M70517 117570117 7 7'0 ape/60? Wufaa mm 523 1102117 1.. V5 110000100000 - 6 1 My? 57? 7 0.0000 0.0000 00000 0.0000 10.2301 20.7070 27.0400 27.0070 23.0720 24.0440 130.0000 0201002030 1 2017 00500009999 00000 00000 00000 0201002030 I 2017 I . . 0.0000 0.0000 {353,427 75? OEEWE 0.0000 PROPOSED 2017 1 1075100122000 1/516 2?4 0 0.0000 00000 00000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0201014057 2017 0000005057 10.0100 17.0010 10.1050 10.5750 20.0070 22.0720 12.4100 13.3020 10.0120 10.0000 15.0340 11.0140 210.0500 2000005150 1 2017 WSWL05000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2000005400 2017 wsw:.05040 31.4070 27.0010 20.0100 31.7100 32.7040 37.4200 10.0110 7.1420 0.0000 0.0000 0.0000 0.7000 224.7000 2000000700 2017 2017 Maw WM SQ 28.2210 23.8810 26.3500 26.5970 28.7300 31.9270 165.7060 E201602930 2018 V5.34) WSWL122009 I 6 1! 1.0520 0.0000 0.0000 0.0000 0.0000 0.0000 1 1.0520 E201514657 2018 . WSWL65857 15.7340 13.6390 15.4310 15.2730 16.0900 16.3170 92.5340 2800005150 2018 - WSWL65940 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 2800000769 2015 2018 ?My? ,wm 51/571910 SINCE. Page 2 of 2 Exhibit 4.2:  Recommended Checklist to Support Determination of the Need for a CCT Study To be completed by:  Primacy Agencies Purpose: To help the Primacy Agency decide whether or not to require a corrosion control treatment (CCT) study for systems  serving 50,000 or fewer people and to document their decision. If "yes" answers are given for more than two questions, the  Primacy Agency should consider requiring a study. EPA recommends that the Primacy Agency require a CCT study for all  systems that have lead service lines. Category Question Response (YES or NO) Presence of LSLs Does the system have lead service lines?1 pH stability Is the range of pH values measured at the entry point > 1.0 pH units.  Yes., 6.98 to 8.85 ( May  (Range = max entry point pH – min entry point pH)? 2018) Is the range of pH values measured in the distribution system > 1.0  No., 7.1 to 7.9 ( 3/06/2018) pH units. (Range = max pH – min pH)? NO Is average entry point iron > 0.3 mg/L? No, 0.125 mg/L Is average distribution system iron > 0.3 mg/L? No., 0.125 mg/L Is average entry point manganese > 0.05 mg/L? No, 0.0245 mg/L Is average distribution system manganese > 0.05 mg/L? No, 0.0163 mg/L Iron Deposition Potential Manganese Deposition Potential Calcium Carbonate Deposition  Potential Chloride/Sulfate Mass Ratio Issues Source Water Changes in the Future Treatment Process Changes Is average hardness > 150 mg/L as CaCO3? Entry point of distribution  No, 40 mg/L average system values may be used. Is the chloride/sulfate mass ratio (CSMR) for either entry point or  Yes 10.7mg/L/4.8 mg/L or  distribution system data > 0.6? Use average chloride level divided by  2.23 the average sulfate level. Yes, Emergency water  Did the system indicate that there may be source water changes in  connection with either  the future?  Aqua or NJAWCO. Did the system indicate that there may be treatment process changes Yes, Klenphos 400 vs.  in the future including changes in coagulant?  current Klenphos 300 1  If the system has lead service lines, EPA recommends the Primacy Agency to require a study. Primacy Agency Decision:  Is CCT  Study Required? (Yes or No) OCCT Evaluation Templates for ≤ 50,000 1 9/19/2018 Mail - Bordentown Water Follow-Up Questions Bagenstose, Kyle Bordentown Water Follow-Up Questions Hajna, Larry To: "Bagenstose, Kyle" Wed, Sep 5, 2018 at 4:03 PM Thank you for sending. I have some follow-ups I would appreciate your considering. My deadline for this story has been extended to next Wednesday, 9/5, at 3 p.m. 1. Respectfully, I do not believe your initial responses answered several of my questions. My questions were not whether water quality parameter testing was conducted due to lead exceedances or a change in water source. I know that it was. My questions were whether or not NJDEP made assessments of water quality based on that data. The questions again below: A. Has NJDEP made a determination of whether or not water quality data taken from 12/20/2017 to the present day indicate the water corrosive? Based on the lead action level exceedances, Bordentown’s corrosion control treatment at the time of the action level exceedances was not optimized for corrosion control for lead and copper; as pH fluctuated between 6.98 and 8.85 and a chloride to sulfate mass ratio was above 0.6. Therefore, the approved Corrosion Control Treatment Recommendation will optimize /adjust the pH (7.2-7.8) for the inhibitor to be most effective. B. Did the NJDEP perform any analysis as to whether or not the new water well brought online in summer 2017 would potentially impact the corrosivity of the system's drinking water? Well No. 2A is a replacement for Well No. 2. Well No. 2 was replaced due to its age and declining capacity. Well No. 2A was drilled within 100 feet of the existing Well No. 2, within the same Lower PRM aquifer at approximately the same depth and pumped at an equal diversion rate of 1,000 gpm. There were no changes to the existing treatment process as the water quality of Well 2A was similar to the other existing wells which are all located in the same Lower PRM aquifer. As required for a new well source, NJDEP performed sampling to evaluate the Primary and Secondary Drinking water standards. 