Benzene in Lake Whatcom: Some Questions & Answers

Today's BELLINGHAM HERALD reported 'Boat docked at lake burns'. It mentioned that: the boat didn't sink, damage was estimated at $50,000, no one was hurt, minor damage was done to the dock and neighboring boats, that the Department of Ecology had determined there was no fuel or oil leakage, and booms were set up around the boat to prevent pollution. Also, that George Henderson, Chief of Whatcom County Fire District No. 18 - the same person and organization that was just fined $21,000 by DOE for illegally disturbing the shoreline in the South Bay - was the responding fire safety officer. He also said the owners had docked the boat after using it 'without any problems during the day'.

Two questions:
1. How do we know the boat was used during the day 'without any problems'?
2. What wasn't 'the lake' described as the Lake Whatcom Reservoir, our Municipal Water Supply?

To the extent this can become a 'teachable moment', the following is in response to a list of questions submitted to staff by me, regarding motorized watercraft management recommendations. Each underlined question is followed by its answer, with some questions having multiple parts that are related to a common subject. Cost estimates are based on a variety of sources but all should be viewed as preliminary estimates. These answers were issued on 3/11/2004.
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1. For how long have the benzene tests been conducted?
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The City has collected benzene data since 1988 as part of our volatile organic chemical monitoring program per Safe Drinking Water Act (SDWA) requirements. Sampling procedures have been refined and improved in the past 5 years.

Treated water is currently sampled annually to establish compliance with the SDWA. Often the treated water sample is paired with an untreated water sample to derive treatment plant removal data for the water utility. The analysis required for Safe Drinking Water Act compliance is a broad scan, and as such, has a detection level for benzene that is up to 9 times higher than more selective methods currently used by the utility (see paragraph below). The detection level for SDWA compliance determination is conventionally reported at the State Reporting Level for compliance determination (typically reported as 0.5 parts per billion or ug/L). When reporting the results for compliance monitoring, it is the convention to report only to the State Reporting Level. Therefore, data derived for SDWA compliance sampling is reported above the benzene levels typically observed in Lake Whatcom.

Benzene, Toluene, Ethyl Benzene, and Xylene (BTEX) Sampling
Because the 1999 Olympic pipeline rupture and explosion occurred directly between the water filtration plant and the filtered water chlorine contact reservoir, there was concern about gasoline contamination in the water supply. The utility immediately began collecting and analyzing water from the treatment plant and in the distribution system for benzene, toluene, ethyl benzene, and xylene (BTEX), which are constituents of gasoline. These BTEX compounds were detected in all but seven of the 120 samples collected from the time of the explosion until the end of that year. Levels of detection were well below the State Reporting Level, and the average benzene levels in all samples collected from that period was 0.07 ug/L. Six of the seven samples that had no BTEX detections were from those samples taken from 11/15/99 until 12/13/99. Those 6 samples comprised all the samples taken during that later period.

With the realization that BTEX compounds were being detected in the treated water supply came the desire to definitively attribute the source of these compounds. Sampling began at the Gatehouse (untreated Lake Whatcom water from the City Intake pipe in basin #2) on June 22, 1999. It came as a surprise to the utility that benzene levels were also detectable at the source of the City’s drinking water, over a mile away from the site of the pipeline rupture. As this monitoring program continued, an analytical method with better detection levels was employed starting in 2001. The Selected Ion Mass Spectrometry (SIMS) allowed detection levels at up to 9 times lower than by the conventional SDWA-required method as it is able to focus in on the specific spectra of interest.

Where are these records kept?
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All records from the Safe Drinking Water Act compliance monitoring are reported and filed with the State of Washington Department of Health and are also filed in the Water Filtration Plant Laboratory.

Records from the post-Olympic pipeline rupture monitoring are filed at the Water Filtration Plant Laboratory. Results from this monitoring are entered into an Excel spreadsheet to allow for data analysis.

What is done with this information? Is it included in any official reports or literature?
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The City included information/data on the BTEX monitoring program in two of its Consumer Confidence Reports sent to all customers of the water utility (June 2000 and June 2001). The benzene levels detected in lake water were also reported in the Water Source Protection Plan (Section 2.1.12), compiled by the City of Bellingham and Whatcom County Water District #10 in 2000.

The City’s BTEX data was also provided to the Citizen’s Advisory Committee formed to provide recommendations on boating on Lake Whatcom. This data is available electronically and is also provided to customers upon request.

Is it true that the levels reported to date are well below actionable levels [MCLs] mandated by Federal and State Law?
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Yes this is true.
The Environmental Protection Agency (EPA) and State of Washington regulatory levels of note are shown in the table below:
The table* depicts the maximum contaminant level (MCL), the maximum contaminant level goal (MCLG) and the Washington State Reporting Level. Though the MCLs are enforceable standards and MCLGs are not, the EPA feels there is no safe level of consumption for carcinogens such as benzene and has therefore set the MCLG at zero.

