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• Mav 87 1999 15:89:32 Via Fax -> Mr. Michael Miller Page 881 [If 882
Visit our Web site at
www_awwa.orgrwaterweek
for daily headline news.
Volume 8 No.19 American Water Works Association • Dedicated to Safe Drinking Water May 7, 1999
Judge claims discretion Data lacking on water sector Y2K status
to consider options Lack of information on the Y2K readiness of US water and wastewater
for SWTR compliance utilities has led federal investigators to press for expanded public
disclosure of status information,including suggesting legislation to
A federal district court judge for the require facilities to tell their Y2K status by September.According to a new
District of Massachusetts has slated an Government Accounting Office survey of EPA,state,trade association
October 14 evidentiary hearing to con-
sider whether filtration is the only and utility activities on the Y2K front,lack of EPA and state demands for
remedy for systems that fail to meet systems to report their status and weak responses to surveys by industry
the Surface Water Treatment Rule's fil- associations makes it difficult to assess and manage the related public
tration-avoidance criteria_ health risks.
Ruling on an EPA motion for sum- Released this week(www.gao govfdaybook/990506.htm),the report
mary judgment to order the Massachu- notes that EPA lacks the power and does not have time to develop rules to
setts Water Resources Authority to require systems to report their Y2K status and"only a handful"of state
filter its surface water supply, US Dis- regulators believe they are responsible for ensuringY2K readiness.GAO
trict Court Judge Richard G. Stearns listed only two states—Colorado and Minnesota—as having taken a
'this week found that MWRA has failed proactive stance on assessing system readiness and providing compliance
to meet the avoidance criteria and a guidance.GAO notes that a late-1998 water industry survey of 4,000
state-issued waiver is "ofaino effect." operators generated only 725 responses,about half of which indicated
But he rejected EPA's claim that filtra they had completed pleted assessments of their internal systems.AWWA,the
tion is therefore mandatory, asserting
that the SDWA judicial enforcement Association of Metropolitan Water Agencies and the National Association
provision [42 USC, Section 300g-3(b)j of Water Companies will send a follow-up survey out this month,with
does not limit the court "to mechanical results due back in July(call Jon DeBoer at 303-347-6187 for details).
enforcement of EPA compliance
orders." Tigard opts for Willamette River supply
He wrote: "Why Congress might
not have wanted to eliminate judicial The Tigard,Ore.,city council on April 27 culminated months of study
discretion in ordering compliance and debate over how best to meet long-term public water needs by
with the SDWA is not difficult to unanimously voting to treat Willamette River water rather than buy water
imagine. Technology evolves more from Portland-With sonic council members claiming this was their most
rapidly than typically does legisla- important council decision for the city as well as the region,the panel
tion, and there is inherent danger in gave a big boost to constructing a$42.7 million filtration/ozonation plant
attempting to legislate today's sci- by 2002 that could wind up serving nearby cities of Sherwood,
ence as the foreordained solution for Wilsonville,and Tualatin as well as customers of the Tualatin Valley
tomorrow's problems." Water District.
The hearing will focus on whether Sherwood,Tigard,Tualatin and the TVWD are members of the
MWRAs watershed protection/ozona-
tion/pipe rehabilitation plan `Shrill better Willamette Water Supply Agency.The treatment plant would be built in
serve Congress's objective of pro Wilsonville,which last year restricted building in the face of a water
viding`maximum feasible protection of shortage and is slated to decide in June whether to support the facility.
the public health' than will EPA's insis- WWSA expects the other three member agencies with an interest in the
tence on filtration." plant to decide by this fall whether to join the effort and how to establish
ownership and funding structures.
immiammommimmiamommi This issue sponsored by MIOX Corporation limommokkommomisms
Move up to water by...
