaldrln
Cndrln
Haptaehior
*
apoxtea
Haxachloroatnana
1,1-Dtchloroathana
1.1.2-TrlchIoroathanal
CM or of on*
4,4»OCO •" . •'.' ..'
0.2
1.0
•
0.3
0.2
0.1
0.1
0.3
0.1
0.1
0.1
0.2
0.2
0.1
t.1
0.1
0.1
8.1
0.1
0.1
0.2
31
63
90
38
*
30
18
20
7
34
144
216
85 -:
4
149
44
13
'7
30
101
1.3
-------
Paga tl
1,1,1-trlchfcroatnana and t,t,2-trrcMoroathana» vafuas ara tha sun of
tfi« two compounds due to chromatcgr«pMc evtrltp.
1,1,2,2-tttr«ehlore«thin« and tttT8Chloro«thyf«n«i valets «r« th« sum
of th« t*e compounds du« to cArcmatograph'c ovarlap*
1,3*dfcMeropropyttn* and cli(orodfbrcmom«tf)an«t values ara ttia SUB of tha
too compounds dua to chrematographle ovarlap.
-------
Paga 12
Analytical Procadurai Insoluble Organic*
. .
..-•'••••-.:•*••••
This taat vas parfcrmad by tnjactlng tha Insolubla E?A organic priority
pollutants, dissolved in a vlnlmum of a mathenel/acatona solvant mlxtura, Into
a moving straw of vatar with high prassura. Mould chromatejrephy ptnss. The
vatar sourea was tha municipal supply. Tha flltars wara tas?ad In cujiica-a.
vith a saparata pump for aach f II tar. Th« Injactlon vas dora continuously at a
point just Ins I da tha fit tar housing. Tha affluant from aach of tr.a flitars
vas samplad at 1, 3, 50 and 190 gallons and than at 100 gallon Intervals.
AM samp I as vara takan according to CPA protocols and vara analyztC by EPA
fiathod 624 (purgaabias) or 629 (basa/nautrala and acids). Tha mathods usa
GC/MS datactlon and quantltatlon. Oupllcata same las vara analyzad by an
cuts I da tast lab for confirmation using tha sama EPA protocols.
Rasultsi
tlstad talov ara tti« coapcunds tastad* tha dataction limit for ascn cs.-:sunc.
tha calculattd avarega Infiuant. tha affluant at ratad Ufa and 9CS taycr.e. and
tha calculatad total loading on tha flltar. Tha calculatad avaraca Ir.f iua*;* is
tha avarasa concantrarion raachlng tna flltar during tha tast. Tha catculataa
total loading Is tha total quanltlty of aach compound injactad Into aac.n
flltar.
Acrolaln
Banzana
Carbon
Tatrechlorlda
(chloromathyl)
2-chloroathyt
vinyl atftar
1.2-diphanyl-
hyflrazlna
Ethylbanzana
Calcuiatad
Ca-tactlon Avarega* £ffiue?r
Limit inf luant i tared
1 ^•'•--
0.1
9.1
0.1
0.1
121
«
229
19
199
14
196
-------
4/23
Page 13
Calculated
Detection Average Effluent Effluent
Halt Influent 6 rated t 501 bt- Total
fpnh) t Ifufaefrl voneXaeM
Otchlcrod!-
fluoraaethane)
propylawlne
A-Nltrotodt-
Mttiylaalne
1 ,2*Benzanthricent
3.4-8enzopyren«
3,4-Benxo-
fluoranthene
11.12-Benzo-
fluortntheiw
Chrysent
1,12-8ento-
perylen*
1,2j3t6-0tbenw
anthracene
Tel u«n«
A! 6- In
CM or dene
(technical
•txturt and
Cndosutfan
sulfar*
0..1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
36
74
149
It
94
*
70
72
72
91
u5.
48
19
78
160
20
20
29
38
<*. «x
e%t d^4U
^.Hl mlJi
^e*e» ^^»e»
*COt_ ^>OtL
<^nt . *^QL
-------
Page 14
Calculated
OatactIon Avaraga Efflutnt fffluant palculatad
1-tntt fnfluant I rat ad f 3C* b«- Tctat
PCB-1016
(Aroclor 1016)
PCB-1221 "
(Aroclor 1221)
PCB-1232
(Aroclor 1232)
FCB-1248
(Procter 1248)
PC8-1234
(Aroclor 1254)
PCS-1260
(Aroclor 1260)
Toxaphana
3.3'-0?chlcro-
tanzldlttt
Chloroform
••'•!
