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HomeMy WebLinkAboutDENALI VIEW General Information (16)MUNICIPALITY OF ANCHORAGE Department of Health and Human Services P.O. Box 196650 Anchorage, Alaska 99519..6650 Date: April 27, 1998 To: Elaine Christian, Director, DHHS Thru: Lura Morgan, Ph.D., Manager, Environmental Services Dlwsk~ From: es Cross, PE, Program Manager, On-Site Water Quality Subject: Response to Paul Myers' Fax dated April 22, 1998. I have read and have the following comments regarding the fax sent by Mr. Paul Myers to the Mayor on April 22: · The April 21~t meeting was requested by Mr. Myers to discuss the nitrate issue concerning the proposed Denali View subdivision. Mi'. Myers had not been told that this Department had additional nitrate information. In fact, Mr. Myers had been told on more that one occasion that the Department had no nitrate information that had not been previously made available to him. · It appeared that the main reason for the April 21~t meeting was to allow Mr. Dan Coffee, a lawyer representing Mr. Myers, to present a legal opinion regarding plat note,,;, and jurisdictional authority regarding plat notes. · I have previously responded to Mr. Myers concerning the "political pressure" and accusation that this Department cannot review scientific data and respond in a timely manner. This is addressed in question #9 in the attached letter to Mr. Myers dated April 24, 1998. This schedule shows the Municipality to be timely and decisive in its actions. · The Department did delay a response to Mr. Myers regarding a proposed plat note concerning this subdivision following the April 21~ meeting. The delay was due to the submittal to the Department of Mr. Coffee's legal opinion regarding plat notes, and a review of the opinion by a Municipal attorney. Mr. Myers was promptly informed of this delay, and its reasons. · Mr. Myers has a copy of my reasoning for recommending a plat note regarding nitrate reducing wastewater disposal systems. A copy of that memo is attached. MUNICIPALITY OF ANCH© AGE Department of Health and Human Ser¥ioes P.O. Box 196650 Anchorage, Alaska 99519-6650 Date: April 24, 1998 To: Zoning and Platting, CPD From:~J/~ ~t~es.. Cross, PE, Program Manager, On-Site/Water Quality Bruce Chandler, MD, MPH, Medical Officer Subject: Request for comments on the proposed Denali View Subdivision. I have reviewed additional information submitted on this proposed subdivision including a Modflow groundwater model performed by Bristol Environmental Services, h~c. I discussed this model in depth witl~ Mr. Gordon Nelson of the U. S. Geological Society. Mr. Nelson was recommended to me by, among others, Mr. Dan Young of Terrasat, h~c., who has reviewed the hydrological work done on this subdivision for the sun'ounding homeowners. Mr. James Munter of Bristol Environmental Services, Inc. stated that he could think of no other hydrologist more qualified to review this work.. My review of the information submitted by Bristol Environmental Services, Inc. involved addressing the following questions: 1. Was the model appropriate for use in an area with the geological attributes of Denali View Subdivision? The answer to this question is yes. Research and discussions with Mr. Gordon Nelson show that this model was appropriately used. The USGS uses this model in bedrock aquifers, and I found no reason to question this usage. 2. Was the data used in the model adequate and accurate? I found no gross inaccuracies in the data used, and, although the amount of data was small, I see no reason to burden the developer with additional expenses to acquire additional data. The model appears conservative in some areas. For example recharge data was not used, and the use of recharge data would have decreased the amount of draw down predicted by the model. 3. Were the assumptions used for the model reasonable? I found no reasons to question the assumptions used for the model. The size and boundary conditions of the model seem appropriate. The model could have been run with a smaller value for transmissivity, but a halving of this value would not cause a large ~hange in the model results. 4.. Did thc model run correctly and converge? Although the initial run of the model showed a percent discrepancy of-29.95, a subsequent run of the model with more iterations brought this discrepancy down to less that 2 percent, which is quite acceptable. 5. Do the results show an undue affect on the surrounding subdivisions? The results fi'om this model show that the impact on adjoining subdivisions will be minimal. The amount of draw down predicted by this modeI at the boundaries of the proposed subdivision will be just a few feet, which is less than the predicted seasonal fluctuation in the aquifer(s). I conclude that this model sufficiently indicates the availability of an adequate volume of water for domestic purposes for the proposed subdivision. The following comments address the issue of nitrates: Ingestion of excessive amounts of nitrate can canse adverse health effects in very young infants and susceptible adults. The United States I:*.nvironmental Protection Agency (EPA) has established a maximum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplies. This level is 10 milligrams per liter (rog/I)--often expressed as 10 parts per million (ppm)--measured on the basis of the nitrogen content of nitrate. This standard of 10 ppm nitrate-nitrogen was set to prevent the occun'ence of infant methemoglobinemia with a reasonable margin of safety. · Data available to the Department of Health and Human Services shows elevated nitrate levels in certain drinking water wells located in subdivisions adjacent to the proposed Denali View subdivision. Two wells in the surrounding subdivisions have levels in excess of the EPA MCL; another five have nitrate levels of 5 to 10 ppm. On-site wastewater disposal systems may be a contributing source of nitrates to wells with elevated nitrate levels. ,, Residents of neighboring subdivisions are concerned that future development may raise nitrate levels through reduction in water flow and increased nitrate loading within the aquifers supplying the wells within these subdivisions. · At present there is no data available to predict future trends in drinking water well nitrate levels. A study to examine trends in nitrate levels throughout the Mmficipality of ?umhorage is in progress; the results of this study should be available in phases over the next 24 months. · The Department of Health and Human Services has been studying and testing low-nitrate- emitting wastewater disposal systems for the past two years. Initial results indicate lfigh efficiency and reliability. However, these innovative systems have not been approved for general use within the Municipality at this time; the testing phase will be completed in the fall of 1998. · Should trend analysis and mapping demonstrate increasing nitrate levels, it may be judicious for the protection of public health to require use of low.-nitrate-emitting wastewater disposal systems for new and replacement systems in this area in the future. · The Department of Health and Human Services recommends the following note be placed on the plat: "Nitrate reducing septic systems may be required by the Department of Health and Human Services for the development of lots within this subdivision." FROM : MMM CONTRACTING PHONE NO. : 6881238 Apr. 08 1998 09:10AM Pi DATE; TO: FROM: RE: APPalL 8, 1998 ]TM CROSS · PAUL MYERS Fax Note 7671 Phone It QUESTIONS TN WRITING PER YOUR REQUEST What is Dill,iS nitrate level of concern? Are thc soils in Denali View acceptable for standard septic systems? Do you have any iuformation on increased nitram trend in Peters Creek? If so please produce it. Is hauling water a legal option for wells with nitrates in the Municipality 0f Anchorage? ls tasting intbrrnafion of nitrates in past years reliable'/ Are property values effected by infbnuation and policy of DHHS? Are you in close contact w/th Sharon Minseh? Does this have too much impact on your decision-making capabilities'? Are you available to discuss these questions and your answers? Could it: be perceived that the inaction and inability of DI-tI.tS to make decisions on Denali View is condemning the property? T/me is of the essence, your hnmediate reply is requested, Rick Mystrom, Mayor Department of Health and Human Services 825 "L" Street P.O, Box 196650 Anchorage, Alaska 99519-6650 April 24, 1998 Mr. Paul Myers Skyline View Corporation P.O. Box 6'70351 Chugiak, AK 99567 Dear Mr. Myers: have listed below the responses to your fax dated April 8, 1998. 1. What is DHHS nitrate level of concern? The United States Enviromnental Protection Agency (liPA) has established a maximum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplies. This level is 10 milligrams per liter (mg/1)--often expressed as l 0 parts per million (ppm)--measured on the basis of the nitrogen content of nitrate. This standard of 10 ppm nitrate-nitrogen was set to prevent the occurrence in infant methemoglobinemia with a reasonable margin of safety. Although available scientific data indicates no identified public health risk associated with consumption of water with less than 10 ppm nitrate nitrogen, the Depatlment advocates regular monitoring for drinking water wells with levels greater than 5 ppm. 2. Are the soils in Denali View acceptable for standard septic systems? From test infm~nation submitted, the soil strata used for on-site wastewater disposal systems within the Denali View subdivision are acceptable for these systems. However, less is known on the geology of the area, and the transport of nitrates from wastewater disposal systems. Should future trend analysis and mapping demonstrate increasing nitrate levels, it may be judicious for the protection of public health to require use of low-nitrate-emitting wastewater disposal systems for new and replacement systems in this area in the future. 3. Do you have any information on increased nitrate trend(s) in Peters Creek? If so, please produce it. I have no data available suitable for statistical analysis or for projection of future trends. 4. Is hauling water a legal option for wells with nitrates in the Municipality of Anchorage? Water storage and hauling is pet'miRed within the Municipality. The projected use of water storage is not justification for subdividing a property, but is allowable for a source on an existing property. 5. Is testing information on nitrates in past years reliable? The available nitrate data at DHHS was either collected by On-Site Services Section Staff of was obtained by the Health Authority Approval (ttAA) process. All work for HAA's is done under the supervision and stamp ora registered professional engineer. The Phase I nitrate study in the Anchorage Hillside area verified some existing data, and found the results to be consistent. 6. Are property values effected by information and policy of DHHS? I have no infmrnation on this topic. 7. Are you in close contact with Sharon Minsch? Does this have too much impact on you decision making capabilities? I usually talk with Sharon Minsch weekly. My contact with her does not affect my decision making at all. 8. Are you available to discuss these questions and answers? Yes 9. Could it be perceived that the inaction and inability of DHHS to make decisions on Denali View is condemning the property? There has not been inaction and inability to make decisions by the DI-IHS. Following the Platting Board meeting in November of 1997, I contacted both your engineer, Mr. Dee High, and your hydrologist, Mi'. James Munter, and asked them how they wished to proceed with this subdivision. I received no response until early March. I then promptly reviewed the infmTnation I had been given regarding the Modflow Model done by Mr. Munter, and rejected the submittal, for I had no information on the data or assumptions used in setting up the model. I then met with you, in a timely manner, and agreed to review the model and make a timely determination if the model was appropriate, and if the data and assumptions were acceptable. I did this review, and at first rejected the model. This rejection was timely enough for the model to be run again, reviewed again and accepted by the review deadline. I see no sign in these steps of inaction or the inability of DHHS to make a decision. j_~e~s~erely' ~ Program Manager On-Site Water Quality Cc~ Elaine Christian, Director, DHHS Lura Morgan, Ph.D., Manager, Environmental Services 04/24/98 P~RI 11:04 FAX 9073434?88 DHHS EhWIRON~IEN"rAL SVC$ [~002 MUNICIPALITY ANCHORAGE ])~pnr~ment of H~alth and Hulnan $~rvlces P,O, Box 1966S0 Anchorage~ Alnska 99519-66~0 Date: .April 24, 1998 To: Zoning and. Platting, Prom:~ ,/~/~....am'~s Cross, PE, Program Manager, On-Site~ter Quality Subject: Request for co~ents on the propose~ D~li View Sub~sion. _ I have rodew~ ~difio~ i~bmation ~b~'Xed o~ ~s proposed subdiwsmn including Me.ow ~dwat~ model pefformM by B~tol En~roment~ So~s, model ia dep~ ~ ~. Gordon Nehon of~e U, S. ~oio~e~ Society. ~. Nelson w~ re~m~d~ to me by, mong o~eN, ~. D~ Yomg of Teaa~at, h~e., who has re~ewed ~e hy~olo~eal work done on ~s submission for ~e s~ound~g homeomerz. ~. Jme~ Munt~ of B~stol Ea~nmcnt~ So.ices, ~c. stated ~at he could ~Jnk of~.o offter hydrolo~t more q~fied to re~ t~s work.. My re~ew of~c ~o~ation sub~ by Bdstol En~onmental Se~'iccs, ~. involw~d ~es~mg the foEo~ng queauom: 1. W~ &e model appropriate for ~ ~ ~ ~ea ~th rte geologic~ a~b~t~s of D~ View Subdi~on? Thc ~swcr to t~ question is ye~. K~ch ~d disc~msions ~th Mr. Gordon N:lson show ~at ~ model w~ ~pmp~ately used, ~ USGS uses ~s model ~ be~ock ~nifers, md. I fo~d no rouen to question ~ia usage, 2. Was ~a ~ta used ~ ~e modal adequate ~d ~ate? I fo~d no goss ~c~i~s in ~e ~ta used, ~d. ~ou~ ~a amo~t of~ta was sm~, I see no re.on to b~dan ~e developer wi~ addifio~ exposes to acquire ad~o~ dat~ model ~p~ co~e~afiw ~ some ~ess. For exmple reah~ge data w~ not used, ~d ~ use of r~b~ge da~ would have decre~cd ~e ~o~t of ~w do~ predicted by ~e mod~l. 3. Were flt~ as~mp~ons used fm ~e model re.enable? conditions of~e mo~el seem appropriate. ~e model coul~ have be~ mn with a smaller v~ue for ~ms~ssi~W, but a hflv~g of ~s value would not cause a lingo ~hange ~n ~e modal results. I00~ Su~uu~[d ~3Iunmluo9 0~9 ~g i06 XV~ fl~:[I 96/9g/~0 04/24/98 ~{! 1~.:04 FAX 907~434786 DHI{S ENVIRONMENTAL SVCS ~uo3 4. Did thc model mtn ¢o~ectly and convcr2e? showed a percent discrepancy of -29.95, a subsequent nm Although the trOt[al nm of the model ' of the modcl with more iterations brought this discrepancy down to less that 2 p¢,'ecnt, which is quite acceptable. 5. Do the results show an undue affect on the surrounding subdivisions? · · · o subdivisions will be fromm;d. The resul~ from this moctel show that the impact on adjoining: The ammmt of ctraw down predicted by this model at the boundaries of the proposed subdivision than fl~e redioted seasonal fluctuation in the aquifex(s). will be just a few fe,~t, which is less P I conclude that this model sufficiently indicates the availability of an adequate volume of water fx)r domestic purposes for the proposed suhdivi.~ion. Thc following commen~s address the issue of nitrates: · Ingestion of excessive amounts of nitrate eau cause adverse health effects in very young infants and susceptible adults. The U, fited States Bnvironmcntal Protection Agency (EPA) has established a maximum acceptable level, k~own as thc Ma~!mum Contaminaut Level (MCL), for nlt~atc in public drinking wat~ supplies. This level is l0 milligrams per liter (mg/l)-oftcn expressed as 10 pasts per million (ppm)--measur~t on the basis of the nitrogen content of nitrate. This staudard of 10 ppm nitratcmitrogen was set to prevent the occurrence ofinfaut methemoglobinemta with a rea~onablc ma~gin of safety. · Data available to the Department of Health and'Hunmn Services shows elevated hi,ate levels in certak~ drk~Ang wat~ w~lls located iu ~bdivisions adjacent to thc proposed Denali View subdivision. Two wells in thc mtrrotmding subdivisions have levels in excess of the EPA MCL; another five have nitrate levels o£5 to 10 ppm. , On-site wastewater disposal systems may he a contdbutittg source ofni~ates to wells with ¢lcvated nitrate level~. ...... e development may raise · P, emdenm of netg]abonng subdivisions are concerned that futur nitrate levels through red~tion in water flow and increased nitrate loading within the aqtdfers supplying the wells within these subdivisions. · At present thee is ~o data available to predict fntm'e trends in drinking wate~ well nitrate levels. A study to examine trends in nitrate l~vels throughout the Municipality of Anchorage is in progress; the results of this study should be available in phases over the next 24 months. · q.'kc Department of Health and Human Services has been studying and testing low-uitrate- emitting wastewater disposal syst~u~m for the past two years. Initial results indicate high efficiency and ~eliability. However, these i~movat{vc syst¢ms have not been approved for general use within the Muui¢ipality at this ti.me; the testing phase will be completed in the f~ll of_ 199~ · Should trend analysis and mapping dcnnonstrate increasing nitrate levels, it may bc judicious for th~ protcctlon of public haMth to require use of low-nitra;e-emitting waatewater disposal systems for new and ~epla~ement systems in this area in the future. · The D~parunent cfHealfl~ and Human Services recommends the following note be placed on the plat: "Nitrate reducing septic systems may bc reqnirexiby file Department of I-tcalth and Human Services fo~ the development of lots within this subdivision." gO0~ MuIuu~ld 2~Iunmmoo Ogg9 g~g ~06 XYA ~:~I ~6/~g/90 MOA HEALTH ~ HUMAN ID:3d3-6740 AP~ 24'98 1~:47 TRANSMIT CONFIRMATION REPORT NO. : 003 RECEIUER : 907 343 4583 TRANSMITTER : MOA HEALTH & HUMAN DATE : APR 24'98 14:47 DURATION : 01'43 MODE : STD PAGES : 02 RESUI_T : OK Rick Mystrom, Mayor Department of Health and Human Services 825 'L" Streel P.O. Box 196650 Anchorage, Alaska 99519-6650 April 24, 1998 Mr. Paul Myers Skyline View Corporation P.O. Box 670351 Chitgiak, AK 99567 Dear Mr. Myers: I have listed below the responses to your fax dated April 8, 1998. 