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At Least Six Times Since 2010, New Brunswick Failed to Declare a Required Water Boil Advisory

City and State Government Notify Public of Serious Water Quality Violations
NB Water Utility
New Brunswick's Water Utility is headquartered in the basement of City Hall. Charlie Kratovil

NEW BRUNSWICK, NJ—Beginning today, the city is actively publicizing the "serious violations" at the water utility that "had the potential to expose the public to disease-causing microorganisms."

According to information in the official announcement, the city ignored state and federal laws and repeatedly failed to notify the public of potentially dangerous water.  For at least three years, water quality failed to meet federal and state standards and the public was not notified.

"People with severely compromised immune systems, infants, and some elderly may have been at increased risk. These people should seek advice about drinking water from their health care providers," read the carefully-worded announcement sent today to every home in New Brunswick.

"New Brunswick failed to provide the required information or submitted false information in reports to the NJDEP and failed to issue mandatory public health and safety notices when these violations occurred... During the period of January 2010 to May 2013, the New Brunswick Water Department violated numerous treatment and monitoring requirements of the Federal and State Safe Drinking Water Act Regulations," says the glossy mailer.

The announcement said that New Brunswick was found to have violated the standards only after a federal investigation exposed the "unacceptably high" cloudiness of the water, but credited Water Director Frank Marascia with reporting the most recent incidents to the state, as was his responsibility.  As we reported, Marascia was hired in October 2012.

"Currently this is not an emergency.  There were times when turbidity [cloudiness] in your drinking water was unacceptably high," begins one paragraph.

It continues to say that turbidity "can interfere with disinfection and provide a medium for microbial growth... bacteria, viruses, and parasites that can cause symptoms such as nausea, cramps, diarrhea, and associated headaches."

It also said that "with frequency" the utility did not adequately treat the water, which it said "can further allow these organisms to survive in the delivered water."

"As a result of investigations performed by the NJDEP and the US Environmental Protection Agency (USEPA), it was determined that between January 2010 and June 2013 New Brunswick repeatedly violated national drinking water quality standards."

The full announcement details dozens of violations in both water quality and monitoring.  The water quality violations were in four categories: the level of cloudiness (turbidity), the number of microscopic bacteria (total coliforms), the amount of time spent disinfecting the water, and the amount of residual disinfectant in the city's distribution system.

WHEN WAS THERE A PROBLEM WITH THE WATER?
"Water samples taken on March 14, 2010; March 1, 2011; December 15, 2011; December 16, 2011; October 2, 2012, and February 9, 2013 showed elevated values for turbidity above the allowable level," reads the notice.

"There was an increased chance that the water might have contained disease-causing organisms," it continues.

After each of these incidents, the city was supposed to notify residents within 24 hours and tell them to boil their water before use.

"We also did not notify our customers or the NJDEP as was required during each of these incidents. This notification was to have been issued to all customers within 24 hours of the incident and would have instructed customers to boil their water before use."

Additionally, the document states that for two months, December 2011 and January 2012, the turbidity readings did not meet standards, and a required public notification within 30 days was not made.

"The persistence of turbidity levels over the standard is of concern," says the announcement.

For more than two years, from January 2010 to June 2012, turbidity readings at the individual filters in the treatment plant were taken hourly instead of continuously as required.  Then, for the next ten months, no readings were taken at all.

Perhaps the most concering news is that the city did not adequately test the water for a certain type of bacteria.  It is required that the city collect and analyze 50 different samples for coliform bacteria, taken from various sites that are geographically representative of the city.

Eight times the city failed to get the proper number of samples.

"During October 2010, May 2011, June 2011, December 2011, March 2012, July 2012, August 2012 and November 2012 we analyzed less than 50 coliform samples during each month," reads the announcement

"Total coliform bacteria are generally not harmful themselves," the announcement says.  "Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other, potentially harmful, bacteria may be present."

Then, the city admits to the cover-up.

"We falsely reported that some collected samples were analyzed; when there was no record that the tests were done."

"We also failed to collect total coliform samples at sites which are representative of water throughout the distribution system during the months in question and failed to inform the NJDEP and our customers."

Additionally, for "significant periods of time," the city's water did not spend enough time exposed to a disinfectant, such as chlorine, that kills microorganisms.

"For... December 3-31, 2010; February 1-19, 2011; November 26-30, 2012; and March 1-13, 2013, we did not provide the minimum required amount of disinfection," reads the announcement.