2. I am attaching a document that appears to be an OCCT Evaluation Template for the Bordentown Water System as of late June, 2018. In the second tab, 4.2 CCT Study Checklist, there is a row for "Chloride/Sulfate Mass Ratio Issues." In the response section, the system is marked as having a ratio of 2.23, which is highlighted yellow due to it being above >0.6 on the CSMR scale. Questions: A. Was this CSMR calculation filled out by NJDEP personnel? No, this was completed by Bordentown Water Department B. If so, where did the data come from (ie 10.7 mg/l for chloride and 4.8 mg/l for sulfate)? Bordentown WD C. In your initial responses, you wrote that if CSMR is above "recommended levels" the DEP would evaluate it as part of a CCT recommendation. What is the recommended level and if it is 0.6 what has the NJDEP done to address CSMR issues in the Bordentown system? Regardless whether CSMR or DIC is utilized, the conclusion drawn for this particular system for corrosion control was the utilization of an inhibitor (Klenphos 400) and the optimization of the pH. D. On the sheet it notes that if there are 2 or more "yes" answers, the EPA recommends a CCT study. There appear to be 4. Has a study been recommended? Based on the actions to be taken as part of Bordentown’s Corrosion Control Treatment Recommendation, NJDEP did not require a CCT Study. Bordentown WD proposed the addition of a corrosion inhibitor (Klenphos 400 containing an orthophosphate component) and optimization of their existing pH adjustment process which is currently being implemented. https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165ab54e01e5bc32&q=H… 1/3 9/19/2018 Mail - Bordentown Water Follow-Up Questions 3. In the third tab of the document, "4.4 study type checklist," NJDEP appears to fulfill the criteria to move on to question 4, which is does the system serve 10,000 people or fewer. The answer is marked "yes." However, on the NJDEP Water Watch website, the system is listed as serving nearly 16,000 people. A. How many people does the Bordentown Water System Serve? This section was completed by Bordentown WD as part of their CCTR submission, not NJDEP staff. Based on data provided in NJDEP’s Drinking Water Watch, Bordentown WD serves 15,821 people. B. If greater than 10,000, has the NJDEP decided to require a demonstration study, per EPA recommendations? {See response to 2D above.} 4. Why did NJDEP recommend/approve the use of an orthophosphate (Klenphos 400) to Bordentown? Bordentown’s submitted Corrosion Control Treatment recommendation as part of the lead action level exceedance was approved by NJDEP in coordination with guidance provided in EPA’s Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primary Agencies and Public Water Systems. A link providing more detail is available at https://www.epa.gov/sites/production/files/2016-03/documents/occtmarch2016.pdf 5. Understood that NJDEP primarily relies on DIC to assess corrosion control treatment. What was the calculated DIC for the water system from WQP testing following the Dec. 2017 and June 2018 lead exceedances? {DIC based upon data provided was 6 – 7.} -Kyle Lawrence Hajna New Jersey Department of Environmental Protection Press Officer (609) 984-1795 NOTE: This E-mail is protected by the Electronic Communications Privacy Act, 18 U.S.C. Sections 2510-2521. This E-Mail and its contents, may be Privileged & Confidential due to the Attorney-Client Privilege, Attorney Work Product, and Deliberative Process or under the New Jersey Open Public Records Act. If you are not the intended recipient of this e-mail, please notify the sender, delete it and do not read, act upon, print, disclose, copy, retain or redistribute it. https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165ab54e01e5bc32&q=H… 2/3 9/19/2018 Mail - Questions following meeting Bagenstose, Kyle Questions following meeting City of Bordentown To: "Bagenstose, Kyle" Fri, Aug 17, 2018 at 5:45 PM Good Evening Kyle, On behalf of Commissioner Myers, below please find answers to your questions at this time. If you wish to discuss anything in further detail, please feel free to give Commissioner Myers a call or forward them in an e-mail. Your patience and cooperation with the City as we move forward addressing the water quality issue for our customers is much appreciated. Thank you. Grace I. Archer, RMC, CMR Municipal Clerk/Registrar City of Bordentown 324 Farnsworth Avenue Bordentown, NJ 08505 Ph: 609-298-0604 Fx: 609-298-8467 Email: btownch@cityofbordentown.com This e-mail message from the City of Bordentown is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Further, be advised that the City of Bordentown is subject to the New Jersey Open Public Records Act and as such, any e-mail sent or received by the City may be subject to a records request. From: Bagenstose, Kyle Sent: Thursday, August 16, 2018 10:23 AM To: City of Bordentown Cc: Joe Myers Subject: Re: Questions following meeting [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=16549dc4097bf5d4&q=%… 1/3 9/19/2018 Mail - Questions following meeting [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] 1. Sampling data for lead at the interconnection for Fieldsboro. Would you be able to provide whatever results you have dating back to and including 2016? I have attached the sampling results that were taken at the interconnection site with Fieldsboro Borough. This type of sampling at the interconnect is not a “norm” and I do not have prior results. 