WATER WORKS ‘DEFICIENCIES’
Trenton boil advisory caused by ‘technical, managerial, and operational deficiencies,’ DEP finds
TRENTON » The New Jersey Department of Environmental Protection (DEP) found numerous safe drinking water violations that prompted the capital city’s boil advisory last month.
In a DEP letter dated July 21 that was obtained by The Trentonian, the state agency reported that an incident evaluation from the June 5 boil advisory in Trenton uncovered “technical, managerial, and operational deficiencies” within the Trenton Water Work’s Water Treatment and Distribution systems “that need to be addressed.”
Trenton, which also provides water to residents in Hamilton, Lawrence, Ewing and Hopewell, was cited for violating the Water Supply and Wastewater Operators’ Licensing Act, the Licensing of Water Supply and Wastewater Treatment System Operators Regulations, the Safe Drinking Water Act, the Safe Drinking Water Act Regulations, the Water Supply Management Act, and the Water Supply Allocation Regulation, the DEP letter states that was signed by A. Raimund Belonzi, the agency’s bureau chief for compliance and enforcement.
DEP said the city was noncompliant for the following five items during the June incident, according to the notice of violation:
• Failure to maintain a disinfectant residual concentration such that the total treatment processes of the system achieved at least 99 percent inactivation or removal of Giardia lamblia cysts and/or least 99.99 percent inactivation and/or removal of viruses. Specifically, the water system reported that it failed to meet the required Chlorine Contact Time on June 5, 2017.
• Failure of the licensed operator to develop a protocol for the system designed to ensure that each employee associated with the system is acquainted with his or her particular responsibilities and obligations, including the protocol to be followed in the event of an emergency or an intervening factor which mandates deviation from routine operations and maintenance (O&M) procedures.
• Failure of the licensed operator to ensure that health and safety measures related to the O&M procedures are followed by the licensee, employee and agents of the system so as to protect human health, safety, welfare and the environment.
• Failure to conduct periodic evaluation of emergency response plans.
• Failure of the water system to provide DEP with a demonstration of O&M procedures, as well as Technical and Financial Capacity as required by the regulations.
During the June dilemma that lasted approximately 24 hours, the city documented a water quality issue occurred at the Trenton Water Works (TWW) and a boil water advisory was issued. Parts of Trenton, Ewing and Hamilton were affected by the potential threat.
In a statement at the time, Trenton Mayor Eric Jackson said that the problem arose from a technical issue at the city’s water treatment plant that caused chlorine levels to temporarily drop.
Despite DEP outlining other factors, city spokesman Michael Walker still claimed Wednesday that a “technical issue” prompted the boil water advisory. He also would not get into specifics if human error was involved, citing the city’s policy to not comment on personnel matters.
“At no time, was water quality impacted,” Walker alleged, despite DEP’s report stating otherwise. “On that particular day, we took multiple bacterial tests, which all came back negative.”
The city spokesman also said a 2017 water quality report was recently mailed to customers, detailing no concerns.
DEP said it met with TWW officials on June 16 regarding the boil advisory. The parties agreed upon the following 10 actions items that need to be addressed to “ensure proper operation” of the water treatment and distribution systems and to prevent future incidents from reoccurring, according to the DEP letter:
1. TWW is to develop a direct notification process for the entire service area that ensures homeowners and appropriate municipal officials are being notified.
2. TWW is to improve their Reverse 9-1-1 system to include all customers within the water service area. The system only currently notifies Trenton residents.
3. TWW is to provide an updated emergency response plan to DEP. This update should include, but not limited to, lessons learned from the June 5 incident.
4. TWW is to train all TWW staff on the Incident Command System/National Incident Management System (ICS/NIMSs), and to make this training standard for employees.
5. TWW is to establish a procedure that will provide instantaneous Chlorine Contact Time calculations.
6. TWW is to develop standard operating procedures to ensure proper day-to-day operation and maintenance of the water system as well as procedures under emergency situations.
7. TWW is to provide DEP with organization charts (positions filled and vacancies) to evaluate technical capacity.
8. TWW is to provide DEP with the status of supervisory control and data acquisition (SCADA) improvements that hinder proper day-to-day operational procedures.
9. TWW is to provide geographic information system (GIS) mapping and a paper map of the entire service area depicting pressure zones and critical users.
10. TWW is to clarify whether the residency requirement is applicable to new employees for positions which require specialized college degrees.
Trenton Public Works Director Merkle Cherry blamed some of DEP’s findings on the city’s inability to fill approximately 65-to70 positions at TWW.
“DEP has concerns related to the staffing levels and some of the qualifications that the city has been challenged with for a while, mostly because our wages sometimes aren’t as competitive to attract some of the licensed folks,” Cherry said Wednesday, noting some of the positions have residency requirements, making it difficult for potential employees to relocate. “The concerns related to attracting some staff with the credentials and licenses that are required are things that we were already starting to work toward and move toward.”
DEP also criticized the city for failing to include all of its customers in the robocall system. The call system only notified Trenton residents during the boil advisory, DEP said.
“We think that DEP wants us to enhance the way we communicate with customers,” Walker said. “That’s something that we are looking at very carefully.”
Cherry said the city also manually delivered notices door-todoor, but that occurred a day after the incident.
“We don’t expect that this will be occurring in the future,” the public works director said. “One of the challenges of the city like Trenton is it’s old and we’re dealing with some of those challenges, but we don’t expect this type of an event that will be occurring in the future.”
The city has until Aug. 11 to provide a detailed report on what corrective actions it will take to address the issues, the letter states. The city may be fined up to $25,000 per day for each of its five violations.