0.1 *
*
0.1
-------
Page 13
Analytical Procedures* Trlhalcoethanes
.*•• . ••• 9 -. .• •-. ,
TrthalOBathena removal vat aeasured using Grind Rapids city water as the
teuret. A short tem tast (4 «eeks) and a long tern fast (6 aonths) «ara run
en rapl testa ftlttrs balng eye I ad aach hour, vtth an 8 hour stagnation parted
•aeh day and too days par vaak stagnation. Short tar* tast had vatar en for
2.3 •Imitaa par hour with ttve long tarn tast cycling at 0*3 ailnutas par hour.
Sanplas vara takan avary 100 gal tons according to EPA protocols and vara
analyzad by EPA tast a»tho4 601.
\
lUsultsi
Itstad balov ara 1*a avaraga Influant and affluent I avals at tha rated Ufa and
301 beyond as well as percant removal.
Trlhai'oaethanes CIMM's) (Averages) -
ftatad Utfe Rated Ufe>los SOS
lotigTam 04.7 spa 1.4 ppb 97.8 58.4 ppb 2.3 ppb 93.7
Short Tera 99.9 ppb _JL 000 99.3 £Su2 Ppb ^S. ppb 95 .3
62.1 .63 98.6 37 ,3* 1.4 97.6
The results she* effactive removal tfirotigh the 730 galtoa oefnt.
-------
4/23 Page 16
Abstract!
2. effectively removes precipitated heavy metals, asbestos, sediment, dirt end
seal*.
Introductions *
This clala was documented In three eiajor testst 1) Precipitated Htavy Metals
Removal* 2) Partteulate Removal, and 3) Asbestos Removal.
Analytical Procedural Precipitated Haavy Metals Removal ' >• .
In the Precipitated Kaavy Matt It study, varar splkad »«th vatar-Inselubla haavy
natal compounds »as pumpad from a 200 gallon tank through dupllcata fI (tars.
Sapplas vara eollaetad just prior to, and aftar tha flltar units avary 1CO
gallons to avaluata tha ramoval capabllltlas of tha units ovar tha ratad Ufa
of tha flltar and to an additional 502 of ratad Ufa to Insura a margin of
safaty.
Tha natal compounds *ara ground to pass a 230 urn seraan feafora balng dlsearsad
Into tha watar. Agitation vas abla to kaap a portion of tha part(cuteras In
susoanslon so that a naesuraabla Quantity raaehad t*a fit tars. Aaneval It
basad on physical removal of tha partieulatas. No claim Is nada for «atats
which ara In solution prlcr to tha flltar. .%
"" . - ** ; .'.''•
Influent and affluent sables «era passed thrsugh a C.iJ «n fss-rer, f Several
'sources, references 1-3, have defined Insoluble as any merer la I trier «l«l -net
pass througn a 0.^5 urn irembrane flltar). Hydrochloric acid was used to bring
the Insoluble materials eollaetad on the 0.45 urn filter Into solution ;r!er to
analysis by optimized atonic absorption. .
Results: •• • ; "'. '''..-• / ' :"' ' • " . • ; .'.-•• :' •
*".--. - »
• -*.
Removal based en partleu I ate filtration capability removes dependence en
particular eompeund selectivity to the activated carbon. Any metal present as
an Insoluble partleuleta greater than 0.45 um diameter, «tll be Affectively
removed.
-------
4/23 PaSt 17
REFERENCES
1* Vogl, C.C. and Angfno, f.f.. Chemical Effects of Safactad Traca-Matals fron
• Sanitary landfill laachatas on Ground Watar Quality* Kansas Vatar Rasoureas
Rasaarch Instltuta, Manhattan, (tec, 1981).
?. Scnock, M.R.. Rasponsa of taad So!ubFifty to Olssolvad Car5onatts In
Drinking Vttar« J. AXWA, (Oae, 1900), Vol. 72, Mo. 12, pp. 695-704.
3. Tanafca, S.» Oarsf, M., and Vlnenastar, J.W., El«m«ntal Analysis of Solubla
•nd Insefubl* Fractions of Rain and Surfaca Watars by Partfcfa-lnducad
X-fiay Eafssfen, Environ. Sclanca and Tachnology, (Mar, 1981), Vol. 15, No.
3, pp. 334-357.
*4. Vangan, L.f. and WUffams, J.M., Control by Alkalfna Nautrallzatlon of
Traea Elanants In Acidic Coal Claantng tfasta Laachataa, J. MPCP, (S«pt,
1982), Vol. 94, No. 9, pp. 1202-1310.