2. Sampling data for lead in effluent from the sewer plant. I know last night we said perhaps the best way to do this would be to just call them. I'll also do that, but just wanted to clarify that I would like to see the actual sample numbers, also dating back to 2016. Richard Eustace, Director of the Bordentown Sewerage Authority, has supplied you with this information. 3. The takeaway I got from the the treatment plant faucet discussion is that the faucet is used as the point-of-entry sample point, but may not be indicative of the actual water quality since it involves piping and fixtures. Can you say definitively whether or not the city believes the 6.9 ppb lead level came from the pipe/fixture and not from the water? Most newer (not all) faucets come with a certification NSF 61/9-G on the box which is important to check when purchasing, which means they comply with current lead levels to be used in fixture. During the meeting one of our employees stated that the faucet was recently replaced with a new unit and it is unclear whether the unit had the NSF 61/9-G rating. At this time I would refrain from speaking in “definitive”, however, I will comment that Mr. Walls as well as our Water Engineer and the City, are confident with the quality of water coming from the wells and processing through the plant and into the distribution system. 4. Following that, my notes are that you said last night the city would look into different means to sample the water leaving the plant in order to assess water quality. Would appreciate any specifics on if/how the city will do this? At this time I do not have any specifics to provide to you. John Walls, our licensed operator, is working with NJDEP and our Water Resource Management company to determine if this can be implemented and what the process may be. 5. It was mentioned last night that new groundwater wells were drilled but that the water quality is believed to have been better than the old wells. Could you provide more information about when and where these new wells were drilled, when they were brought online, and how much water they contribute compared to the total gallons per day? The wells, based on testing results, eliminated the need for iron and manganese treatment; eliminating this treatment results in better water quality. Included is Addendum A from the water allocation permit which provides additional information. 6. Could you also provide the most recent lead tests from each of the wells used for the water supply? I need to confirm with John Walls that we do have testing result records for this and if so, he can pull these records and I will get those results to you next week. 7. I asked a question last night that I don't think was answered, which was whether or not the water department's engineers have evaluated water quality data to see whether or not the water may have become more corrosive in 2017 compared to years prior. Has the city made such an evaluation, and if so what parameters were examined (pH, alkalinity, calcium, etc.) and what did it find? The water quality of the new wells vs the original wells was reviewed. Our Water Engineer has provided the information below to assist in answering this question. Well 1 Original Well (Still Active) Well 2 Original Well Decommissioned Replaced with 2A Well 3 Original Well (Still Active) Well 5R Well 2A New Well New Well ( Back up to Well 5 R, only used once in January 2018 for one day) https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=16549dc4097bf5d4&q=%… 2/3 9/19/2018 Mail - Questions following meeting Total Iron Total Manganese Total Calcium 0.133(mg/L) 0.842(mg/L) 0.689(mg/L) 0.0461(mg/L) < 0.10(mg/L) 0.015 0.015 0.29 0.0233 0.031 2(mg/L) 1.186(mg/L) 1.593(mg/L) 4.47(mg/L) 3.1(mg/L) <4.2 <4.2 5.81 5.39 pH Total Dissolved Solids 38(mg/L) 40(mg/L) 28(mg/L) 49(mg/L) 63(mg/L) Alkalinity 3 ND ND ND <5 Iron and manganese since the original plant was an iron removal plant, exceed the 0.60 mg/l sequestering level. New wells are below this level and treatment was no longer required but sequestering Klenphos 300 still used since it is also listed by NSF as a corrosion inhibitor, and has been used for years. Alkalinity levels were equal to the original wells and adjusted by the use of Lime pH adjustment. Calcium levels in the new wells were higher than the previous wells. pH levels in the original wells were lower than the new wells by at least 1 pH unit Alkalinity to be raise by the addition of lime as a pH adjustment. WQP results show an increased to an average 