1. What is DHHS nitrate level of concern? The United States Environmental Protection Agency (EPA) has established a maximum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplies. This level is 10 milligrams per liter (mg/1)--oiSen expressed as 10 parts pet' million (ppm)--measured on the basis of the nitrogen content of nitrate. This standard of 10 ppm nitrate-nitrogen was set to prevent the occurrence in infant methemoglobinemia with a reasonable margin of safety. Although available scientific data indicates im identified public health risk associated with consumption of water with less than 10 ppm nitrate nitrogen, the Department advocates regular monitoring for drip,king water wells with levels greater than 5 ppm. 2. Are the soils in Denali View acceptable for standard septic systems? From test infm-mation submitted, the soil strata used for on-site wastewater disposal systems within the Denali View subdivision are acceptable for these systems. However, less is known on the geology of the area, and the transpm't of nitrates fi`om wastewater disposal systems. Should future trend analysis and mapping demonstrate increasing nitrate levels, it may be judicious fbr the protection of public health to require use of low-nitrate-emitting wastewater disposal systems for new and replacement systems in this area in the future. 3. Do you have any information on increased nitrate trend(s) in Peters Creek? If so, please produce it. I have no data available suitable for statistical analysis or for projection of future trends. 4. Is hauling water a legal option for wells with nitrates in the Municipality of Anchorage? Water storage and hauling is permitted within the Municipality. The projected use of water storage is not justification for subdividing a property, but is allowable for a source on an existing property. 5. Is testing information on nitrates in past years reliable? The available rdtrate data at DHHS was either collected by On-Site Services Section Staffofwas obtained by the Health Authority Approval (HA_A) process. All work for HAA's is done under the supervision and stamp ora registered professional engineer. The Phase I nitrate study in the Anchorage Hillside m'ea verified some existing data, and found the results to be consistent. 6. Are property values effected by information and policy o f DHHS? I have no information on this topic. 7. Are you in close contact with Sharon Minsch? Does this have too much impact on you decision making capabilities? I usually talk with Sharon Minsch weekly. My contact with her does not affect my decision making at all. 8. Are you available to discuss these questions and answers? Yes 9. Could it be perceived that the inaction and inability of DHHS to make decisions on Denali View is condemning the property? There has not been inaction and inability to make decisions by the DHHS. Following the Platting Board meeting in November of 1997, I contacted both your engineer, Mr. Dee High, and your hydrologist, iVh'. James Munter, and asked them how they wished to proceed with this subdivision. I received no response until early March. I then promptly reviewed the information I had been given regarding the Modflow Model done by Mr. Munter, and rejected the submittal, for I had no information on the data or assumptions used in setting up the model. I then met with you, in a timely maturer, and agreed to review the model and make a timely determination if the model was appropriate, and if the data and assumptions were acceptable. I did this review, and at first rejected the model. This rejection was timely enough for the model to be run again, reviewed again and accepted by the review deadline. I see no sign in these steps of inaction or the inability of DHHS to make a decision. f~erely, ~ erogi a m~Man~ge~ater Quality J~¢~es Cross. PE Ce~ Elaine Clu'istian, Director, DHHS Lura Morgan, Ph.D., Manager, Environmental Services ,q MOA HEALTH g HUMRN ID:343-6740 APR 24 _8 14:0~ NO. RECEIVER TRaNSmITTER DATE DUI~ATION P~GES RESULT 001 907 343 4583 MOA HEALTH & HUMAN APR 24'98 01'21 STD 02 OK 0,W27/98 I~t~ CDNTRRC'F [ N~ PHONE NO, ,~ION 08:19 FAX 907 343 SKYI,INE ViE CORPORATION P. O. Box 670351 C'hugbk, Ak. 99567 MOA OPERATIONS ~[GR ~ III'IS ~001 6881238 Po~t-it' I~x No~o 7071 Apr. 27 [cJ05 07~ 14AM P1 DATE; TO: FAX TI*,_ANSMITTA1. APRIl. 22, 1998 MAYOR lUCK MYS'rROM No &pages ........ FROM: PAUL MYERS D£NA].,I VIEW, NrrRATE. NOTE ON THE PLAT On April 2!. 1991~ l attendod a me~ing with Jim Cross from tho- l-loalth Dopartment. We had requested a m,efing wflh Elaine Christian, however she was not available, so Lure Morltan was present as wall as Dr. Brace Chandbr, Jira Cross, Jim Munter, D~ Coff~, Arl~on Myers and mysol£ 'rhi~ m~ting wag called to go over the nitrate issue and lo this issue s©ttl~i on Denali Vi~:w. We sut i, this meeting and Jim Cro,~q had nothing ~y a~out nitrates, ho had no infom~ation available that he wa~ b~ing his uit~'m~ nm~ it was our un,minding he was going to ~v~ the information at this m~ting for us over, ~is w~ promised ate p~viout meeting. TM lack of~spons~ msultod in ampi waat~ of*vory~y'a timo. This is ~at has b~n going on for a y~r ~w. W~ have s~nt a y~ar's ~ffoa t~ing m resolve this in a process thai has b~n ~olifidt~, q'hero has ~a ~o much ~fl~tleal ~ ssu~ bearing on Jm Cross ihat it ha~ m~ him wh~ro cannot re, iow th, scientific fans and do his job. At ~o ~nelusion oflhis meeting Mr. Cross promis~ to have ~h}~..)nf6rmation ~o u~ 4:00 p,m, At 4:00 p.m. he called and said that sin~ we had breast up a qaesuon m me legali~ of putting a note on the phs t~t Ma. ~ Resdh Doputy Municipal Attorney the legal de~rtm~nt Ms ~s~ him not to give us any ink}marion, Thb is ridiculous as one ia a leal qnes~on, the other is a s~jentifie question as ~o whgther hu should ~iantifieally M maiming the ni~to no~ on the plal in Ih~ first place, 2he legal questi~ ~n ba solvM through legal m~ans l~ sdentific question n~ds to be gone over wilh the ~ngin**ra ~ ToirlOrfOw i5 tho d~linc for r~mmendations to'be pro~nted m communi~ planning and Mr, Cross afi*r all th~ time has hil,d to supply any scientific ~view of the suplmrting his mcommcndati~ tbr a nitrate note on t~ pl~t. ,/ Any assistance you ~ ~v* in this matter is appreciated. Timo is orlh, case;me, your imm~iam response is roquust~. CC: Jim Cross Luna Morgan FROM : MMM CONTRACTING PHONE NO, : 6881238 Apr. 17 1998 08:08AM P1 SKYLINE ViEW CORPO]LttT1ON p. o. Box 670351 Chugiilk, Ak. 99567 Phone: 688-I 237 Fax: 688-1238 DATE: FAX TRANSMITTAl, April 17, 1998 No. of pages~/ TO: JIM CROSS FROM: AR[/EEN MYERS RE: DENALI VIEW SUBDIVISION - NrI'RATE NOTE ON PbAT This is a request to set up a meeting to discuss the proposed nitrate note on the plat. We request that Mr, Bruce Chandler, Ms. Lure Morgan, a representative £rom the Mayor's Office, Mr, Jim Munter, Mr. Dee High, Mr, :Dan Coffee and ourselves to all, nd, We understand Mr. Chandler is only available in the mornings. Please set this meeting up for around 10 or 10:30 a.m. on either Monday or Tuesday if at all possible ns time is of the essence in this matter. APR Z 1998 ' Municipality of Anchorage , Jept. Health & Human Services Rick Mystrom, Mayor Department of Health and Human Services 825 "L" Street P.O. Box 196650 Anchorage, Alaska 99519-6650 Apfil17,1998 Mr. James A. Munter CGWP Principle Hych'ologist Bristol Environmental Services Corporation P.O. Box 100320 Anchorage, AK 99510 Dear Mr. Munter: I have reviewed your Modflow Model information concerning the proposed Denali View Subdivision. My review of the model involved addressing the following questions: 1. Was the model appropriate for use in an area with the geological attributes of Denali View Subdivision? The answer to this question is yes. Research and discussions with Mr. Gordon Nelson of the U. S. Geological Society show that this model was appropriately used. The USGS uses this model in bedrock aquifers, and I found no reason to question tlfis usage. 2. Was the data used in the model adequate and accurate? I found no gross inaccuracies in the data used, and, although the amount of data was small, I see no reason to burden the developer with additional expenses to acquire additional data. The model appears conservative in some areas. For example recharge data was not used, and the use of recharge data would have decreased the amount of draw down predicted by the model. 3. Were the assumptions used for the model reasonable? I found no reasons to question the assumptions used for the model. The size and boundary conditions of the model seem appropriate. The model could have been run with a smaller value for transmissivity, but a halving of this value would not cause a large change in the model results. 4. Did the model run correctly and converge? Although the initial nm of the model showed a percent discrepancy of -29.95, a subsequent mn of the model with more iterations brought this discrepancy down to less that 2 percent, which is quite acceptable. i)EF'T. OF ]ENVIRONMENTAL CONSERVATION OFFICE OF THE COMMISSIONER TONY KNOWLES, GOVERNOR 410 Willoughby Ave., Ste 105 Juneau, AK 99801-1795 PHONE: (907) 465-5065 FAX: (907) 465-5070 hnp://www.state.ak.us/dec/home.htm Dan Coffey Attorney at Law 207 East Northern Lights Blvd, Suite 200 Anchorage, AK 99503 Dear Mr. Coffey: MCS9g.048 I've received your letter asking that the Department of Enviromnental Conservation (DEC) "withdraw" two letters written by department staff regarding the Denali View Subdivision. Specifically, you asked that the department inform the Municipality of Anchorage and the Platting Board that they should not use or rely upon Keven Kleweno's letter of August 5 nor James Weise's letter of February 22 when making any decisions regarding the Denali View Subdivision. As I previously explained to your client, Paul Myers, the department will not "withdraw" these letters. You state in your letter that DEC is not authorized to do subdivision plan reviews and, therefore, Mr. Kleweno has acted outside his authority. Mr. Kleweno's letter is not a subdivision plan review. In fact, Mr. Kleweno's August letter was the result of a request made by Dee High, your client's engineer, to review information relating to the proposed subdivision. The February 22 letter by Mr. Weise xvas the result of your request to DEC to review Mr. Kleweno's letter. You state that this letter should be withdrawn because it does not consider all of the information now available on the proposed subdivision. Mr. Weise's letter was based upon the information available to the department at the time. When we were told there was additional information not factored into Mr. Weise's letter, we offered to ensure our public records are complete by adding that information. We also offered to provide copies to both the Municipality and the Community Council. However, we cannot be expected to revise letters continually as new information is developed. All analyses reflect information available at a given point in time. Both the Municipality and the Platting Board are experienced enough to know that. Your specific point on the February 22 letter regarding the information on the Troll Knoll subdivision has already been corrected. Attached, you will find a copy ora letter that was sent to Mr. Myers dated April 2 which further explains the department's findings of the nitrate levels in this subdivision. Jim Cross with the Municipality was copied on this letter.---.._.__ The Municipality has made it clear that it will use a number of sources of information for its review of this proposed subdivision. DEC is just one of them. We cannot remove a document from the DEPT. OF ENVIRONMENTAL CONSERVATION DIVISION OF ENVIRONMENTAL HEALTH DRINKING WATER AND ~VASTEWATER PROGRAM 555 Cordova Street Anchorage AK 99501 http://www.state.ak.us/dec.home.htm TONY KNOWLE$, GOVERNOR (907) 269-7647 (907) 26%7655 April 2, 1998 Paul Myers P.O. Box 670351 Chugiak. AK 99567 Subject: Troll Knoll Subdivision. PWS #210778, nitrate levels. Dear Mr. Myers: This letter provides the follow-up from our March 27, I998 meeting, in which you requested clarification of nitrate levels in the Troll Knoll Subdivision public water system (PWS) as reported in my February 22, 1998 letter to Mr. Dee High. I stated in my February 22. 1998 letter that, "The Class "A" PWS located in Troll Knoll is of most concern because its' nitrate levels have increased from non-detect in 1982 to 8.2 mg/L in 1992." Drinking water samples collected May 27. 1980. June 1. 1988, and March 4, 1992, had nitrate levets that were non-.detect (ND), 1.2 rog/L, and 8.2 mg/L respectively. These samples do represent a noticeable and significant increase over time (please refer to the attached graph showing nitrate levels in the Troll Knoll Subdivision PWS). The sample which tested 8.2 mg/L is over the action level (AL) which is 5.0 mg/L. and is only slightly below the maximum contaminant level (MCL) for nitrate which is 10.0 mg/L. Samples that have nitrate concentrations above the AL require a PWS to begin quarterly monitoring tbr nitrate rather than annual monitoring. Basically. the AL for nitrate is a "health advisory" and requires the PWS. or the State, to become proactive in a preventive manner to additional contamination. A sample that exceeds the MCL is both a public health tN'eat and a reportable violation of the State Drinking Water Regulations. Nitrate levels did show an apparent decline in the Troll Knoll Subdivision PWS from the hio~h of 8.2 mg/L in 1992, to a low of 1.91 mb/L in a sample collected August 17, 1994. However]'it is important to note. that nitrate levels have steadily increased in the Troll Knoll Subdivision PWS from the low of 1.91 mg/L in 1994. to 4.50 mg/L from a sample collected December 17, 1997. This most recent sample, as well as the overall increasing trend in nitrate levels since 1980. and especially since 1994, is a concern to the Department. The most recent sample is just under the AL for nitrate. FROM HMH CONTRACT lNG PHONE : 6BB127B Apr. 21 1998 ll:23AM P1 SKYLINE VIEW CORPOlkRTION P, O, t:lOX 670351 Chub. ink, AK. 99567 I)A FL. April 21, 1998 TO: JIM CROSS FROM: PAUL MYERS Post-it* Fax Nots 7671 Oo./DSpb ~ Phone: 6f48-1237 Fax: 688 ,.1238 8ItARON MINSCH HAS BROKEN CODE OF MORALS AND ETHICS Sharon Minsoh ha~ broken thc oode of morals and ethios with a eampai~ of misinformation, behind the scenes manipulal, ions designed for deslructive purposes. I am mquesling Sharon Mh~seb, Prestdenl of lbo Chugiak Community Council lo resign from fl~e Water Tcch Boar~, The impartial honest and fair treataten~ of Denali View Subdivision did noi occur. The scioniific inlbmmfion was ~cmtinized in unfair mannem Sharon Min~ch, President of the Chugiak Community COlmC{I pnlilicized thi~ i~me wifll a cam~ign designed to refute thc scientific reports and coufuse the issues. She misused her ~lifical connections to infltmoce l~ople in ADEC to bc involved ~n a ptqiudi~d way lo defeat Denali View. Polidcs thai include misinformation lo the public on volatile issues of water, which incases many people to do things, they would not normally do. Poli,kdan Shm'an Minseh should not be on lhe MOA Water Tech Board. Mar biased actions show she is incapable of using ll~e position honestly and objectively. Because of Sharon Minsch'a fanallzal approaoh liar impact on water issues aaa only lead to imbalance and is unconstmctivc, 8heron Minseh only knows the power of destruction and does this ¢ommunit~ tremendous harm. She proudly states"My involvement in tho light against the, septic ordinance several years ago earned me the title, Queen of Crap. I aho lead a pnblie, campaign that stopped tho Mirror Lake Sewer Lagoon." Sharon Minsch ha~ let this title go to her head. Sharon Minseh, President of the Chugiak Community Council should be asked to resign immedlaloly f'rom the Water Teeh Board. CC: Mayor Rick Mystrom Elaine Christian, DHHS I,ura Morgan, Dllll~q Rep. Vie Kohring Ombudsman Mtohollo Brown, ADEC Oct. 12 1997 0-?:58AM P1 FROM : PHONE NO. : ' 7 I~l~lllrll llll i J Ms. Elaine C~¢art, Director DI-~IS RB; D~mli Vi¢~v Blalno Christian debt,mom the st~toun~ng The r~sidents itl this area hired Ten. sat lnc, 'co deterfnJllo wlmt ~'as the can~ c~ wale, r qn.nfi~ and te~S, aerial ~oto~¢S, ~trate t~ts, ~d ~stot Environn~n~l r~ds, They detormz~ t~t this tr ar~ of rte Monn~ Ms ]lido if mW ~bw~, T~at u~d written ~stialo~ from ~a ; t~ ~le~'how many ~ople we~ ~ao~y ~c~d and ri wMt u~er. 23 hoa$chol6s surrOlutding Detmli View agreed to allow be tested this relxesertts ~rox. 92% ~ ~e ben.holds wit~ 1000 ff of ether Denali ~n a~ ~¢~ously on moaermts ~casions to alter their Hold to ass~¢ ~t no harm would ~mo to the ~ny 0~mets, they ~vom stat~l at a public ,, omfld ~ n~stcd to fix any pro~l~s t~lt o~u~ as a teault Or sod to lan tlfi~ m writing, If thc ~v¢l~r a~d not ca~ tp ~ll~ one ~ their mvn, Cer~mly, they were shown flint rite a the M~d*ling rOlX,n. Jim Cross atalodLh~ ~as not ~'c~ ed lo a~p[ m~dlng until ~cr ~$ wcrc ~c ~ ¢~l~o a ~um~atb~ plm~ ~*ith ~e commwdty. Nv w lt~ lm~ uigu~ ~ memo (~utI~) with tAo ~'clo~rs smtlng hz will r~ie~v ~m~hi~ he was UOI reviow~ ~o~rly it muot ~ r*vi¢w*d by ~ hy~m-goolo¢$t UfiO8 ~ a~d to i~n~nOy r~i~v ~ work. ~e ~si&m* of thi$ arcs ~li~c all wod¢ from ~th Bristol Term~t Ino, sho~d bo i~ndontly tm, lowed to fakly a~sess the present r~om;~n~ w~t 8hould ~ dou* ~ allow thio ,u~ivi¢o~ to ~ built pro~rty, no ~olid c~lunion ¢m ~ 1~ from tho cu~t m~oli~, Om' te~eamh ~¢atog ~t the Me.ow Mo&l i~ not &till ~r ~k aqt~m. It wmdd alto ~nx tlmt ff we ~d a 5OOfi-~d~k aq~er (a~ M~cated on the ~e~a) we would klve ~m watel quantJ~ problem~ in fbi* ama. Sincerely Ieffr~yD W lliam~ TO: PLATTING BOARD AUTItORITY FROM: SKYLINE VIEW CORPORATION RE: DENALI VIEW SUBDIVISION S-10054 DATE: APRIL 1 1998 THE PURPOSE IS THIS MEMO IS TO REQUEST A CONTINUANCE OF THIS ABOVE REFERENCED MATTER BASED UPON DISCUSSIONS WITH THE DEPT. OF HEALTH AND HUMAN SERVICES OF THE MUNIC~ALITY OF ANCHOR_AGE. TItlS CONTINUANCE IS REQUESTED IN OP, DER TO ALLOW DHHS TO REACH A CONCLUSION ON THE QUESTION OF WltETHER OR NOT PLAT APPROVAL 14~.VE A SUBSTANTIAL EFFECT ON THE SU1LROUNDING NEIGHBORHOOD. THE POSTPONEMENT IS ILEQUESTED TO ENABLE DHHS TO DO THE FOLLOWING: BRISTOL ENVIRONMENTAL CORPORATION SUBMITTED A MODELING REPORT DATED FEB. 9, 1998 IN RESPONSE TO THE DIRECTIVES OF THE PLATriNG BOARD NOV. 5, 1997 FOR REDESIGN. THE DHHS SHALL REVIEW THE MODELING REPORT, THE DATA AND ASSUMPTIONS UPON WHICH THE REPORT IS BASED TO DETERMINE IF THEI~E ARE ANY SUBSTANTIAL OR MATERIAL DEFECTS OR DEFICIENCIES IN ~I-IE MODEL WHICH WOULD ALTER THE CONCLUSIONS IN TIlE MODELING REPORT. IF DHHS CONCLUDES TIIAT THERE ARE NO MATERIAL OR SUBSTANTIAL DEFECTS OR DEFICIENCIES IN THE DATA OR ASSUMPTIONS, THEN THE MODELING REPORT CONCLUSIONS WILL BE DETERMINED TO BE VALID AND DHHS WILL RECOMMEND PLAT APPROVAL. IF DHHS DETERMINES TH&T THE DATA AND THE ASSUMPTIONS IN THE MODELING REPORT ARE NOT VALID AND THAT THERE MAY BE SUBSTANTIAL EFFECT ON THE SURROUNDING NEIGHBORHOOD, DHHS SHALL RECOMMEND DENIAL OF THE SUBDIVISION AND SI-IALL STATE CLEARLY AND CONCISELY EACH AND EVERY REASON FOR SUCH RECOMMENDATION. DHHS AND THE PETITIONERS REPt~ESENTATIVE SHALL MEET, REVIEW AND DISCUSS THE MODELING REPORT AND THE DATA AND THE ASSUMPTIONS IN A TIMELY FASHION TO PEILMIT DHHS TO SUBMIT ITS REPORT PRIOR TO APRIL 17, 1998. DURING THIS PROCESS DHHS AND THE OWNERS REPRESENTATIVE SHALL DEAL DIRECTLY WITH ONE ANOTHER. PUBLIC COMMENTS CAN BE MADE AT THE CONCLUSION OF DHHS REPORT. DURING THE COURSE OF THIS PROCESS TIlE IDEA OF WELL TESTING HAS BEEN DISCUSSED EXTENSIVELY. IT IS AGREED 'II4AT NO FURTHER PUMP TESTS WILL BE REQUIRED FOR DHHS TO MAKE ITS DECISION. 5. AS TO THE ISSUE OF NITRATES, THE QUESTION OF A PLAT NOTE WILL BE FURTHER DISCUSSED BY DI4~tS AND THE OWNERS REPRESENTATIVE. SHOULD DHHS DETERMINE TItAT A PLAT NOTE IS APPROPRIATE, TIlE OWNER'S REPRESENTATIVE WILL BE ABLE TO PARTICIPATE IN THE DRAFTING OF THAT NOTE. 6. THIS~APPLICATION WILL BE ttEARD ON MAY 6, 1998. ~ //~ SKYL~'JCIEW CORP ORATION CONCh: /JAM/~ CROSS, P~I~ 04/03/18 14:57 ~907 344 1490 DAN YOUNG ~001 ! ]!! ~0g!¢~i:C0ns,lt!~!g .~ Envtr0~.!n~nbal Re~st0ra.~9~ ~ · ]!~![!~ Cgmpl~ I ~"fl~l'g~'] ..... II [ ' ~1 ~l [ I I' I I I ill I~te. ~1031~ ~e. 1.27 PM ~X . To: ~a~e ~ .~o~: 9073436718 ~ . ~A D~ :F~: ~7 343 6740 ~ l~ Bffi ~me Phone: ~7 3~ 9370 ~SAT ~C. ~F~: 907 3, 149y Re: J~ Cro~ letter - Den~ View GrGund Water Model~ Eviction T~qu~ CC: Sharon ~ch,CCC, James Fddedd, ~q., ~a~ ~okos~-D~, E~h~e DHHS, Jeff W~m -Scholar tlo~ome~ Page~ including cover sheet: 5 [-1 U~'gent ~ For Review [] Please Comment [] Please Reply [] Please Recycle · Message: Ms. Clidstiml, Attached please find the April 1, 1998 Paul Myers letter concerning a continuance of the prolx>sed Denali View Subdivision, signed by Mr. Cross, and our letter sent to Mr. Cross oa April 3, 1998. 04/08/18 14:59 ~'907 344 1490 DAN YOUNG ~002 TO: PLATTI~O BOARD AUTHOrdR~ FKOM: SKY'LIN]{ VI~W COrd'ORATION DEN'ALI VI~W SUBDIVISION S-I0054 DATE; APRIL 1 1998 TIt~ PURPOSE IS qqIIS ~O IS TO RrQUES'r A CONTINUANCE OF TH/S ABOVE rd~FER]~CED MATI~R BASgD UPON DISCUSSIONS WITIt TH~ DI:.PT, OF tE~ALTtt AND tlYJMAN SERVICES OF 'i'f~ MUNICE~AI]TY OF ANCHORAGE. TIILq CONTINUANCE IS P, EQUEMq'ED IN ORDER TO ALLOW DHHS TO P,~CI{ A CONCLUSION ON TH]S QUESTION OF WHETKER OKNOT PLAT APPROVAL HAVE A SUBSTA~XYU_AL KFI~CT ON TKB SURROLtNDING NEIGHBORHOOD. TH~ POSTPONFaMENT ]S REQUESTED TO I~qABL~, DHHS TO DO TH~ FOLLOWING: 1. BRISTOL ENVIRO~AL CORPORATION SUBMIITED A MODELING P~POI%T DATED FEB. 9, 199S IN RESPONSE TO TH~ DIKECTIVES OF THE PLA'r llNG BOARD NOV. 5, 1997 ~OK REDESIGN, ~I-[E D~r~.q SHALL REVIEW TIq~ MODEL/NG REPORT, ~ DATA AN]) ASSUMP'gONS UPON V~CH 'rlq~ KEPOI[T IS BASED TO DETI~RMINH 1F Tl4q~[l~ AKE ANY SI/BSTANTLAL OK MATE. rdAL DEFECTS OK DEF[CFRNCIES IN ~ MODEL WHICh[ WOULD ALTHR THE CONCLUSIONS IN THE MODELING R~PORT. IY DHI{S CONCLUDES Ti{AT THEKE ARE NO MATE~ OP. SUBSTA/qTIAL DEFECTS OK DF~ICTgNC~S IN THE DATA. OR. ASSUIv~TIONS, THEN ~ MODBq/ING KEPORT CONCLUSION~ WILL. BE DETERMJNIfD TO BE VALID AND DHHS WILL RECOMMEND PLAT APPROVAL. 2. I1~ DHIqS DETERMINI~q THAT THE DA;rA ,AND TI{E ASSUM2TIONS IN T}IE MODELING KEPORT ARE NOT VALID AND THAT llikRE MAY BE SUBSTANTIAL ~PPECT ON THE SqJRROUNDINO NEIO~HBORHOOD, Drg4S~ SHALL P~COMMEND DENIAL OP THE SUBDMSION AND SHALL STATE CLP_AKLY AND CONCISELY ~CH AND EVEKY REASON FOP, ,%~JCH RECOMiVIF2qDATION. 3. DHH8 AND THE PBqTrIONERS REPKESENTAT]Tv~ SHALL MEET, REVIEW AND DISCUSS THE MODF~LIN(} RItPOKT AND TH~ DATA AND THE ASSUMPTIONS IN A TIiV~LY FASHION TO PERMIT DHtL$ TO SUBMIT 1TS KEPOKT PRIOR TO APRIL 17. [998, DUKING THIS PROCESS DHI-IS AND '11-1t~ OWNERS llEPP~SENTATIVE SHALL DEAL DIRECTLY WITH ONE ANOTI{EIL PUBLIC COMNI~2qTS CAN 'BE MADE AT TKE CONCLUSION OF DMMS REPORT. 4. DUrdNG TIIE COURSE OF TIES PROCESS, THE IDEA OF WELL TESTING }LAS BEEN BE DISCUSSED EXTtSN$IVELY. IT IS AGR~,~D THAT NO FUR//tEK PUMP TESTS WILL REQLrIRED FOR Dt{ItS TO MAKE ITS DECISION. 5. AS TO ~ ISSUE OF IqYI~RATES. THE QUESTION OF A PLAT NOTE.WILL BE FURTKER DISCUSSED By DKI-IS AND THE OWNERS RBPRESENTATIVE, SHOULD DttHS DETERMINE THAT A PI,AT NOTE !8 APPROPRIATE, THE OWNER'S REPRESENTATIVB WILL BE ABLE 'ro PARTICIPAT6 IN IHE DtLAFIq/qG OF TEAT NOTE. ror no CO.cow:, A : os? DfaS .,, 04/03/18 15:02 8907 344 1490 DAN YOUNG ~003 TERR'AS' INC. ' " "-'-- 9200 Lake O~is Parkway 2nd floor, Anchorage, Alaska 99507 (907) 344-9370 Fax: (907) 3444490 Geolagical Con.qu?ing ,, Envlvonmental Re~torat~on · Regulatory Com[~t~mce[ April 2, 1998 Mr. Jim Cross, P.E. Municipality of Anchorage Depm'~ment of Health and Human Services Environmental Services Division 825 L Street, Room # 50'2 Anchorage, Alaska 99519-6650 KE: Denali View ground water modeling ewd.uation techniques Dear Jim: This letter is a follow up to our meeting today, q'q~e Homeowners of Scimitar Subdivision axe very concerned that the ground water m,odel reported by Bristol Environmental Services is based on speculation and invahd assumptions~ As we pointed out in our March 20 letter, Bristol fised an aquifer thickness of 500 feet. This is not a reasonable assumption based on the more than one hundred well logs that we reviewed. Our experience suggests that mo~t of the rock aquifers have thicknesses of 5 to 30 feet. ThiDker values would unreasonably skew model results showing much more available water than what is actually availabI~e. Bristol did not report most of t!~e wdues: that they used in their modeli,ng. The homeowners have tdred TERRASAT INC. to independently review Bristol s model. However, an h~dependent review cannot he:done without their data. One of the most common tnistakes in model/nB is unit conversion (see McDonald & l-Iarbaugh, 19~]4, pg.46). If the data isn't checked by a peef review, then the model must be approved on faith. We request the data be available to the public for 30 days before recommendations are made to the Platting B6ard. Modflow was not intended by the USGS fqr use in rock. While Bristol discuss how accepted the USGS model is, they fail to report that they nmy have misapplied the model to the conditions in t ~e Denali View ~ea (refer to the memo by Roy h'eland of Feb. 27, DNR). If Morrow is applied to a rock aquifer, the model then ass~mes that the rock behaves as a porous media and flow is cantinuous from cell to cell. This requires cell size to represent actual rock fracture spacing. This phenomena is omitted in Bfistol's report. We question the rationale for grid spacings that range from 106 to 850 feet (page 6). As we pointed out in om' March 20 letter, Bristol's general concept is flawed. Th, ey used the 'rheis method to predict 20 feet of drawdown 600 feet from the producbon well after 180 days..~T?? omitted that draWdown at the production well would be 158 feet, which is much greater than the available drawdown in Dena.ii View wells. These simulation results suggest that the model inputs arc not reasonable and that thcy.haye not been properly calibrated, since the simolation has shown drawdown that exceeos tl~e available ground water. 04/08/18 15:03 ~907 344 1490 DAN YOnNO ~004 Bristol estimated a transmissivity of 5.4 ~day based on a calanlated geometric mean from av~able data. However, they used a ttansmissivity of 10W/day for their Modflow model (page 5). This would bias their results to show more favorable flow conditions. We believe a detailed discussion is warranted on how they selected transmissivity and why they think it is repre,sentativc of the model area. Bristol calibrated thckr Modflow model frown the two wells at Denali View that were flow tested. This does not constitute a model calibration (ASTM D 57-18 3.1.3). If the model is not calibrated on reasonable data, the probability is low that the model could reasonably represent conditions in the Den'ali View area. We could continue to ask questions about the reasonableness of the model but believe Bristol should first provide their data inputs and rationale for how the inputs are representative of sit~ conditions. The info ,r!nation we are requesting is expected for a valid model (see AS rM D 5718). Based on Bristol's report, we conclude that 'the tr~msrnissivity and aquifer thickness are not represenh'~tive of site conditions and are not reasonable approximations. The model is not calibrated on valid data (only two e!ose]y spaced points). Thus, conclusions from the model results are wrong and should be ignored. I have included a list of publications that are useful references when evaluating ground water models. Many of these are available from the National Ground Water Association or fi'om the American Society of Testing Materials. Aa I discussed today, Gordon Nelson of the United States Geological Survey ia available to provide the Municipality an impartial review of Bristol's model. The USGS developed Modflow, and Dr. Nelsoh has been using this model since at least 1986. Because of the number of families that could be adversely affected by erroneous model results, we urge you to seek Dr. Nelson's impartial expertise. You may also Fred someone with Modflow experience at the Co~ps of Engineers that would be willing to provide an impartial review. ; If TERRASAT INC, can provide additional information, please feel welcome to call. Sincerely, Dan Young Principal hydrogcologist Cc:: Jim Frklerici, Esq. Honorable Mayor Rick Mystrom Sharon Minsch, Chugiak Communit3; Counci} Gary Prokosch, DNR Elaine Christian, DHHS Scimitar, Peters Gate, Chugach Estates I-Iomeowners 04/03/18 15:05 9907 g44 I490 DAN YOUNG ~005 BIBLIOGRAPHY FOR MODELING AND AP ~CATZON$ TO FIU~CTURED ROCK Paul van der l-Iei, ide et al..- Groundwaler Management: the use of numerical models J'ohnathan Istok - Grou~tdwarer Modeling by the Finite Element Method National Research Council - Grou,d Water Modeh',- &'iemific and Regulatory Applic'ations William C. Walton - Practical Aspecrs of Ground Water Modeling Daniel Eves and Thomas Nicholson, ed. Flow: and Transpo~ Through Unxamrated Fractured Rock : USGS - The Effects of Boundary Conditions on (he Steady-State Response of Three Hypothetical Ground-Water Systems Results and [mpliea,, tions on Numerical :Experiments Bear and Vermijt - Modeling Grottndwater Flow and Polh~tion National Water Well Association - Solving Ground Water Problems with Models USGS - A Modular Three-Dimensional F~'nite-Difference G~vund-Water Flow Model National Water Well Association - Practical Applications of Grottnd Water Models ASTM -Srandards on Analysis of Hydtvlogic Pctrao~eters and Ground Water Modeling ASTM -D 5447 Gttide for Application of o Ground-Water Flow Model to ct Site-$pecifie Problem ASTM - D 5490 Gulde for Comparing Grmmd-Water Flow Model Simulations to Site-Specific Information AS'I'M-- D 5609 Cadde for Defining Boundary Conditions in. Ground-Water Flow Modeling ASTM - D 5610 Guide for Defining blitial Conditions in Ground-Water Flow Modeling ASTM - D 5611 Guide~tbr Conducting a Sensifivity Anatysis for a O'ound-Water Flow Model Application ASTM- D 5718-95 Standard Guide for Documenting a ground-Water Flow Model Application FROPI: HMM CONTRACTING PHONE NO. : 6881238 Apr. 88 1998 89:11RM P1 April Ms. Elaine Christian Direotor, DIIHS, MOA Dept. ofklealth & Human Services Anchomge, AK 99501 Re: Meeting Scheduled for April 10, 1998 Dear Ms. Christitm: Per our phone conversation this date you stated you will not meet with our hydrolollist and us as requested on Friday April 10th to discuss the nitrate issue. It was explain~ is your s~cmtary yesterday morning end to you this morning that Mr. Cross m~d Mr. Munt*r are me, ting on Thursday, April 9th regarding the modeling report. However, our hydrologist Mr. Munter requested we set up a meeting so that he could discuss the nitrate issue with yon. 1 explained that it is imperatlv, that tiffs meeting be held either on Friday a.~ originally scheduled or on Monday or Tuesday of ~¢xt week in advance of final s~ffoommonts due Friday April 17a', this camtol bo left m thu last migrate. It was diffi¢alt to find a time where we were MI available for fl~c meeting. According to your calendm' and our~ when this m~ling was first ~hedu]ed Pfiday Was a good day fbr ovewone. Now you refuse to meet and you are using 'thc excuse of Mr. Cross and M_r, Munters xn~¢ting tomorrow. It was o~plained to you that this is a separate issue. You became ' you confrontational. I did not yell at you, I wastrying to schedule a meeting. I stated that we needed to keep our lines et' colnlnunicatlon span with Mr. (;mss and wifl~ you. You stated that you would only talk to a Denali View representative. I advised you I was the owner of Denali View and was a representative of Denali View. Mr. Maurer is also a representative of Donali View and has requesieA thi~ meeting. You then advised llle you could ~ et make a d~ision and would not sohedulo a meatlng. I cannot understand your refi~sal as time is of the essence in this matter. Sincerely, Paul Myers, Skyline View Corp. Co: Jim Mmltor Dan Coffey George Vakalis Dan Kendall FROI'I : NMH CONTRACT lNG April '/, 1998 Ms, Elaine Christian Direoto~, Dill-IS, MOA Dopt, oftlealth & Human Services 825 "1,7 Street Anchorage, AK 99501 Re: Meeting April 4, 199g Dom' Ms. Christian; PHONF NO. : 6881238 This letter is to confirm the discussion at our meeting on Friday April 6, 1998. You agreed to gut a legal datifit;atkm ot"s,Jbstnntial Pr,pact" with regards to yom wat~:r quantity and quality policy. We also discussed tile Iow impact of l I lots ou 37 acres with an average Iol size of 3.44 acres. We talked about our hydrologist aud engineer working with Dill-IS using information from your detriment and the area and that they have come up with positive r~ports, An agreemem on final review of Jim Munters hydrology report was agreed to by Jim Cross. He said he would move tbrward immediately with Jim Monier on this matter. 1-1is only concern was oompulations of data and subs~ntial o~l~t. Restfully p~ our eonversaHon your department has no real definitive ~liey on mbstantial eff~t The proposed nitrate note on the plat was also discussed bringing tip the point that this was unnecessary and was handbd by tho s~ptb pm'milling pro¢ess. The only consequence of this plat note would be to devalue the pml~rty. Sharon Miusch (who has requested without compensation to the owners that this area be a park), want, to condemn Denali View with DI-itt$ action. This typo of policy and polities is wrong. Nitrates arc a volafito issue duo to MOA and DEC i~avolvament with publiebing health issues. The real lgalth hazard, which 1 still question and which I communicated to you, I tbmd in talking with l~alth professionals was "blue baby" diseast~ (methemoglobinemia). In my conversations with these health professim~als 1 found it is not a major eone~m in Alaska. I asked Jim Cross for any DHIIS information that had not bees provided over the last year to my hydrologist os myszlfconeeming this bsue. 1 asked Jim Cros~ whore the level of concern would be tbr his department policy and if $ would apply as it does at DEC. Mr. Cross would not state where his level of conc0m is. He said lhe issue was tot} eomplo, x for an answer. Your department should resolve this issue. Jim Cross said that. he was doing this within the next two months eoncermng the mtrat issue. I would like clarification to what ho wa~ referring to. My under.