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XXX Memorandum Water Discoloration and Potential Citric Acid Incursion Individual AA, Operations Manager of company XXX had arranged to flush part of the XXX system on the morning of the incident. In preparation for the flushing operation, XXX placed notices in the local newspapers for approximately one month ahead of the flushing. In addition, XXX placed notices on all of the invoices sent to its customers in the area where the flushing would take place in advance of the flushing so that they would be prepared. Flushing is customarily accomplished approximately once every year in order to flush out any particulates, which may have settled into the distribution system. Flushing sometimes causes discoloration in the water and turbidity in the water. XXX began its flushing operation at approximately 12:30 AM on the day of the incident and commenced to flush through approximately 5:00 AM on the day of the incident. In the morning of the incident at approximately 9:00 o’clock, person AA received a call from school B complaining of discolored water. This is the type of call which person AA would normally expect to receive after a flushing because of the occurrence of turbidity and discoloration sometimes caused by the flushing. Person AA went to school B after receiving the phone call and flushed the water to a far fixture. (AA and the school maintenance personnel ran water through and into fixtures and sinks to a point farthest from the connection point of the XXX system to the school. AA then checked the water at the farthest fixture from the XXX point of connection and found that it had readily cleared. AA drank the water to ensure that its taste was appropriate and found it to be appropriate for potable water. The Principal of school B then advised AA that one of the children had thrown up and that the Principal was not sure whether it was from the water or from some other cause. AA believes that it was decided that the children would be given bottled water and would not ingest the water from the taps connected to the XXX system for that day. AA believes a note was sent home with the children of school B, but AA does not have a copy of that at this point. Later in the morning, AA received a call from the C Retirement Community whereby he was advised that there was a greenish tint to the water. The telephone call to AA was made by individual DD and in their discussion it was agreed that AA would call individual EE who is the maintenance manager of the C Community. AA then telephoned EE and advised them that they should flush all of the systems in all of the buildings in the C Community. AA then immediately proceeded to the sample station which is at the entrance (connection point) of the XXX system at the C facility. AA examined the water at the connection and found it to be clear. AA then telephoned EE who was inside the C complex in order to determine how EE’s men were making out with respect to the flushing of the systems in each building. EE advised AA that the water was readily clearing. AA then went to the construction trailer on the C site in order to check the water in its tap and found it to have a bluish/greenish tint. AA ran the tap to flush the water and it readily cleared within moments. While AA was investigating the C matter, they received one or two telephone calls from customers regarding turbidity in the water which is something AA would normally expect after a flushing. After leaving C, AA considered that the color they were seeing in the water on the morning of the incident was different from color they had seen in the past after flushing the system. AA considered the fact that FF had contracted with YYY to install new carbon filtration systems on VFCC wells 2 and 3 which are part of the XXX system. AA believes these systems were installed the day before. AA then immediately contacted YYY to determine whether the complaints and reports they received on the day of the incident morning could be related to YYY’s activities with respect to the carbon filtration systems. AA contacted individual GG in the early afternoon of the day of the incident. GG was not sure whether anything YYY was doing would cause the discoloration in the water but indicated that he would call AA back. Shortly thereafter, AA received a telephone call from individual HH who represented themselves to be the toxicologist at YYY. HH indicated to AA that a small pH change coming from the carbon units could be the cause of the aquamarine (blusih/greenish) tint in the water, and further advised AA that this would not pose any health issues for XXX’s customers other than a small possibility that the change in pH could cause someone to vomit. AA told HH about the boy who had reportedly vomited at School B earlier that morning. Immediately before HH’s call to AA, AA had received a telephone call from a person in an office building adjacent to XXX’s offices complaining about a bluish/greenish tint to the water. With this in mind, AA advised HH that tests must be immediately conducted at the office adjacent to the XXX offices. HH then caused GG to come to the site of the office adjacent to XXX’s offices with testing bottles in order to conduct tests. At this time, AA then telephoned the parents of the boy who had gotten sick on the morning of the incident at school B. AA spoke with the boy’s father and asked how the boy was. AA advised the father that if he had any concerns he could speak with YYY’s toxicologist and AA gave the boy’s father HH’s name and telephone number. The boy’s father during the telephone conversation advised AA that there had been some discoloration in his tap water but that it had cleared and there was no longer discoloration in the water. (At the end of the day, AA was advised by HH that the boy’s father had not called.) AA then went back to the neighborhood, which was the location of the residence of the boy who had reportedly become ill at school B. As a precautionary measure, AA began flushing the system in that