25 mg/L and calcium raise to on average of 14 mg/L NJDEP Water Watch has a table of the corrosivity testing leaving the plant. Well 5R was placed into service and pumped into the system, July 2017 the level was reported as -1.19 mg/l. in August 2017 Prior to this it was recorded to be on average -1.95mg/l, reaching levels down to -2,2 mg/L . Therefore, the level of corrosivity has gotten better than previous years. [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] 2 attachments L7054575.pdf 981K back up bct questions.pdf 710K https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=16549dc4097bf5d4&q=%… 3/3 9/19/2018 Mail - Follow up from Tuesday meeting regarding past testing Bagenstose, Kyle Follow up from Tuesday meeting regarding past testing City of Bordentown To: "Bagenstose, Kyle" Fri, Aug 17, 2018 at 1:19 PM Kyle, With regard to your questions of Mayor Lynch following the public hearing on July 31, please find his responses listed below. Thanks and have a great weekend! Grace I. Archer, RMC, CMR Municipal Clerk/Registrar City of Bordentown 324 Farnsworth Avenue Bordentown, NJ 08505 Ph: 609-298-0604 Fx: 609-298-8467 Email: btownch@cityofbordentown.com This e-mail message from the City of Bordentown is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Further, be advised that the City of Bordentown is subject to the New Jersey Open Public Records Act and as such, any e-mail sent or received by the City may be subject to a records request. From: "Bagenstose, Kyle" Date: August 2, 2018 at 4:08:06 PM EDT To: JAMES LYNCH Subject: Follow up from Tuesday meeting regarding past testing Mayor Lynch, Following up on the meeting from Tuesday, specifically regarding your comments on past testing. Would appreciate your consideration and response to the following: https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=16548e82930bf617&q=ly… 1/3 9/19/2018 Mail - Follow up from Tuesday meeting regarding past testing 1. A resident asked why lead levels were suddenly being seen in 2017/18 and not prior years. You answered that you believed those homes might always have had lead levels, but were just recently discovered. Does this mean you believe residents in these homes could have been exposed to elevated lead levels dating back years but the past testing missed it? My statement was merely speculating that there may have been issues, but there is nothing concrete to determine that lead issues existed then. The City can only act upon what is known in the present and not the unknown of the past and we are doing our due diligence in investigating, providing for public education efforts and working with officials of the NJDEP to take all measures necessary to insure that good, quality water is provided to the City, Township and Fieldsboro by our Water Utility. 2. I believe you said you have not read our newspaper coverage. I would urge you to read our second report, in which I reviewed and organized every lead sample taken by the city back to 2000. I provided an Excel file containing the data to commissioner Myers and will also attach it to this email. I noted that several homes (which I will paste below) have been tested in recent years and did not show elevated levels of lead. 16 W. Constitution (2018 19.9 ppb, 2016 1.6 ppb) 19 Charles Bosset (2017 43 ppb, 02,03,07: 0 ppb) 2 Cemetery Lane (2018 64 ppb, 13: 0.2 ppb, 10: 0.4 ppb) 20 Crosswicks Street (2017 360 ppb, 2016 1.5 ppb, 2007 26 ppb) 211 Crosswicks (2017 24 ppb, 2010/13/16: 0 ppb) 231 Spring Street (2017 130 ppb, 2010 0.2 ppb) 234 Spring Street (2018 34 ppb, 2016 0.2, 2013 0 ppb) 30 E. Union Street (2017 32 ppb, 2013 0.3 ppb) 415 Oliver Street (2017 34 ppb, 2013 0 ppb, 2010 0.3 ppb) 46 Thorntown Lane (23 ppb 2018, 2013/16 0 ppb) 53 Vine Way (2017 19 ppb, 2016 0.3 ppb, 2013 0 ppb) 63 Park Street (2017 27 ppb, 2013 0.3 ppb) 7 Homestead Avenue (2018 47 ppb, 2016 0.7, 2013 0.1) 7 Walnut Street (2018 51 ppb, 2013/16: 0 ppb) You mentioned that you believe a possible explanation was that the samples taken from prior years were flush samples. Could you check and confirm whether or not the prior tests were flush samples? The chain of custody reports would have to be pulled for each location to ascertain what type of sampling was completed, if noted. I believe at this point, however, our efforts have been concentrated on resolving this issue and moving forward to assist our customers in identifying and/or correcting the causes for the leeching of lead from internal plumbing into the water they are consuming. 