Low Flows Increase Concentration Of Pollutants In Rivers Used For Drinking Water And Pumped To Reservoirs
Low Flows Violate The Technical Conditions In DEP Water Pollution Permits, Water Quality Standards, And Risk Assessments
The NJ Drinking Water Quality Institute (DWQI) just announced that it will meet on Tuesday, December 10, at 10:00 AM. The meeting will be a hybrid public meeting (in person and virtual) at the Public Hearing Room at DEP Headquarters at 401 E State St, Trenton, NJ.
1984 amendments to the New Jersey Safe Drinking Water Act (Act) at N.J.S.A. 58:12A- 20, established New Jersey’s Drinking Water Quality Institute (DWQI) as well as the drinking water standard setting process. The DWQI is responsible for developing Maximum Contaminant Levels (MCL) or standards for hazardous contaminants in drinking water and for recommending those standards as well as recommendations for the implementation of the drinking water quality program to the Commissioner of the N.J. Department of Environmental Protection (NJDEP).
The DWQI has been meeting sporadically over recent years – they used to meet on a regular quarterly basis – and they did not post an agenda, so its hard to tell what’s going on and why the meeting was called right now.
(Wow, the Health Effects subcommittee hasn’t met since 2009, over 15 years! Their last meeting was the controversial episode that led Christie DEP Commissioner Martin to suspend DWQI meetings for almost 5 years, see:
Why Christie DEP Commissioner Martin Shut Down The Drinking Water Quality Institute
I doubt but will assume that the December 10 meeting could be related to the drought. Regardless, the drought has significant impacts on NJ’s water quality and therefore on the risks to drinking water.
So I will put the drought water quality and public health issues on the DWQI agenda via submission of these comments. I am submitting them 2 weeks prior to the meeting to give DEP time to prepare public responses during the meeting and avoid the severe time restrictions (3 minutes) DEP puts on public comments. DEP can’t accuse me of ambushing them and use that to avoid responses in public.
I recently wrote about how the drought reduces stream and river flows and therefore increases the concentrations of pollutants in rivers used for drinking water. Drought driven extreme low flows violate core scientific and technical assumptions DEP relies on in setting waste pollution discharge permits, surface water quality standards, and human health risk assessments. But I failed to also mention that millions of gallons of polluted river water is pumped to pristine NJ reservoirs, often triggering algae blooms that require additional disinfection treatment, which increases risks posed by toxic disinfection byproducts, see:
Many of these pollutants are unregulated chemicals. DEP identified over 600 unregulated chemicals in NJ’s drinking water. There is little or no systematic monitoring of these chemicals and no health effects data, see:
Read the stunning findings by DEP in DEP’s Denial Of A Petition For Rulemaking (hit link to or see: 55 NJR 2430(a)) (verbatim quotes):
- In 2003, the Department partnered with the USGS to evaluate the occurrence of contaminants of emerging concern in New Jersey’s streams and drinking water supplies. The study utilized analytical methods developed by USGS for the determination of more than 95 contaminants typically found in domestic, industrial, and agricultural wastewaters, including pharmaceuticals, antibiotics, hormones, personal care products, and various industrial and commercial products. This study found trace level organic contaminants that represent a broad suite of uses and origins can enter and persist in ambient waters and subsequently occur in finished drinking water supplies.
- [In groundwater] Seventy-two percent of the pesticides and volatile organic compounds sampled are not currently regulated.
- in March 2003, the Department published results regarding the occurrence of approximately 600 “tentatively identified compounds,” or TIC, in [drinking] water systems
- toxicity information was available for only 22 percent of the TICs found in the New Jersey water samples, and that the information that was available was mostly regarded acute health effects. Information on chronic health effects is necessary to establish drinking water standard
- the Department developed a list of potential options to address unregulated contaminants and sought public comment on them in a February 2004 Interested Party Review (see 36 N.J.R. 889(b)). Based on the comments received, the Department determined that implementing the water treatment technology approach would likely have the best outcome of the options presented. Of the few treatment technologies available to remove the various unregulated contaminants from drinking water, granular activated carbon (GAC) seemed to be the most promising.
Over 20 YEARS ago, DEP scientists recommended that DEP mandate GAC treatment at drinking water systems to remove unregulated chemicals, instead of the flawed current individual chemical specific MCL approach.
These public health risks alone – which are exacerbated by drought and low flow conditions – are a sufficient basis for Governor Murphy to declare a drought emergency.
Worse, according to DEP’s own scientific Reports, DEP has known for over a decade that there is currently available cost effective drinking water treatment technology to remove virtually all of these chemicals to below detection limits, see:
DEP Completed The Study Required By Senator Smith’s “Forever Chemicals” Bill A Decade Ago
The Murphy DEP has not only refused to address these public health risks and regulate, they have tried to change the subject, see:
We will share the comment letter to the DEP and DWQI in our next post.