~tandin8 wag that DFIHS was just letting a contract out for the Eagle River Area and that years of study wel'e needed. (l) FROM : MMM CONTRACTING PHONE' NO. : 6881238 Apr. 08 1998 08:$8AM P2 1 again asked ,lira Cross wherever the soils in Denali View were good or had for s~ptie systems, I-Jo again refused to answer the question. I advised you that Mr, Cross requested flow tests at a Chugiak Community Council meeting to substantiate wa~er problcins in the ~rea. Not one was done and qot one was reeeiwd by DHI.IS, The fact is tha~ if a private ~rson is ia need ofmore waler your advioe to thorn should be to seek professional advice and fix the problem. Instead ei~,y has let polities have free reign. The effect has been to devalue real surrounding Del~ali View. We ask for fair, honest and expedie~}t action on these matters. gineerely, Skyline View Corp. (2/ Denali View Subdivision Chronology April 18, 1997 First comments on subdivision submitted. These required an hydroingist's report which would address water availability and quality. These comments also require soils testing and delineation of original and replacement wastewater disposal sites for each lot. July 25, 1997 Additional comments are submitted by Jim Cross and Dr. Brace Chandler. Prior to these comments, the soils and septic requirements had been satisfied, with the addition of a plat note on nitrates. An aquifer test had been accomplished that did show that adequate water was available for the subdivision itself, but was weak on showing the subdivision's affect on snn'ounding properties. Efforts were then initiated to design a more comprehensive test to satisfy the shortcomings of the original test. September 23, 1997 Additional comments are submitted by Jim Cross, stating that guidelines were being developed to outline the test procedures. Much effort is being done by DHHS and the developer's consultants to form conseusus with the surrounding property owners concerning monitoring their wells. Surrounding subdivisions are ve~T vocal in their opposition to this proposed subdivision. October 27, 1998 Additional comments are submitted by Jim Cross, stating that efforts were still being made to resolve well monitoring question. November, 1997 Platting board sends subdivision back to developer for more information. Following this meeting, Jim Cross contacts developer's consultants to detemtine if they want to continue the process. No response is given. March 1998 A ground water modeling report is received by DHHS concerning Denali View Subdivision. Jim Cross reviews and comments on the report. The comments reiterate the plat note concerning nitrates and state that the modeling report contained inadequate information to determine the effects of the proposed subdivision on surrounding properties. A_t~ril1998 Meeting is held with staff from DHHS, the developer, and the developer's lawyer and consultants. An agreement is reached stating that the model will be reviewed in detail, including all data used in preparing the model, by Jim Cross and Jim Munter. Concluding this detailed review, the model will either be accepted or rejected outt'ight. The agreement also states that the uitrate note will be discussed further. MUNICIPALITY OF ANCHORAGE .Department of Health and Human Services P.O. Box 196650 Anchm-age, Alaska 99519-6650 Date: April 18, 1997 To: fh · ~Zoning and Platting, CPD Fronf.,~.~ja~mes'~t t.~ / Cross, P.E., Pro~ram~ Manager, On-Site/Water Quality Subjec¢ Request for Comments on Cases Due: April 18, 1997 The Environmental Services Division, On-Site Services Program, has reviewed the following cases and has these comments: S-9190: Hamann. No objections. S-9920: Cedar Estates. No objections. S-10013: Gout. Same comments as my memo dated 02/06/97. S-10053: Skyway Park Estates. No objections. S-10054: Denali View. h A hydrologist's study and report must be conducted to determine the availability of potable water for this subdivision. The study shall include the installation and testing of a minimum of two (2) wells and their effects on neighboring properties. 2. Soils testing, percolation testing and ground water monitoring to confirm the suitability for development using on-site wastewater disposal systems is inadequate. All soils logs must bear the original seal and signature of the engineer. 3. Areas designated for the original and replacement wastewater system disposal sites (reserve areas) must be identified and must meet all criteria specified in A/viC 15.65, including slope setback requirements. MUt~I~CIPAL[T¥ OF ANCHORAGE MEMORANDUM Department of Health and Human Services DATE: July 25, 1997 TO: Zoning and Platting, CPD FP, OM: /~_,~s Cross, PE, Program Manager, On-Site Water Quality CONCUP~ ~/4~/~_.ruce Chandler, MD, MPH, Medical Officer SUBJECT: S-10054, Denali View Subdivision As a follow up to the comments made in my April 18, 1997 menlo regarding this subdivision, have the following additional comments: 1. Items 2 and 3 regarding soils testing and disposal system sites have been complied with. 2. An hydrologist's study was conducted as requested. The following is a discussion of the results of this study. Title 21, section 21.15.110.B.4.b covers the requirements for sub-dividers concerning the substantiation of a safe and adequate supply of water. This section reads, in part: "The sub- divider shall submit suppo~ling wdtten information including: all plans, data, tests and engineering reports required by the Department of Health and Human Services to substantiate the availability of a safe and adequate volume of water for domestic purposes ..." The hydrologist's study met the requirernents stipulated by DHHS in that it included the installation of ,',,vo wells within the proposed subdivision, and the study monitored the affects of pumping one cf these wells on the other well within the proposed subdivision and two existing domestic water supply wells serving single family homes adjacent to the proposed subdivision. The pumped well produced approximately 5.5 gallons per minute for a period of twenty four hours, during which time the water level in the second well within the proposed subdivision fluctuated, but these fluctuations did not correlate with the pumping. The two existing domestic wells which were monitored during the pump test both recovered (water levels rose within the well casings) dudng the 24 period of pumping. This presumably could have been caused by the cessation of water usage by the homes they support, but also shows little or no affect from the pumping. 'i'here is a possibility that these wells would have recovered faster if the pumping had not occurred, but that is unknown. More details of the study can be obtained from the repor~ prepared by Bristol Environmental Services Corporation. These results, taken on their own, satisfy the requirements outlined above for the availability of adequate water to support the proposed subdivision. The question of whether the taking of this water will unduly effect existing wells nearby is discussed below. The area of the proposed Denali View Subdivision and Scimitar Subdivision to its north are underlain by bedrock. Existing wells in Scimitar Subdivision all obtain water from areas within this bedrock. Bedrock wells typically produce water from fractures and fissures within the bedrock which have relatively small flows. There are numerous fractures and fissures under these subdivisions, and they are typically not interconnected. This can be seen by comparing static water levels in vadous neighboring wells, which can fluctuate by over 100 feet. It also can be verified by the fact tibet the production of water from one bedrock well will not affect the production of water in neighboring wells. However, there is the possibility that the drilling of a new well could intersect the same fissure that an existing well is using for its production. In this case, the existing well's production would be affected (and the affected owner would presumably have water dghts for protection). In my professional opinion, the chance that the ddlling of the 11 wells which will serve the proposed Denaii View Subdivision will affect the production of any existing well within Scimitar subdivision is slight. The chance that these 11 wells will cumulatively effect all of the wells in Scimitar Subdivision is rernote. Residents of Sc!mitar Subdivision have stated that their wells have produced less water in recent years. Due to the fact that there has been little or no development in this subdivision in the 90's, this drcp in production is most likely caused by climatic effects (lower rainfall and snowfall to recharge groundwater sources), as is the case within other areas of the Municipality of Anchorage. Because ingestion of excessive amounts of nitrate can cause adverse health effects in very young infants and susceptible adults, the United States Environmental Protection Agency (EPA) has established a maximum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplk;s. This level is 10 milligrams per liter (mg/I)-often expressed as 10 parts per million (PPM)--measured on the basis of the nitroger~ content of nitrate. This standard of 10 PPM nitrate-nitrogen was set to prevent the occurrence of infant methemoglobinemia with a reasonable margin of safety. Consumption of water with less than 10 mg¢] nitrate nitrogen poses no identified health risk for humans of any age. Some neighbodr:g homeowners have voiced concern about the potential degradation of water quality, especially in regard to nitrate concentrations, on existing wells in the vicinity of the Denali View subcivision. While most properties in Scimitar Subdivision have Iow nitrate levels, some properties have moderate levels below the EPA MCI..; two properties have levels which exceed the EPA MCL. These elevations appear to be isolated and localized. There is no evidence of widespread nitrate elevation throughout the subdivision or underlying aquifer. Further study wculd be required to determine the source of elevated nitrates in each well. Nitrate levels in water from two test wells in the Denali View Subdivision have been very Iow or non-detectable. Based on available data, itis unlikely that responsible development of Denali View subdivision will significantly impact the drinking water nitrate levels of neighboring properties. Details of the nitrate concentrations and their distribution can be seen in the report prepared by Bds~ol Environmental Services. The developme~.; of Denali View Subdivision will be monitored by the DHHS, and nitrate levels will be followed through the Health Authority Approval which includes the testing of wells. If there is any indication of elevated nitrate levels within, or due to development in Denali View, DHHS will require the installation of nitrate reducing septic systems for any newly developed lots. To accompiish this, the following plat note shall be added: "Nitrate reducing septic; systems may be required by DHHS for the development of each lot within this subdivision." I am also aware ~at a second hydrologist's report is being prepared by a different firm at the request of some homeowners surrounding this proposed subdivision. I have seen no information from 'his report as of this date. MUNICIPALITY OF ANCHORAGE Department of Health and Human Services P.O. Box 196650 Anchorage~ Alaska 99519-6650 Date: September 23, 1997 To: Zoning and Platting, CPD From: ~Z~,ff~s Cross, PE, Program Manager, On-Site Water Quality Subject: S-10054 Denali View Subdivision Following the submission of my July 25 memo regarding the Denali View Subdivision, a great deal of information has been assembled and submitted by various agencies and members of the public. Review of this information has generated questions concerning the affects of the development of this subdivision on the wells of the existing sun'ounding homes. The original aquifer tests conducted on the wells in Denali View Subdivision did show that adequate water could be produced within the subdivision to support the requirements of the subdivision. Due to the concerns of agencies and homeowners alike, efforts have been made to define additional pumping tests on the two existing wells in Denali Vie;v Subdivision. These additional tests will monitor the affects of long term water usage by Denali View Subdivision on the existing wells on sun'ounding properties by modeling this long term usage in a short te~rn pumping test. In addition, a third well has been drilled within Denali View Subdivision to be used as an observation well during the additional pumping tests. Currently, evaluation guidelines are being developed to deten'nine the rules for evaluating the testing prior to starting the test. The results and conclusions dra;vn fi'om these tests will be forwarded as soon as possible. MUNICIPALITY OF ANCHORAGE Department of Health and Hmnan Se~wices P.O. Box 196650 Anchorage, Alaska 99519-6650 Date: To: From: Subject: October 27, 1997 Zoning and Platting, CPD James Cross, PE, Program Manager, On-Site Water Quality S-10054 Denali View Subdivision Since the last meeting of the Platting Board, efforts have been made to obtain more information concernhag the water issues concerning this subdivision. Currently, some agreement has been reached on pumping tests, hoxvever the obstacle at the moment is resolving differences in opinions regarding written agreements to monitor existing wells xvithin Scimitar Subdivision. I cannot recommend approval of this subdivision until fitrther data is available on water availability. MUNICIPALITY OF ANCHORAGE Department of Health and ttuman Services P.O. Box 196650 Anchorage, Alaska 99519-6650 Date: To: From: Subject: March 27, 1998 Zoning and Platting, CPD James Cross, P.E. Program Manager, On-Site/Water Quality S-10054 Denali View Subdivision I have read the Effects of New Wells at Proposed Denali View Subdivision, Peters Creek, ?v£u~icipality of Anchorage, Alas~'a by Bristol Environmental Services Corporation, and have the following comments: Prior to the November 1997 meeting of the Anchorage Platting Board, in discussions xvith Nix. James Munter of Bristol Environmental Services Corporation and Mr. Dee Hi of Dee Hi Engh~eering, the Department of Health and Human Services stated its position on what information was needed to satisfy the requirements concerning water availability at the proposed Denali View Subdivision. The position was that ~rther efforts had to be made to coordinate with local residents additional aqnifer tests on the existing wells within the proposed subdivision. This additional testing was needed to adequately stress the aquifers and to determine the effects of the taking of water from these wells on the existing wells surrounding the proposed subdivision. Even Mr. Munter had stated in a public meeting that the o~nal pumping tests were not sufficient to adequately stress the aquifers to make this determination. This report contains no data concerning new aquifer tests conducted at this proposed subdivision, so it must be assumed that well flow data used for the models is fi'om the ori~nal tests. Shortly a?ter the November, 1997 meeting of the Anchorage Platting Board, I contacted both NIX. Munter of Bristol Environmental Services Corporation, and ~IX. Hi of Dee Hi Engineering to determine if they planned on continuing with the requirements for the proposed subdivision, and was given no definitive answer. Since that time, the Department of Health and Human Services has had no information submitted for review or comment, nor has it been requested to make any determinations concerning submittals for review, until this report was submitted. Although both the State of Alaska Departments of Natt~ral Resources and Environmental Conservation received advance copies of the above referenced report for review and corranent, the Department of Health and Human Services received no information in advance. In summary, there is still inadequate information to determine the effects of the addition of 11 newly producing wells within this subdivision on the existing surrounding wells. Adequate flow tests must be conducted on these new ~vells, and example wells from the multiple bedrock aquifers surrounding the subdivision must be monitored to make this determination. Due to the concerns of elevated filtrate levels in ground water in this area, the following note shall be placed on the plat: "On-site wastewater systems using nitrate reducing technology may be required to develop lots with/n tiffs subdivision." TO: PLA'ITINO BOARD AUTHORITY FROM: SKYLINE VIEW CORPORATION RE: DENALI VIEW SUBDIVISION S-10054 DATE: ..