®THE LEADING TECHNOLOGY FOR WATER DISINFECTION EQUIPMENT
tel: (505) 343-0090 • email: info@miox.com • website: www:rniox.com
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May 87 1999 15:18:25 Via Fax -> Mr. Michael Miller Page 882 Of 88Z
May 7,1999,
Hot topics concentrations,testing time cut to about four hours and
cost-savings from being able to measure the presence of
PUBLIC NOTICE RULE.EPA is expected to dozens of microorganisms in a single test.UWS,
publish proposed revisions to SDWA public notice Lyonnaise and bioMerieux expect the method to be
regulations for public comment next week.EPA has operational upon completion of the pilot test.Call Olivia
already slated three public meetings to seek comment on Barberis at 404-253-3993 for details.
the rule and its companion handbook:May 26 in CRYPTO WORKSHOP.During a late-April
Madison,Wis.;June 3 in Washington,D.C.;June 8-9 in workshop sponsored by the EPA Office of Water's Office
Allentown,Pa.;and June 23-24 in Phoenix,Ariz.Call of Science and Technology,Cryptosporidium experts
Carl Reeverts at 202-260-7273 for details. discussed whether any species other than C.parvtun are
SOURCE PROTECTION.EPA has announced it is of regulatory concern under the SDWA.EPA opted to
seeking proposals by June 7 from state,local and tribal make the Interim Enhanced Surface Water Treatment
governments and non-for-profit community water systems Rule particular only to the Cryptosporidium genus,
and technical-assistance orIK nizatians for$2 million set giving scientists more time to assess whether any of eight
aside to help fund source-protection projects in small, other known species or strains are infective to humans.
rural or economically disadvantaged communities.As Experts at the April 29-30 meeting reviewed a report that
described in the May 6 Federal Register,EPA will divvy C.feria has infected an immunocompromised person,
up $1.625 million of the total among its ten regional which would be the first time a non-C.parvwn species
offices to allocate as they see fit and retain$375 million has been identified as a human pathogen.They also
for EPA headquarters to award to national,multistate or discussed how current technologies limit understanding
multiregion projects.Preference will be given to projects of its occurrence,the range of pathogenic species and
located within priority watersheds identified by states in route of disease transmission.Call Steve Schaub at'202-
their Unified Watershed Assessments developed under the 260-7591 for details.
CleanWater Action Plan.Eligible projects may support TOXICOLOGY.Mixtures of aldicarb,atrazine and
community source water assessment and protection nitrate in concentrations commonly found in
activities as well as stormwater,nonpoint source or wet groundwater can significantly influence neurological,
weather activities that help integrate groundwater immune and endocrine systems,according to the findings
concerns into watershed assessment/restoration plans, of a team of researchers at the University of Wisconsin at
support wellhead protection programs or help Madison.Published in the January-March issue of
communities considering new source-protection plans or Toxicology and Industrial Health, the report by Warren P.
ordinances.Contact regional offices or Evyonne Harris at Porter et al describes results of five years of assessing
EPA HO at 202-260-1399 for details. health effects on mice exposed to drinking water
ANALYTICAL METHODS.Consumers of Atlanta containing the corrtanunants at levels equivalent to their
city water learned today that the new contract operators current federal standards.In a UWM press release(at
of Atlanta's water utility will pilot test the first gene- wwwnews.wisc.edu/thisweek/researcbibio/y99/pesticide.
probe technology for detecting waterborne pathogens.In html),Porter says the"single most important finding of
a May 7 press conference in downtown Atlanta,officials the study is that common mixtures,not the standard one-
from New Jersey-based United Water Services and its chemical-at-a-time experiments,can show biological
French parent company Lyonnaise des Eaux announced effects at current concentrations in groundwater.
that Atlanta will be the sole US site for a two-year pilot RISK MANAGEMENT.Water systems that handle
test of the GeneChip array method being developed 2,500 lb or more of chlorine,10,000 lb or more of
under a$9 million development effort by Lyonnaise and anhydrous ammonia or 20,000 lb or more of aqueous
bioMerieux,one of the world's top biological diagnostic ammonia have until June 21 to submit Risk Management
companies(US office in St.Louis,Mo.).The technology, Plans to EPA as required under RMP provisions of the
developed for medical uses,works by matching up to Clean Air Act.For details,check the EPA's RMP Web
400,000 programmed genetic codes with the DNA site at www.epa.gw/swercepplacc-pre.html or call 800-
signature of microbial contaminants.Touted advantages 926-7337 to order an AWWA video(No.65151)and/or
include accurate identification of microbes even at low an AWWA Research Foundation report(No.90760).