[Compressed Table*]
Compound//EPA Maximum Contaminant Level//EPA Maximum Contaminant Level Goal//State Reporting Level
[all values expressed in (ug/L)]
Benzene//5//0//0.5
Toluene//1000//1000//0.5
Ethyl benzene//700//700 //0.5
Total xylene//10000//10000//0.5

The EPA realizes that real financial and technological constraints often make zero unattainable, so they set MCLs as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. The maximum level of benzene found in all treated water samples taken from 2000 to present is 0.123 ug/L, and the maximum level of benzene in untreated water (for which these level do not apply) is 0.137 ug/L.

The other contaminants toluene, ethyl benzene and xylene have MCL and MCLG levels that are the same because unlike benzene, the EPA believes those levels provides sufficient protection from the potential health problems associated with these contaminants.

The EPA has grouped contaminants into five groups based on the seriousness of their health effects upon humans. The health impact is based upon whether or not the substance being classified has been determined by USEPA to cause cancer in animals or humans.

Group A is described by USEPA as a known human carcinogen, or cancer-causing substance in humans.
Group B has been determined by USEPA to be a probable human carcinogen.
Group C includes possible human carcinogens.
Group D includes substances for which there is insufficient evidence to document carcinogenic effects upon humans.
Group E is not considered a carcinogen.

Benzene is a volatile organic compound (VOC) listed as a Group A contaminant, The EPA feels that adequate human data exists to support this classification. Another Group A VOC, vinyl chloride, is also of concern.

2. Is there any discernable trend in recorded benzene levels over time, aside from the periodic spikes? Is the fact that measurable concentrations have been found a cause for concern?
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The seasonal variations seem to be the only apparent trend.
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Please refer to prior response for discussion on MCLGs and benzene.

3. Where are the sampling points and with what frequency are samples taken and tested? Does sample location or frequency matter?
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Since 1999 samples are collected at least monthly and consist of paired gatehouse and treated water samples. The gatehouse sample represents the water coming into the City’s intake pipe. The water does not stratify thermally at the intake location, therefore there is a much greater likelihood that substances on the lake surface could make their way to the intake at the bottom of the lake.

In (only) one instance were samples collected from both the intake and from the surface of the water above the intake (where one would assume more hydrocarbon to exist). This sampling occurred in August 2000. The data were:

Benzene (ug/L or parts per billion) Single ion monitoring
8/28/00 Gatehouse 0.123
8/28/00 Surface of lake near intake 0.230

4. Is the City's present water treatment process capable of removing benzene from the raw water to produce our drinking water? From the data, it appears not likely because there is little difference in concentration.
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You are correct, the City’s treatment plant is not capable of removing benzene.

5. What is the estimated expense for upgrading the water treatment plant to remove benzene and/or other organics harmful to humans?
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A full comparative analysis of equipment costs, plant remodeling costs, potential for other contamination, expected benefits of the treatment options and other factors is needed to answer this question.
The EPA has selected two preferred treatment methods for removal of Volatile Organic Compound (VOC) contaminants such as Benzene. Packed tower aeration or air stripping is one method. This process transfers the VOC's from water to air. The air is discharged into the atmosphere. Consideration must be given on a case-by-case basis to ensure that the airborne VOC contaminants do not cause health risks. While it is possible to place additional treatment on the air discharge, the additional costs involved make this method very expensive especially when higher concentrations of VOC contaminant are present. One would also need to be concerned about introducing air borne contaminants into the water.

The other method of removal is granular activated carbon (GAC) adsorption. When water passes through a bed of activated carbon, VOC's attach or stick to the carbon. The attaching or sticking process of VOC's to the carbon granules is called adsorption. The carbon must be monitored carefully so that it can be replaced before it is exhausted. Carbon which is exhausted, or has adsorbed all the VOC's it can, may allow the adsorbed VOC's to be released back into the water in higher concentrations, due to the amount of VOC accumulation upon the carbon granules. Contaminated carbon must be regenerated on site or properly disposed of so that recontamination of the water does not occur. This treatment technology also has been shown to encourage the proliferation of microorganisms at the treatment plant, some of which have shown resistance to disinfectants currently in use.

Would such an upgrade be justified?
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In the final determination of which treatment process to use for VOC removal, all elements relevant to our water system should be considered. These elements include the cost, the types/concentration of VOC's present, the amount of removal deemed acceptable and the surrounding neighborhood.

How would it be paid for and by whom?
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Water utility customers would pay the costs for changes to the water system. The utility users also pay for maintenance and operation costs.