neighborhood by opening the fire hydrants. AA determined quickly that the water was clear. Even though the water was clear, AA continued to flush that neighborhood by leaving the hydrants partially opened for a period of approximately twenty-four hours. To the best of AA’s knowledge, he did not receive any other complaints in this zone of the XXX system where that residence was located, after that time frame. Late on the day of the incident or early the next morning, AA activated the XXX well 15 in order to supply water to the XXX system in sufficient capacity so that they would isolate the section of the system where complaints were received and which may have been potentially affected by YYY’s actions with respect to the carbon filtration systems. At this time, from the information given to AA by GG, AA was under the impression that there may have been a slight pH differential caused by the installation of the carbon filtration systems. Therefore, by activating XXX well 15, AA was causing pressure to force water which would have come out of the carbon filtration systems into the enormous volumes kept in XXX’s stand pipes so that any pH differential would be readily dissipated. Meanwhile, late on the day of the incident, AA received a few complaints from customers on I Drive. AA went to the I neighborhood in order to investigate and went to the houses who had called the XXX offices with complaints. AA was advised that one child in each of two houses had vomited. AA advised the residents not to ingest the water until the system had been completely flushed. AA gave the residents HH’s number and advised them to that if they had questions, he was the toxicologist for YYY and they could contact him. AA also gave the residents their own cell phone number. AA then had their men flush the I neighborhood. AA never saw any tint to the water when they were flushing the neighborhood. However, the residences AA visited were the children got sick did appear to have a tint in the water. AA ran their taps and the color seemed to clear from the water. AA caused XXX’s employees to canvas the I neighborhood on the day of the incident evening. Neighbors were advised to avoid tinted water and were told to run their taps to flush the water. There is a school at the end of this section of the XXX system known as school J. Knowing this, AA contacted individual KK, the school engineer and arranged to meet KK’s personnel at the school J on the morning of the day after the incident. In anticipation of meeting KK’s personnel at the school J, AA caused the fire hydrants in that section of the XXX system to be left opened to flush the system in the vicinity of the school J on the night of the incident. Prior to going to school J on the morning the day after the incident, AA went to school B where he met the custodian between 6:00 and 6:30 AM (approximately). AA ran the water in the school B and satisfied AA that it was clear. AA also drank the water to determine that there was no taste in it. This was accomplished before the school children arrived for the day. Subsequently, AA received no complaints from either school B or school J. Approximately mid-morning on the day after the incident, AA received a complaint regarding bluish/greenish tint in the water of a residence on L Lane. AA flushed the neighborhood by opening fire hydrants until the water was clear. AA then left the hydrants partially open to continue to flush. AA then canvassed the neighborhood and advised as many residents as they could that they should not drink the water until it was entirely clear. The homes which AA investigated in the L neighborhood had the same bluish/greenish tint to the water, but it readily cleared upon running the taps. Because of the repeated complaints AA was receiving, regarding the tint in the water, AA again contacted YYY in order to determine if there could be something other than a pH differential caused by their installation of the carbon filtration systems. AA spoke with both GG and HH. The day of the incident, at approximately mid-day, YYY had taken the carbon filtration systems off-line so that they were no longer connected to the XXX systems. GG had advised AA that they had taken the carbon filtration systems off-line because of a “control probe problem”. They did not advise AA that they had taken the carbon filtration systems off-line because of any contamination they were causing in the XXX system. However, later on the day after the incident, when AA contacted HH and GG, AA was advised that in fact YYY had used what was described to AA as a “citric salt” in flushing the carbon units when they were connected to the XXX system. AA, upon learning this immediately contacted ZZZ’s emergency connection in order to report what AA had just been advised by YYY’s personnel. AA spoke with the duty person on call at the emergency number and asked to speak with a water quality specialist because AA thought that they could possibly have a contamination problem in the XXX water system. The duty person advised AA he would have someone call AA back. In the meantime, AA contacted their personnel in order to have them canvas the neighborhoods where the complaints had been received on the day of the incident and the day after. AA instructed the personnel to advise residents in the affected neighborhoods that they should not drink the water unless it was perfectly clear. AA also instructed the personnel to ask residents whether there were any more incidents where people were sick or otherwise affected by the water. The XXX personnel who were canvassing the affected neighborhoods were instructed to give AA’s direct cell number to residents. The residents were instructed by XXX personnel to call AA on the morning two days after the incident in order to update him. AA wanted to hear from the residents as to whether there was coloration or no coloration, and to determine if there were any more illnesses reported. AA then received a telephone call from MM, a water quality specialist with ZZZ. AA explained to MM the