3. It was said at the meeting that the city has had no lead issues for 25 years. The data here, as well as the NJDEP website shows there was an official lead exceedance in 2000. Is this correct? When I was speaking, I was referring to the Consumer Confidence Reports that Commissioner Myers had in front of him covering close to 25 years that showed that we have had no lead issues at the Water Treatment Plant. Thanks again for your consideration. -Kyle -https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=16548e82930bf617&q=ly… 2/3 9/19/2018 Mail - Bordentown Water Follow-Up Questions Bagenstose, Kyle Bordentown Water Follow-Up Questions Hajna, Larry To: "kbagenstose@couriertimes.com" Thu, Sep 13, 2018 at 1:21 PM Kyle -- Responses to your latest questions 1. I saw some materials stating that NJDEP staff requested a meeting with Bordentown City water officials in early August, for the purposes of discussing potential lead service lines in the city. In simple terms, it seemed as if the city was saying they didn't think they had any and NJDEP staff wanted them to bring any supporting documentation or information regarding that assertion and potentially discuss next steps. The NJDEP held a meeting with Bordentown Water Department on August 15, 2018 to discuss their Lead Service Line inventory. Bordentown was able to provide documentation/records of their distribution system maintenance and repair log book, which included customer service line replacements, which dated back to 1960. This documentation indicated that Bordentown Water Department does not have any lead service lines within their distribution system. Thus Bordentown Water Department is not required to implement Lead Service Line Replacement (replacing 7 percent annually) at this time; however, Bordentown Water Department is expected to continue to confirm service line materials to ensure maintenance of accurate records. NJDEP requested Bordentown submit a strategy for continued identification and confirmation of service line materials, which was received on August 20, 2018. Bordentown stated that if any lead service lines are identified, then they will be replaced. NJDEP is currently evaluating the strategy and will continue to work with Bordentown on finalizing this strategy. 2. A: The city switched its iltration media from greensand to WRT Z88 because of lower radionuclide levels in new water source This interpretation is not correct. Bordentown Water Department changed the treatment process objective at their existing treatment plant (TP001003) from iron/manganese removal to radium removal and iron/manganese sequestration. To accomplish this, the existing greensand iltration media was changed from greensand to Water Remediation Technology's (WRT) Z-88 iltration media as this was determined to be more effective iltration method for radionuclide removal from existing Wells 1, 2, 3 and 5. Klenphos 300 was added as the chemical feed for iron/manganese sequestration. source B: The city also ceased treatment for metals (believe iron and manganese) because of lower levels in new water This interpretation is not correct. Treatment for iron/manganese did not cease as Bordentown Water Department changed the treatment process objective at their existing treatment plant (TP001003) from iron/manganese removal to radium removal and iron/manganese sequestration. https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165d3f4373bd9f6f&q=lea… 1/5 9/19/2018 Mail - Bordentown Water Follow-Up Questions -------- Original message -------From: "Bagenstose, Kyle" Date: 9/11/18 3:25 PM (GMT-05:00) To: "Hajna, Larry" Subject: [EXTERNAL] Re: Bordentown Water Follow-Up Questions Larry, Not really a question but I did want to point out that I believe information provided below is not accurate. Well No. 2A is a replacement for Well No. 2. Well No. 2 was replaced due to its age and declining capacity. Well No. 2A was drilled within 100 feet of the existing Well No. 2, within the same Lower PRM aquifer at approximately the same depth and pumped at an equal diversion rate of 1,000 gpm. There were no changes to the existing treatment process as the water quality of Well 2A was similar to the other existing wells which are all located in the same Lower PRM aquifer. As required for a new well source, NJDEP performed sampling to evaluate the Primary and Secondary Drinking water standards. My understanding is that A: The city switched its filtration media from greensand to WRT Z88 because of lower radionuclide levels in new water source B: The city also ceased treatment for metals (believe iron and manganese) because of lower levels in new water source -Kyle On Wed, Sep 5, 2018 at 4:03 PM, Hajna, Larry wrote: Thank you for sending. I have some follow-ups I would appreciate your considering. My deadline for this story has been extended to next Wednesday, 9/5, at 3 p.m. 1. Respectfully, I do not believe your initial responses answered several of my questions. My questions were not whether water quality parameter testing was conducted due to lead exceedances or a change in water source. I know that it was. My questions were whether or not NJDEP made assessments of water quality based on that data. The questions again below: https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165d3f4373bd9f6f&q=lea… 2/5 9/19/2018 Mail - Bordentown Water Follow-Up Questions A. Has NJDEP made a determination of whether or not water quality data taken from 12/20/2017 to the present day indicate the water corrosive? Based on the lead action level exceedances, Bordentown’s corrosion control treatment at the time of the action level exceedances was not optimized for corrosion control for lead and copper; as pH fluctuated between 