The following is in response to a list of questions submitted to staff by
Council President John Watts regarding motorized watercraft
management recommendations. Each question is followed by an answer
in bold text. Some questions have multiple parts under one number but
all parts are related to a common subject. Cost estimates are based on a
variety of sources but all should be viewed as preliminary estimates.
1. For how long have the benzene tests been conducted?
The City has collected benzene data since 1988 as part of our
volatile organic chemical monitoring program per Safe Drinking
Water Act (SDWA) requirements. Sampling procedures have been
refined and improved in the past 5 years.
Treated water is currently sampled annually to establish compliance
with the SDWA. Often the treated water sample is paired with an
untreated water sample to derive treatment plant removal data for
the water utility. The analysis required for Safe Drinking Water Act
compliance is a broad scan, and as such, has a detection level for
benzene that is up to 9 times higher than more selective methods
currently used by the utility (see paragraph below). The detection
level for SDWA compliance determination is conventionally reported
at the State Reporting Level for compliance determination (typically
reported as 0.5 parts per billion or ug/L). When reporting the results
for compliance monitoring, it is the convention to report only to the
State Reporting Level. Therefore, data derived for SDWA compliance
sampling is reported above the benzene levels typically observed in
Lake Whatcom.
Benzene, Toluene, Ethyl Benzene, and Xylene (BTEX) Sampling
Because the 1999 Olympic pipeline rupture and explosion occurred
directly between the water filtration plant and the filtered water
chlorine contact reservoir, there was concern about gasoline
contamination in the water supply. The utility immediately began
collecting and analyzing water from the treatment plant and in the
distribution system for benzene, toluene, ethyl benzene, and xylene
(BTEX), which are constituents of gasoline. These BTEX compounds
were detected in all but seven of the 120 samples collected from the
time of the explosion until the end of that year. Levels of detection
were well below the State Reporting Level, and the average benzene
levels in all samples collected from that period was 0.07 ug/L. Six of
the seven samples that had no BTEX detections were from those
samples taken from 11/15/99 until 12/13/99. Those 6 samples
comprised all the samples taken during that later period.
With the realization that BTEX compounds were being detected in
the treated water supply came the desire to definitively attribute
the source of these compounds. Sampling began at the Gatehouse
(untreated Lake Whatcom water from the City Intake pipe in basin
#2) on June 22, 1999. It came as a surprise to the utility that
benzene levels were also detectable at the source of the City’s
drinking water, over a mile away from the site of the pipeline
rupture. As this monitoring program continued, an analytical
method with better detection levels was employed starting in 2001.
The Selected Ion Mass Spectrometry (SIMS) allowed detection levels
at up to 9 times lower than by the conventional SDWA-required
method as it is able to focus in on the specific spectra of interest.
Where are these records kept?
All records from the Safe Drinking Water Act compliance monitoring
are reported and filed with the State of Washington Department of
Health and are also filed in the Water Filtration Plant Laboratory.
Records from the post-Olympic pipeline rupture monitoring are filed
at the Water Filtration Plant Laboratory. Results from this
monitoring are entered into an Excel spreadsheet to allow for data
analysis.
What is done with this information? Is it included in any official reports or
literature?
The City included information/data on the BTEX monitoring
program in two of its Consumer Confidence Reports sent to all
customers of the water utility (June 2000 and June 2001). The
benzene levels detected in lake water were also reported in the
Water Source Protection Plan (Section 2.1.12), compiled by the City
of Bellingham and Whatcom County Water District #10 in 2000.
The City’s BTEX data was also provided to the Citizen’s Advisory
Committee formed to provide recommendations on boating on Lake
Whatcom. This data is available electronically and is also provided
to customers upon request.
Is it true that the levels reported to date are well below actionable levels
[MCLs] mandated by Federal and State Law?
Yes this is true.
The Environmental Protection Agency (EPA) and State of
Washington regulatory levels of note are shown in the table below:
The table depicts the maximum contaminant level (MCL), the
maximum contaminant level goal (MCLG) and the Washington State
Reporting Level. Though the MCLs are enforceable standards and
MCLGs are not, the EPA feels there is no safe level of consumption
for carcinogens such as benzene and has therefore set the MCLG at
zero.
Compound
Benzene
Toluene
Ethyl benzene
Total xylene
EPA Maximum
Contaminant
Level(ug/L)
5
1000
700
10000
EPA Maximum
Contaminant
Level Goal(ug/L)
0
1000
700
10000
State Reporting
Level
(ug/L)
0.5
0.5
0.5
0.5
The EPA realizes that real financial and technological constraints
often make zero unattainable, so they set MCLs as close to MCLGs
as feasible using the best available treatment technology and taking
cost into consideration. The maximum level of benzene found in all
treated water samples taken from 2000 to present is 0.123 ug/L,
and the maximum level of benzene in untreated water (for which
these level do not apply) is 0.137 ug/L.