events which had occurred on the day of the incident and the day after leading up to the end of the day on the day after the incident when he learned for the first time that YYY had used what they described to him as “citric salt” in flushing the carbon filtration systems which was then put into the XXX water supply in that area where the neighborhoods were affected. MM advised AA to conduct tests and advised that those tests should include tests for alkalinity, metals, and pH analyses. AA advised MM of their actions including direct contact with customers in the affected neighborhoods, continued flushing of the system by leaving the fire hydrants partially opened and the precautions taken by AA to open XXX well 15 in order to isolate the affected area. MM stated that he believed that AA knew the system better than anyone and should therefore take what actions AA thought were appropriate. AA continued to flush systems in the affected areas by further opening the fire hydrants to make sure that through flushing was taking place. At approximately 8:00 PM on the day after the incident, AA, individual NN who is XXX’s operations specialist, and GG from YYY took eight samples from approximately five locations in the affected areas. The samples were doubled in three of the locations so as to cross-check them. In addition, at each of the five locations, pH tests were conducted and it was confirmed that there was no material pH balance problem with the water. By confirming that the pH was not out of balance, AA felt that no appreciable citric salt or acid was present in the water. Early in the morning two days after the incident, AA began to compose a formal notification to be published by radio and other media in the event it was necessary because of continued complaints or in the event test results showed a problem. In addition, AA began to review his emergency response plan in the event he had to implement it. Beginning on the morning two days after the incident, AA and GG from YYY conducted pH tests at various locations throughout the affected areas in the XXX system to confirm that the pH remained in balance. They did confirm that the pH remained in balance. AA also continued to flush they XXX system through mid-day two days after the incident. All of the call-backs AA received from residents two days after the incident indicated that there was no discoloration in the water or continuing ill health effects. Two days after the incident, AA contacted two residents near the XXX water tower in order to determine whether they had experienced any discoloration or ill health effects from the water. AA wanted to contact these residents because they would be in a zone of the XXX system which was most probably separated from the affected sections of the XXX systems and AA wanted to assure themselves that there had been in incursion of the discoloration past the XXX station. They reported no discoloration or ill health effects. On the afternoon and evening two days after the incident, XXX personnel canvassed residents outside of the zone in the XXX system which had previously registered complaints. In other words, XXX personnel canvassed areas where no complaints had been received in order to insure that there was no discoloration or ill health effects. That canvassing produced no complaints about discoloration or ill health effects. YYY Memorandum This memorandum has been prepared to document the background and events of 2006 related to placing the wellhead treatment units (WTUs) into initial operation at two of the XXX water supply wells (VFCC-2 and VFCC-3). The purpose of the WTUs is to protect potable water sources during the implementation of planned upcoming chemical oxidation injections at the nearby WWW Superfund Site, located in Pennsylvania. Beginning in late 2005, full scale granular activated carbon (GAC) systems were placed at VFCC-2 and VFCC-3. Each full-scale system is constructed of new materials designed for use in potable water systems. Each WTU consists of two 5,000 pound GAC vessels, two suspended solids filters, control valving and a monitoring system. Concurrent with these installation activities, YYY pursued water supply permit modifications for each well from ZZZ. In min 2006, the GAC vessels were filled with pH-adjusted new granular activated carbon. Upon initial wetting, virgin carbon can produce water with a high pH typically between 10 and 11 standard units (SU). pH-adjusted activated carbon is modified by the manufacturer to reduce the initial pH to approximately 9 SU. After the initial carbon fill, the WTUs were flooded with water and backwashed in preparation for placing the units on-line. After backwashing, the pH of the water within the units was documented to be between 9 and 9.5 SU. XXX requested that the pH of the units be further adjusted to between 6 and 8 SU. YYY contacted the supplier of the WTUs and the GAC, UUU, for recommendations to meet the request of from XXX. UUU recommended that the residual pH basicity be neutralized by recycling a citric acid solution through the GAC units until the desired pH was achieved. XXX was verbally provided the details of the proposed neutralization and advised of the schedule to complete the activities. A neutralization system was brought to the WTU locations and consisted of a 50-gallon poly tank fitted with a sump pump adjacent to the WTU. The tank was filled with water from the WTU, solid food-grade citric acid was added to the tank, and the solution returned to the WTU. The citric acid solution was continually recycled in an upflow mode through each of the individual 5,000 pound units and additional citric acid was added as the pH of the solution rose in the tank, indicating that he acid was consumed. During this time period, the WTUs were physically disconnected from the XXX system. Ten days before the incident, UUU and YYY mobilized to the VFCC-2 WTU location and began the set-up for neutralizing the observed residual basicity. Neutralization activities were continued the following day and neutralization