~PRIL 1 1998 THE PLTtPOSE IS THIS MEMO IS TO REQUEST A CONTINUANCE OF THIS ABOVE REFERENCED MATTER BASED UPON DISCUSSIONS WITH THE DEPT. OF HEALTH AND HUMAN SERVICES OF THE lvlUNICIPALITY OF ANCHOKAGE. 'DtlS CONTINUANCE IS REQUESTED LN ORDER TO ALLOW DHHS TO KEACH A CONCLUSION ON THE QUESTION OF WHETHER OR NOT PLAT APPROVAL Ix. AVE A SUBSTANTIAL EFFECT ON THE SURROL :~rDING NEIGHBORIIOOD. THE POSTPO_N~EMENT IS REQUESTED TO ENABLE DHHS TO DO THE FOLLOWTNG: BRISTOL ENVIP. ONMENTAL CORPORATION SUBMITTED A MODELING REPORT DATED FEB. 9, 1998 IN RESPONSE TO THE DIRECTIVES OF THTE PLATTING BOARD NOV. 5, 1997 FOR REDESIGN. THE DH3IS SHALL Pd:~VIEW THE MODELING REPORT, THE DATA AND ASSUMPTIONS UPON WHICH THE REPORT IS BASED TO DETEILMINE IF THERE ARE ANY SUBSTANTIAL OR MATERIAL DEFECTS OR DEFICIENCIES IN THE MODEL WHICH WOULD ALTER THE CONCLUSIONS IN THE MODELING REPORT. IF DHHS CONCLUDES THAT THERE ARE NO ~IATERIAL OR SUBSTANTIAL DEFECTS OR DEFICIENCIES IN THE, DATA OR ASSUMPTIONS, 'II-IEN THE MODELING REPORT CONCLUSIONS WILL BE DETERMENED TO BE VALID AND DHZdS ~VILL RECOMMEND PLAT APPROVAL. ~ DHJE~S DETERMINES THAT TIlE DATA AbiD TH~ ASSUMPTIONS IN THE MODELING REPORT ARE NOT VALID AND THAT THERE MAY BE SUBSTANTIAL EFFECT ON 774E SUT,_ROU~'NDING NEIGHBORHOOD, DHHS SHALL RECOMMEND DENIAL OF THE SLq3DIVISION AND SHALL STATE CLEARLY AND CONCISELY EACH AND EVERY REASON FOR SUCH RECOMMENDATION. DHZqS .~2ND THE PETITIONERS REPRESENTATIVE SHALL MEET, REVIEW AND DISCUSS THE MODELING REPORT AND THE DATA AND THE ASSUMPTIONS IN A TL'vLELY FASHION TO PERMIT DHHS TO SUBMIT ITS REPORT PRIOR TO APRIL 17, 1998. DURING THIS PROCESS DHHS AND THE OWNERS REP1LESENTATIVE SHALL DEAl_ DIRECTLY WITH ONE ANOTItER. PUBLIC COMMENTS CAN BE ivIADE AT THE CONCLUSION OF DHI-IS REPORT, DL'RD,-G THE COURSE OF THIS PROCESS THE IDEA OF WELL TESTING IIAS BEEN DISCUSSED EXTENSIVELY. IT IS AGREED THAT NO FURTHER PUMP TESTS WILL BE REQLTRED FOR DHHS TO MAKE ITS DECISION. AS TO THE ISSUE OF NITRATES, THE QUESTION OF A PLAT NOTE WILL BE FURTHER DISCUSSED BY DHHS AND THE OWNERS REPRESENTATIVE. SHOULD DH5tS DETERMINE 'tHAT A PLAT NOTE IS APPROPRIATE, THE OWNEI~S REPRESENTATIVE WILL BE ABLE TO PARTICIPATE IN THE DRAFTING OF 'IT71AT NOTE. 6. THIS APPLICATION WILL BE HEARD ON MAY 6, 1998. /,~ SKYLD,'E~)qiEW CORP ORATION CONCURR: /JAM~ April 5, 1998 Mr. James Cross, Program Manager, Water Quality Program Department of Health and Social Services Municipality of Anchorage P.O. Box 196650 Anchorage, AK 99519-6650 Dear Mr. Cross: We the undersigned residents of Petersgate Subdivision remain very concerned about the pending decision of your Department regarding the proposed Denali View Subdivsion. Our concerns are based in general on a long history of water problems of some residents in this subdivision, and more specifically, the recent water' problems of several residents adjacent to the proposed subdivsion, it is our understanding that after a lengthy meeting between you and the developer, you rescinded your earlier decision to require well tests to determine the impacts of the proposed development on existing wells in the area. It is our further understanding that the Department's decision will be based on a model that uses limited data and numerous untested assumptions, some of which Dan Young of Terrasat Inc. has called into question. We do not presume to be experts in hydrology but we are knowledgeable enough to know that outputs from models using faulty assumptions and limited real data frequently lack validity. Because of the complexity of this case, we strongly recommend that the Municipality submit the developer's model to an independent review by a qualified hydrologist. The suggestion of Dr. Gordon Nelson of the U.S. Geological Survey as a reviewer is one that would be acceptable to us. CC: Mayor Rick Mystrom Elaine Christensen Sincerely, The Below Signed Residents, Petersgate Subdivision April 5, 1998 Mr. James Cross, Program Manager, Water quality Program Department of Health and Human Services Municipality of Anchorage P.O. Box 196650 Anchorage, Al( 99519-6650 Dear Mr. Cross: This is a fotlowup to the enclosed letter from residents of Petersgate Subdivision. Its purpose is to provide you with greater detail on the recent water problems experienced by Petersgate residents adjacent to or near the proposed Denali View Subdivision. Event No. 1: For years, the well on Lot 9, Block 1 was artesian. When we had power outages, residents frequently went there to get water. When Lot 3, Btock 1 was developed about four years ago, the well on Lot 9 ceased to be artesian. Lot 3 is across Sullins Road from the proposed Denali View Subdivision. Lot 9 is kitty-corner from Lot 3 and is one lot removed from Sullins Road. After the test well was dug on Denali View last summer, this well degraded further and finally went dry. The best well in the entire subdivision failed! The owners were forced to drill a new well this winter at great expense. Event No. 2: Since it was drilled several years ago, the well on Lot 3 was a good producer. Coincidentally with the drilling of a test well along Sullins on one of the Denali View tots, the water level in the well on Lot 3 dropped precipitously resulting in a burned out pump. The well also began producing some silt. Coincidence or cause and effect? Event No. 3: Coincident with the recent drilling of a new well on Lot 9, the owners of Lot 10a exprienced a temporary loss of water. This also was hardly a coincidence, but likely cause and effect. I could provide you with other examples of water problems in this subdivision and on neighboring properties. What these events tell us is that many of the wells located on lots near the proposed Denali View are interconnected and that water is limiting. Is it any wonder residents of Petersgate Subdivision are concerned about the development of 5 additional lots adjacent to their own. Our experiences have taught us that only through well testing can the effects of additional wells on existing wells be demonstrated. We are very leery of any models developed by Bristol Environmental that lack real test data. Sincerely, Anthony R. DeGange President, Petersgate Homeowner's Association Rick Mystrom, Mayor Department of Health and Human Services 825 "L" Street P.O. Box 196650 Anchorage, Alaska 99519-6650 April 28, 1998 The Law Offices of Mr. Dan K. Coffey 207 East Northern Lights Boulevard Suite 200 Anchorage, AK 99503 Dear Mr. Coffey: I have included with this letter nitrate data referred to in the memo to Community Planning and Development frown Dr. Bruce Chandler and me dated April 24, 1998. These data, from files at the Department of Health and Human Smwices, have all previously been given to Mr. Myers of Skyline View Corporation, or Ms engineer Mr. Dee High (DHI Consulting Engineers), or his hydrologist Mr. James Munter (B~Sstol Enviromnental Services Corporation). A map (DHI Consulting Engineers comp. file #298CRDMP dated 6-12-9'7) submitted to this office by Skyline View Corporation of the proposed Denali View Subdivision and the existing surrounding subdivisions used these same data. The basic reasoning for the plat note is also outlined in the memo to Co~rmmnity Planning and Development from Dr. Bruce Chandler and me dated April 24, 1998. Mr. Myers has a copy of this merno, and I have attached an additional copy for your convenience. I hope that this information satisfies your request. If you have any additional questions please contact me. ,Sinc/ely, /2 Ja/nes' Cross, PE ' l~ro gram Manager On-Site Water Quality cc: ,'Elaine Christian, Director, DHHS Lura Morgan, Ph.D., Manager, Environmental Services N~nib~ Pl~ene F~,x Ph FROM MOA TRANS PLANNING From: Phone Fax Phone. 9~4~4786 P. 01 Munic!palityiof Anchorage COmmunity Plan~ing i~ Dev~lopmen~ Ancho~ge,I/~K 99519'.66~0 ~ ',~,,n ~l!Uma~ervioe~ · $onta Wall~er 343-4267 343-4220 or your review [] ReplyAS~P Hcolllr~eflt MAY-04-19~8 14:04 May 4~, .lC~ )8 VIA l~,~b D DELI% Mr. Jerry Weaver Mum¢~pal' ~' of An D~m of C°~ Re: c0mn ~nm o~ Dear Mr. WeaVer: low-m~at s~ie ~e ~ht ~ote w0ui8 be n~~ at Den~i is ov~re ~eting to ~e h6m wo~ld~ M, have ~er in~cafi°r ~e pr ~ ~sed n0t~ ordi~ac~ :s. wou~ be illeg~; Eve~ D~ tis a~t r~ui~ed or m~ena t~ rest: DHHS not i~ note~: , Teac ni~dgen ~os~ n0 FROM 3RY MOA TRANS PLANNING TO 9~4~4786 P. 02 Bristol Environmental Serviqes Corporation , ~ Subsidiar~ o~Brlsto/~3ay~Cative Co} orage ~ tunity Pbnning and Development ~t'note, Denali View Subdivision of the applicant, this letter is to request that th~ proposed pla~, note. ~b0ui ,,terns be{ reiuoved as a condition of plat approval have the effect of promoting an overly-alarmist attitude regard~ing ~dtrate~ by known: facts. There is no clear conclusion that such syste~Os will., ever View, No'study has been conducted to support their required u~Se, ittate concerns. ,e' the eff%t'og further lowering property values in the enfir~ area.~ We a that lot v~lues a.re depressed by 30 percent already, outlined :in the DHHS memo is Luadequate and we have ~ot iahd au ippears to:'go beyond the authorities of existing onsite wastew~ter disposal 10cumematinn has been presented to the Municipality that sucl} a plat note d.the munictpality, has chosen= not to seek a legal {:leterrnination.~f, its own.. that this 'technology is still experimental. Ordllnance changSs wCgld applica!i0l~, which is likely years into.the fature. Om estimat',es off ~ystem :e tripb those of a standard system, with Problematic o~erat',~, and fibilitiesl red its: signed agreement or proper procedure in recommending memo fz0m DHHS does not adequately account for the fo[lo, ,FI~IS concluded that "Consumption of water With less than 1.0 clentified health risk for hunaan.q Of any age." Over 85 perce P.O, Box 100320, Anchorage, Alasl~ 99510 201 E. 56,~ Avenue, ·Suite 301, Anchorage, Ala~ka 99'518 phone (90?) 563.0013; Fax (907) 563-6713 ~l~e plat ~ing ,facts: ! mg/Li nitraie nt of ~tra~e M~Y-04-1998 14:05 FROM t u~t Of thg 0.6 Subdi, at dep~s nitrat6s The ~ to It app~earS syste~ The strong '~h¢ trends ne, subjected to i'equh Muntcipa ity:,and :th propgl:ty ~ ~wne~:s in. Dataiare lvailable t repo~t iof ,June 18, repo~ted ut~ate val data ~x~er: used tg. expired to have a} disa~ree~ with thi., comment requ~stec .receDed mer~o .ol and have Althpugl an ai~thm De~0i Vie ~8 ktyflrolog May ¢-, 19 DttH$ p, that the: t reSpokls April 24, been metl the April , it not'si a memo. ~e to maki MOA TRflNS PLflNNING TO Bristol Enwronraental Se~e s rporat~on A Subaidia~ ofl8riswl 8ay N*t~ve Co~oration comes ~om ~mral hi.ate content of vegetables. Addifi ml fl[mils ex~ted co~ents by DHHS, ~e State of Alaska, and O~ers w~ hi. utes over t0 mg/L. one was r~h~ by a wel~ a~ ~th wells are more th~ 600 ~f~t from D~ ~ie~ should iav~tigate whe~er wells wi~ :elevat~ mtr~$ ~qy be~ per~at~i ~an MOA ~des ·allow. Numerous lots clear te D~li nitrate ~trogen. D~S-approved ~chorage Htlls~fle mtrate s~y sl~ow~} ~ations if ~ey occur at all, rand to be gradu~, on ~e se}lc o~ years wmanted careful long-tern pI~mg ~athm- ~ ~ al~st ~tmde intends to use ~is plat note as an e~orcmg agent for low-nl~atq sept of ord~ce authorities, ~owever enfor~ent crimria are[ not be "should ~'end a~ysis ~d mapping dem0~lrate ine~e~ing [filtrate requke low-nj=ate systems at ~eir sole dNcretion using the p~, note ion, It is V~ unclear where t~ese ~m~ds ~e g0mg to be me sUregl ~ow ~a to be wlmt ~e ca. es miuht be, ~nd wh~er other crope~U~s should ~ents'for Io~ aimm sys~ ' We su~°~ ~er sddy ¢~ the ~ ~ursuit of orderly policy or ord~ce c~ges ~at apply fffeeted ~eas following due process. , :predici future trends in nitrate levels, These 0ara were evalfi., ate~ in our t997. Om: analysis of 22 lots surrmmdir, g Denali View' w~itlx .mialtiple ,es there is 'no clear trend of increasing nitrate ieveis in the 4rea. ! Thes~ eo'nclude 'that less-dense development in adjacent areas :wduld ldot be large effect on existing nitrate patterns and trends. The DIiI~q h~!never finding, however it does not seem to be consistent with ~aeir!'!ecent amised anq offered to work with us on the wording of a plat note ~a~d w,e ~urPose, of the plat note be identified so that we could talk,/W~,neve~ to this: request prior to tlle issuance by DHHS of the recommertdafion 1998. We have repeatedly requested information and dialogue witt{ DHHS ~ith delays and avoidances of the issues. ' i i 24 memo has the marne of Dr Bruce Chandler, DHHS Medical Of:ricer ;ned or initialed by him. When asked on May 4, 1998, wheth ~r he iwould A}h the recommended plat note language, he said. that he did m knn~:, b~t ,,some inquiries, ~:lRequest to Community Planrfing i Page. MFIY-04-1998 14:05 Cone!usi~n. We consiiterixlg the she adja*~nt 'r De,ali not b~een ~ ~bject to note ~egm ting If thq pla DHHS tlmt: ~S :no e. (Si We al~re sigek ly Princ{ip~l Attac{lmae I' Denati Vie May 4, }9c. Proje{~ 80C FROM MOA TRANS PLANNING TO 934~4786 P.04 Bristol Environmental Services CorpOration A Subsidiary o Br~tol~t~yNa~ive CSrporation =lieve D~HS is promoting an overly-Ma~st ·policy reg~d[ng gmge of. doemenmtion of h~fl ~wate concenuation in [well water ieW Subdivision. DHHS ~ present~ an inadeqmte justifisat'}on that ha~ ;~ropriate review. We request ~at ~e plat be approv~ wl~6ut the pla~ .trate septic syst~. : ' ca~ol b) approved wi~out the plat note, we r~uest ~at ~e case be ~em~d. resolutio i~ acc0rd~ce wi~ ~e signed agreement of APril 1, 1998 ~hich gmte~ . to,~e ~{.te of nltrams, the question of a plat: note wili :be ~her! d}scusbgd rHs me owner's r~resenmtive. Should DHHS detemne tMt a plat ~ropriate ' he owner's ~presen~tive will be able to pa~cipate in the dra~ing 2of tM$ [ Myers. dare :your: Mumer, £ ffydroge~] (two ul Myers: n C0ffey; e High Hydrolog · , (Signed) Jm'nes Cross, PE, DHHS ctendor~ to ~ese matters. t0il servlee*'Corporatiot' GWP ogist ,,es excerpted comments about nitrates) Request to Community planning Page ~¥-04-1990 Qno~s from n~es nitrat~ report, i The question f~r nit Quetes from irt Conse~atl~ ~ hi All available d~ c reviewing lhe ~m~ have some old ~d s~o These new ~om~ anot~r $3,~ in the aflja~t SDwh tMt alt: future tms~ra sys~m tc wade 'i~fiative~ com~ar~ ~ e~Jsti~ Reviewing th~ g and analysis would:have sm~:~th ~nt Unfommmdy~ Th~ ~our~s o~]nk md farms, im~ Quote from discussion o~Ai~' l f~l th~ wdh info,nation ~ He s~ms he had will fle~nfl ~n 14:06 from FROM MOA TRANS PLANNING TO 93434?86 P.05 rlment:.ofEnvlronment~] Conservatlon~s file on review ofN r. Munl.er s: :here a nih'at, problem in the a~a?", , ~. Drln~ng W~ter Coordinator, ~eparment ~ff Envlronm~ ~t~l~ ~ qew No~s~ ' ~n tMre is:not ~de sp~a~ Niira~ Found waler ~ntami~tiom In~i~iflual mt there is not a pa~em of~flespr~fl high Nilra~ values. So~e o~lle fla~ hes~ hOmeS have be~ there a long t~me too. i ', ~ : ~ may be roquired m instal] Lo~ Niffate ~a~ent systems wh)~h c0!t about ae usual :on-si~ ~l. In addition ther~ ~re about ~ existing uni~evclb~d 10~ in ,e, mqui~d to ins~l these moro ex~nsive syste~, an~ the~ is ~e ~sibility h~m~ will have to ~a~,~ there e~s}ing septio gystem ~ a Ni!~ t~uei~g dOA H~lfll Ce~cate. ~ h~ implicatwns are su~s~n~ial iftho~ Is ~ ~ afl ama ~n~ol Ni~ ~ l~ols~ Do~ MOA held the deVel0~r to a higla trea~ent stahflar~ ~s gand othe pmP°sedhomes? i l lonlmu,~i let~rtoSharonMinsehdale$F~ 10, 1998~ ~ : ' ,ha Io~t~ in Appendix C, a ~end may bo indicted by some historical da~ [ro~?~e o}d~r ~s. ~hm~,, ~e num~ous'problems with ming ihe'da~ m~.out:doing a more m,q~th mwew ~ maul1. ~1 he e~or induced by sampling', tlae ~e of flifferent~laboramfies, ~fl tlj~ eha~e in used to de [e~ine ~e tev~[ of nitrate in e given ~ampl* are just a f~ of Ih} prob}~s lhat that~t~ san upward tr~ a smflstiml analyhs of all ~ta woula ~d t.o ~ 3e~mn~ cushily do:s ~t have lhe stuffing or funding to ~mplete ~h~ ms~,l z~s am m aumus, ~e more common sources ~m f~ilizers, animal ~sl:~$ fra~ f~fl lets ,fy ~ntei ~to ~tt~ (domestlo and n~Momestm), and ni~m g~emfi~ pl~s su,h · : · ' . i , ledge ofil :.nmr sUff~e g~logieal ~ndiOons agit ~e hydr01~g~l sysmms m ~¢ ~ of tt impossi le to d~nnine, ~fl~out a ~adow of doubt, whO,ll hap~n. ~e~ ~s ~ ~ual ', i~n of~ilizer to ta~ in the'~ma may have an ~lual oF g~ a~t on " " .~ Bu~ as w~ noted by Mr. Jamm Wei~ during our ~mb~ 30, !9'* this ~efit;~ ~ h~ have the r~oums, at this time, m continue ~n in d~l o on Mi~sel ih memo to J~mes Weise, Department ofEnvir?nmenml Con~orva~ibn m~rding ~on!mu~ a d. Mr. Weise's res~nse in ca~: ~ ; ~ 22,19~81e~err g g .~.~ . · ' ' t e ar lr~btua~ e a~in the o s~ Dena i V ew SuMIviSl~ ni~qss~la~ an m ~stion R se~s appmpn~e m light oflh~ D~tm,nts eff~ to ~ h r f~ DEC [~ue[~ms and yom recent mvmw of the D~li V~ew m~rts. : ~ ~on~ 'ovjeWe8 y ,~r l~ter, ~ mid me ~. the d~isiog in your le~er is u~tes~ . hm ~OA, t~idos m ~, He indi~t~ ~at nitrates in D~nali ~iow i8 a 20 y mr a~ay MAY-04-1998 : · ~FiM CONTRACTINt :~ lhe dye test tmx~el ti year problem any=lon VOULD TAKE ~SURFACE FL~ ,ND AND DRAWL. FERF~'I' T~vEL '1 )BQUA~ DATA? ra~ is a normml natuml hi.ate l~Dr~mton f~o~.th~ ,~mlnaflon. I {~t ;,~but oo~pounds ~fn nsFo~a~ons ,man .~ra~ :nta~ ~k~ of nitrate'in ~.t of~voge~bl~g. raribug~b0~ ur%s of 0it~a~ ~ ~) h~.