Moorestown Patch Letter to the Editor: Water is Safe to Drink

To the Editor:

In response to a Letter to the Editor on November 6, I would like to provide information regarding our drinking water supply, the presence of 1,2,3-TCP and whether water consumed was safe during the time that Wells 7 and 9 were operating.

Unlike those that would rather grandstand for their political interests, including standing along-side uneducated politicians the week before an election, using Moorestown as the poster child and back-drop for their contaminated drinking water supply video, (which quite frankly offended me), my approach will be to provide information regarding the TCP issue without fear-mongering for political purposes.

It’s a shame that individuals do not think through the repercussions of such acts. If they did, they should have thought about what folks outside our fantastic town might think as they spread unnecessary fear, and how it may affect everything from our property values to our ability to attract families and their children to live here.

Make no mistake; there is no reason for fear. They chose to take an opportunity to spread fear about issues in which they have no expertise, while standing beside a council member for whom I have tremendous respect as a person; albeit one who in my opinion made a very bad decision as a councilman to be a part of the circus that occurred involving politicians proposing legislation that is already effectively in place via the Safe Drinking Water Act and subsequent state bills. Hopefully, with the election over, we can limit further grandstanding and unnecessary public press conferences.

Although I do not profess to be an expert in everything, regarding my qualifications, I have served as a National Expert on sites throughout the country involving drinking water and environmental contamination. In my case, I am a licensed professional engineer who, for the last 25 years, has investigated and/or remediated thousands of contaminated groundwater sites throughout the country including more than half of the EPA’s Top 10 NPL sites.

In addition, my credentials include being a Master Level certified hazardous materials manager, a licensed potable water treatment system operator, a licensed water distribution operator, and finally a Licensed Site Remediation Professional.

This information is not stated to impress anyone but to simply provide my thoughts on the issue that are based on much more experience than I would expect from a pizza shop owner, who has elected to be the voice of facts on this issue. I also wish to educate those that may be unnecessarily concerned about our drinking water due to sensationalistic acts by a few vocal, googling, politically motivated individuals.

To pose as such an expert is insulting to those of us who actually are experts in this area.

Here are the facts: Although the chemical, 1,2,3-TCP, as we all know, is something that we do not want to drink, eat or inhale, the concentrations that currently exist in our drinking water supply are safe to consume and do not possess any appreciable risk to human health or the environment. In my field, similar to the medical field, it’s not about the presence of a chemical; it’s all about the dose.

Everything we eat and drink on a daily basis has chemicals in them including carcinogenic compounds. Anyone can research known food chemicals and contaminants and you will find that we eat everything from polycyclic aromatic hydrocarbons in grilled and barbecued meats; pesticides in dairy products; herbicides in corn, wheat and soybeans; synthetic hormones and antibiotics in cheese; among many others.

Then there is the whole issue of dioxin. Without intentions to scare anyone, dioxin happens to be one of the most toxic chemicals known to science and is present in everything from paper products (including tissues, toilet paper, tampons and pizza boxes) on through dairy and other animal products that we eat every day.

Humans are exposed to dioxin primarily via consuming animal products, with concentrated dairy products, such as cheese and butter, being the worst offenders. Why do I bring up dioxin? Because it is universally agreed to be the #1 most toxic chemical known and researchers found that Americans get 22 times the maximum dioxin exposure suggested by the EPA through food alone.

FYI, Vegans were found to have much lower levels of dioxin. Due to measured levels of dioxin that exceed safety standards, the National Academy of Science has, for years, recommended that people avoid eating a diet rich in animal fats. Obviously, consumers have not taken heed of this advice.

In an EPA study performed on a single serving of hamburger, pizza, fried chicken and ice cream, the findings showed that all food tested contained a “toxic soup” of chemicals including dioxin/PCB levels from 400 to 1,000 times the maximum daily allowable dose established by EPA.

So knowing this as an environmental engineer, do I restrict my children from eating ice cream or pizza or meat? The answer is no because it’s the dose over time, not merely the presence of chemicals.

They do not eat these foods daily and the reality is that they would likely suffer from heart disease and other medical issues long before they got sick from eating an occasional hamburger, slice of pizza or scoop of ice cream.

The chemical 1-2-3 TCP is an intermediate chemical and industrial solvent, and nowhere near as toxic as dioxin.

It can be found in water from pipe coatings and has also been found in drilling fluids used in the construction of new potable wells. That being said, EPA has not promulgated a regulatory limit or maximum contaminant level (MCL) for this chemical in drinking water.

They have included it as a likely human carcinogen on what is called a Contaminant Candidate List (CCL3) along with dozens of other possible carcinogenic compounds that are also unregulated.

Basically, these lists are used to identify compounds that may become regulated in the future once additional data is developed and the science community can agree on its need for regulation.

EPA establishes MCLs using a variety of factors including the risk of getting cancer from exposure to chemicals based on a one in a 1,000,000 risk.

To put this in perspective, currently it is generally accepted that our chances of getting some form of cancer from any cause is one in three or 33%. A chemical in drinking water at its MCL means that our risk of getting cancer increases by a mere 0.0003% or basically zero, so your new risk of cancer would increase to 33.0003%. Effectively, MCLs are developed to simulate no increased risk.

So what do states and/or the feds do when there is no MCL? They can perform their own risk assessments or rely on cancer risks developed by the EPA in their Drinking Water Standards and Health Advisories tables. FYI, the results in Moorestown were observed to range from 0.038 ug/l to 0.067 ug/l.

