Saturday, February 03, 2018

Water this, water that.

“Water this, water that,” City of Trenton spokesman Michael Walker said in response to an email query about Trenton Water Works from the Post.
So reports Rob Anthes in a very good article in the February edition of the Hamilton Post. Anthes highlights the recent issues at Trenton's water utility that serves some quarter of a million people in Mercer County.

This past Thursday night Trenton's Public Works Director, Merkle Cherry, and key members of the TWW staff presented an update for the city council. The hope was that the city's governing body and the public alike would come out of that meeting with a fuller understanding of what the situation actually is at the water utility.

Unfortunately, that presentation came up woefully short. Kevin Moriarty blogged about the meeting on Friday. Basically, it consisted of a brief power point presentation, a Q & A between members of the council and the water works team, and then public comment.

It lasted 3.5 hours (council then had to go on to their regular business afterwards) and what was learned was that Mr. Cherry has a less than firm grasp on the operations of TWW. We also learned that some of the long time staff who work day to day in the utility don't have a much better grasp of how things work there than Cherry does. That was a huge disappointment. 

The lack of investment in the utility and the lack of staff definitely contributes to the marked increase in citations of non-compliance issued by DEP. That's certain. The lack of communication... effective, timely communication... between the city/TWW and its customers is the one thing that came up time and time again during the discourse.

One of the big complaints has been the length of time between when an "event" occurs and the public is notified. City representatives have continually sworn that they were delayed in issuing notices because they were waiting for DEP to approve the language in the advisories before sending them out.

Strangely, in the same breath, there is always mention of  "templates" that exist for the notices.

It's hard to fathom how, if there is an existing template for, say, a boil water advisory, there has to be approval from a state agency before the notice can be sent out. That sort of defeats the whole purpose of having a template, doesn't it?

Curious about this, we spent some time wading around in the DEP website. There is a lot of information available to the public there. Granted, you might have to be a bit of a nerd or wonk to delve into this stuff, but it is there for the curious. 

The following is based upon a couple of hours of browsing, following links, reading and, yes, THINKING about how one handles events that adversely effect the quality of water service. We are not licensed plant operators; we have not taken any classes in water supply operations or management. We're just reasonably intelligent parties interested in what the process is; how it is supposed to work; and trying to figure why it seems to continually break down when it comes to TWW. 

If we miss something or make faulty statements and anyone can point us to accurate information countering our incorrect assumptions, we welcome the correction. We're trying to educate ourselves and our readers as to what is the right way to handle these things. 

Water quality regulation and enforcement in New Jersey falls under the Department of Environmental Protection, division of Water Supply and Geoscience.  From the division's page, there are various links under "Drinking Water Systems; Emergencies & Security. There's a lot of information available to anyone who wants to poke around awhile. 

As stated right on the page, a water utility has to report an emergency to DEP within six (6) hours. There is a 24 hour hotline just for such purposes. There are also required follow ups with the engineering office during normal work hours and a form that must be completed an emailed to DEP.

The incident form includes a section about notifications on the second page.   

The first question asked is "Has the appropriate water use advisory been issued?"  Now, if this form is what is used to record and track an incident with DEP and DEP must be notified within six hours of the event, doesn't it seem likely that there is an expectation that notifications to the public, et al were made sooner rather than later?

There are links on the page to templates for various advisories pertaining to water main breaks. The templates are right there in a very user friendly form (Microsoft Word). The utility just has to fill in the event specific information and distribute.

But what about non-water main break related events?

Further down on the page are links to "Water Use Advisory Information".
Within that grouping is a link to a 166 page document that is a clearly written and organized EPA Drinking Water Advisory Comprehensive Toolbox. It is filled with very good, common sense ideas about how to prepare for, execute and follow up on the issuing of an event advisory. The document includes fill-in-the-blank templates, in English and Spanish. The document is so comprehensive that after reading it we feel confident that we could effectively execute the issuing of an advisory. Certainly, if anyone from TWW and/or the City of Trenton had there would not be the continual issues with fumbled notifications.

There are other resources on that section of the page. The three main types of advisories are described:
  • Advisories:
    • Boil Water Advisory: Advises customers to boil the water before drinking, cooking, and other potable water uses due to the potential for the water supply to be contaminated with disease-causing microorganisms.
    • Do Not Drink Advisory: Advises customers not to use the water supply for potable purposes and only advocates its use for sanitary and fire-fighting needs.
    • Do Not Use Advisory: Advises customers not to use the water supply for any purpose, including sanitary and fire-fighting needs.
There are also more links to templates and handbooks:
Obviously, there is a wealth of material available to help a water supply system effectively communicate about any event that adversely affects the potability of the water.

Earlier on we established that NJ DEP must be notified within six (6) hours of an event. Diving deeper into the subject we discovered EPA guidelines (linked to from the DEP site, so we assume these are the operative standards in New Jersey) for three levels of notifications.

You'll note that in Tier 1 (Immediate Notice) events water suppliers have 24 hours to notify {our emphasis} people who may drink the water.  TWENTY FOUR HOURS!

That seems like a long time. We assume because the guidelines are applicable to systems of all sizes in densely populated areas as well as sparsely populated ones, the federal standards are somewhat generous.  We also assume that common sense dictates system operators would get the notice out as soon as possible, well within the 24 hour deadline.

We feel it is important to note here that at no time has TWW made the argument that their delayed notifications have fallen within the allowable 24 hour time period. Rather, they keep falling back on the excuse of having to wait for DEP approval of the text and/or translation into Spanish...EVEN THOUGH TEMPLATES FOR BOTH EXIST AND ARE AVAILABLE!  In addition, for all of our fishing in the rules and regulations we have yet to land any evidence that DEP requires approval of the verbiage of advisories prior to them being released.

We have also found, repeated, reference to the 10 items that must be included in an advisory:
Notices must contain:
  • A description of the violation that occurred, including the contaminant(s) of concern, and  the contaminant level(s);
  • When the violation or situation occurred;
  • The potential health effects (including standard required language);
  • The population at risk, including subpopulations vulnerable if exposed to the contaminant in their drinking water;
  • Whether alternate water supplies need to be used;
  • What the water system is doing to correct the problem;
  • Actions consumers can take;
  • When the system expects a resolution to the problem;
  • How to contact the water system for more information; and
  • Language encouraging broader distribution of the notice.
Anyone with basic English composition skills and the required information at hand should be able to craft an acceptable advisory notice in less than hour without a template. With a template, the notice should be ready for distribution within minutes. Not hours. No external approvals required!

From what we have found, it is readily apparent that the failures of TWW to notify customers in a timely manner originate internally. Whether it is due to the acknowledged shortage of qualified staff, management indifference or both doesn't really matter.

What does matter is that they are failing to execute critical responsibilities. Instead of pointing fingers to outside agencies, they need to look at their own processes and procedures and fix them. Immediately.

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