~.d~da uote f~m Sharoh ~fo~e~ble and th~ 14:07 FROM MOR TRRNS PLANNING TO 93434788 P. 06 :, ne in ~in ,ilar was 1200 feet in 5 weeks time 1 do not: s~e how anyona can Feel tl~s i~ ~ D~I', T~STS T"XOUO~OI~ TI~ SCIMITAr; $~.DIVIglON, A~ )~S ~ ~FI m ARBA, TO OBTA~ A "OOOD ~OUGH i { ' i'} A~A"BEDROC~ AQ~ER?' EACH COI~ HA~ .I~Y~E PKOB]~, THE CONC~T OF '~SO~ SC~CB" AND . :. g Ph ~ ;~t¢ of Ai~ka Dopt. ofH¢altfi ~ So~ial So~ic~sJ dasd a~ril ofvgg~m laS. The con.button from drinking ~ is usually qui~ . ~: {~rau~[ i:~ con~minu~, ; small ~a~2- sva}lSBh i,formafion was ~at nitrate is not nee~smHly :a marker of cai: ~t ki~le ~IS of fe~] coliform b~t~ri~ (E. ~[i) ~m a ~R~' ma[kef ?r.}~t. : ~tio~ in ~r: nking ~r would defingfly m~car~ the hazed asso~mtea wlm[ . ndl~,~MI ~JMPH, Muni¢ipa{i~ of Anohbmge Heal~ ~pa~munt da~ A~ril 1~97 ~t: -;1~ Ei~h's~mospheg is about 7g ~c:nt nilm~ and ~nmins a~out ~il~le i~ :hi~ onvir0ament Mo~t of this ~i~ogen is in thc renu of element ~t ~l~gon trosen~nt Oxygcn~alao'are proso~. S~c of~cs~ ~m~unds a~ ~ d by ' : ~bs~ ~; ~d a.'~bstan~l.amo~t a~ ml~s~ into ~ amo~ho~a fr~ ~ the: . su~h ~:C ~l ~d g~lin~. Hi.each ~m~unds in the almospha~ und~rl ilually ~' .oJthe nice.n in the fo~ ofn{~. Nitrate can dissolv~ in fait ~tor 0r s~ims' o ground wat~ in runoff or s~ge- Ni~iS { noml~ ~mpon~t of~o hum~m dia. 'r~ major sour~ ~11~ f~6 w er Nitmlo is ~sen; in ~l pl~; vegetables ar~ a m~Jor ~t, ~rl ~e in a t~i~ ?dult diut colnos:~.l the nature} ~1~. ~0~ 'nus; '1~. melons. ~ba~. ~pmaoh, and many, of th~ ~t w nd ~imt~ ~ the diet, ~ro h~$ ba~n no Si~ifl~nt upw~d' ~d in th~ ni m~ ~nm~l :hg sub~ .fi~ inu~g that haw o~ in f~li~r usage, ~hur~jo~ dio~ d. smffs} gu :h as cu~d m~at produca and ~ain ~s of~h~uso ~ ~cn r · c~ ~ggnt or pr~s~atiw, :t th~m, ~:th ~'t ~otl~. iostim°lsy b~for~ tho Plaiting BoardNov, 5, 1997: St~tg doi'sWt proteet them, uot'g~dY pro~otS ~grd., Those, plat · TI3T8~ P. 06 SKYLINE VIEW CORPORATION p. O. Box 6'/0351 Chugiak, AK. 9956'/ Phone: 688-1237 Fax: 688-1238 DATE: April 21, 1998 TO: JIM CROSS FROM: PAUL MYERS SHARON MINSCH HAS BROKEN CODE OF MORALS AND ETHICS Sharon Minsch has broken the code of morals and ethics with a campaign of misinformation, behind the scenes manipulations designed for destructive purposes. I am requesting Sharon Minsch, President of the Chul~ak Community Council to resign from the Water Tech Board. The impartial honest and fair treatment of Denali View Subdivision did not occur. The scientific infommtion was scrutinized in unfair manners. Sharon Minsch, President of the Chugiak Community Council politicized this issue with a cmnpaign designed to refute the scientific reports and confuse the issues. She misused her political connections to influence people in ADEC to be involved in a prejudiced way to defeat Denali View. Politics that include misinformation to the public on volatile issues of water, which incenses many people to do things, they would not normally do. Politician Sharon Minsch should not be on the MOA Water Tech Board. Her biased actions show she is incapable of using the position honestly and objectively. Because of Sharon Minsch's fanatical approach her impact on water issues can only lead to imbalance and is unconstructive. Sharon Minsch only knows the power of destruction and does this community tremendous harm. She proudly states "My involvement in the fight against the septic ordinance several years ago earned me the title, Queen of Crap. I also lead a public campaign that stopped the Mirror Lake Sewer Lagoon." Sharon Minsch has let this title go to her head. Sharon Minsch, President of the Chugiak Community Council should be asked to resign immediately from the Water Tech Board. CC: Mayor Rick Mystrom Elaine Christian, DHblS Lura Morgan, DHHS Rep. Vic Kohring Ombudsman Michelle Brown, ADEC LAP/OFFICE OF DAN K.. COFFEY 207 Eaff Norrh~r~ Light* Boul~.& $uite 200 BEFORE THE MUNICIPALITY OF ANCHORAGE PLAI-rlNG BOARD IN THE MATTER OF THE APPLICATION FOR APPROVAL OF DE-'NALI VIEW SUBDIVISION SKYLINE VIEW CORPORA'FION, APPLICANT --!998 Planning Dept. File No. S-10054 SUPPLEMENTAL BRIEF OF APPLICANT SKYLINE VIEW CORPORATION The purpose of this supplemental memorandum is to inform the Board as to those matters as to which the parties appear to have reached a consensus, and those issues which are still outstanding, since the parties' last appearance before the Board. I. Development of Denaii View Subdivision Will Not Unduly Affect the Quantity of Well Water Available to Existing Area Homeowners The staff of the MunicipaLity'of ,~hchorage Department of Health and Human Services ("DHHS") now agrees that the development of Denali View Subdivision will not unduly affect the quantity of well water available to existing area homeowners. _See letter from James Cross, P.E. to James Munter, CGWP dated April 17, 1998, copy submitted herewith as Exhibit '1. In that letter, Mr. Cross acknowledged that the Modflow model used by Mr. Munter to simulate groundwater recharge and flow in the Denali View Subdivision area was "appropriate for use in an area with the geological attributes of Denali View Subdivision." _See Exhibit 1 at page 1. Mr. Cross also acknowledged that the data used by Mr. Munter in the Modflow model was adequate and accurate; that the assumptions used for the model were reasonable; and that the degree of error or discrepancy exhibited by the model was "quite acceptable". Se.e_ Exhibit 1 at page 1. Mr. Cross concluded that "the results from this model show that the impact on adjoining subdivision.'; will be minimal", and that the model "sufficiently indicates the availability of an adequate volume of water for domestic purposes for the proposed subdivision." See Exhibit 1 at page 2. SUPPLEMENTAL PLATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 1 LAW OFFICE O1~ DANK.. COFFEY In conclusion, the staff at DHHS now agrees that the testing and modeling conducted by applicant Skyline View Corporation's hydrogeologist James Munter satisfies AMC Section 21.15.110(B)(4)(b)'s requirement that the applicant "submit all plans, data, tests, and engineering reports required by the Department of Health and Human Services to substantiate the availability of a safe and adequate volume of water for domestic purposes...". Accordingly, the adequacy of the water supply for Denali View Subdivision is no longer a valid basis for withholding subdivision plat approval. The applicant therefore respectfully requests preliminary plat approval pursuant to AMC 21.75.010. II. Development of Denali View Subdivision Will Not Unduly Affect the Qttality of Well Water Available to Existing Area Homeowners The only water quality issue which has been raised to date by DHHS and by interested persons concerns elevated nitrate levels in the nearby Scimitar, Peters Gate, and Chugach Park subdivisions. Anchorage Municipal C. ode.('AMC") Section 15.55.060 (I) requires that water used for domestic purposes contain not more than 10 milligrams of nitrates per liter. The concern is that on-site wastewater disposal by Denali View Subdivision residents will raise nitrate levels in these surrounding areas to unacceptable levels. As noted in hydrogeologist James A. Munter's report dated June 12, 1997, (copy submitted with the applicant's opening brief as Exhibit 4), 30% of all lots in the above-referenced area have reported nitrate levels at or below the minimum levels necessary for detection, and 97% of the sampled lots in the area have nitrate levels below the drinking water standard of 10 mg/L. Id~ at page 2. Only three percent of the area lots have reported nitrate levels in excess of the drinking water standard, id. Finally, Mr. Munter found no evidence of a trend of increasing nitrate levels in the area. Ld_. at pages 2 and 3. At the time the applicant's opening brief was filed, the applicant's counsel did not have possession of the documentation supporting Mr. Munter's conclusion that area nitrate levels are not increasing. The applicant now has copies of this voluminous documentation, a representative sampling of which is submitted herewith as Exhibit 2. This documentation SUPPLEMENTAL PLATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 2 LAIV OFFICE OF DANK. COFFEY supports Mr. Munter's conclusion that nitrate levels are not increasing in the Denali View Subdivision area. In order to sidestep tile fact that nitrate levels in the Denali View Subdivision area are above the drinking water standard in only 3% of area lots or wells, the individuals who have opposed the approval of Denali View Subdivision have inferred that nitrate levels below the drinking water standard of 10 milligrams of nitrates per liter are still somehow injurious to human health. This is clearly not the case. In her memorandum dated April 10, 1997, Lori A. Feyk, Ph.D. of DHHS stated, with regard to the 10mg / L nitrate standard, that "there is a high degree of confidence in this number, which provides protection for the most sensitive human health endpoint." See Exhibit 3 (submitted herewith) at page 2, paragraph 2. Similarly, in a paper entitled On_~N't~~n-~g-water, and Humap Health dated April 1997 authored by Bruce Chandlar, M.D., M.P.H., (copy submitted herewith as Exhibit 4), Dr. Chandlar writes (at page 3, paragraphs'3-4): Because ingestion of excessive ameunts of nitrate can cause adverse health effects in very young infants and susceptible adults, the United States Environmental Protection Agency (EPA) has established a maxirnum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplies. This level is 10 milligrams per liter (mg/I), often expressed as 10 parts per million (ppm), measured on the basis of the nitrogen content of nitrate. The standard of 10 ppm nitrate - nitrogen was set to prevent the occurrence [of] infant methemoglobinemia with a reasonable margin of safety. For example, one study of over 100 Illinois children 1-8 years in age ingesting water with nitrate nitrogen content ranging from 23 - 204 mg/I found no elevation in methemoglobin levels in the children and no relationship between ingestion of high nitrate water and the measured methemoglobin level. The foregoing discussion proves that the 10 mg/I standard is a very conservative standard, and that nitrate levels below that standard pose no adverse consequences to human health. Skyline View Corporation has demonstrated that Denali View Subdivision can adequately dispose of all waterborne domestic wastes as required by AMC Section 21.15.110(B)(4)(b). Based on this showing, its plat application must be approved. SUPPLEMENTAL Pt. ATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 3 LAW OFFICE OF DAN K.. COFFEY III. No Legal Authority Exists to Require a Plat Note Mandating or Suggesting the Use of Low - Nitrate Emitting Septic Systems in Denali View Subdivision Tile Municipality of Anchorage Department of Community Planning and Development has indicated that it may condition [ts approval of Denali View Subdivision on the developer's agreement to place notes on the recorded plat which state that the lots at issue are restricted to Iow nitrate-emitting septic systems. However, the Municipality has to date failed to approve any Iow-nitrate emitting septic systems, let alone enact any ordinances or regulations which specify when iow-nitrate emitting septic systems may be required as a prerequisite to plat approval. This raises the question of whether a municipality may legally condition subdivision plat approval on a developer's agreement to take actions not otherwise required by law. The short answer to this question is that a municipality has no authority whatsoever to condition plat approval on actions not required by ordinance or regulation. 'Fhe leading authority on sub¢ivis on platting is Yo~~f ub--b~ti¥isi°n-s (The Michie Company, 2nd Edition, 1981) (hereafter referred to as "Yokley"). That treetise states, at Section 9, pages 32 and 35, as follows: The power to approve and exercise control over subdivision plats must be expressly conferred. It is not an implied power of local government. Statutes granting broad powers concerning planning and zoning do not encompass authority to control subdivision activity by implication. The regulations of a planning board, to be effective as a basis for disapproval of a plan, must be comprehensive, reasonably definite, and carefully drafted, so that owners may know in advance what is or may be required of them and what standards and procedures will be applied to them. in the portion of the Yokley treatise specifically addressing subdivision plat approval, Yokley states (Sections 52 - 58 at pages 218 - 281: [W]hile public policy requires municipal control of [development], nevertheless the authority of a town to deny a landowner the right to develop his property by refusing to approve the plat of such development is, by statute made to rest upon specific standards of a statute or implementing ordinance. SUPPLEMENTAL PLATTING BOAR[) BRIEF OF SKYLINE VIEW CORPORATION PAGE 4 LAP/' OFFICE OF DANK. COFFEY In passing upon a plan, the action of a planning board or commission is controlled by the regulations adopted for its guidance. The power to control the subdivision of land is not an unbridled power. Local agencies vested with the power of subdivision control must operate within the framework of the statutes, ordinances, and regulations prescribing their powers and duties. An arbitrary or unlawful exercise of power in matters affecting subdivision control will de much to destroy public confidence in local planning programs.. It is clear that the imposition of subdivision controls must be effected within the framework of properly observed statutory requirements .... Where there is no adopted plan, the right to exercise subdivision control is subject to serious question. In order to require [~arti~ular actions] by subdividers as a condition of approval of subdivision plans and plats, a municipality must act under proper enabling statutes or charter provisions, implemented by ordinances enacted pursuant thereto. Conditions of approval - whether authorized by statute, by municipal charter or ordinance, or by planning commission regulations - must be reasonable. Where requirements for the filing of plats have been observed, a city council my not withhold approval by imposing unauthorized conditions. In conclusion, as stated at Section 70, page 371 of Yokley's treatise: A city council will not be permitted to exercise arbitrary discretion in approving or disapproving plats where it has enacted no ordinance on the subject. In such situation, a subdivider is only obligated to conform with statutory requirements. Likewise, a municipal body may not impose conditions in connection with approval or filing of plats by subdividers where such conditions are not authorized by statute. SUPPLEMENTAL PLATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 5 LAP/OFFICE OF DANK, COFFEY Each proposition stated in the Yokley treatise is supported by numerous, recent case citations. Accordingly, there can be no question but that the views stated in Yokley's treatise represent the views of the vast majority of courts throughout the United States. in conclusion, based on the unequivocal statements in the Yokley treatise, it is clear that the Municipality, having enacted no ordinances or regulations whatsoever governing the use of Iow-nitrate emitting septic systems, may not require the use of, or a plat note requiring the use of, such systems on Denali View Subdivision lots. Were the Municipality to maintain this position, Skyline View Corporation would be entitled to issuance by the Superior Court of a mandatory injunction forbidding enforcement of this unfounded requirement. IV. Many of the Statements Made at the November 5, 1997 Platting Board Hearing by Those Who Oppose the Approval of Denali View Subdivision Were Sirnply Not True. Skyline View Corporation has taken the time to prove, in the document submitted herewith as Exhibit 5, that many of thc statements made at the November 5, 1997 Platting Board Hearing by those who oppose the approval of Denali View Subdivision were demonstrably false. The Board should take this into consideration in passing on the credibility of the parties' respective positions. Conclusion It is impossible to guaranty any future state or event, particularly when natural processes are involved. However, AMC Section 21.15.110(B)(4)(b) does not require any such guaranty. It requires only that the appl!cant "substantiate the availability of a safe and adequate volume of water for domestic purposes and the capability of the proposed subdivision to adequately dispose of all waterborne domestic wastes." Further, this being a civil proceeding, the applicant is not required to make this showing "beyond all reasonable doubt", but rather must show only that his evidence and position are "more probable than not". Skyline View Corporation has more than satisfied the requirements of AMC Section 21.15.1 lO(b)(4)(b), and all other requirements, prerequisite to plat approval. The applicant's professionals have substantiated the availability SUPPLPMENTAL PLATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 6 of a safe and adequate domestic water supply for the proposed subdivision, and the capability of the proposed subdivision to adequately dispose of its waterborne domestic wastes. gly, Applicant Skyline View Corporation respectfully requests that the Board approve its y subdivision plat at this time. RESPECTFULLY suBM,TTED this J_~ay of May, 1998. LAW OFFICE OF DAN K. COFFEY, P.C. Attorneys for Skyline View Cg~p_.o__ra~t~n I~W OFFICE OF DANK. COFFEY ATTACHMENTS: Exhibits 1 - 5 C:kJDD.N EWAMYERS\BRIEF.2 SUPPLEMENTAL PLATTING BOARD BRIEF OF SKYLINE VIEW CORPORATION PAGE 7 FROM ~ FCicR My~lrOl~, Mayor MMM CONTRACT ] HG Apdll'?,1998 Municipally of Anchorage Oepartmenl of Health and Humall Service8 628 "L" Street P.O, 86x 196850 Anchorage, Alaska 99519-6550 Mr, James A. Muntm COWl* PrinoipleHydrolo~ BHstol E~v'J. ronmentalServices Coq~oratioo P,O. Box 100320 Anchorage, AK 99510 RHONE NO, : 6881258 Apr-, 17 1998 03:08PM Pi Post-It* Fax Note 7671 D~ar Mr. Munter: have reviewed your Modflow Model information con¢,,m'ng the proposed Denali View Snbdlvlslon. My review of tho model involved addressing the following quastiono: 1. Was the model appropriate fbr use in mi area with die geolog/e}fl aitribntes of Deoali View Subdivision? The ~nswer to this question is yes. Resern'ch and discussions with Mr. Gordon Nelson of the U. S. Geolo~cal Society show that tiffs model was ~ppropriately u~d. The USGS uses thia model in bedrock aquifers, and l' found no ronson to question this usage. 