So what is a ug/l? It’s the same as saying part per billion (ppb). So 0.038 ug/l means our water showed .038 ppb or 38 parts per trillion (ppt).

Pretty low numbers.

In fact, they are so low that up until only a few years ago, lab analytical methods couldn’t even detect this chemical at this low a level. Even today, most municipalities do not use the new method and thus cannot detect TCP at such a low concentration.

The first round of UCMR sampling performed by EPA shows states reporting limits between 0.5 ppb (500 ppt) and 5 ppb (5000 ppt) for TCP, which means anything below those levels (ours ranged from 38 to 67 ppt) would not be detected.

New methods can see lower and are now showing detections that otherwise would never show the presence of many chemicals that, although they are present, do not necessarily pose a risk to human health or the environment at such low levels.

Here are more fun facts: Although TCP does not have an MCL, it has lots of proposed numbers, health advisory numbers and risk assessors/industrial hygienists all debating and arguing about what the appropriate MCLs should be or are reasonable to establish.

MCLs can be easily affected by changing variables on slope factor, cancer risk, ingestion amounts and so forth. The reality is that water has lots of chemicals, minerals and metals in it whether you drink bottled water or Moorestown’s finest.

The EPA has established several levels for TCP; the first called a Drinking Water Equivalent Level is 0.1 mg/l (same as 0.1 ppm, 100 ppb and 100,000 ppt). So we have between 38 and 67 ppt in our water and EPA’s DWEL level is 100,000 ppt, so we are over 1,000 times lower than this level.

EPA also published in 2012 a recommended level for a 10 kg child ingesting 1 liter/day for 10 days at 0.6 mg/l (0.6 ppm, 600 ppb, 600,000 ppt).

Hawaii has the only promulgated MCL for TCP at 0.6 ug/l (0.6 ppb, 600 ppt), as does Alaska’s groundwater cleanup level. Both are 10 times higher than our concentrations.

Florida has a lifetime health advisory level of 40 ug/l (40,000 ppt), or 600 times higher than what we have in our water. New York applies an MCL of 5 ug/l (5,000 ppt) based on their principle organic contamination default standard and Canada also uses 5 ug/l (5,000 ppt) as their applicable drinking water standard for TCP, both 100 times more than the levels in our water.

In New Jersey and California, the states that are the most heavily regulated and overly cautious in regard to environmental standards, both established 0.005 ug/l (5 ppt) as drinking water guidance or notification levels although neither state has an MCL and neither state requires water systems to shut down in excess of these values, likely because TCP is being found widespread at low levels and issuing a regulation at levels so much lower than EPA’s guidance would result in millions of dollars of upgrades to water systems state-wide unnecessarily.

In California, out of 372 potable water supply sources that were sampled since the new lower detection limits were implemented, 367 had detections of TCP (99%) at or substantially above the levels observed in our wells. All are currently operating.

Why is this technical stuff important? Because attempting to clean up a chemical in our water at a concentration below a reasonable cancer risk of one in a 1,000,000 (as select individuals in NJ and CA agencies have suggested be attempted) is comparable to limiting highway traffic to 0.1 mph to avoid the possibility of an accident.

It’s not the presence of a chemical that causes cancer; it’s the dose and currently the levels in our wells have not exceeded any level in the country that has been established to prevent against a one in the million cancer risk and according to most safe levels established by other states and EPA, our concentrations are 100s to 1,000s times lower.

To put it another way, our risk of dying in a car accident is roughly one in 7,700, on a bike is one in 410,000 and dying in a plane crash is one in 2,000,000 as compared to EPA and other state levels 100 times higher than ours that would result in a one in a 1,000,000 risk of just getting cancer, not even dying from it.

To evaluate the risk myself, I used EPA’s risk assessment tools using extremely conservative values to come up with an MCL. For a 15 kg infant that drinks 1 liter of water a day, 350 days a year for 70 years with a one in a million cancer risk, the concentration of TCP in water would have to be greater than 80 ug/l (80,000 ppt) and for a 80 kg adult, the level would need to be greater than 133 ug/l (133,000 ppt); both orders of magnitude higher than our 38 to 67 ppt.

My point is to stop the unnecessary fear. Everyone can relax and let our township council work through the process of investigation; remedy evaluation and implementation.

TCP can be removed through simple carbon adsorption and I am sure the township is evaluating this and other approaches to remove it completely from our drinking water, even though its levels do not constitute a risk to anyone even if the wells were turned back on with our current concentrations.

My opinion is that the township did exactly what they should upon being notified of the issue; they shut off the wells in order to gather more information and began researching the relatively unknown chemical since we are not in peak demand season.

Even though Mr. Newcomer would like to know the source of TCP, that may never be known. It is very likely a regional issue that would cost tens of millions of dollars to investigate, since our wells are screened in the PRM, a deep drinking water formation atop bedrock, and it is quite frankly unnecessary.

If we drill wells and encounter elevated iron, millions are not spent investigating the source, instead it is simply treated. The reason and need for treatment is because TCP levels appear to be increasing and although not a risk currently, they could become one in future years if not dealt with now.

As a resident and consumer of our water, I am equally interested in this issue being handled correctly and plan to monitor its progress, while at the same time, having absolutely no concerns whatsoever about drinking our current water with or without wells 7/9 running.

Sorry for the long message.

Happy Holidays.

Peter J. Palko,

P.E., CHMM, LSRP

Moorestown Resident