WATERWEEK is published weekly by the American Water Works Association, 6666 W. Quincy Ave., Denver CO 80235.
Copyright® 1999 by AWWA. Distribution limited to recipient facility. Editor: Mark Scharfenaker. Phone: 303-347-6263. Fax:
303-794-7310. E-mail: mscharfeilawwa_org_ To subscribe call 303-347-6167. Internet site: http:ffr w_awwa_vrglwaterweek
Expanded reporting of selected stories in AWWA MAINSTREAM.
Y!a.Y—'d-99 FRI 09:O( AV: CITY OF 'Pi PUBLIC ;MAKS FAX:50368286616 PAGE 2
QUALITY ASSOCIATES, INC.
Review of Montgomery Watson Willamette River Monitoring Data
Executive Summary:
QUALITY ASSOCIATES, INC. (QAI),a consulting firm located in Columbia.
Maryland,conducted an independent evaluation of Willamette River monitoring data that
have been developed by Montgomery Watson.Americas, Inc.,Portland,Oregon,and
Montgomery Watson Laboratories,Pasadena,California,from July, 1998 through
February, 1999. This assessment was at the request of the City of Wilsonville,Oregon,
which is considering using the Willamette River as a potential source(after treatment)of
drinking water. The developed data were based on a work plan which called for periodic
sampling and analyses of a wide variety of organic and heavy metal contaminants and
microorganisms of concern, as well as routine water quality parameters.
The analytical findings were reviewed by QAI primarily from the standpoints of meeting
the work plan goals and overall quality,including achievement of stated detection limits
and conformance with quality control standards. Sampling data and related information
Please GROUTING REQI-J-E7psings,as described herein,QAI deems
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toreported data are of overall
HandleTa: ted detection limits. One target
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MAY-]4-99 FR] 09:00 AM CITY OF WV PUBIC WRKS FAX:5036823i'16 PAGE 3
Introduction:
At the request of the City of Wilsonville,Oregon,QUALITY ASSOCIATES,INC.
(QAI)conducted a independent review of Willamette River raw water monitoring data
developed by Montgomery Watson Americas,Inc.,Portland,Oregon and Montgomery
Watson Laboratories,Pasadena,California(hereafter both entities are referred to as
"Montgomery Watson")over the period July 1998 through February 1999 for the cities
of Wilsonville and Tigard,Oregon. The basis for the review was two documents
prepared by Montgomery Watson entitled Scope of Work for the city of Tigard
Willamette River Raw Water Monitoring Plan(hereafter referred to as the work plan)and
an interim report of findings entitled City of Tigard, Quarterly Report,March 1999
(hereafter referred to as the quarterly report). The former document spelled out the
overall scope of work to be performed by Montgomery Watson for the Willamette
monitoring project,including the proposed sampling schedule and the rationale for the
target analytical parameters. The quarterly report summarized the findings through
• February 34, 1999,as well as providing a number of explanatory notes regarding
sampling and reported findings.
The QAI review was based on review of photocopies of original sampling and analytical
data generated by Montgomery Watson and its analytical subcontractors. Due to time
constraints and the large volume of available data,only a portion could be examined by
QAI in any detail. Focus was given to review of all sampling information and analytical
data for organic compounds(including the dioxin,TCDD and pesticides)and heavy
metals,as these were deemed most critical from the standpoint of potentially harmful
contaminants in the river. Organic compounds and heavy metals were sampled and
analyzed for on three occasions on roughly a quarterly basis and,as part of the overall
review,an attempt was also made to evaluate representative sampling and analysis data
for all three events.