2. Wast he data used inthcmodel ad~uateand accurate? I £emtd no gro~s inaecuraeie~ h~ the data used, and, Mthough the amount ofd~ta w~ small, I see no reason to bttrdcm the developer with additional exp*uses to acquire additional data~ Th* model appenr~ conservative in some re'cas. For example re¢}l~rrge data was not used, and the use ofr¢aharge data would hay0 d, ora°sod the amount of&aw down predicted by the mod*L 3. Were the assumptions nsed for the mod~l reasonable? I found no reasons to question tho assumptions u~e¢l for the model, The size md botmd~ry conditions of the model seem appropriate. The model Gould have been r~m with a ~me, ller value for transmisslvhy, but a halving oft}tis yahoo would no* cause a large change h~ the model results. 4. Did the model rmi correctly and converge? Although the initial mn of the model showed a percent discrepm~ey of-29.95, a subsequent mu of the mede[ with mare iterations brought this discrepancy down to les° that 2 percent, wl~eh is quite acneptable. EXH I BIT___/__.-PA('I L..~- FROM MMM CONTRPCT I MG PHONE NO. : 6881258 Ap~-, 17 1998 03:08PM P2 5. Do the results show an undue affect on tho ~urtounding subdivisions? Thc results fi'om this model show that the/mpact on adjoining subdiv/sions will be minimal. Tho rune'am of draw do'~ predicted by this model at the boundaries of the proposed subdivision will be just a few feet, which is less than the, predicted seasonal fluctuation in tho aquifer(s). I conclude that this model suuefieiently indicates the availability of mi adequate volume of water for {tomesti¢ purpose,q for the proposed subd/vision. Pro,'am Manager On-Site Water Quality Paul Myers, Skyline View Corporation Elahl¢ Christian, D/rector, DB'/tS Lura Morgan, Ph.D., Manager, Bnviro .nule~ttal Serv'ees Divmion Nitrate (rog/I) 2/16/83 ~ 8/16/83 - 2/16/84 - 8/16/84 2/16/,85 ~ 8/16¢85 ~ 2/16/86~ 8/16/86~ 2/16/87 8/16/87 2/16/88 8/16/88 ' 2/16/89 8/16/89 ~ 2/16/90 8/16/9O 8/16/91 2/16/92 8/15/92 2/16/93 - 8/16/93 2/16/94 8/18/94 2/16/95 8/16/95 2/16/96 8/16/96 2/16/97 8/16/97 Nitrate (mg/I) 6/1/88 10/1/88 2/1/89 6/1/89 10/1/89 2/1/90 6/1/90' 1011/90 2/1/91 6/1191 10/1/91 211192 6/1/92 10/1/92 2/1/93 6/1/93 10/1/93 2/1/94 6/1/94 10/1 ,/94 2/1/95 6/1/95 10/1/95 2/1/96 6/1/96 10/1/96 Nitrate (mg/I) Nitrate (mg/I) 1/1/83 7/1/83 1 / 1/84 7/1/84 1/1/85 711/85 1/1186 7/1186 1/1/87 7/1/87 1/1/88 7.'1/88 1il/89 7/1/89 1,'1/90 711/90 1/1/91 7/I/91 1il/92 7/1,'92 1/1/93 7/:/93 1/1/94 7/1/94 1/1/95 7/1/95 1/1/96 7/1/96 1/1/97 7/1/97 Nitrate (mg/I) 0 o 0 o Nitrate (mg/I) .- Nitrate (mg/I) o"1 ~ 0 Nitrate (mg/I) IN) ', 'i L ,. -- I ~x, ~1 /~ ~ : - ~ ..... ~' ' DE~. OF I-IE~I & $OCL~ SEI~qCES DIVISIOt4 OF PUBLIC HEALTH ~o. SECTION OF EPIDEMIOLOGY ANCHOP&G~, TONY P. 02 (907~, 269.8C03 DATE: April lO, 1997 TO: CatherLne Schumacher, M,D., M.S.P.H. FROM; Lori A. Feyk, Ph.D. 5UBd'ECT. Health hx.:p!icatiop, s of Nitrates in Drmkix~g Water The following is a short summary of the hfformation obtah~ed from the TOMES data base (thamks for being patient!) l have more detailed ini'ormadon, including references, if you nee. d it. Just let n.e ~qow. · To.,dciry Nitr~te toxiciD' is due primarily to i~s coaversion to nitrite, which oxidizes the Fo(+2) form of iron in hemogiobin to the Fo(+3) state. This compound (meu~emoglobin) does not bind oxygen, re~,nalting in reduced oxygen transport from lungs to tissues. Low levels of methemoglobin occur in normal individuals. Concentrations above 10% metb_emoglobin (of total hemoglobin) may cause a bluish color to skin and lips (cyanosi~), wNle values above 25% lead to weal, mess, rapid pulse and tachypnea. Death may occur if me,$emo¢obin values exceed 50-60%. The: most sensitive human health endpoint ot' concern for nitrates is methemoglob[n_em..m.i.[a-[" ini'~lnt-'~ Conversion of nitrate to nitrite is mostly mediated by bacteria-iff th'~-~ggastrointesti.nal system. Consequently, the risk ot methemoglobinemia from ingestion of nitrate depends not only on the dose of nitrate, but also on the number' and ~'pe of enteric bacteria. Conversion of nitrate to nitrite may occur in the stomach if the pH of thO. gastric fluid is sufficiently high (above pH 5) to permit bacterial growth. This is of concern in adults with diseases such as achlorhydria or atrophic gastritis. It is also of concern in infants, since the infant gastrointestinal system normally has a kigh pH that favors the growth of nitra;e-reducing bacteria. l~'k is especially high in infants who are exposed to v/ater that is contmrdnated with bacteria, since this tends to protnote high concentrations of bacteria irt the stomach and kttestines. EXHflBIT~--~PAG J TUff 10:56 Catherine Sehumacher, M.D., .M.S.P.H. April I0, 1997 .. Page 2 Nitrate is a normal component of the htm~an diet. Over 85% of nitrate intake in a w. pical adult comes from the natural nitrate content of vegetables. The contribution from drinking water is usually quite small (about 2 -3 % of total), unless '.he water supply is contaminated. Some adults consuming high levels of vegetables along with water containing Ugh levels of nitrate could receive total doses of nitrate approacn'ng the recommended maximal daily intal~e. The Reference Dose for drinking water is 10 mg nitrate-nitrogen/L, This level should not be exceeded in drip&lng water. The number expresses the amount of nitrogen within the nitrate molecule, which is what is E,~2ically measured. There is a high degree of co.o/~dence in this number, which .p~des.~_2Lotection tBr the roost se~_nsitive hujrlan health endpoint. Calculations were made con~sidering the ingestion of dri ~nking water used to prepare infants' formula. Methemoglobinemia has been obsen'ed in inf~,nts when this level has been exceeded. Cases r~ported at levels of 1 20 mg/L .nirr__a!e-ni[rogen were usually associated _wwith ccmcomJta, nt-exposure to Xoacteriologic_all7 c~ontaminated water or to excess nitrate from other soux.¢.~. Repeated Studies proviOe convincing evidence Sat infantile methemogloblnemia does not occur at drinking water levels of 10 mg nitrate-nitrogen or less. Marker of Fecal Con ,taminatlon? My impression fi'om the available information was that__nj[rate is not necess~arily a_. marker of fecal contamh~ation. I thir2~ that high levels of fecal coliform bacteria c'"'~ti) are a better marker fei that. However, fecal contamination in drinking wa~er would definitely Mcrease cbc hazard associated with concomitantly high nitrate levels in drinking water, Carcinogenic Potential Some chemical~ kn the class called "nitrosamJnes' are kd:own mammalian carcinogen. A potential pad, way for the formation of such chemicals is the nJrrosation of secondary amines that are naturally present in the diet. The source of the nitroso group is nitrite, mos~ of which is produced endo?~ously in humans from nitrate. However, while endogenous exposure to such nilroso compounds appears to be fairly ubiquitous, their relevance '~o the development of human neopla.~ia is questionable. To my knowledge, recommended intake levels of nitrate have not been based on this endpoint, and the i~fformation surrounding it is much l¢~s certain than that for infant methemoglobinemia. Just wanted to make yon aware of the subject. Let me know if you need more info! EXI-IIB r]',~,___FAG E~ On nitrates, drmbng ,,nter, and hum:in he:l[th ,,. Bp. tee C!:~mdl',:'r, MD,. L .. April 1997 Nitrates in th(: cnvirnnmcnt - -, .-,, ' "'3,:' , ~.' ,. .~h,.: :.'ibotlt '.hree-6')urth:; o(the The E3.Fd2 £ ,.!'re!esr ':=re ,c ab,,_ t t .,8 ~.el,,¢.lt ,ih,k ,=e,l slx1 ' ,, . ' ' ~ &e :, mop,here and a substaatial amounl are rele~ed into the ~roducec :,y c,~en!lCal rcac~:ons ..... , . ' ' .:.. n; .....' '- ' ' · ' ;- ~ · :md improper a{sposal or 17211ifil Zlk- . ' ' for , -. -:~ have a mtrog.an cur. toni o, ~1 and ,n percent, resaect:ve ,' ,, cftc .`tie widdy used liquid " of domes;it ~, ell,: ~d ' ,0.' ' suppb' ~elI= :xceed ,,his s~andard.'" t~.~ ofpubh¢ Tee movement ofcontm~inm~ts in ~roundwa~er is a eomple:< process i~dlueneed by many some of these ;~e die a[iiotlll~, size. arid soluNh9' oi the con:o~inant: fl~e physic'al, cnom cai, microbial ch~ac:er of ~ll~ soil ~:d rock; nature of o~ erlying vegetation; the depth of ~oundwa~er: rate of groundwater flow; and the amount Of precipitation. Nile:lob;oleg}cai -. · cm~t~:;mts 5tlC}l :'~ bacteria :md viruses usually :ravel a 3ho~ dislance through sturdy loam ........ { Chemical cont~linm~ts. bein~ of' alt:cE sturdier size than bacteria or ,.';roses. tend to :ravel much taNhe, 111 aqmtcrs. ' ,., ; < ' ~2 Lis potentm~ ~k>r contamination oF?oundwater m=pend o~1 sc'. era: e ....mc'.udhb the soil charac~e:dsdcs, location and characteristics o/the umkr~ound.. ,~- fom~ations, and climatic condi;tons. Nitrates ~0 extremely soluble ill water and can mo*e ¢tsib ~hrough see in~o the drinking water supply'. Thc potential tbr conlai~nath m of d-ink in~ water also depends on tile depth and col~str~lcuoll O; wells. ~ecuu~e nitrates move with the flow of groundwmer, th~ source may be located at considerable distan¢= ~om ~le ,,.cU. Il mmlv caleb, d~e dine needed ;bt nitrate to ptl~s through th~ soil !hie gromq, dwater is di:?.cuR to predi,ct due :o man;.' va. riables inc!uding appEcation rate, the soil tS.'p¢, and the dc?th to the water t:tbic.' !der. dl'.'-ing the source ofr, hrates or off:er cL,¢mical st'udles trod moni:oring ,.,,ells to trace :i',e migration ,.'T Ihe contaminan~ Ln :he grotmdwater may aquifer_,'. :.u':d groun&.vater con]z:'::h':.a:ion '.','ith nitrates or od'..er che:nic:'.!s 2:,.>' persist ;',-,r decades or lo~lger.6 t'-tu man nilr;tt.e Nitrate iz ?. nc, ri'ali camI'Onent ,~F :he ha. man diet. Thc mcdor ::-ourc~ ,'st :'Er:atc. s t:',.ken {nec hum.;m bcd':' is usa:ally it>od r:'.:her than ,,vate:. Nitrate ts pr=sent in ail i;iam's; veg,.:tablcs ;rte a major sci:rca of 25:rate Ln '.he dict. O,~:: ..q 9".',, el'nitrate in:eke it: a D'picai adult diet comes tI~e :'tamrai 5trate .:..'ntent ct"-e:.:et:.]k'.es. Celer}', potatoes, Ic~tc::. melt':':5, caN>age, q>irtach, and many et' the roof ,.',-"getabics eoi~t:ibuto l?oth ::iwutes and nitrites :o ihe diet.= There }:ms been no that have occur:ed in fertilizer usage. Other 115ajor dictao' oourccs of nitrate are t'ood-smffz such as cured meat pr,.'.d'acts ::nd .,'er~z::.n '.:: !:<~' o£cheese :,'> which ::i~rare (or nitrite) has been added a eta'big agent cc ,.'-re..s~r',ati', e.s dail.'- nitre e illta~:e h, crea*e,: a?m'o,::matelv tl'd:¢e-~'oi \V'here .armgmg water is to a level o= :,0 mg.'l la times d:c EP.\ },faxin"mn': COlltanlllla:lt Loved h'~£an[s in the first from water u=d i,., the prepa.radon of :'om'mia. I-~umm'~ breast milk i~ net a significant source of nitrate to breast._ Nitrate toxicity q..~e toxicity ol'nitr:.tte is due iwimariis' Jo its cm'~vcrsion to nitrite; [5:ri'~c oxidizes the Fe(-2) Ii>ma o£ircn in hemog!cbi:'~, lhe rnole.:u[¢ in :he red hh'~od cull which dist~dbuteu oxygen to thc: body's cells, to d'~e Fe(-3) state. T~is cnmpoup, d--metl'~e:noglobirt--does .".ut bind oxygen, ¢csulting in reduced oxygen :r?a,..spo~ .q'o[n lung:. '.c :2:~ue$. Low leve!s ofmethcmoglobht occur in norn'Jai individual.~. Concentrations above 10% methemoglobin rna.v cause a bluish color to skip. ired lips, ,.chile ,, alues abc,x e 25q'~ !e::d to v.'eaknes':;, rapid pulse and :uchypnea. Untreated, severe n:ethet:n, ogl~fi:ine.'n, ia can :e:~uh ill brai.n damage; death, ma? occur if w.c~hemoglobin values exceed 50-60'!.0. 1"he human health risk or'~rcate.-:t conc~=m For nit:ares is r'net}:cmo~zlobinerr~i:~ ttmorJu [)l~all(s. Consequently. th= risk o~n~e~he:noglop~incmia ti'om ingcution of niwatc depends not only on the dose of nitrate, but :else on the n'~nbcr ,md type o I' enteric bacteria. Conversiotl of [xi~rttt~ to nithrc may occur :.n the stemach if the pit of thc gastric fluid is sufficieat!y high (above pr r 5) to pem~Jt bac erla growth, This is of concern in adu!ts wkh ceaain diseases such a achiorhydr{a or ' ' ~: c ~ *c.~ productbn in the. to I/a~h is reduced. It l_ al.,o of,encore :n ' ' , "r ,;.,' e' normally has a high pll ~at Favors :he ~ox~h ~f mtrate-reducm~ bacteria. ~k is ~.q =~.,.lly m?~ in infants who are exposed to water thai is conta;r~ated '"." ' ' er.-~ ...~ - x,,m cactcna...,a,~ .N., ,Mlda [o promote high concentrations of bacteria in the s omach tm~ [ate:stines. In "' ':':' ....... ~.a, the red blood ce~1s of newborn hghnts col!ta{n Feta! oxidation by nitrite ~han ~: ad,tit ncmog!obm. }!cmogioom. waic;>is mu.:h...t.e u.~l~.iglo ... ' Med~emo_e!obinen',ia in ini:a, ms ur, der six months o£ a~e is ~hc only illness ~ Nth is cl¢~rly cau~cM by the ~:'&e ofdrir~ng water v, ith ¢]c'.'ttied ~itra:~c }ex'ds. Thc re~a{ionsh!p I:e~vccn inlhnt me~hemo~k~b~e:nia and dri~Xing '.~ ater containing more than 10 rag'[ of nkrae ~trogen was firs: descrilocd Lq [9z5. Subseq~:ent ei>ide:niologica[ studies have dcmonswatzd a dose dependent re!aG>~hip ber, vecn nitrate conaenlratbn in tho &inking water and raised methemog}obin levels, Ft->r i~':mts con!u::lii2g v.'.-:ret ;,ith :0 mg:[ nm'are nitrogen of A comprehe:~sb'¢ stud? ~;f ip, x',:::t mcthen:ogiobincmia !l'~ ibc United States in thc 1940s and 50s by Walton fi>uad t~at only 2 percent oF~he cases oi'nltratc water-induced methemog!ebinemi~ occu~eo in association with :~tratc nitrogen cencenn'atk>ns of 20 rog/1 or [ess, wkile sl~ghdy over S0 percent of cases ~ere corrc!ated with nitrate nitrogen concentrations orS[ ~gq or ~watcr.~ Cases repor;ed at lex'e!sof 11-20 mg,L nit:'ate-n~',rc,?:: 'x'erc usually ~sociared x~i~ cotlcomi~;mt exposure io bacte:'iolo~ically cot!taminated water ~r io excess nitrae .."rom o~er sources. Rcpcutetl sRidicx have shown that illfant methemogiobb~emia does not occm~ ar dF~Uag water !c~:is of 10 mg nitrate-ailr,'ogen or less? Similarly, water with nitrate l~ve!s nom~ally poses no risk to older children or adults. For examg!e, one study of over 100 illinois 'c~dren 1 -g ye:ws in age ingesting water x~ ith nitrate mu'ogen content r~nging 23-204 mgq ~bund no elevation in mcthemog!obin levels in thc children and no rc!ationship be~.,~ea ingestion of high nitra:c water and thc memqured mcthenlog]obln level.14 Because Lugestlon of excessive amounts oFnitl'atc can cause advc:'se h. ealth effects m yeU yottn~[ infxnrs ~d susc~ptlb[e adults, the United States Environmental Protection Agency (EPA) has established a maximum acceptable level U~o~n] as thc Maximum Centamimmt Leved (MCE), for hi,ate ia public &'i~h-4ng water supplies. This lc'.'d is 10 milligrams per liter (mg'l)-oflen expressed &s 10 pmxs per million (ppm)--measured on the basis of :he rfi~ogen content of Ntrate. T~s sta~d,gd o( 10 ppm ni:rate-~zi[rogen was set to prevent tile occun'encc in ii,mit melllcmoglo~izem{a ,.X"lL. ~ ,~ reasonable margin o1' sar~)'." ~.~0 V,~!e mssociatiecs of nitrate cer. trmninatioa o£ground water with a munber of other health effects (including hype2ension, c!inical methemoglobinemia in older children, increaaed inter mo~aliD', prod cea:rat '.:e>.'ous =?'stem birth detects) have been reported, only the association ber, veen ?,~t:z~-watcr contamin,xlion fey aitrates and intern :ncthemoglobhlemia has been prosen.i: LS 'lqlere i;a,.'e }:'..'..'n cOIlC~."'?IS l}lal i~itr:.ltc-conlainhlg compounds lll{ghl caug. e c:llleer or bil'th dc£~gc[g. Conc!~si,.'e prm:f .:,f a"~ar,"'.not:~.,X:,,'"' ' effcat in humans c,.r rdtrate compounds is currently lacking. ......... io20 ['ne res:.:lt~ or eptde::'~:oleg~cal .q:x.hes arc° contradictory iu~d tnconc t:sive. ' The Illajo~[y of evidence by which nitrate exposure has been associated with ~ incre0zed ex?,cer :5.'sk is derived ~om correlational ~,mdies which, by their nature, providc only weal cvid. e::cc. Al He present time, nitrate e>:l'.osure in dri,p&ing W;LtC:' ,:elmer be i:nplkaEed of cxc!udcd its a causatlvc fhc~or t'or ee~ain "4 pos of cancer." .~.nimal data !:as nc, t sho\~qq ~_videnc: ,',t'bi~% ,.lo fee!.-: or ma!.%m~a:ions atqributabie to nitrate nv nitrke h~ges~ion. Ads erse :mime[ repmductix, e effcc:s in ihe fo~ of L<cre~ed rural loss have be=n repotzed o~215 ~n doses :hat were 1,000 times t~nd higher thtm the e:~tima:cd k, umcm intro. The resuhs ofepidemiologic:fi 5indies :o date are c~mtradic:~ry and i~eondush'e. A~ the pres<~at e~Z'cts or congeng, a~ maitbm~ations.