9. Ttotf, T.I., Vastrfck, J.O., Hsu. C.L.. and Karl ay, J.J., Ptald
Invfttfaatlon of Traca Matala In Ground Vatar from Fiy Ash Disposal, J.
KPCF, (Nov, 1978), Vol. 50, No. lit, pp. 2457-2469.
-------
4/29 *a8a 11
Analytical Procedural Part leu I at* Removal
Tha f lltar «ff Iclenpy was tested for email spherical particles.- A suspension'
of particles consisting of titanium dioxide (TI02) In a slza range tetvwn
0.1-10 u« In dlamatar In filtered, distil ltd water was passed thrcu-gn the
flltars. Samp I •« *ara eollactad of ttia Influant to, and affluant from, tht
flltar at 3 and 5 gallons throughput. Samp Its vara ftltarad and partleularts
collactad on 0.2 urn Nuelapora* substrata flltars. Tha flltars wara axt^intc cy
eomputar control lad scanning alactron microscopy (CCSEM). Particles vara
lecatad, slzad, analyzed by x-ray fluoraseanca (XRF), classified by type tased
en tha analysts, counted and removal calculated based on titanium containing
particles, this ansurad that removal vas basad on a reduction of tha
cha Hang Ing partlculates. Tasting MBS conducted at an outslda test agency.
5 6allenT««t
97.8 1.9x107 0.0 0.0 IOCS
9 Gallon Ta«t
98.6 2.2 x 107 0.3 1.2 x 10< 99 .7S 99. 5S
Tha -filter block Is at least 99.7*'«ffIclant In removing pertlcaleres dc
and below 0.2 micrometers In dlamatar.
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4/23 face 19
Analytical fVocadurai Asbattos Ramoval
In ordar to accurataly measure tha ramoval affIclanclas of tha Anvay filtration
systam for asbastos* • suspension of Chrysotlla asbastos (partlela fixe
distribution of 0.1-10 ua In diameter) In flttarad, distil lad water vas passad
through tha flltars. Replicate samples «ara col I actad at tha thraa and flva
gallon points for both Influant and affluant. Resulting samples *ara flltarad
onto 0.2 m Nuclapora* substrata flttars. Each Nuclepora" flltar vas axaninad
using computer control lad scanning aI actron microscopy (CCSDO. Tasting vas
eonduetad at an outs I da tast agency.
ftasttl+si
Fartlclas »ara stzad, analyiad by x-ray fluorascanca (XRF), classtflad by typa
basad on tha .XRF rasults, counted, and ramoval calculated on only asbastea
ftbar ramoval. Given below are tha asbastos removals snovn as both a «alght
percent and parflcta nunbar percent ramovalat
3 Gal Ion Tast
tiT.<
.38.8 1.9 x 1C* 0.3 3.0 «101 99.9S 99.9$
3 Gallon* Tast
yr.f
68.1 3.1 x 10* 0.0 0.0 100$ 100$
Tha flltar block Is at laast 99.SJ affacttva In ramovlng asbastos partlclas.
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4/29
fege 20
•3. Ramoves
t»*tit
cysts
introductions
.* ' •
ptar^fa la-feita Is <«n Intestinal paraslta that Is known to populate
•raas of tha United States but In the past few years, Is shewing uo acres* tr.e
country.
eausis severa Intastinal distress and Is vary difficult to tree*, In
•ost water systems, since It Is axtramely resistant to normal ch I or I nation
natar traatnent tacnnlques,
Analytical Procadurat
Uva
cysts vara Introducad Into rapltcata filters at the 0
SCO
rate Ufa and an adiltfsntl SOS of ratad tlfa vlth 50.000 cysts par fitter.
four tftar affluant sample vas eollactad from aech fitter after eecn soUe,
•flovad to sattla, and vas concentrated to 1 ml and axaminad mlcresccalcai ly
for cysts. Tasting «as dona at an outs Ida tast agency.
Results*
Given belc» ara tha cyst counts Introduced and racaverae for each reslicsre:
Cysts Cysts ' .
0
JOO
130
5C.5CO
50,800
50,800
50,800
50.800
50.800
50.600
50,800
50.800
0
0
0
0
0
0
fi
0
0
••CC5
^rts
ices
•icc«
ices
The Mvay Water Treatment System removes Biff*
cysts.
-------
»aga 21
Abstracti
4. ftaaovas Chlorlna.