6.98 and 8.85 and a chloride to sulfate mass ratio was above 0.6. Therefore, the approved Corrosion Control Treatment Recommendation will optimize /adjust the pH (7.2-7.8) for the inhibitor to be most effective. B. Did the NJDEP perform any analysis as to whether or not the new water well brought online in summer 2017 would potentially impact the corrosivity of the system's drinking water? Well No. 2A is a replacement for Well No. 2. Well No. 2 was replaced due to its age and declining capacity. Well No. 2A was drilled within 100 feet of the existing Well No. 2, within the same Lower PRM aquifer at approximately the same depth and pumped at an equal diversion rate of 1,000 gpm. There were no changes to the existing treatment process as the water quality of Well 2A was similar to the other existing wells which are all located in the same Lower PRM aquifer. As required for a new well source, NJDEP performed sampling to evaluate the Primary and Secondary Drinking water standards. 2. I am attaching a document that appears to be an OCCT Evaluation Template for the Bordentown Water System as of late June, 2018. In the second tab, 4.2 CCT Study Checklist, there is a row for "Chloride/Sulfate Mass Ratio Issues." In the response section, the system is marked as having a ratio of 2.23, which is highlighted yellow due to it being above >0.6 on the CSMR scale. Questions: A. Was this CSMR calculation filled out by NJDEP personnel? No, this was completed by Bordentown Water Department B. If so, where did the data come from (ie 10.7 mg/l for chloride and 4.8 mg/l for sulfate)? Bordentown WD C. In your initial responses, you wrote that if CSMR is above "recommended levels" the DEP would evaluate it as part of a CCT recommendation. What is the recommended level and if it is 0.6 what has the NJDEP done to address CSMR issues in the Bordentown system? Regardless whether CSMR or DIC is utilized, the conclusion drawn for this particular system for corrosion control was the utilization of an inhibitor (Klenphos 400) and the optimization of the pH. D. On the sheet it notes that if there are 2 or more "yes" answers, the EPA recommends a CCT study. There appear to be 4. Has a study been recommended? Based on the actions to be taken as part of Bordentown’s Corrosion Control Treatment Recommendation, NJDEP did not require a CCT Study. Bordentown WD proposed the addition of a corrosion inhibitor (Klenphos 400 containing an orthophosphate component) and optimization of their existing pH adjustment process which is currently being implemented. 3. In the third tab of the document, "4.4 study type checklist," NJDEP appears to fulfill the criteria to move on to question 4, which is does the system serve 10,000 people or fewer. The answer is marked "yes." However, on the NJDEP Water Watch website, the system is listed as serving nearly 16,000 people. A. How many people does the Bordentown Water System Serve? This section was completed by Bordentown WD as part of their CCTR submission, not NJDEP staff. Based on data provided in NJDEP’s Drinking Water Watch, Bordentown WD serves 15,821 people. B. If greater than 10,000, has the NJDEP decided to require a demonstration study, per EPA recommendations? {See response to 2D above.} 4. Why did NJDEP recommend/approve the use of an orthophosphate (Klenphos 400) to Bordentown? Bordentown’s submitted Corrosion Control Treatment recommendation as part of the lead action level exceedance was approved by NJDEP in coordination with guidance provided in EPA’s Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primary Agencies and Public Water Systems. A link providing more detail is available at https://www.epa.gov/sites/production/files/2016-03/documents/occtmarch2016.pdf https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165d3f4373bd9f6f&q=lea… 3/5 9/19/2018 Mail - Bordentown Water Follow-Up Questions 5. Understood that NJDEP primarily relies on DIC to assess corrosion control treatment. What was the calculated DIC for the water system from WQP testing following the Dec. 2017 and June 2018 lead exceedances? {DIC based upon data provided was 6 – 7.} -Kyle Lawrence Hajna New Jersey Department of Environmental Protection Press Officer (609) 984-1795 NOTE: This E-mail is protected by the Electronic Communications Privacy Act, 18 U.S.C. Sections 2510-2521. This E-Mail and its contents, may be Privileged & Confidential due to the Attorney-Client Privilege, Attorney Work Product, and Deliberative Process or under the New Jersey Open Public Records Act. If you are not the intended recipient of this e-mail, please notify the sender, delete it and do not read, act upon, print, disclose, copy, retain or redistribute it. -Kyle Bagenstose Reporter, environment & investigations Bucks County Courier Times The Intelligencer Burlington County Times https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165d3f4373bd9f6f&q=lea… 4/5 9/19/2018 Mail - Final confirmation on lead in Bordentown water prior to publishing today Bagenstose, Kyle Final confirmation on lead in Bordentown water prior to publishing today City of Bordentown Mon, Jul 30, 2018 at 4:24 