of the VFCC-2 WTUs was completed two days after it began. At the conclusion of the activities, the pH in the VFCC-2 WTU was approximately 7.1 SU. Seven days before the incidents, the neutralization set-up was then moved to VFCC-3 and the process was repeated that day and the following day. Water was recirculated until the pH stabilized at approximately 6.8 SU throughout the units (as measured in the tank fill hose) and low pH waster was not observed in the low-level drains. Once the VFCC-3 WTU was observed to be at a stable, neutral pH, YYY returned to VFCC-2 and rechecked the pH of the WTUs at several points to verify that the previous day’s pH did no change due to slow chemical processes within the system. The pH avired between 6.8 and 7.1 SU at the VFCC-2 WTU the second day. With the WTUs neutralized to near neutral pH and within the range requested by XXX, YYY contacted XXX to schedule placing the WTUs on-line for shake-down and operation prior to the planned upcoming permanganate injection. The day before the incident, YYY met with XXX to place the WTUs on-ling. Due to concerns of potential solids (e.g., activated carbon particles, ruse, etc.) within the influent and return hoses, we agreed to flush the system with water diverted from XXXs supply system. The return hose was disconnected from the air stripper influent pipe and flush water was discharged to the ground surface. Since XXX needed the wells to remain in operation and continue to supply the distribution system., only a portion of the flow was diverted for flushing. When the GAC units were flushed, the return line hose was disconnected from the downstream water supply. The flushing rate was estimated to be between 50 and 75 gallons per minute for both VFCC-2 and VFCC-3. The initial water from flushing was observed to have some activated carbon particles and a slight green tint, both of which cleared within approximately 5 minutes. The flushing continued for another 5 to 10 minutes and the water was observed to be clear, free of solids and any visible color. Once XXX was satisfied that he WTU systems were clear, the return hose was connected and the WTU systems were placed on-line. The VFCC-3 WTU was started at approximately 10:00 a.m. the day before the incident and completed by approximately 11:15 a.m. the same day. The flushing of the VFCC-2 WTU was started at approximately 1:45 p.m. on the day before the incident and was completed by approximately 3:00 p.m. the same day. The unties were left on-line to allow YYY’s control/monitoring system subcontractor to test/calibrate the monitoring and alarm system and to collect baseline operations data (e.g, influent oxidation/reduction potential (ORP)) prior to the planned upcoming ISCO injections. The control/monitoring system subcontractor was scheduled to complete their portion of the work on the day of the incident. On the day of the incident, YYY arrived at VFCC-3 at approximately 7:45 a.m. to begin checking the WTU at VFCC-3 for baseline operational characteristics (e.g., pressure drops across carbon beds). At 7:50 a.m., YYY received a call XXX indicating that the water company had received complaints from several customers regarding a blue-green color to their water. The first of the complaints was received at approximately 4:00 p.m. on the day prior to the incident from a customer in close proximity to VFCC-2 and VFCC-3. As time went by, complaints were received from further distances, indicating to XXX that the issue was emanating from VFCC-2 and VFCC-3. XXX and YYY reviewed the neutralization of the WTUs and potential issues that could have resulted in the color complaints. AA of XXX stated the XXX had experienced blue-green color complains in the past, when it was necessary to open an interconnection with an adjacent water system owned by VVV. Apparently, a small variation in the pHs between XXX’s and VVV’s water, on the order of 0.5 SU, had resulted in a similar situation. YYY reiterated the pH results for the WTUs and that the pH of the well water was approximately 6.3 SU. At approximately 8:30 a.m., XXX met YYY at VFCC-3 to review how the WTUs operated since being placed on-line and to take the units off-line for the control/monitoring system subcontractor. During the discussion, XXX received a complaint at approximately 8:50 a.m. from the school B. XXX advised YYY that the school reported a green tint to their water and that XXX had advised them to open their faucets and flush their system. XXX further related that one student had consumed some of the water and may have vomited. YYY met the control/monitoring system subcontractor and proceeded to VFCC-2 to begin the finalization of the control/monitoring system. XXX was flushing their water mains the preceding night and their activities probably drew water from VFCC-2 and VFCC-3 in the direction of the school. Under normal conditions, the water from VFCC-2 and VFCC-3 would not have migrated in that direction. In discussing the likely “migration” on the issue, XXX indicated that there might have been a reaction between the water and copper service pipes. This was based on the fact that no reported problems from customers with black iron water service pipes had been received, while customers with copper service pipes were reporting the tinted water. YYY contacted TTT on the day after the incident regarding the wellhead treatment unit operations. On the day of the incident, YYY collected water samples for chemical analyses at three point-of-use locations within an office building near the XXX offices. Two samples were collected from within the kitchen space of the office and one sample was collected from a bathroom sink. The samples were forwarded via courier to SSS Laboratories for analysis. The requested analyses included TAL metals including total chromium and cobalt, pH, RORP, TOC, ammonia, TSS and alkalinity. The samples were transported on ice under proper chain-of-0custody seal. YYY expects to receive the analytical results fro these samples by close-of-business 5 days after the incident.