The classes of organic compounds reviewed by QAI included nitrogen and phosphorus
pesticides,chlorinated hydrocarbon insecticides,chlorinated acid herbicides,carbamate
insecticides, base-neutral acid extractable compounds,volatile organic compounds
(VOCs)and the ethylene dibromide group,as well as the individual•herbicides
glyphosate,endothall,linuron,diuron,paraquat and diquat. The heavy metal analyses,
including mercury were also evaluated Reported TCDD(a dioxin)findings were also
reviewed. All available sampling data were reviewed.
The Montgomery Watson and other associated analytical data were evaluated by QAI
with respect to: (I)Conformance with standard methodology(including meeting the
target parameter list and holding times);(2)achievement of stated detection limits;(33
meeting quality control(QC)parameters and associated acceptance criteria;and(4)the
overall level of documentation. Sampling data were evaluated primarily from the
standpoints of completeness and preservation.
It should be noted that,although included by Montgomery Watson as part of the quarterly
report,some the routine water quality parameter findings,such as alkalinity,ammonia, •
MAY-:4-99 FRI 09:01 AM CITY OF WV PUBLIC WRKS FAX:5036C28616 PAGE 4
hardness,total organic carbon(TOC),dissolved organic carbon(DOC)and several other
indicators, were determined directly for the City of Tigard,Oregon by AmTest Oregon
L.L.C.,located in Tigard. Underlying raw data and other records were not provided to
QAI for these determinations-only the analytical reports-thus a full assessment of
reliability could not be performed by QAI. It appeared from the reported fmdings,
however,that there may have been analytical problems with the determination of
dissolved organic carbon for samples collected during August and September.
Montgomery Watson subcontracted out the analyses of several organic compotinds,
including TCDD(a dioxin)to Quanterra Laboratories,Sacramento,California and the
herbicides linuron,diuron and oryzalin to North Coast Laboratories, Arcata,California.
Raw data were provided to QAI for all but the oryzalin determinations and the reported
results were determined to be supportable. Radionuclide analyses were also
subcontracted to another Quanterra analytical facility in Richland,Washington,however,
these data were not further reviewed by QAI beyond verifying the findings given in the
quarterly report were consistent with the individual Quanterra reports.
In summary,in spite of some noted deficiencies,primarily the need for an enhanced level
of underlying documentation,the organic compound and heavy metal results,as reported
by Montgomery Watson in the quarterly report was deemed acceptable by QAI for their
stated purpose. Several targeted organic compounds and one heavy metal that were not
analyzed for during the first three quarters of monitoring will be determined during the
next sampling event.
Specific Findings:
Sampling
Documentation of Willamette River sampling events was provided by Montgomery
Watson primarily through notebook entries,Chain of Custody records and sample
container order forms. Sample receipt at the laboratory was documented for each
shipment by Montgomery Watson Laboratories(Pasadena,California)through a standard
Acknowledgement of Samples Received form. This form,a copy of which was returned to
the Portland based Montgomery Watson sampling staff,also listed(for verification
purposes)the various analyses to be performed for the particular sampling event. The
sample container order forms provided documentation that the appropriate preservative
had been added- The only noted deficiency was that it could not always be verified -
through available records if the samples were shipped to the laboratory on ice,as
required,and whether the samples were still in chilled condition when received.
Review of these aforementioned records for the period August 12 through January 26,
1999 revealed that the work plan goals for weekly,monthly and quarterly sampling and
associated parameters were largely met,even though the collection events did not occur
precisely at weekly,monthly and quarterly intervals. Sampling during the target
quarterly low and high water periods was met. According to Montgomery Watson
I
MAY-14-99 FR] 09:01 AM CITY OF V PUBLIC WRKS FAX:5036828616 PAGE 5
records,several planned weekly sampling events in late December, 1998 were missed
due to storm damage at the intake point and one weekly sampling was missed due to a
faulty sampling pump. These problems should be considered normal for such a large and
lengthy project and appear to have only affected the weekly sampling for routine water
quality parameters and resulted in short delays in the December determination of the
parasites giardia and cryptosporidium.
Of significance is the fact that,according to the available records, the target quarterly
sampling for pesticides and other organic compounds,heavy metals, radio-nuclides and
viruses were met and reflect occurrences of both low and high water flows for the
Willamette.