The other contaminants toluene, ethyl benzene and xylene have
MCL and MCLG levels that are the same because unlike benzene, the
EPA believes those levels provides sufficient protection from the
potential health problems associated with these contaminants.
The EPA has grouped contaminants into five groups based on the
seriousness of their health effects upon humans. The health impact
is based upon whether or not the substance being classified has
been determined by USEPA to cause cancer in animals or humans.
Group A is described by USEPA as a known human carcinogen,
or cancer-causing substance in humans.
Group B has been determined by USEPA to be a probable
human carcinogen.
Group C includes possible human carcinogens.
Group D includes substances for which there is insufficient
evidence to document carcinogenic effects upon humans.
Group E is not considered a carcinogen.
Benzene is a volatile organic compound (VOC) listed as a Group A
contaminant, The EPA feels that adequate human data exists to
support this classification. Another Group A VOC, vinyl chloride, is
also of concern.
2. Is there any discernable trend in recorded benzene levels over time,
aside from the periodic spikes? Is the fact that measurable
concentrations have been found a cause for concern?
The seasonal variations seem to be the only apparent trend. Please
refer to prior response for discussion on MCLGs and benzene.
3. Where are the sampling points and with what frequency are samples
taken and tested? Does sample location or frequency matter.
Since 1999 samples are collected at least monthly and consist of
paired gatehouse and treated water samples. The gatehouse sample
represents the water coming into the City’s intake pipe. The water
does not stratify thermally at the intake location, therefore there is
a much greater likelihood that substances on the lake surface could
make their way to the intake at the bottom of the lake.
In (only) one instance were samples collected from both the intake
and from the surface of the water above the intake (where one would
assume more hydrocarbon to exist). This sampling occurred in
August 2000. The data were:
Benzene (ug/L or parts per billion) Single ion monitoring
8/28/00 Gatehouse
0.123
8/28/00 Surface of lake near intake
0.230
4. Is the City's present water treatment process capable of removing
benzene from the raw water to produce our drinking water? From the
data, it appears not likely because there is little difference in
concentration.
You are correct, the City’s treatment plant is not capable of
removing benzene.
5. What is the estimated expense for upgrading the water treatment plant
to remove benzene and/or other organics harmful to humans?
A full comparative analysis of equipment costs, plant remodeling
costs, potential for other contamination, expected benefits of the
treatment options and other factors is needed to answer this
question.
The EPA has selected two preferred treatment methods for removal
of Volatile Organic Compound (VOC) contaminants such as Benzene.
Packed tower aeration or air stripping is one method. This process
transfers the VOC's from water to air. The air is discharged into the
atmosphere. Consideration must be given on a case-by-case basis to
ensure that the airborne VOC contaminants do not cause health
risks. While it is possible to place additional treatment on the air
discharge, the additional costs involved make this method very
expensive especially when higher concentrations of VOC
contaminant are present. One would also need to be concerned
about introducing air borne contaminants into the water.
The other method of removal is granular activated carbon (GAC)
adsorption. When water passes through a bed of activated carbon,
VOC's attach or stick to the carbon. The attaching or sticking
process of VOC's to the carbon granules is called adsorption. The
carbon must be monitored carefully so that it can be replaced before
it is exhausted. Carbon which is exhausted, or has adsorbed all the
VOC's it can, may allow the adsorbed VOC's to be released back into
the water in higher concentrations, due to the amount of VOC
accumulation upon the carbon granules. Contaminated carbon must
be regenerated on site or properly disposed of so that
recontamination of the water does not occur. This treatment
technology also has been shown to encourage the proliferation of
microorganisms at the treatment plant, some of which have shown
resistance to disinfectants currently in use.
Would such an upgrade be justified?
In the final determination of which treatment process to use for
VOC removal, all elements relevant to our water system should be
considered. These elements include the cost, the
types/concentration of VOC's present, the amount of removal
deemed acceptable and the surrounding neighborhood.
How would it be paid for and by whom?
Water utility customers would pay the costs for changes to the
water system. The utility users also pay for maintenance and
operation costs.
How much more capacity is available using the current water treatment
plant, and when would an expansion normally be expected, using the
same technology?
At what point would such an upgrade be anticipated?
It is quite difficult to determine when we will reach capacity on our
water treatment plant. It is an element of our comprehensive plan
(1993) and was slated for expansion in 1995. Since 1993 the City’s
overall water consumption has been flat and our peak use days have
been significantly reduced. So at this stage we do not have a plan
for expansion. At some point growth will overcome conservation and
we will have to expand the facility. The current peak capacity
available is approximately 20 % or 5 million gallons per day.
