Mar 03

Water Testing Questions Answered

Posted on March 3, 2017 at 9:39 AM by Parris Crooks



Looking at lead testing data trends since 2002, the results of the EPA required lead testing, from when soda ash was used in comparison to when sodium silicate was used our trends show minimal difference.  The pH range required by the EPA in the past has always been lower. When we went off soda ash and back on to sodium silicate the EPA required a much higher dose of sodium silicate than the town had ever used in the past. We did some jar testing and found that this dose would have a dramatic impact on our pH. The EPA acknowledged this and increased our maximum pH to a higher level so we could continue dosing the sodium silicate at EPA's desired level. The end result is that our requirements have been changed and what was done in the past and what is being done now is not comparable because of the change in dosing and resulting pH.

It is very important to understand and take into account the change in environment at the EPA. Pinedale has a new rules manager and the emphasis on lead has dramatically changed. Pinedale water is unique and our system has been under very close scrutiny because there are no other systems quite like ours to compare with. Our system has been reviewed by the EPA research and development department and we are currently conducting further testing to optimize our system and provide our citizens with the best water.  

On Thu, Mar 2, 2017 at 10:43 AM, Stephen Crane <scrane@pinedaleroundup.com> wrote:

    "Based on the minimal info we have regarding the school testing, the most plausible explanation for the decrease with the school test results is the increase in pH of the incoming water."

    So how does this relate to the water treatment previously done when soda ash was the primary CCT? Were the appropriate pH levels not being adequately achieved? If not, why not. And if so, why would the levels at the district now drop with sodium silicate but not the previous soda ash treatment?

    Stephen Crane, editor
    Pinedale Roundup
    editor@pinedaleroundup.com
    (307) 367-2123

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Mar 02

Response to Lead Questions from the Pinedale Roundup

Posted on March 2, 2017 at 10:26 AM by Parris Crooks

The Pinedale Round up recently submitted some questions to the Town regarding our water treatment corrosion control. Please see below for the original email and the Town response.


Email sent to Town on 3/1/2017

Hey there Hayley,

I wanted to follow up on the water testing the town is currently conducting in its effort to switch its EPA-approved CCT from sodium silicate to soda ash. And can you remind me who is involved in the testing, including the Colorado-based company?

I recall you mentioned at a meeting about a month ago that the town is currently conducting "jar testing" to demonstrate soda ash's effectiveness as a CCT.

In reading through my back-and-forth with the EPA last fall, they list a handful of testing methods that can be used, but jar testing is not one of them.

"The EPA requires conducting a “study” using this water via pipe rig or loop tests, metal coupon tests, partial system tests, or other documented analyses based on other systems of similar size and pipeline configurations, and with similar water chemistry as the Fremont Lake water chemistry."

From all I gather, the "jar test" consists of little more than taking water from the town's source, putting it in a jar, letting it sit around awhile, and seeing what shows up.

So how does this method take into account the old service lines that are in place in town?

How can the public be reassured that if/when the town makes a switch to soda ash, which clearly seems to be the mission, that they're drinking water will be safe?

No one disputes that the town's water supply and its infrastructure is free of lead. But the service lines are another story.

The school district just received the results of its latest testing and the levels continue to drop, which implies that the sodium silicate is working and coating the pipes as intended. However, we all saw what happened using strictly soda ash.

So how can town residents and school staff/students be reassured they'd be safe under that potential scenario?

Did the EPA approve the jar testing method?

In communications with the EPA, what are the priorities they're pushing for the town when it comes to a potential CCT switch? What steps does the town need to complete before a switch can be made?

How does the town's approach relate to EPA requirements? In other words, is the town's priority to check off the EPA boxes or to ensure that the drinking water at every tap is safe to consume? Would not a "partial system test" - in which, hypothetically, the school's piping system was closed off and town water (with soda ash as the CCT) was pumped through - demonstrate a more accurate picture of soda ash's potential effectiveness, since it's replicating the "source to tap" requirements of the Safe Drinking Water Act?

Long story short, I have heard from a few people, including one with expertise in the field, who are worried about the town's effort to switch to soda ash, since it seemed to cause problems last time it was used vs. sodium silicate - as demonstrated in the school district's recent testing results.

Any timely information you can provide on this subject is greatly appreciated.

Thanks,
Stephen
Stephen Crane, editor
Pinedale Roundup
editor@pinedaleroundup.com
(307) 367-2123

Town Response sent on 3/2/2017.

Hi Stephen,

The Town has hired JVA Consulting Engineers to assist with the testing and provide the Town with an OCCT recommendation.