In summary,although some weekly target sampling dates for routine water quality
parameters were not met due to storm damage and equipment failure,the work plan goals
of the more critical monthly and quarterly sampling events were met. Necessary
preservatives were recorded as having been added to the sampling containers,and
although not every custody sheet reflects the presence of ice,this record keeping lapse
appears to have been due to oversight by Montgomery Watson.
Holding Times
The term"Holding Time"refers to the periods of time between sample collection and
initial extraction and the time between the extraction and final determination. Only the
holding times for organic chemical(including pesticides and dioxin)were evaluated as
part of the QAI data review. Montgomery Watson acknowledged in their quarterly report.
that holding times had elapsed on two occasions(for the August 12, 1998 and November
2, 1998 sampling dates)for determination of nitrogen-phosphorus(NP)pesticides.
Review of the Montgomery Watson data revealed that on both occasions the subject
Willamette River water samples were extracted and analyzed within the required time
frames,however,the holding times for other water samples from non-related locations
were not met,thus the entire original sample set appears to have been rejected.
The August and November, 1998 samples for the determination of nitrogen—phosphorus
pesticides were collected again by Montgomery Watson in September and December of
1998,respectively. Analyses of these additional samples,as well as the originally
collected samples for both months,resulted in no detectable nitrogen-phosphorus
pesticides. No other holding time problems were apparent from the data reviewed.
Scone of Analysis
The overall scope of analyses for this project is presented in the work plan and the
specific compounds(or groups of compounds),elements and/or organisms targeted for
analysis are also spelled out in the quarterly report. The quarterly report also cites in the
General Notes section that EPA approved(or other acceptable)methodology is currently
4
MAY-14-99 FRI 09:02 AM CITY OF Uri PUBLIC '+`i'RYS FAX:5036828816 PAGE 6
not available for a number of the target compounds or elements. Communication with
Montgomery Watson staff indicated that methodology and laboratory capability are now
available for the metal vanadium,the pesticides terbufos and pronamide,and the
commercial chemical nitrobenzene. These will be analyzed for in the next quarterly
sampling. Adequate EPA or other.Montgomery Watson analytical methodologies
currently do not exist for three other target organic compounds(all herbicides), i.e.
bromoxynil,propanil and MCPA or specific microbial contaminants on the EPA
Candidate Contaminant List.
Analytical Methodology
Review of the available raw data and records revealed that Montgomery Watson(and its
contract laboratories)used the appropriate methodology to analyze for the various target
parameters identified in the work plan and as cited in the quarterly report. To the degree
possible,particularly for organic compounds and heavy metals,standard U.S.
Environmental Protection Agency(EPA)or EPA recommended analytical methodologies
were cited as having been used by the laboratories. Some modifications were
documented in the data,such as changes in sample and extract volumes, additional(or
changes in)surrogate(quality control)compounds and changes in reference standard
dilutions. These changes were deemed by QAI to not have had a significant impact on
the performance of the method or the quality of the reported findings.
Detection Limits
Since most of the analytical results for organic compounds (including pesticides and
dioxin)and heavy metals were reported as"Not Detected"or"ND"at the method
detection limit(MDL)or considerably below the EPA Maximum Concentration Limit
(MCL),the accuracy of these reported ND findings are deemed significant For all
organic compound and heavy metals analyses reviewed,the detection limits were
determined to have been accurately reported,based on the factors of initial sample size,
final extract volume,lowest reference standard concentration and fortified sample
recoveries.
A positive values for the herbicide simazine during the August 12, 1998 sampling date
and a positive result for the organic solvent,dichloromethane,for the November 2, 1998
sampling event are discussed in the Montgomery Watson quarterly report and the
circumstances and explanation were deemed to be plausible.