•
latroductloai
CMortna raaoval vas avaluatad using rapllcata filters and vas tastad to SOS
graatar than ratad filtar lift.
Analytical Procedural
Fraa and total chlortna rameval vas naasurad using Grand Rapids city vatar as
tha aourea fn a long tana taat (7 •onths). Each filtar vas run dally with «n fl
hour stagnation parted aaeh day and a two day stagnation parted aacn vaak.
fnfluant and affluant sasplas «ara takan dally, aftar a six • I nut a flush
fartod.
Samp I as vara analyzad using Haeh CPO 14077 «nd 1*076 tast kits that aaasurad to
tha nairast 0.1 ppn. Raplleata sampias nart run for aaeh filtar.
ftasultss - •;; ' ' - .-. ',.•: .,;.-._•
List ad bale* ara tha avaraga Influant and affluant results for tha long ttra
tast for both fraa and total ehlorlna. k :
Long tar« .3 ppa D ppai IOCS
Tata! CMaptn^ ffv€PB*»| . . [nf ! mtir»
Long tana .5 ppa 0 pp» 100S
* t '
Chlorlna was not dataetabla, fn tha affluant. throughout tha tasting parlod.
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4/25 Page 22
Abstracts
3. Dots net rtmovt beneficial «I nereis and fluoride.
•
Introductions
This el•!« has been documente'd In two parts:
1) Removal of Minerals and 2) Removal of Fluoride.
Analytical Procedure: Removal of Minerals
Afflway Wall Number 11 «as tha sourca of water for • long tarn (I aonth) tast cf
tha water fit tar to • point 30* beyond tha ratad lift. This Is a vail en tha
Away complex. Each rapI teat* flltar vas eyelad on and off aaeh heur for 16
hours with an eight hour stagnation parted each day and a two day rr
parlod aaeh «aak.
Influant and affluant saaplas «ara takan bi-««akly aftar a stx minuet flush
parled. Hardness «as maasurad with 01 sodium EDTA using ammonium cnlcrtca and
ammonium hydroxlda as • but far and titrating to an ErIchroma Black 7 end polnr.
Results:
flusters given tele* ere the average of all Influent and effluent se-:tes
' tnf t'j
34.9 grains 34.9 grains OS
Calelua s ^gnestun Ratio 4:1
, " , i
The minerals calcium and magnesium are not removed by the carbon block fcesed en
the above results.
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4/23
Analytical flrwaduras Sanoval Of PI world*
Grind Rapids city watar was tha source of a long tar* (7 months) fluortda
Taaovai tast. Each raplfcata fltrar vas eyeI ad .on and off aaeh hour for 16
hours with «n I hour stagnation parted aaeh day and a 2 day stagnation parlod
•ach vaak.
Infltiant and affluant sanplas vara takan vaakly aftar a six mlnuta flush
parfod. Analysis vas don* "sy spaelf tc Ion alactroda.
Rasultsi '
• ' .*
Rasults balow ara ttia avaraga of all data points for tha tastt
0.99 pea O.$1 ppa 4.25
Vhlla thara Is a slight mnarlcal raduetton In fluerlda, tha lavais ara
statistically tha sama at tha 95S eonftdanca Itvai:
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Page 24
Abstracts
*" -,... *• •'..."• - . f ' '
4. 4ftprov«* water tistt and odor.
*•'"•*•*" - - * ' •
7. improve* taste *f coffee, tea. Juices, Ice cubes end soup.
•
Introductions
*
ThtM two claims will be covered In one abstract since thay ara fceth
by tha s«na panal tasts.
Proeadurat
Too panal tasts vara eonduetad on this product. Tha first vas • pantI tart
using Airway amployaa fanltlas and eonduetad by our Prodoet Evaluation
Laboratory. Tha sacond was eonduetad by an outsI da agancy, In anothar atata,
us109 all non-Awway parsennal. Tasts vara eoordtnatad and tna rasults
tabulated by tha Amway Product Evaluation Laboratory.
Tha quastlonnalras usad contained numerous questions as to Installation end
function of the units as veil as specific questions on vater quality
Improvements^ water taste and odor and Improved taste of coffee, tea. juices,
lea cubes and soup.
Tha panelists, In each study, were broken de«n by water source Into Tvo-tMrss
municipally treated vatar and one-third well water.
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4/25 P,9. 23
ReSUltBS
Given below art the averages for both panel tests end both elelnst
Improves Meter Te*ste end Oder
•
Taat Improved
65 Anvey Families 70S
70 Outside. Noft-*mey.
Families 63$
03 tawey tallies 82S S9S
TO Outside. Non-Amvey
Pea 1 1 lee 69$ 67$
(•proves taste of coffee* tea, juices. Ice cubes, end soup.