PM To: "Bagenstose, Kyle" Cc: "Commissioner Joseph D. Myers" , John Walls , "George E. Hann Jr." Kyle, In speaking with Commissioner Myers, he has confirmed that as previously indicated by Mr. Haijna, this sample was taken from an old sink faucet at the Water Plant which is very similar to that of internal home plumbing. The sampling was not indicative of the quality of the water itself. Grace I. Archer, RMC, CMR Municipal Clerk/Registrar City of Bordentown 324 Farnsworth Avenue Bordentown, NJ 08505 Ph: 609-298-0604 Fx: 609-298-8467 Email: btownch@cityofbordentown.com This e-mail message from the City of Bordentown is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Further, be advised that the City of Bordentown is subject to the New Jersey Open Public Records Act and as such, any e-mail sent or received by the City may be subject to a records request. From: Bagenstose, Kyle Sent: Monday, July 30, 2018 12:36 PM To: Joe Myers Cc: jwalls@cityofbordentown.com; City Bordentown Subject: Re: Final confirmation on lead in Bordentown water prior to publishing today [Quoted text hidden] https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=164ecdf2b6497dda&q=%… 1/1 I I I I 10:45 ill mm . . - Muimum Residues ?nial for?lM's Sample'l?ype: - WMhutlon Sm Suuple P- {'1th (Ti-tad Wm} Sample ljl. l'l+ 11z1 - Raw Wltu- (Unmet! Simple} - CHEMICAL - Analytical Muls In in excepl cola. odor. turbidity. pH. V0. and Putin-Ma. MFL - million ?lm: liter Al. - action level (Drinking water stand-?hi In: in mm) MCL monilo?nl required SAMPLE NUMBER 2 SAMPLE NUMBER 2 76 SAMPLE NUMBER '2 I76 8 Cola; (l0) 2 .5 Aluminum (0.21 0. I75 Lead (0.0l5 AU 0 . 0061: Antimony lomnl 40 ()0th Mnngunnin (0.05) 0.035% gymn- 3-59 H714 Arsenic {0.005) (0.00016! Mercury (0.002) {0.00608 (6.5 - 8.5} 14.70 Asbestos (7 Nickel - Alkalinity I Barium (2i 0 054? Nitrate um 3, {23$ Tonal Dis. Solids (500) Beryllium (0.004} 0. Nitrite (m (I) 0. 001351 (0-5) 55' Cadmium (0.005) (0 ?00366 Selenium (0.05) (0.00935: Chloride 950) if Cluumium 8" sum Lam {is} Hardness (250) 20 . ?5 Copper (1.3 AL) 0. (1 ?47 Sodium ism 5- Pesticide I. 2. 3 Cyanide (0.2) 0. 07.? Sulfate (150) "0 . 1+ V0 Scan Fluoride (4) 0- 337 ?allium Luann (6.00an 1: blank ND Iron 0.161 Zinc (5) LZ-Di?chlon all! 6.119 . . l-?Z pf'b (was; - alpha? lg. 5 I Roi-r120, F33 [La-Dibrvaell?ikL 10.04% Fri: 123 5.52, pCi It: Agmcy DE) DEP Projcct Code Trip Blank I G: 0 053 T8 'omments: I. - Mose/l COPIEE Bfu: - Water Purvewr White - Bureau of 30}? Drinking Water Green - Health Author?y Canary - Chemistry Lab Pink - Bacterl' Gold - Extra illogical Lab 9/19/2018 Mail - Burlington County Times, Questions on Lead Exceedance in Bordentown (deadline EOD Wednesday, 9/12) Bagenstose, Kyle Burlington County Times, Questions on Lead Exceedance in Bordentown (deadline EOD Wednesday, 9/12) Covington, Tayler To: "Bagenstose, Kyle" Tue, Sep 18, 2018 at 4:57 PM Hi Kyle, My sincerest apologies for missing your deadline by so much. I hope you’re still able to use responses below. Thanks, Tayler QUESTION 1. Has EPA Region 2 consulted at all with either the NJDEP or the Bordentown City Water Department (PWSID NJ0303001) on the recent lead exceedances in that water system (Dec. 2017 and June 2018)? If so, What is the substance and nature of those consultations? Was EPA R2's assistance requested or did EPAR2 insert itself? ANSWER: EPA is aware of the Bordentown Water Department Action Level Exceedance. The State of New Jersey has been delegated primacy for the Public Water Supply Supervision Program, with NJDEP as the primacy agency, and is responsible for the initial interaction with the water system. Should NJDEP request EPA’s assistance on this matter, or if involvement by EPA is appropriate, we will work with NJDEP to take appropriate actions to ensure the safety of drinking water for the residents of Bordentown. QUESTION 2. After the June 2018 lead exceedance, an Optimal Corrosion Control Treatment (OCCT) Template was completed per EPA guidance. Several things of note, with questions: QUESTION 2A. NJDEP staff has told our newspaper that members of the Bordentown Water Department filled out at least one section of the OCCT Template (ie "4.2 CCT Study Checklist,") despite the directions at the top of the sheet saying it is to be completed by Primacy Agencies. Given the document's record of authorship it appears the entirety of the document may have been completed by Bordentown staff. Is EPA aware of this and is this an acceptable practice? ANSWER: The checklist is to be completed by the primacy agency with data provided by the water supply system operator. See page 63 of the Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems). The State of New Jersey has been delegated primacy for the Public Water Supply Supervision Program, with NJDEP as the primacy agency. QUESTION 2B. Following the criteria of the document set forth on "4.4 study checklist", the EPA recommendations call for both a desktop and demonstration study to be conducted to assess solutions to lead corrosion. NJDEP told this newspaper no such studies are being required because "the conclusion drawn