How much more capacity is available using the current water treatment plant, and when would an expansion normally be expected, using the same technology?
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At what point would such an upgrade be anticipated?
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It is quite difficult to determine when we will reach capacity on our water treatment plant. It is an element of our comprehensive plan (1993) and was slated for expansion in 1995. Since 1993 the City’s overall water consumption has been flat and our peak use days have been significantly reduced. So at this stage we do not have a plan for expansion. At some point growth will overcome conservation and we will have to expand the facility. The current peak capacity available is approximately 20 % or 5 million gallons per day.

What are the estimated costs of a more sophisticated water treatment system based on advanced technology to remove benzene and related compounds?
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We do not have cost estimates of alternative treatment systems to address issues such as benzene. It would require us to retain a consultant to develop the feasibility of removing targeted compounds and what that would cost from a capital and O & M basis. It also would require that we evaluate the benefits of certain treatment schemes and the risks associated with using that technology. We would want to be assured that in the process of removing one contaminant that we did not introduce new risk factors which might be as great or greater than the targeted agent.

What about the idea of obtaining drinking water from another source besides Lake Whatcom? What estimated costs might this entail, assuming another source is available?
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Other drinking water sources have been reviewed. They include changing our point of withdrawal from the Nooksack River, piping Middle Fork water around the Lake directly to the water treatment plant and reverse osmosis treatment of salt water from Bellingham Bay.

Withdrawing water from the lower Nooksack is estimated to cost between $100 and $150 million for construction and $10 million or more in yearly maintenance and operations costs. The option would require land acquisition, big pumps, settling basins, new treatment facilities, etc. Electricity would be a big part of the yearly M&O costs. Due to the large sediment load and the need to pump continually equipment maintenance costs would be high. Water in the lower river receives contaminants from Everson, Lynden and Ferndale treatment plants as well as runoff from agriculture and other land uses, therefore requiring a high level of treatment.

Pumping around the Lake from the Middle Fork diversion is estimated to cost around $45 million. Yearly M&O might be
$2 million. This option relies heavily on the availability of land for the pipeline and a water reservoir. Probably big pumps would be required with high electric use. Depending solely on water withdrawal from the Middle Fork is not feasible given the instream flow constraints on our withdrawal management.

A reverse osmosis plant would be constructed on the City waterfront that would provide the supply source for drinking and industrial process water for the City’s residents and industrial users. The system would include a treatment plant, reservoir, pumps and pipes.

Reverse osmosis is, in general, very expensive ($180 million) and typically done when there is no fresh water alternative.
The advantage that reserve osmosis has is that there is no water right requirement for salt water. The supply is inexhaustible, available and located within Bellingham Bay where the City is located. In addition, a reverse osmosis plant to supply only potable water, although cheaper, does not completely relieve the City’s reliance on Lake Whatcom as a source of supply for industrial process water purposes.

How would this be paid for and by whom?
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The costs for changes to the water system would be paid by water utility customers. Maintenance and operation costs are also paid for by the utility users.

6. What is the estimated cost of moving the City's water intake to a more sheltered area in Basin 3?
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In the past the cost has been estimated to be $1000 per linear foot with an estimated distance of 5000’ for a cost of $5 million. This should be considered a minimum given anticipated cost increases by the time a project is construction ready.

Would such a move be expected to be helpful?
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We are currently reviewing this issue. The review is assessing the water quality and other issues in the portion of Basin 3 nearest Basin 2.

Would these costs be justified?
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This question will be answered after the completion of the review.

How would this be paid for and by whom?
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Water utility customers would pay the costs for changes to the water system. The utility users also pay for maintenance and operation costs.

7. Does the City have any way of systematically identifying: boaters using the Reservoir; the number by type of watercraft used; how particularly sensitive areas might be better protected; how to fairly & equitably enforce boating BMPs; how many of these boaters use the Bloedel-Donovan launch?
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At the present time, there is no comprehensive count of the numbers and types of watercraft used. Counting the number of boat launches at Bloedel Donovan Park (see below) is an inaccurate estimate of boat use, since boaters also access the reservoir at the public WDFW boat launch, as well as the boat launches at Sudden Valley and Wildwood Resort. Boat use counts are further complicated by the significant boat use that originates from the hundreds of private docks that encircle the reservoir.

How could particularly sensitive areas might be better protected?
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Identifying particular areas, such as the intake pipe, for enhanced protection is not included as a management recommendation.

How would we fairly and equitably enforce boating BMPs?
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It is recommended that the Whatcom County Sheriff’s boat patrol enforce any new boating regulations. The Sheriff currently patrols the reservoir on a limited basis. The committee has recommendation is that the boat patrol’s hours be increased, at least to cover the hours that the boat launch is open on weekends and holidays.

The recommendations include actions the City could take to improve facilities available to boaters and thus make it easier to comply with the fueling, bilge dumping and other waste related issues.