What are the estimated costs of a more sophisticated water treatment
system based on advanced technology to remove benzene and related
compounds?
We do not have cost estimates of alternative treatment systems to
address issues such as benzene. It would require us to retain a
consultant to develop the feasibility of removing targeted
compounds and what that would cost from a capital and O & M
basis. It also would require that we evaluate the benefits of certain
treatment schemes and the risks associated with using that
technology. We would want to be assured that in the process of
removing one contaminant that we did not introduce new risk
factors which might be as great or greater than the targeted agent.
What about the idea of obtaining drinking water from another source
besides Lake Whatcom? What estimated costs might this entail, assuming
another source is available?
Other drinking water sources have been reviewed. They include
changing our point of withdrawal from the Nooksack River, piping
Middle Fork water around the Lake directly to the water treatment
plant and reverse osmosis treatment of salt water from Bellingham
Bay.
Withdrawing water from the lower Nooksack is estimated to cost
between $100 and $150 million for construction and $10 million or
more in yearly maintenance and operations costs. The option would
require land acquisition, big pumps, settling basins, new treatment
facilities, etc. Electricity would be a big part of the yearly M&O
costs. Due to the large sediment load and the need to pump
continually equipment maintenance costs would be high. Water in
the lower river receives contaminants from Everson, Lynden and
Ferndale treatment plants as well as runoff from agriculture and
other land uses, therefore requiring a high level of treatment.
Pumping around the Lake from the Middle Fork diversion is
estimated to cost around $45 million. Yearly M&O might be
$2 million. This option relies heavily on the availability of land for
the pipeline and a water reservoir. Probably big pumps would be
required with high electric use. Depending solely on water
withdrawal from the Middle Fork is not feasible given the instream
flow constraints on our withdrawal management.
A reverse osmosis plant would be constructed on the City waterfront
that would provide the supply source for drinking and industrial
process water for the City’s residents and industrial users. The
system would include a treatment plant, reservoir, pumps and pipes.
Reverse osmosis is, in general, very expensive ($180 million) and
typically done when there is no fresh water alternative. The
advantage that reserve osmosis has is that there is no water right
requirement for salt water. The supply is inexhaustible, available
and located within Bellingham Bay where the City is located. In
addition, a reverse osmosis plant to supply only potable water,
although cheaper, does not completely relieve the City’s reliance on
Lake Whatcom as a source of supply for industrial process water
purposes.
How would this be paid for and by whom?
The costs for changes to the water system would be paid by water
utility customers. Maintenance and operation costs are also paid for
by the utility users.
6. What is the estimated cost of moving the City's water intake to a more
sheltered area in Basin 3?
In the past the cost has been estimated to be $1000 per linear foot
with an estimated distance of 5000’ for a cost of $5 million. This
should be considered a minimum given anticipated cost increases by
the time a project is construction ready.
Would such a move be expected to be helpful?
We are currently reviewing this issue. The review is assessing the
water quality and other issues in the portion of Basin 3 nearest
Basin 2.
Would these costs be justified?
This question will be answered after the completion of the review.
How would this be paid for and by whom?
Water utility customers would pay the costs for changes to the
water system. The utility users also pay for maintenance and
operation costs.
7. Does the City have any way of systematically identifying: boaters using
the Reservoir; the number by type of watercraft used; how particularly
sensitive areas might be better protected; how to fairly & equitably enforce
boating BMPs; how many of these boaters use the Bloedel-Donovan
launch?
At the present time, there is no comprehensive count of the
numbers and types of watercraft used. Counting the number of boat
launches at Bloedel Donovan Park (see below) is an inaccurate
estimate of boat use, since boaters also access the reservoir at the
public WDFW boat launch, as well as the boat launches at Sudden
Valley and Wildwood Resort. Boat use counts are further
complicated by the significant boat use that originates from the
hundreds of private docks that encircle the reservoir.
How particularly sensitive areas might be better protected;
Identifying particular areas, such as the intake pipe, for enhanced
protection is not included as a management recommendation.
How to fairly and equitably enforce boating BMPs;
It is recommended that the Whatcom County Sheriff’s boat patrol
enforce any new boating regulations. The Sheriff currently patrols
the reservoir on a limited basis. The committee has
recommendation is that the boat patrol’s hours be increased, at
least to cover the hours that the boat launch is open on weekends
and holidays.
The recommendations include actions the City could take to
improve facilities available to boaters and thus make it easier to
comply with the fueling, bilge dumping and other waste related
issues.
It also is recommended that a boating education program be
developed to promote voluntary compliance with laws and BMPs.
How many of these boaters use the Bloedel-Donovan launch.