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4/25 Page 26
Abstracts
8. Fit* standard water fauctts
•
Introduction:
This el aim can ba documented by panal tast rasults from both the Airway fasiiiy
and outs I da, non- Amway pant! tast as wall as a survay of plumbing supply
housas.
Procedure)!
Two panal tasts were eonductad on the water treatment system. Tha first was a
panal tast using Araway amployaa f am 11 las and eonductad by our Product
Evaluation Laboratory. Tha second vas eonductad by an outs Ida agency, In
anothar stata, using all non-Amway parsonnal. Tha tast was coordinated and tf.e
rasults tabulatad by tha Amway Product Evaluation Labcratery.
An Initial Installation questionnaire vas a portion of both these par.*! tests.
Questions on ease of Instal I at ion -and specific problems with Install at! en were
Included for response.
Tha Water Treatment System, existing faucet option, cones with three ace;rcrs
for attaching the dual line dlverter to a faucet. A survey was dare ef
plumbing supply houses to cetera I ne what pert I en of faucets ccaic ae
accsr-'socatea ty the etve.— rer Itself and the three
•Results:
Results given belev ere a car.bi nation of both panel tests.
99.1$ of all respondents said tha adaptors fit their faucets.
1.81 of all respondents encountered problems with portable
(As a result of this Input, Amway offers the appropriate quic* •
adaptors for portable dishwashers as an extra Item).
8?. 3J Of all res:ondents found the water filter easy or very easy ts
Install.
*
The survey of plumbing supply houses shewed that 90S of tnt faucets teir.g
Installed had threaes that matched those on the dual- line dlverter vetve.
Another 5J can be acccmr.oeated by three adaptors supplied with the Instal Jati
kit. This gives a total of 95$ of faucets that can be accommodated directly.
The potential remaining 5$ have two options. First, the euxlllary faucet kit
can be used as this does not require attachment to an existing feuce?. S«eo*
If a consumer knows what type of feucet they have, a call to the *arer
Treatment Hotline will help Identify the proper adaptor required.
-------
27
Abstract^
9. Easily raplacaabla filter cartrldga.
Introductions
This claim was docunantad using laboratory parsonntl and • prototype flitar
housing*
•Voc»dur«s
Pan* It tts vara glvan • vitar flitar with a eartrtdga alraady In ptaea and a
flitar with flitar ehenga Instructions. Pana lists ««ra ehosan basad on an
•qua I *lx of mala and faaala but all vlth Halted knevf«6ga of tfta w«tar
Waatnant Systan. Thvy wtra askad to raad tfta Instructions and ettanga tft«
fltttr.
Rasultss
AM pana lists chan^ad ttia flitar In lass thin 13 mtnutas and found no major
pr ob lams In doing so.
-------
4/23 PaSt 28
Abstract:
10. Will trtat tnough drinking water and cocking water fcr an ev«.-e;e
for one ytar..
Introduction:
In ordtr to tvaluett tht Amway* Wat«r Treatment System, sent rated life
to bt tstabl Ishtd.
Rtsultss
References (1. 2, 3) Indicate that an average family uses a given caentltv cf
water per year for ccoktng and drinking. All testing was conductec to *'.
beycnd this point in orotr to insure tht recommended one ytar lift.
has tlso put In place • reminder system. Based uoon reglstra-'cr. rest
card Information, contact will be mace with rnt consumtr 10 mcntp.s after -rt
filter Installation to remind then that a filter change Is dut.
1. National Water "Sur^.ary 1SE3 - Hycrotcglc Evenrs ar.d Issues. U'.S.
Geologic Survey Water Suspty pastr 2250.
2. Water Ccsllty Assccletlcn - Po'r.t c^ use Trea-rerrr for Cc-.:1, '.:*:»
Orlnnir.g ««e-er Srsr.cercs. ^By S, *5£2.
3. StetlsTical Abstract of The United States 198i, U.S. Desertre— c*
Commerce, Bureau of tht Census.
-------
ATTACHMENT E
Written Comments
From Montgomery Township
-------
RALPH & MASON '. -.-
GORDON O. GRIFFIN -: .
KESTER R. PIERSON. •"
EDWIN W. SCriMICKCM
CRAIG M. DAVIS'"
RALPH S. MASON. Ill"
KRISTINA P. HAOINGER
KEVIN M. BRIODY'
ARTHUR G. LASHtt
DONALD 8. VEIX. JR.