It also is recommended that a boating education program be developed to promote voluntary compliance with laws and BMPs.

How many of these boaters use the Bloedel-Donovan launching site?
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As reported in the Water Source Protection Plan (2000), in past years, the Bellingham Parks and Recreation Department charged during the boating season for weekend and holiday use of the Bloedel Donovan Park boat launch. During that time, Parks employees counted the number of vessels using the launch. Parks was able to provide data for weekend and holiday launches from Memorial Day to Labor Day 1986 (800 launches), 1998 (2156), 2000 (1375), and part of 2001 (Memorial Day through July 20, 525 launches).

In 2001, the Parks Board decided to discontinue the practice of charging for parking and use of the boat launch.

8. Does the fact that manufacturers of personal watercraft using 2-stroke carburated engines will eventually phase them out, have anything to do with these craft not being used in the Reservoir now?
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The Environmental Protection Agency (EPA) established a new standard for marine engine emissions in 1996. This standard requires marine manufacturers to achieve a 75% reduction in outboard and personal watercraft (PWC) engine hydrocarbon emissions by the year 2006. Although this standard is designed to improve air quality, they also result in engines that produce significantly less water pollution.

The California Air Resources Board (CARB) decided that the EPA’s standard was not sufficiently strict and was being implemented too slowly. As a result, CARB accelerated the EPA timeline and set stricter standards for new marine engines sold in California. The CARB standard requires manufacturers to meet EPA 2006 standards by 2001 and to produce 65% lower emissions than the EPA standard by 2008, for a total of 91% lower emissions than carbureted two-stroke engines. Because California has such a large share of the marine engine market, manufacturers are designing their engines to meet the stricter CARB limits.

Because PWC engines are subject to the same restrictions as other marine engines, manufacturers are developing PWC with four-stroke and two-stroke DFI technology to reduce emissions. The new two-stroke engines are lighter and simpler in design than four-stroke engines, and some are almost as clean.

This does not mean that two-stroke carbureted PWC will not be manufactured after 2006. The EPA allows product averaging, which means that the “Family Emission Limit” (FEL) must meet or exceed applicable emission standards. This means that some two-stroke carbureted PWC will continue to be manufactured as long as their higher emissions are offset by other low-emission members of its engine “family.”

Neither the EPA nor CARB require boaters to dispose of carbureted two-stroke engines. The EPA estimates that old engines will no longer be used by the year 2050.

The CARB has estimated that the exhaust emissions from operating a PWC for seven hours is equivalent to the emissions from a 1998 passenger car operated for 100,000 miles. This means that one hour of PWC use generates as much air pollution as one year of automobile use. Because carbureted two-stroke engines exhaust through water, the pollution is received directly by the water body.

9. Recognizing the City's rationale for 'limiting its liability' by avoiding any sort of fee or permit system per RCW, what can be done to actually prevent or measurably mitigate any of the careless boating practices, short of closing the launch to watercraft using internal combustion engines? [Note this is already City policy at Lake Padden]
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The recommendations from the Motorized Watercraft Citizens Advisory Committee and the Lake Whatcom Management Committee include actions to change poor boating practices. Provision of a fueling area and a bilge dump facility are examples of very positive actions that the City can take to mitigate polluting activities.

10. Aside from the benzene spikes [public health issue] being discussed most prominently, what other concerns drive this discussion? [e.g. public/personal safety, nuisance & noise, the message conveyed by increasing unbridled use of a valuable and essential public resource for private recreation purposes]
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Although other issues associated with boating practices were recognized by both the Citizen’s Advisory Committee and the Lake Whatcom Management Committee, neither Committee made recommendations based on those additional issues.

11. What regulations are relevant to the recommendations? (Added)
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Both the State and City already prohibit the deposit of petroleum-based products into water, although neither regulation specifically refers to exhaust of such products into water.

RCW 90.48.080 states:
Discharge of polluting matter in waters prohibited.—It shall be unlawful for any person to throw, drain, run, or otherwise discharge into any of the waters of this state, or to cause, permit, or suffer to be thrown, run, drained, allowed to seep or otherwise discharged into such waters any organic or inorganic matter that shall cause or tend to cause pollution of such waters according to the determination of the department, as provided for in this chapter.

In addition, section 10.60.100 of the Bellingham Municipal Code states:
Deposit In Water Prohibited.—A. No person shall throw or deposit litter in any fountain, pond, lake, stream, bay, or other body of water in a park or elsewhere in the City of Bellingham. B. No person shall pour, allow to drain, discard, or otherwise introduce motor oil and other petroleum-based products, antifreeze, paint, or any other unauthorized substance including solid materials into any surface water drainage course or body of water, including but not limited to lakes, ponds, streams, creeks, storm water catch basins, storm water detention ponds, ditches, and storm water inlets, culverts, and manholes.
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