for this particular system for corrosion control was the utilization of an inhibitor (Klenphos 400) and the optimization of pH." Is the EPA aware studies were not required despite EPA guidance recommending them and is this acceptable? https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165ee79879fb12bf&q=co… 1/2 9/19/2018 Mail - Burlington County Times, Questions on Lead Exceedance in Bordentown (deadline EOD Wednesday, 9/12) ANSWER: If the primacy agency determines that a study is not required, they must either approve the OCCT option recommended by the system or designate alternative CCT(s) from among those listed in §141.82(c)(1) - §141.82(d). Per the responses NJDEP provided to the Burlington County Times (attached to your email; Question 2D), NJDEP, as the primacy agency, approved Bordentown Water Department’s proposal to add a corrosion inhibitor and optimize pH. Since the State of New Jersey has been delegated primacy, any actions required by the Lead and Copper Rule would be the responsibility of the state. QUESTION 2C. Within the OCCT document, the CSMR of the system was calculated to be 2.23, which is in significant excess of the >0.6 level associated with corrosivity and a factor in the recommendation to complete a water system study. Further, Virginia Tech professor Marc Edwards has given his opinion to our newspaper that corrosion problems generated by CSMR are not solely solved by the addition of orthophosphates, as Bordentown is doing. This seems to be a major reason why EPA recommends a study to be completed when CSMR is elevated. Does the EPA believe it is acceptable for Bordentown to rely on the implementation of orthophosphates when CSMR is elevated? ANSWER: See NJDEP’s response to 3B (in the attachment). QUESTION 3. The Bordentown water system changed approximately 60% of its water source to a new groundwater well in July 2017. The well was permitted by NJDEP in Feb. 2017. Although the well water was tested for SDWA contaminants prior to being permitted, the NJDEP does not appear to have performed any level of analysis on the corrosivity of the water, or on subsequent changes in water treatment, to assess whether or not the system's water would become more corrosive due to the new well, nor required the city to perform any such analysis. It appears neither the NJDEP or city has performed any retrospective analysis to assess whether the new water source or treatment systems are causing lead corrosion in the water system. Is the EPA comfortable with no such analyses being completed, despite changes in water sources causing lead issues in communities such as Flint, Michigan? ANSWER: Per the responses NJDEP provided to the Burlington County Times (attached to your email; Question 1B), the new well (Well 2A) is located in the same groundwater source (the Lower PRM aquifer) as the previous well (Well 2). Should NJDEP request EPA’s assistance on this matter, or if involvement by EPA is appropriate, we will work with NJDEP to take appropriate actions to ensure the safety of drinking water for the residents of Bordentown. QUESTION 4. Is the EPA aware that testing results from the new water well in October 2016 show a lead level of 6.48 ppb, and that tests at the water system's point of entry in June 2018 show a lead level of 6.9 ppb? If these lead levels are indicative of general source water quality, is 6 pbb+ of lead acceptable? ANSWER: Since the State of New Jersey has been delegated primacy for the Public Water Supply Supervision Program, any actions required by the Lead and Copper Rule would be the responsibility of the state. Bordentown is not required to take additional action unless they exceeded the action level and New Jersey set a treatment requirement for source water. From: Bagenstose, Kyle [mailto:kbagenstose@couriertimes.com] Sent: Monday, September 17, 2018 4:44 PM [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0/?ui=2&ik=f3f7ca0134&jsver=HaWAij9wtf4.en.&cbl=gmail_fe_180911.11_p4&view=pt&msg=165ee79879fb12bf&q=co… 2/2 Exhibit 4.4:  Recommended Checklist to Support Primacy Agency Determination of When to Require a  Desktop or Demonstration Study To be completed by:  Primacy Agencies Purpose: To help the Primacy Agency decide what type of study to require and document their decision. Question 1. Does the system have multiple sources of water? 2. Is the system planning future treatment changes? 3. Is the system planning future source water changes? 4. Does the system serve 10,000 people or fewer? Response (YES  or NO) Recommended Next Step Yes (4 wells) Yes (Klenphos  400) Yes Emergency  Inteerconnecti on Yes If the answer to at least two of the first  three questions is yes, go to question  4. If not, consider requiring the system  to conduct a desktop study . If yes, consider requiring a desktop  study  unless lead service lines are  present. In that case, discuss the most  appropriate steps with the system. If  the population served is greater than  10,000, consider requiring a  demonstration study . Primacy Agency Decision: Is a Desktop or Demonstration  Study Required? OCCT Evaluation Templates for ≤ 50,000 1