ELLEN B. HERRERAt
CATHARINE B. CRESSON
CHARLES C. DALEY. JR.*
SHAWN M. BURKS
David E. Tomlinson
MASON, GRIFFIN &. PIERSON
COUNSELLORS AT LAW
Id POOR FARM ftOAO
P.O. BOX 391
PRINCETON, NEW JERSEY
HERVEY S MOORE. JR.
OF COUNSEL
TELEPHONE
(6O9) 921-6543
I6O9I 587-2224
FAX: 6O9-6837978
•ALSO ADMITTED IN PA.
"ALSO ADMITTED IN NY
"•ALSO ADMITTED IN CO
TALSO ADMITTED IN FL.
ttCERTIFIED CRIMINAL
TRIAL ATTORNEY
August 12, 1987
Jcffcey Folmer
Senior Area Coordinator
Bureau of Community Relations
Division of Hazardous Site Mitigation
New Jersey Department of
Environmental Protection
C.N. 413, 6th Floor
401 East State Street
Trenton, NJ 08625
Re: Written Comments of Montgomery Township in Response to
the Remedial Investigation/Feasioillty Study and the
Proposed Remedial Action Plan for the Montgomery
Township Housing Development Superfund Site
Dear Mr. Folmer:
In response to the RI/FS and the PRAP for the well water
contamination in and around the Sycamore Lane area of Montgomery
Township which was the subject of a public meeting on July 29,
1987, Montgomery Township submits the following comments:
1. Montgomery Township continues to maintain the position
that it has consistently espoused since the time the
contamination was initially discovered with respect to the issue
of reimbursement of costs for remedial measures to the citizens
of the affected area. To reiterate this position, Montgomery
Township contends that reimbursement for corrective measures must
-------
MASON, GRIFFIN & PIERSON
COUNSELLORS AT LAW
be equitably achieved, treating each resident in the area in a
similar fashion.
Needless to say, the residents in the area affected by the
ground water pollution are not responsible for the problem. In
response to the potential public health threat presented by the
ground water pollution, the Township contracted for and provided
public water to the areas affected at that time. Residents were
encouraged to tie into the public water lines, but some chose to
«
deal with the problem by the installation of individual well
water treatment systems. Still others in the affected area,
whose wells showed no sign of TCE contamination, chose to monitor
their drinking water to ascertain the extent of the problem
before deciding on an appropriate course of action.
Regardless of the corrective choices* made, all area
residents were assessed equally for the extension of the public
water lines into the area. Logic dictates that these residents
also share any reimbursement resulting from the correction of the
problem equally.
2. Montgomery Township has already noted for the record
its objection to the parameters originally used to determine
eligibility for reimbursement from the Spill Compensation Fund,
N.J.S.A. 58:10-23.11 et. seq. Officials of the Fund originally
required both timely hook-up to the water line and timely filing
of a claim for reimbursement to homeowners. Following the
institution of several law suits on the subject, and negotiations
-;'^:,v^*^^a£-^4^
.:-ci^-£2i:??*$_r*i'^:i-*:^ ;•&:*•- v.j....,..'>..-.-.-.-.-«...-«-..-!>.v~-,-i.«-T--^ T~ . •-
-------
MASON, GRIFFIN & PIERSON
COUNSELLORS AT LAW
with variaw parties, a later date for claim filing was allowed,
coupled with no date specified for hook-up to the public water
system. However, neither the officials from the Spill
Compensation Fund, nor any other representatives from the
Department of Environmental Protection provided notice to the
general public or the affected homeowners concerning the changes
in the requirements necessary for reimbursement from the Spill
Compensation Fund. As a result, some homeowners failed to take
the action necessary to insure reimbursement from the Fund even
though they had paid their fair share for the public water lines,
while other area homeowners similarly situated from a public
health standpoint were fully reimbursed. Montgomery Township
believes the Spill Compensation Fund was created with the intent
to fully compensate the victims of the same 'pollution incident
equally. For this reason, we feel that any costs associated with
the final resolution of the problem which will not be covered by
Superfund should be allowed by way of claim submission to the
Spill Compensation Fund.
3. With respect to Superfund payment of costs associated
with remedial action, DEP has stated that Superfund will not
cover past costs already incurred, but will cover any new costs
associated with the recommended corrective action. If DEP's
preferred alternative is chosen, Superfund would reimburse
homeowners for extensions of the public water line and connection
to the new or existing water mains. However, Superfund would not
-------
MASON, GRIFFIN & PIERSON
COUNSELLORS AT LAW
reimburse homeowners for the water assessments already assessed
to pay for the original public water lines in 1981.