Additionally, for a total of twenty-four months, the city failed to meet a standard for the amount of residual disinfectant in its pipes, which helps combat the spread of bacterial infections through the water distribution system.

"During the months of July 2010 to December 2010, March 2011 to January 2012, and April 2012 to November 2012, disinfectant residual was undetectable in more than 5% of the samples. The standard is that disinfectant residual may be undetectable in no more than 5% of samples each month for two months in a row."

Additionally, the methodology for monitoring of the residual chlorine was also in violation and that fact was also kept from the public.

"During the period of January 2010 through May 2013, we were required to monitor the chlorine residual level continuously but only did it hourly, and did not report this to NJDEP and our customers as required."

WHAT IS BEING DONE?
Under the "What is Being Done?" section, the announcement says: "The City of New Brunswick authorized a Comprehensive Performance Evaluation of the water treatment plant, including a review of technology, personnel, policies, procedures and budgetary matters."

"Some of the recommendations of the evaluation have already been implemented, and the City will continue to make improvements over the next six months with the assistance of an independent consultant."

Perhaps hinting at the root cause of the problem, the document continues: "The City has also restructured its water treatment staff organization to improve the supervision of treatment operations. The City’s licensed operator has been suspended."

As we reported this week, it appears city officials had the option to fire him, but instead the operator, a donor to the mayor's re-election campaign, was suspended without pay pending an administrative hearing.

Below is the city's announcement in its entirety:

IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER
City of New Brunswick Water Department did not meet certain treatment and monitoring requirements 

During the period of January 2010 to May 2013, the New Brunswick Water Department violated numerous treatment and monitoring requirements of the Federal and State Safe Drinking Water Act Regulations. While the New Jersey Department of Environmental Protection (NJDEP) and the City of New Brunswick have no direct evidence that public health was impacted, the violations are considered to be serious because they had the potential to expose the public to disease-causing microorganisms.

As a result of investigations performed by the NJDEP and the US Environmental Protection Agency (USEPA), it was determined that between January 2010 and June 2013 New Brunswick repeatedly violated national drinking water quality standards for turbidity, total coliforms, and residual disinfectant levels. New Brunswick failed to provide the required information or submitted false information in reports to the NJDEP and failed to issue mandatory public health and safety notices when these violations occurred. Although this is currently not a public health emergency, we are obligated under the law to inform you of these violations. We would also like to provide information on what we have done and are doing to correct this situation. In addition, we want to assure you that the New Brunswick Water Department is currently in compliance with all Federal and State Safe Drinking Water Act requirements. 

WHAT HAPPENED?
We are required to monitor your water for turbidity (cloudiness). This is an indicator of whether we are effectively filtering the water supply. Water samples taken on March 14, 2010; March 1, 2011; December 15, 2011; December 16, 2011; October 2, 2012, and February 9, 2013 showed elevated values for turbidity above the allowable level of 1 turbidity unit. Because of these high levels of turbidity, there was an increased chance that the water might have contained disease-causing organisms.
We also did not notify our customers or the NJDEP as was required during each of these incidents. This notification was to have been issued to all customers within 24 hours of the incident and would have instructed customers to boil their water before use. In addition, no more than 5% of turbidity samples may exceed 0.3 turbidity units per month. In December 2011, 9.1% of turbidity measurements exceeded 0.3 turbidity units, and in January 2012, 6% of turbidity measurements were over 0.3 turbidity units. The persistence of turbidity levels over the standard is of concern. Because of this high level of turbidity, there was an increased chance that the water may have contained disease-causing organisms during this time. Normal turbidity units for our plant are now in the range of 0.02 to 0.3 turbidity units. We did not notify our customers or the NJDEP as was required during each of these two months. This notification was required within 30 days of the end of the month. We are also required to continuously monitor for turbidity for the combined flow of all individual filters but instead performed hourly monitoring. We did not report this to NJDEP or our customers as required.

New Brunswick Water Department was also required to continuously monitor turbidity levels at each of the individual filters in the plant. We failed to do this for some of the filters, and either conducted hourly readings (from January 2010 to June 2012) or no readings of individual filters (from July 2012 to May 2013). In these instances, we provided false information to the NJDEP that readings were done as required and that all turbidity levels were below levels of concern. 

