Non-detect
– what does that mean? It does not mean that perchlorate is not
present in the water supply. It means that the city measured to 4
ppb. Anything under 4 is by legal definition termed non-detect
(ND).
Non-detect – what does that mean? It does not mean that perchlorate is not present in the water supply. It means that the city measured to 4 ppb. Anything under 4 is by legal definition termed non-detect (ND).
Perchlorate at 3.7 ppb or 2 or 1 could still be present. The city manager assuring the public that all is well is an illusion. He says all wells are “non-detect”. What you did not hear is that that the wells are “perchlorate free”. The non-detect term is misleading. It is presented to give us an assurance that cannot ever be acceptable.
On the city’s web page on this issue you will find misleading values. The city has given wells tested below 4 ppb (ND) a value of zero (0) as averages the readings. The average cannot be correct. You can not average a missing (ND) value. Unless there is another explanation, the zero in the calculation is in error and the findings skewed to reflect less contamination.
The table is filled mostly with NDs and the numbers behind them are missing. The city’s publication says that it is meeting federal safety standards. There is no federal limit; there are monitoring requirements which are different. The city manager cannot say that we are meeting federal safety requirements/limits because none exist. The EPA national assessment center has proposed a draft “reference dose” for perchlorate in drinking water of 1 ppb (epa.gov/swerffrr/documents/perchlorate_qa.htm). We are well off that mark.
I am not an alarmist but I am a researcher and legal limits cannot ever give us needed assurance. It can be based on averages, standard deviation and other general descriptive statistics. There are those that fall outside the mathematical curve and could be sensitive to any level of perchlorate even those within today’s legal limits.
It is difficult to think that a mother-to-be would drink or even cook with any water that contained any amount of “rocket fuel” even if it was within those same legal limits. She wouldn’t if she knew and as a city we have an obligation to warn her and her young children that non-detect does not mean free from perchlorate.
Legal limits – I love the term in this context. It is legislative-based not scientific. I envision bureaucrats in some “smoky chamber” determining risk, death rates and other political factors and determining for us what they could live with, regardless if we could or not.
The Bush Administration is fighting any review or regulation and has issued a “gag order” on the EPA. While bureaucrats are playing with our lives, the city is holding onto limits and continues to deliver water that could, in fact, hold legal amounts of the substance that with continuing research could prove to be harmful.
The city risks great liability knowingly distributing water that contains the toxin and could be found to be at fault tomorrow just as Olin is today. The most recent findings suggest health risks at lower levels and that 1 ppb should be the maximum contaminate level (MCL). Some states (New Mexico, Maryland and Massachusetts Maryland) have already adopted 1 ppb level. Our city executive is shielding the city with old studies and legal limits that we know cannot stand.
Some local officials tell us that it has not been proven that 4 ppb or 3 or 2 is harmful, suggesting that we wait perhaps years for federal authorities to tell us otherwise and to assume it is safe. This is just wrong. It should be that it is not safe until it is proven conclusively that it is. When it comes to the public’s health, we must err on the side of caution. What value system or ideology would justify otherwise? Bottom line: Perchlorate is a manmade toxin/carcinogen and should not be allowed to remain in our water supply at any level.
The Olin Corp. is dragging its feet, denying any responsibility for perchlorate north of Tennant Avenue. The firm says it’s physically not possible – but water can travel uphill from pressure, capillary action or through an unmapped channel. A legal battle is ensuing but we cannot afford to wait for the outcome.
We currently have a healthy reserve earmarked for this purpose. We should be using those resources to install equipment, accurate testing devices and securing additional services to make sure our water is 100 percent pure and safe to drink and bill Olin for the cost. The public cannot be satisfied with “non-detect” the public will find assurance only in a finding of “perchlorate-free”. Nothing in between can ever suffice. Any well that has been found to contain perchlorate should be taken off line immediately and remain off line until it is known to be pure or can be purified. Water quality and public’s health can never be compromised.
It’s time we had a Town Hall meeting.
Mark Grzan is an active member of the Morgan Hill community and a current member of the Green Belt Advisory Committee. He can be reached at gr******@*****on.net The Board of Contributors is comprised of local writers whose views appear on Tuesdays and Friday.