As reported in the Water Source Protection Plan (2000), in past
years, the Bellingham Parks and Recreation Department charged
during the boating season for weekend and holiday use of the
Bloedel Donovan Park boat launch. During that time, Parks
employees counted the number of vessels using the launch. Parks
was able to provide data for weekend and holiday launches from
Memorial Day to Labor Day 1986 (800 launches), 1998 (2156), 2000
(1375), and part of 2001 (Memorial Day through July 20, 525
launches).
In 2001, the Parks Board decided to discontinue the practice of
charging for parking and use of the boat launch.
8. Does the fact that manufacturers of personal watercraft using 2-stroke
carburated engines will eventually phase them out, have anything to do
with these craft not being used in the Reservoir now?
The Environmental Protection Agency (EPA) established a new
standard for marine engine emissions in 1996. This standard
requires marine manufacturers to achieve a 75% reduction in
outboard and personal watercraft (PWC) engine hydrocarbon
emissions by the year 2006. Although this standard is designed to
improve air quality, they also result in engines that produce
significantly less water pollution.
The California Air Resources Board (CARB) decided that the EPA’s
standard was not sufficiently strict and was being implemented too
slowly. As a result, CARB accelerated the EPA timeline and set
stricter standards for new marine engines sold in California. The
CARB standard requires manufacturers to meet EPA 2006 standards
by 2001 and to produce 65% lower emissions than the EPA standard
by 2008, for a total of 91% lower emissions than carbureted twostroke engines. Because California has such a large share of the
marine engine market, manufacturers are designing their engines to
meet the stricter CARB limits.
Because PWC engines are subject to the same restrictions as other
marine engines, manufacturers are developing PWC with four-stroke
and two-stroke DFI technology to reduce emissions. The new twostroke engines are lighter and simpler in design than four-stroke
engines, and some are almost as clean.
This does not mean that two-stroke carbureted PWC will not be
manufactured after 2006. The EPA allows product averaging, which
means that the “Family Emission Limit” (FEL) must meet or exceed
applicable emission standards. This means that some two-stroke
carbureted PWC will continue to be manufactured as long as their
higher emissions are offset by other low-emission members of its
engine “family.”
Neither the EPA nor CARB require boaters to dispose of carbureted
two-stroke engines. The EPA estimates that old engines will no
longer be used by the year 2050.
The CARB has estimated that the exhaust emissions from operating
a PWC for seven hours is equivalent to the emissions from a 1998
passenger car operated for 100,000 miles. This means that one
hour of PWC use generates as much air pollution as one year of
automobile use. Because carbureted two-stroke engines exhaust
through water, the pollution is received directly by the water body.
9. Recognizing the City's rationale for 'limiting its liability' by avoiding any
sort of fee or permit system per RCW, what can be done to actually prevent
or measurably mitigate any of the careless boating practices, short of
closing the launch to watercraft using internal combustion engines? Note
this is already City policy at Lake Padden.
The recommendations from the Motorized Watercraft Citizens
Advisory Committee and the Lake Whatcom Management
Committee include actions to change poor boating practices.
Provision of a fueling area and a bilge dump facility are examples of
very positive actions that the City can take to mitigate polluting
activities.
10. Aside from the benzene spikes [public health issue] being discussed
most prominently, what other concerns drive this discussion? [e.g.
public/personal safety, nuisance & noise, the message conveyed by
increasing unbridled use of a valuable and essential public resource for
private recreation purposes]
Although other issues associated with boating practices were
recognized by both the Citizen’s Advisory Committee and the Lake
Whatcom Management Committee, neither Committee made
recommendations based on those additional issues.
11. What regulations are relevant to the recommendations? (Added)
Both the State and City already prohibit the deposit of petroleumbased products into water, although neither regulation specifically
refers to exhaust of such products into water.
RCW 90.48.080 states:
Discharge of polluting matter in waters prohibited.—It shall be
unlawful for any person to throw, drain, run, or otherwise
discharge into any of the waters of this state, or to cause, permit,
or suffer to be thrown, run, drained, allowed to seep or otherwise
discharged into such waters any organic or inorganic matter that
shall cause or tend to cause pollution of such waters according to
the determination of the department, as provided for in this
chapter.
In addition, section 10.60.100 of the Bellingham Municipal Code
states:
Deposit In Water Prohibited.—A. No person shall throw or deposit
litter in any fountain, pond, lake, stream, bay, or other body of
water in a park or elsewhere in the City of Bellingham. B. No
person shall pour, allow to drain, discard, or otherwise introduce
motor oil and other petroleum-based products, antifreeze, paint,
or any other unauthorized substance including solid materials
into any surface water drainage course or body of water,
including but not limited to lakes, ponds, streams, creeks, storm
water catch basins, storm water detention ponds, ditches, and
storm water inlets, culverts, and manholes.