In order to ensure proper disinfection, water in the treatment plant must be in contact with enough chlorine or a similar disinfectant for a minimum amount of time. For significant periods of time, including the periods of December 3-31, 2010; February 1-19, 2011; November 26-30, 2012; and March 1-13, 2013, we did not provide the minimum required amount of disinfection. Although chlorine quickly kills most bacteria, it is less effective against organisms such as viruses and parasites. For this reason, water needs to mix with chlorine for a longer time period to kill such organisms. The amount of time necessary, or the “contact time,” depends on the amount of disinfectant in the water and the temperature of the water. We also did not notify our customers or the NJDEP as was required during each of these time periods. This notification was required within 30 days of the end of the month.

We must routinely monitor for disinfectant residual in the distribution system. These measurements tell us whether we are effectively disinfecting the water supply. Disinfectant residual is the amount of chlorine or related disinfectant present in the pipes of the distribution system. If the amount of disinfectant residual is too low, organisms could grow in the pipes. During the months of July 2010 to December 2010, March 2011 to January 2012, and April 2012 to November 2012, disinfectant residual was undetectable in more than 5% of the samples. The standard is that disinfectant residual may be undetectable in no more than 5% of samples each month for two months in a row. We also failed to report this information as required to our customers and to the NJDEP. 

We are required to maintain a chlorine residual of at least 0.2 milligrams per liter entering the distribution system. Water samples taken and recorded manually during March 2010, September 2010, November 2010, December 2010 and April 2011 indicated that the chlorine residual entering the distribution system fell below 0.2 mg/L for at least four hours on several occasions. We failed to report this to our customers and NJDEP. During this same time period, we were required to report to NJDEP the lowest measurement of chlorine entering the distribution system, which we did not do. During the period of January 2010 through May 2013, we were required to monitor the chlorine residual level continuously but only did it hourly, and did not report this to NJDEP and our customers as required. We are required to take at least 50 samples at our approved sampling plan locations each month to monitor for total coliforms and chlorine residual. Total coliform bacteria are generally not harmful themselves. Coliforms are bacteria that are naturally present in the environment and are used as an indicator that other, potentially harmful, bacteria may be present. During October 2010, May 2011, June 2011, December 2011, March 2012, July 2012, August 2012 and November 2012 we analyzed less than 50 coliform samples during each month. We falsely reported that some collected samples were analyzed; when there was no record that the tests were done. We also failed to collect total coliform samples at sites which are representative of water throughout the distribution system during the months in question and failed to inform the NJDEP and our customers.

WHAT SHOULD I DO?
At this time, there is nothing you need to do. You do not need to boil your water or take other actions and do not need to use an alternate (e.g., bottled) water supply. The violations listed above have been addressed and are not currently ongoing

WHAT DOES THIS MEAN?
Currently this is not an emergency. There were times when turbidity in your drinking water was unacceptably high. Turbidity has no health effects. However, turbidity can interfere with disinfection and provide a medium for microbial growth. Turbidity may indicate the presence of disease causing organisms, these organisms include bacteria, viruses, and parasites that can cause symptoms such as nausea, cramps, diarrhea, and associated headaches. In addition, inadequate disinfection, as occurred with frequency, can further allow these organisms to survive in the delivered water.

Please be aware that you could also experience these symptoms from other causes not related to your drinking water. If you experience any of these symptoms and they persist, you may want to seek medical advice. 

During the violation periods listed above, people with severely compromised immune systems, infants, and some elderly may have been at increased risk. These people should seek advice about drinking water from their health care providers. General guidelines on ways to lessen the risk of infection by microbes are available from EPA’s Safe Drinking Water Hotline at 1-800-426-4791. 

WHAT IS BEING DONE?
The City of New Brunswick authorized a Comprehensive Performance Evaluation of the water treatment plant, including a review of technology, personnel, policies, procedures and budgetary matters. This Evaluation was performed by an independent consultant following the USEPA Guidance Manual protocol. 

The purpose of this evaluation was to identify ways to optimize performance of the treatment plant. Some of the recommendations of the evaluation have already been implemented, and the City will continue to make improvements over the next six months with the assistance of an independent consultant. The City has also restructured its water treatment staff organization to improve the supervision of treatment operations. The City’s licensed operator has been suspended. Since June 2013, New Brunswick has been performing all required water quality monitoring and sampling and all results have been within regulatory limits.