The Township has two related comments concerning Superfund
reimbursement. First, conceptually the assessment for public
water can be viewed as a present cost, since payments for local
improvements are generally annualized in equal payments over a
ten-year period. Such is the case with the water lines installed
and assessed for by the Township in 1981. In that sense, the
assessment is on-going and, therefore, part of the current
remedial costs presently being incurred by the affected
homeowners. It is submitted that Superfund could reimburse for
assessment costs if they are viewed in this matter.
Second, the Superfund legislation was enacted by Congress on
December 11, 1980. However, the ordinance authorizing the water
line extensions into the Sycamore Lane area and assessment to the
area homeowners was passed by Montgomery Township on August 21,
1980, approximately four months prior to the enactment of
Superfund. Arguably, remedial measures which pre-date enactment
of Superfund, but which are also totally consistent with the
recommended remedial action- proposed by DEP and funded under
Superfund, should likewise be included in the Superfund
reimbursement. If the Township had acted less promptly and
effectively to solve the public health problem presented by the
ground water pollution, Superfund would unquestionably be
reimbursing all the homeowners for all the costs associated with
-------
MASON, GRIFFIN & Pi EPSON
COUNSELLORS AT LAW
4:
the cleanrtzg. The area homeowners should not now be penalized
for the diligence of the Township in attempting to solve the
problem at the site seven years ago.
4. As follow-up to some of the comments which were made at
the public meeting of July 29, 1987, Montgomery Township believes
that the methodology employed in examination of the four proposed
alternatives which led' to the designation of the preferred
alternative may have been too rigid in that possible combinations
of the various alternatives, if considered, could possibly
provide a satisfactory resolution to the health problem at the
site in a more cost-effective manner. The extension of the water
line along Montgomery Road from Route 206 to the border of Rocky
Hill to serve only a few residences should be reexamined to see
if it truly represents the best overall solution to the problem.
5. Finally, it appears obvious from the public meeting
that the area residents are concerned with the water quality from
the Elizabethtown Water Company distribution system. To date,
DEP's emphasis has focused on the poor quality of the
contaminated well water in the area. Any decision concerning a
preferred alternative must consider the quality of the water
which is being suggested as an alternative to the present source.
In addition, DEP should be cognizant of, and sensitive to, public
sentiment concerning this issue by addressing the area residents'
misgivings about the quality of the Elizabethtown Public Water
during the decision-making process.
-------
MASON, GRIFFIN & PIERSON
COUNSELLORS AT LAW
On behalf of Montgomery Township, I would like to thank the
Department for the opportunity to present these written comments
concerning this most important issue. It is our hope that these
comments will help the Department develop a fair and reasonable
course of action to eliminate the problem at the site. The
Township anticipates that such a course of action can and will be
developed. To that end, Montgomery Township is eager to assist
the Department whenever possible in its task.
MASON, GRIFFIN & PIERSON
By
David E. Tomlinson
cc: Peter N. Rayner, Township Administrator
Charles G. Searfoss, Health Officer
^•£>^£^
-------
ATTACHMENT F
Excerpt from CERCLA
Regarding State Credit
-------
FEDERAL LAWS
jposure to > hazardous substance, pollutant, or contain-
and that a release may have occurred or be
occurring, he may undertake such investigations, moni-
toring, surveys, testing, and other information gathering
as he may deem necessary or appropriate to identify the
existence and extent qfflM release or threat thereof, the
source and nature of flffe hazardous substances, pollu-
tants or contaminants involved, and the extent of danger
to the public health or welfare or to the environment. In
additionrthe President may undertake such planning.
legal, fiscal, economic, engineering, architectural, and
other studies or investigations as he may deem necessary
or appropriate to plan and direct response actions, to
recover tne costs thereof, and to enforce the provisions of
this Act
[104(b)( I) designated by PL 99-499}
(2) Coordination of investigations. — The President
shall promptly notify the appropriate Federal and State
natural resource trustees of potential damages to natural
resources resulting from releases under investigation
pursuant to this section and shall seek to coordinate the
assessments, investigations, and planning under this sec-
tion with such Federal and State trustees.
(104(b)(2) added by PL 99-499]
(c«) Unlaae (A) the Prendent fade that 0) continued
action at* immediately required to prevent, limit, or mitigato an
emergency.