On January 9th I emailed the EPA and asked “as for the proposal to be submitted to the EPA by June 30th, is there something which we can refer to with the list of deliverables and info to be included in the proposal? In addition to the jar testing, what pilot-scale testing would be required? Would this need to be implemented now, prior to the proposal submittal?” The EPA responded on February 17th saying, “we don’t have a specific outline or protocol for a proposal like this because when water systems propose their corrosion control treatment recommendations, they have evaluated the most appropriate corrosion control using tests described in CFR § 141.82(c) – "pipe rig/loop tests, metal coupon tests, partial system tests, or other documented analyses based on other systems of similar size and configurations, and with similar water chemistry” and we are falling into the "other" category.”

Because of our system design, jar testing is the most appropriate option, the other options would be very difficult and costly to set up and monitor. JVA conducted computer modeling, which is commonly used, based on our water characteristics the use of sodium silicate was not even recommended as one of the top 10 options in the model. The EPA did recommend that we start with jar testing to evaluate the best OCCT. JVA is planning to discuss their recommendation with the EPA prior to submitting the proposal to make sure we are on track. Overall, the EPA is well aware and on board with what we are doing.

There are several factors which lead to reduced corrosion, one which includes the maintenance of a specific pH range in the distribution system that reduces the solubility of lead contained in the building water systems. If in fact the school is experiencing lower lead levels, one reason may be because we are targeting this pH range in the distribution system with the sodium silicate. As you know corrosion control can be achieved in some circumstances by coating pipes with the silica; however, based on our water characteristics and pipe materials, after long discussions with EPA researchers it is their opinion that the silica is just running thru our distribution system, not sticking to the pipes, and only acting as a pH adjustor. Based on the minimal info we have regarding the school testing, the most plausible explanation for the decrease with the school test results is the increase in pH of the incoming water. Positive lead tests are a result of lead in that building’s pipes/fixtures, those pipes/fixtures should be replaced if there is any doubt about safety. Anything the Town does with the water supply is at best, just going to lower the risk, not eliminate it.

Please note that your email and this response is being posted on the Town website today.

Thanks and I hope I answered your questions,

Hayley
--
Hayley Ryckman, E.I.T., M.S.
Director of Engineering and Zoning
Town of Pinedale
townofpinedale.us
Phone: 307-367-4136
Fax: 307-367-2578
Dec 07

Letter from the EPA-Originally posted 11/23/2016

Posted on December 7, 2016 at 4:12 PM by Parris Crooks

In response to questions from the Pinedale Roundup to the E.P.A.(Environmental Protection Agency) in regards to the Pinedale Water System's recent violation, the E.P.A. sent the following letter:

Hi Stephen-- thanks for the follow-up inquiry regarding the Pinedale drinking water system. I want to emphasize that The Town of Pinedale has been cooperative and quick-to-act in response to EPA’s Notice of Violation (issued on October 17) regarding the use of the EPA-approved corrosion control treatment technology at the water system.  The approved treatment is back on at levels that will help mitigate corrosion and lead in drinking water and EPA is satisfied that this matter has been addressed.  As you may know, last month, the Pinedale water system submitted its most recent reporting for lead and copper which (based on the 90th percentile calculation of collected samples required by the Act) is below the Safe Drinking Water Act action level for lead.

 

Pinedale has a long history of cooperation with EPA in delivering drinking water in the community. While we regret any miscommunication or missed opportunities to clarify drinking water requirements with local officials, the Safe Drinking Water Act does require a clear set of steps related to changing approved control technologies.  Moving forward, we are committed to maintaining clear lines of communication with operators and local officials to make sure our collective efforts recognize local needs and are consistent with the Safe Drinking Water Act.

 

The Town’s current EPA-approved corrosion control technology is sodium silicate.  While other control technologies may be used, under the Safe Drinking Water Act, water systems are required to conduct studies and notify EPA in writing prior to making any permanent changes in treatment.  EPA must then review and approve these changes before they are implemented.  In this case, EPA was aware soda ash was being used by system operators, however the intention to permanently replace the approved sodium silicate corrosion control inhibitor with soda ash was not made clear to EPA, nor were the appropriate bench studies done to determine the effectiveness of this method.  My understanding is that EPA became aware that the sodium silicate was turned off permanently during a sanitary survey in August 2016.

 

Although sampling of schools is not specifically required, the School District is implementing a voluntary sampling program.  I understand Gregg Anderson of the Sublette County School District is leading this effort and is in contact with the operators from Pinedale water system.

 

Hope this is useful. 

 

A safe and happy Thanksgiving to you and yours!

 

Rich Mylott

USEPA Region 8

As stated in the letter, please be assured that your water is and always has been safe to drink.