What have we learned (so far) from the Plano and Frisco chlorine burn results?

(1) When we compare each city’s January 2018 & 2019 PRE-chlorine burn TTHMs, there is little difference. However, when we compare their 2018 & 2019 MID-chlorine burn TTHMs, we see some significant increases this year.

When we averaged the 2018 independent test results and the most recent set of 2019 independent test results for each city, here’s what we found:

  • Plano’s average chlorine burn TTHMs increased from 73.1 ppb to 91.9 ppb.
  • Frisco’s average chlorine burn TTHMs increased from 80 ppb to 93 ppb (99.6 ppb if we count the highest concentration of TTHMs regardless of date)

(2) While Frisco provided more *rounds* of tests, Plano tested at the same point in the chlorine burn (3 weeks & 2 days) both years, making it easier to compare apples to apples.

(3) Plano tested at the pump stations (Frisco did not), which is where we saw some of the most dramatic increases. Why is that?

TCEQ is choosing not to test for TTHMs and HAA5 during NTMWD chlorine burn

Texas Commission on Environmental Quality (TCEQ) replied to our attorney, Chris Nidel’s, letter and request to test for disinfection byproducts (DBPs)during the upcoming 2019 chlorine burn. You can read their reply below.

To summarize, TCEQ is choosing not to test for TTHMs and HAA5 during NTMWD chlorine burn. While we strongly believe this goes against what Texas Administrative Code and the Code of Federal Regulations requires and seems ethically wrong (see our original request with documentation HERE), at the end of the day TCEQ is in charge of compliance for water systems in Texas. As such, moving forward, we encourage Safer Water North Texas members to continue to ask for your cities to run independent tests for these DBPs during the burn and make all resulting data publicly available. Both the cities of Plano & Frisco have already announced that they will be doing this during the 2019 NTMWD chlorine burn. Plano has gone a step further and suggested that they will include the data on their Consumer Confidence Reports as supplementary data provided for consumers to review. Since TCEQ is choosing not to collect data during this time frame, we believe this is the next best scenario. If you are a Plano or Frisco resident, please get in touch with your city officials to thank them for their willingness to test and make the results available; we applaud and sincerely appreciate their initiative and transparency.

https://saferwaternorthtexas.files.wordpress.com/2019/03/chloramine-conversion-process-response-letter-from-tceq.pdf

swntx_resp2

 

Some of the concerns expressed by our attorney remain unaddressed

SWNTX response to the reply from Sara R. Thornton to Chris Nidel sent on Feb. 13, 2019:

First and foremost, Safer Water, North Texas (SWNTX) is pleased to see that North Texas Municipal Water District (NTMWD) began implementing new monthly disinfection by-product (DBP) testing in December. We will be eagerly following the results of these tests along with tests run independently by member cities such as Plano and Frisco. This additional information is vital for the education of consumers who want to understand how DBP levels are impacted during the chlorine burn so they can make informed decisions for themselves and their families. We sincerely thank the cities that have chosen to run additional tests and make the results available to their customers.

Unfortunately, some of the concerns expressed by our attorney remain unaddressed:

• Will the water district’s new, monthly tests be considered “official”, with those results being submitted to the Texas Commission on Environmental Quality (TCEQ) and included in the annual Consumer Confidence Reports that are shared with North Texas citizens?

• Our letter was addressed to both NTMWD and the TCEQ. We have yet to receive a response from the TCEQ regarding how avoiding Stage 2 DBP monitoring during chlorine burns is legally or ethically justifiable, as Texas Administrative Code mandates that “All systems must monitor during month of highest disinfection byproduct concentrations.” SWNTX looks forward to receiving more complete, and timely, responses from both the NTMWD and the TCEQ, regarding these pertinent issues.

https://saferwaternorthtexas.files.wordpress.com/2019/02/swntx-official-response-to-ntmwd-feb-13-19-letter.pdf