-------
71:07
Sute expenses which the President determines to be
reasonable, documented, direct out-of-pocket expendi-
tures of non-Federal funds.
(B) Expenses before listing or agreement. — The
credit under this paragraph shall include expenses for
remedial action atjjMffity incurred before the listing of
the facility on liTOfetinnil Priorities List or before a
contract or coop^Mfe agreement is entered into under
subsection (d) far iiirfcality if—
*- • ft) after such expenses are incurred the facility is
listed on such list and a contract or cooperative agree-
menus entered into for the facility, and
(ii) the President determines that such expenses would
have' been credited to the State under subparagraph (A)
had the expenditures been made after listing of the
facility on such list and after the date on which such
contract or cooperative agreement is entered into.
/" (C) Response actions between 1978 and 1980. — The
credit under this paragraph shall include funds expended
or obligated by the Sute or a political subdivision
thereof after January 1, 1978, and before December 11,
1980, for cost-eligible response actions and claims for
'damages-cornpensable under section 111. '.
*- (D) State expenses after December 11,1980, in excess
of 10 percent of costs. — The credit under this para*
graph shall include 90 percent of State expenses-in-
curred at a facility owned, but not operated, by*'such
State or by a political subdivision thereof. Such credit
applies only to expenses incurred pursuant to a contract
or cooperative agreement under subsection (d) and only
to expenses incurred after December 11, 1980, but
before the date of the enactment of this paragraph.
(E) Item-by-item approval. — In the case of expendi-
tures made after the date of the enactment of this
paragraph, the President may require prior approval of
each item of expenditure as a condition of granting a
credit under this paragraph.
***"" (F) Use of credits. — Credits granted under this
paragraph for funds expended with respect to a facility
may be used by the State to reduce all or pun of the
share of costs otherwise required to be paid by the State
under paragraph (3) in connection with remedial actions
at such facility. If the amount of funds for which credit
is allowed under this paragraph exceeds such share of
costs for such facility, the State may use the amount of
such excess to reduce all or pan of the share of such
costs at other facilities in that Sute. A credit shall not
entitle the Sute to any direct payment.
{104(c)(5) — (9) added by PL 99-499]
(6) Operation and Maintenance. — For the purposes
of paragraph (3) of this subsection, in the case of ground
or surface water conumination, completed remedial
tion includes the completion of treatment or other me
sures, whether uken onsite or offsite, necessary to r
store ground and surface water quality to a level th
assures protection of human health and the environment
With respect to such measures, the operation of sue
measures for a period of up to 10 years after th
construction or installation and commencement of open
ation shall be considered remedial action. Activhie
required to maintain the effectiveness of such measure
following such period or the completion of remedial
action, whichever is earlier, shall be considered operationi
or maintenance.
(7) Limiution on Source of Funds for O&M. —
During any period after the availability of funds received
by the Hazardous Substance Superfund established un-
der subchapter A of chapter 98 of the Internal Revenue
Code of 1954 from ux revenues or appropriations from
general revenues, the Federal share of the payment of
the cost of operation or maintenance pursuant to para-
graph (3)(C)(i) or paragraph (6) of this subsection
(relating to operation and maintenance) shall be from
funds received by the Hazardous Subsunce Superfund
from amounts recovered on behalf of such fund under
this Act.
(8) Recontracting. — The President is authorized to
undertake or continue whatever interim remedial actions
the President determines to be appropriate to reduce
risks to public health or the environment where the
performance of a complete remedial action requires
recontracting because of the discovery of sources, types,
or quantities of hazardous subsumes not known at the
'time of entry into the original contract. The toul cost of
interim actions undertaken at a facility pursuant to this
paragraph shall not exceed $2,000,000.
M(9) Siting. — Effective 3 years after the enactment
of the Superfund Amendments and Rcauthoriz^tion Act
of 1986, the President shall not provide any remedial
actions pursuant to this section unless the Sute in which
the release occurs first enters into a contract or coopera-
tive agreement with the President providing assurances
deemed adequate by the President that the Sute will
assure the availability of hazardous waste treatment or
disposal facilities which—
(A) have adequate capacity for the destruction, treat-
ment, or secure disposition of all hazardous wastes that
are reasonably expected to be generated within the Sute
during the 20-year period following the date of such
contract or cooperative agreement and to be disposed of,
treated, or destroyed,
(B) are within the Sute or outside the Sute in
accordance with an intersute agreement or regional
agreement or authority,
11
»y THE BUREAU OP NATIONAL AFFAIRS. INC.. WuNngion. O.C. 30037
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