MAY-14-99 FRI 09:02 AM CITY OF WV PUBLIC 4YRKS FAX:5036628816 PAGE 7
unlit Control
Quality control (QC)related analyses are normally conducted in conjunction with each
set of determinations to verify the reliability of the analyst and the utilized
instrumentation,as well as verifying that there are no other significant negative factors
entering into the use of the prescribed analytical method. These determinations include
analysis of method and reagent blanks to verify absence of potentially interfering
substances from reagents,solvents and/or laboratory ware,and verification of acceptable
accuracy through determination of recoveries derived from analysis of representative
samples fortified with compounds of interest. Recoveries of specified representative
compounds fortified into the actual samples(called"surrogates")of interest also yield an
indication of method and analyst performance. A reference standard response
verification for extended analytical runs is required of most EPA methods,and a specially
prepared laboratory evaluation sample is required to be periodically analyzed for some
EPA methods to allow determination of instrument performance.
Review of a representative portion of the Montgomery Watson data for the organic
compound and heavy metal results cited in the quarterly report indicated that both the
level of quality control(QC)and the QC results themselves were adequate. The level of
QC determinations with some minor exceptions,were consistent with method
requirements and sound laboratory practice. Upon review,one negative QC result for
TCDD(a dioxin)mentioned in the General Notes section of the quarterly report was
found to be in error, probably due to a report writing error;there appeared to be no low
recovery of TCDD,as stated.
On a few occasions QC results were observed to be slightly outside the stated
acceptability criteria(e.g.organic phosphorus pesticides for January 27, 1999 sampling)
with no laboratory comment or repeat analysis and,on at least one occasion(e.g.
chlorinated hydrocarbon pesticides for November 2, 1998 sampling),the laboratory
evaluation sample was analyzed,but the results were not calculated or otherwise .
reported. Visual inspection of the chromatographic data indicated no particular problem
in this case,however.
Analytical Documentation
The level of documentation,i.e.the recorded raw data necessary to reconstruct what was
actually performed in the laboratory,by whom and when,is necessary to allow full _
reconstruction of procedures used and to verify the findings and conclusions given in the
analytical report. Although data were reasonably complete for some Montgomery
Watson analyses,such as for chlorinated hydrocarbon pesticides,acid herbicides and
nitrogen-phosphorus pesticides, such information was lacking for the determination of
carbamate pesticides,the herbicide glyphosate and the ethylene dibrornide group. Other
determinations are supported by some level of documentation between these two
extremes. In some cases,only the internal standard solution is not identified and in other
instances the fortification solutions and/or levels are not specified. In each case where
documentation was lacking it was assumed that the cited analytical method was follower!.
6
MAY-14-99 FRI 09:O3 AM CITY OF WV PUBLIC WRKS FAX:5036826816 FACE S
In summary,there is definite room for improvement in the level of documentation and its
attribution being provided by Montgomery Watson to support their analytical findings.
QAI will provide advice to the Montgomery Watson Laboratory with respect to
enhancing their overall level of documentation, particularly for analyses conducted in
support of the next Willamette River sampling event_
Report prepared May 13,1999 by: •
Dean F.Hill,Senior Consultant
QUALITY ASSOCIATES,INC.
9017 Red Branch Road,Suite 102
Columbia,Mi) 21045
TX:410-884-9100
PLEASE REGISTER
DATE: May 24, 1999
MEETING: Tigard Water District Board Meeting
NAME - (Please Print) (Do you wish to sneak?)
Yes or No
kathv\\visitor
DSS
DAVID S. STRAUSS
16418 S. W. 129th Terrace — Tigard, Oregon 97224
Phone(503)598-4602
Email: daomi@aol.com
May 24. 1999
Members of Tigard Water District Board:
Last year at budget time I pointed out that State Statutes called for three year rotating terms for
budget committee members. This was found to be the case. The reason, obviously, is to give the
board a certain amount of experience and consistency from year to year.
This year when the budget committee was selected, these statutes were ignored. Four of the five
members are new to the committee, while some members of last years committee were not
approached to serve for a second year. In addition, one of the new committee members called
me when he received his materials to tell me he had never agreed to serve!
I request it be recorded in the minutes that I strongly object to the methods used this year and
insist e ,olio- 't State Statutes governing our actions in the future.
Pr
David Strauss
Board member
Tigard Water District