- ......... 1. Nitrates...c,~,L ........ .~,.m,,,,.' y L': air,' soil., ptunt$. ;.'.nd gloundwa er. ~ Elevated nim~te levels in grotmdwater may bc ,ne .,..,,.It ofhum,?.n actl'v'llleS SUCll ,0x'e.~a,~c ............. c t ,..c.ll.,.,..I f'e~xi!izers and 5mlm:~p,::r disposal of httmm~ ox, d atlm:m ..,.v " l'he delineation oftl:e -,- "' , in,groundwater is oken ~:r i ,-,, ¢,. o. >ourc~ o, rate..'? t.,. lieu.t, · nitr.2te~ ~e sma!l n'..oleculcs w; ell i re bighl,v soluble ill mt.ate_ ,may move great dlsmi:c::s {'rolI1 theh' point ,>t e::tr,v illto .tm ~llderground aqtufer. · niu'ures cor. tar'eination in ur. der~retmd aqui£ers a-~.ay poi'stat for decades, 4..X[cthemog!obi~.cmia in young inf'a.,'.ts is the primar,v human heakh ~sk .posed by ,,:t.. nswn[..t.t,,~ o~ q il'.2 c-,,,onta lltlla ed ,a a er. '[his dos¢.dcpende.nt ol.ltCODle hi.!5 beel'i ob~erx'¢d ,.rev ~lo,~g .,,.,tmg m.tams who consumed v.'ater containit:e more than l0 nitrate nitrogen. L.t)IIsI. IIIlp{IOI1 ot'v,'ater ,t: n less than .; m~.,I ~litrate t~itrogen poses ao identilied health risk for hum?.zts of any age, Holmes l', Jensen ~, Con,way CB. ,N'irrat¢ con;;mina~ion ofdnm~*ric 2otab;~ ,~er .... '-*. Amet~c~ ]o~ai o;' Preven:ive .Medicine :r;~5; 4, _ ~.p~,l~;.. ' V, e~cnb~gr DD. Polcn!:3{ Heahr, coflsequeaces o(2zound-,.va~cr COHt,ill~lla,;011 b~,' ni~ale~ in ".k -. ; ~'ess ~C. mai b¢~ (:~. ~rt ncr DR, = a}. 'F,I¢ rrm'ate .'c, ncentza,n~l ,a~ m':vatz ,.v¢~ - . ..... Ho~es T, Jenson ~, Conway ~." ' ' ..kmedc~Jo,~lorPrc~cnfiveMcd~chlc 198~: :5!-7 · . , ~ra~e .ufilammahon er d~mcsr~¢ ~otah(~ ~a:ef sugplie:,. Ame~c~ J;3u~ ..~fP:c~cntive Medicine 198:?; ' 51.7. Epidcmiologv e~, ,. . I .... i';24-320 ~ We~nhur~er DD. P~nel d~scus~ion: Ilcahk ,:an~¢quenc~: panel ~:an~.e -u~ ,)* ~ cl~.htl3t . c, ~: ! canscquenc~S of dcvated nitre ~c',ds. Ncbra...c ',lc ical Journal ;993; li-2 ~o Clubers C. .:n" -- -;',- · H~._,,~., T. Jcmsefi ZL. Cenwav .~ N ~ra!e cc, i;Limi~iat:on o[ domestic po 30 c x 2let " .*..cnc~Juum~c~Pre~e: ~eMed;dne:gs5:i:51.7, ~ ' "Webenbu~zcr Df). P~ne} discussion: hcahh con~:euencrs: I);mc! ' -- '- elevated nitrate :ovals. Nebraska Medica~ q>,mlal 1993:" ' ' Gt, Grea~m~e ~ .G. (Jundcr. on DI4. Mefl~aumoglobm levels in young c]:ildren censumit}z water b ~he 1.'nk~J SIa:c~. international Jour:lal t>f Epid~mJolt)~7 1981:10 J09-, 7, u ,~;¢..~ ' - aeal..l u~n.,equen~s: panel consensus tg'put~atja] dove[ed ai~ c :eve~. Nebraska S[~dlca~ Jouraai ',993; 11-2 's ~'oss BC, Ha]lbc~ G~ Brunet DK et al. ]he n r lc cmllumina';on of pri~ ate ~c!i '.valor ~r: Xn~ a. American JcumM oCPublic ~.Iral[h 1995: 83: 270-2. ,Vc:2ub~ger DD. Pnrenda] heallh consequc::ce¢ ot ground-water cunmminudon bv ~lllri~tcs bi Nebraska, Neb~ Medi~ Jomal 1993; a F~ ..bM. Willhke CC. Bock SA. ' · ' n','alu,dmn of :he re[rate ddnkina water standard ~ ith rel~rence 1o infant m~themogk~b~.~ia and pmenfiai reproductive tox/c:t~ Regui~tolw Tuxicolo~v and Pl:am;aco[o,,v 1987;7:135-148. -- ~ Tsezcu ..X. ' .... ~m~ou-,zcb 5 _uur,~ods D, et al ,h~h n t ate contcn ;n drf~lng ',~a~e:': c','[ogenetic ex[oscd childzen..~-chives o(Env{ronmenlul Heakh z°K"einlmnsJCS'Al~mngmo. Ma~.~,etal. Niware :onmm na onofdrmk~ne .... in kumaa popui~on$. Em'iro~,cmal Hcahh ?vrspeclives 19914 9ar 189-¢jYa'¢t' c za,uahoa ot gcno~ox~,: risk .b.r_.rDD. 3 ...... ' .' ' , .. :-,l~l d ~c;,~sloa. tc th cor,~cq'.;c::ccs: panel ¢otBcn$u~ ot paten a~ he2ilh zo~equenccs or' devate~ ~ate '. ..*els. N'ebrmska Mca!cai Journal 1993; ', }-2 ,.veb, Nebraska Me'ica[ Journal .99~, I Fan AM. W[JJhtt¢ CC. Bouk SA. Eva!ua hmo 'the nttrate .Jr~nki;l~ ~a;er ~tandard mz:hemo~oblnemta :md ~ctenfia~ :eproducm'c toxic/tv, Rceul~mp.. Foxicolo~x ~d Pham/accioa7 fan AM. )lember2 ~. Health ~m~hcat!on~ ,' . · me:~cmo~obin~tu occu~ellcg and rcprc, ducl~ve and dcvelopmenlaJ toxJcjh. R eaula~,',r,-. T,~xbolc., Pham nco 057 1~)~:23 ~f- J). · - ~Y" ~le, i~)~s JCS..M~mg NJ. Marx ..X, ti al. Nitrate ;ontaminam)n ot'drmk:n~ water: evaluation ul'~eilOtOXiC .'JX~ m ~ut:;~ 7opuiam)ns. !Javirortmunra[ Heakh Perlpccfives 991; 9a:i 89-92. FROM : MMM C3NT~PCT]NG TO: PLATTING BOARD FROM: RE: SKYLINE VIEW CORPORATION TESThMONY AT NOV. 5 PUBLIC HEARING This letter is to review and respond to public testimony made by several individuals. Annette Smith: Annette Smith, stated "We are haulin,e 500 gallons of water every week. all the way to the Valley to get water". We am driving Response: Paul Myers talked to Larry Sm/th about hauling water. He stated that he hauls it for bis. wife to do laundry at home and they have a large family with four children, lie hauls water from the Valley becau~ he goes to see a friend out there. There is water readily available in the Chng/ak, Peters Creek area. Larry Smith: Testified "When the test wel]s were completed on Wednesday, the testing for lhose that they did first started on Friday morning, and as of 10 o'clock that ni,,~at, my ho}ding tanks had not recovered but 1o half the amount they would hold." Response: Paul Myers talked to Larry Smith who stated that he knew this was just a coincidence and not from our testing. That he understood fi'om Mr. Young and the reports submitted by Environmental Services that umge more than 100' away would not interfere with his well. Annette Smith: Said "To say that we as a community have been uncooperative, that I t~k¢ offense at that when we have been advised legally not to sign the ho!.d harmless that was presented to us. We'd be idiots to do so. We're not going to sigt it. So, where is the compromise in between. We tried to make a proposal. I have not formally heard the petitioners response to that request". Larry Smith: Sa/d "Their hold harmless smd for $I we cannot hold you or anybody affiliated with Denali View, DHI Engineenng or Environmental Services, or their heirs, ever responsible for anything that occurred". Response: This statement is not true. We can be held responsible for ~tny negligence for work done. For Mr. Smith to say that his lawyer has advised btm not to sign the hold harmless when he is the one requesting the testing does not make sense. I believe this could be clarified with his lawyer. { requested from Larry Smith that I have a meeting with his lawyer or that his lawyer talk to our lawyer so that he would beuer understand tbe i.q~ues, however Mr. Smith did not respond to that. =ROM : MMM C3NI~PCT~qG ~CNE >~C. : &~Si~iS D~c. !Z 19~7 i~:ilAM R2 Smith: Sis'ted that "The developer has not, as far as I can tell you, contacted ute or any o,rmy other neighbors as to what a second proposal, proposed test would be" Response: We have talked to Mr. Smith time after time about these issues. Mr. High has talked to Larry Smith & JeffWilliams many times. Paul Myers had just talked to l.arry Smith for approximately three hours on November 3rd, two days before the platting board hearing. For the Smiths to say that they did not know what the problem was with their proposal is not tree. Paul Myers had talked to him and so did the project engineer Mr. Dee High. Lar~ Smith: Stated that he filed for his water rights after Mr. Myers had filed water fights for the development. Response: Mr. Sm/th has and his neighbors have all known about their water rights for years. This subject was gone over a few years back when they were voting, on nublic water. Mary. Willimns: Stated that "We had gotien something fi'om Myers that stated that they could come and do anything t}mt they wanted to our wells and we could not hold them harmless for any damages that happened." Response: This is a blatant misrepresentation of Ihe hold harmless. This hold harmless stated it was for the purpose of hydrology study, well static level and flow tests. It also held developer & engineers responsible for negligence for any work they do. Mary Williams: Stated "Tho la.st test that they did, one of the people at the end of the read, the De.~ers have had water problems, or pump problems, well problems, we don't know since mat t~Sl". Respen3e: We had the Degners problem checked out. Mr. Sullivan of Areti~Well and Pump went up and check out their system. He could find nothing wrong. Hi~ said they may have air leaking throul?,h a pipe. However, it vms abmlutel¥ nothing that we caused This is exactly why our experts will not proceed with any work on sites without a hold harmless signed that protects them except for negligence. EXHIBFI' <----~''- PAGF~_. Mary Williams: Stated *'We have not heard one single word from them in weeks". Response: Mr. l-Iigh has talked with Mr. Jim Cross in response to their proposal. Mr. Cross has been keeping Mr. Williams apprised of all prowess. Paul Myers had, also, talked to Larry Smith and advised him why their proposal would not work. Penny-Brewe~. Test/fled thai her well is 387'. That they haven't done any improvements or additions to their well. They don't have any holding tanks. She states her and her husband have had no problem since ]986 when they purchased the home. Penny Brewer, also, stated "My husbm~d and I have been discussing it. Financially, its a big burden upon us. We're young, we only make so much money. It may not effect your pocketbook if this development does in, but it will effect mine". Response: Tbev are r/ght next door to Mary & JeffWill/ams and do not and have not had a water oroblem, rkis home whmn is less than 22.',' away [Tom Mary wdl~arda autl her water ctoes not affect lhem. This development which is much fi~rther a,~av and in a different l~uifer will not affect them. In mai/tv the financial burden to boris the Chugialc Com. mumty Council repeatedly talki~g about water problems iii Scimitar Subdivision with substantial hnnaet on oroeerly values. Mrs. Degner: Stated that after our running the water test in May that they have since had problems va'th air in their system and that we did not do anything about it. Response. We did do something. We had Mr. Sullivan of Arctxc Well and Pump go up and check out her system, ble could find nothine wrong. He said they may have air leaking through a pipe. However, ~t was absolutely noti~mg that we caused. We shut offthe power to their pump and disconnected the wires, measured the static water level and reconnected the wires and turned the pump back on. We have talked to Mr. Degnar twice and so have Mr. Sullivan. We were astounded that Mm. D%,mer and Mary. Williams all got up before this board and testified that we did not respond to the Debmer's stated problem. This is exactly why our experts will not proceed with any work on sites without a hold harmless signed that protects them except for negligence. Sharon Minseh' Said that she was unereparod. Response: For Sharon Minsch to state that she was unprepared to go before the Plaiting Board is ridiculous. Sharon Minsch has submitted 68 pages of comments and information to the Plattim, Board rem~rdins this qn[xtivisio, n eno stated that the developers have continually delayed this, The developers delayeo this MMM CDNTSAcT]NG ~CNS NO. : 6S81S38 Dec, .-~ ~cc~ ~,i~M =4 previously at the request of the health depamnent. I! was not because the developers wished to delay but to give the health department tuore time per the r requcst~s. Sharon Minsch has spent an extraordinary atuount o£time fighting this subdMsion and has been current with everything that has happened w/th this platting process. She has used her position ms Community Council President and member of the Water Teeh Board for access to influence personnel in both city and state offices. *n Minsch: Sharon Minseh stated that Mrs. Degner had a proble~n with the developer. She also stated that we have not been forthright with the community. Sharon Minsch called harself"The Queen of Crap" and repeatedly cia/ms extensive knowlextge regarding water wells and septic systems and is on the water tech board throud~ ~he Demu~nent ot' r~l~alth and Human Services. :onse: She maxle this statement without clarifying and making sure ocher facts. Sharon Minsch's saying that the Degnars had a problem w/th the developer is a misrepresentation of the facts, h is her responsibility as the President of the Community. Council and as a proponent against this snbdivision to honestly address these issues before making a statement and passing this information am~md to the other homeowners. She has .slandered us hath no-r.qallallv and as a develnn~r i~ h~,r eanmai~n or writings. Her statement that we have not been forthright w~th the e0mmun/ty Is a misrepresentaUon, when in actuality the,developer has been honest & forthr/ght with all information to Sharon Minsch, the Community Council, and home6wn~s in the adjoin ng subdivisions. We have }md a hard time receiving any information from the Community Council although we have requested information time after time without any response. We have been continually blind sided with new information submitted to the platting board at the l~t minute by Sharon Minseh. Sharon Minsch now states that Dan Belies has information on which he is going to test/fy. Sharon Minsch. Jeff& Mary Williams and Larry Smith have omhestrated a emnpaign of misinformation that is shown in the misrepresentations in their testimony and documents. Sharon Minsch made an offer to the Platzeks to donate the property for her and the local people use this property as a park for the next 30 years with no compensation. If there is t o be no compensation then the property is worthless. As a Realtor I would hope that she understands the value of properly and what continually misrepresenting the situation can do lo proper~y values in an area. Scimitar subdivision and surrounding area's properties am selling for 30% less than comparable properties. Sharon M/nsch has a 50 .GPM yvetl, sh~. knows_there is adeauate water in the majority of tho area. TO: PLATTING BOARD AUTHORITY FROM: SKYLINE VIEW CORPORATION RE: DENALI VIEW SUBDIVISION S-i0054 DATE: APRIL 1 1998 TIlE PURPOSE IS THIS MEMO IS TO REQUEST A CONTINUANCE OF THIS ABOVE REFERENCED MATTER BASED UPON DISCUSSIONS WITIt THE DEPT. OF HEALTH AND HUMAN SERVICES OF THE MUNICIPALITY OF ANCHORAGE. TItlS CONTINUANCE IS REQUESTED IN ORDER TO ALLOW DHHS TO REACH A CONCLUSION ON THE QUESTION OF WHETHER OR NOT PLAT APPROVAL HAVE A SUBSTANTIAL EFFECT ON TIlE SURROUNDING NEIGHBORHOOD. THE POSTPONEMENT IS REQUESTED TO ENABLE DHHS TO DO THE FOLLOWING: BRISTOL ENVIRONMENTAL CORPORATION SUBMITTED A MODELING REPORT DATED FEB. 9, 1998 IN RESPONSE TO THE DIRECTIVES OF TIIE PLATTING BOARD NOV. 5, 1997 FOR REDESIGN. THE DHHS SHALL REVIEW THE MODELING REPORT, THE DATA AND ASSUMPTIONS UPON WHICH THE REPORT IS BASED TO DETERMINE IF THERE ARE ANY SUBSTANTIAL OR MATERIAL DEFECTS OR DEFICIENCIES IN THE MODEL WHICH WOULD ALTER TIlE CONCLUSIONS IN THE MODELING REPORT. IF DttHS CONCLUDES TtlAT ri'HERE ARE NO MATERIAL OR SUBSTANTIAL DEFECTS OR DEFICIENCIES IN THE DATA OR ASSUMPTIONS, THEN TIlE MODELING REPORT CONCLUSIONS WILL BE DETERMINED TO BE VALID AND DHHS WILL RECOMMEND PLA']? APPROVAL. IF DHHS DETERMINES THAT THE DATA AND THE ASSUMPTIONS IN THE MODELING REPORT ARE NOT VALID AND THAT THERE MAY BE SUBSTANTIAL EFFECT ON THE SURROUNDING NEIGHBORHOOD, DHHS SHALL RECOMMEND DENIAL OF THE SUBDIVISION AND SHALL STATE CLEARLY AND CONCISELY EACH AND EVERY REASON FOR SUCH RECOMMENDATION. DHHS AND THE PETITIONERS REPRESENTATIVE SHALL MEET, REVIEW AND DISCUSS TIlE MODELING REPORT AND TIlE DATA AND THE ASSUMPTIONS 1N A TIMELY FASHION TO PERMIT DHHS 'FO SUBMIT ITS REPORT PRIOR TO APRIL 17, 1998. DURING THIS PROCESS DHHS AND TIlE OWNERS REPRESENTATIVE SHALL DEAL DIRECTLY WITH ONE ANOTHER. PUBLIC COMMENTS CAN BE MADE AT TIlE CONCLUSION OF DHHS REPORT. DURING THE COURSE OF THIS PROCESS THE IDEA OF WELL TESTING HAS BEEN DISCUSSED EXTENSIVELY. IT IS AGREED THAT NO FURTHER PUMP TESTS WILL BE REQUIRED FOR DHHS TO MAKE ITS DECISION. 5. AS TO ri'HE ISSUE OF NITRATES, THE QUESTION OF A PLAT NOTE WILL BE FURTHER DISCUSSED BY DHHS AND THE OWNERS REPRESENTATIVE. SHOULD DHHS,DETERMIN~THAT A PLAT NOTE IS APPROPRIATE, THE OWNER'S REPRESENTATIVi~ WILL BE ABLE TO PARTICIPATE IN THE DRAFTING OF THAT NOTE. / 6. THIS,APPLICATIOI~ WILL BE HEARD ON MAY 6, 1998. ~//// B Y:~.L,.~.~,SKYL~IEW CORPORA' ?ION~,~/~ CONCURR: ~~~/~/JAM~S CROSS, ei(~_} _~/~ 07/10/97 0~,:21~ FA~ 9073434526 HERITAGE LAND BK OO2 DEI~T. OF ENVIRONMENTAL CONSERVATION DIVISION OF ENVIRONMENTAL HEALTH DRINKING WATER AND WASTEWATER PROGRAM 555 Cordova Street Anchorage AK 99501 http://www.state.ak.us/dec.home.htm TONY KNOWLES, GOVERNOR (907) 269-7647 (907) 269-7655 April 2, 1998 Paul Myers P.O. Box 670351 Chugiak, AK 99567 Subject: Troll Knoll Subdivision, PWS #210778, nitrate levels. Dear Mr. Myers: This letter provides the follow-up from our March 27, 1998 meeting, in which you requested clarification of nitrate levels in the Troll Knoll Snbdivision public water system (PWS) as reported in my February 22, 1998 letter to Mr. Dee High. [ stated in my February 22, 1998 letter that, "The Class "A" PWS located in Troll Knoll is of most concern because its' nitrate levels have increased from non-detect in 1982 to 8.2 mg/L in 1992." Drinking water samples collected May 27, 1980, June 1, 1988, and March 4, 1992, had nitrate levels that were non-detect (ND), 1.2 rog/L, and 8.2 mg/L respectively. These samples do represent a noticeable and significant increase over time (please refer to the attached graph showing nitrate levels in the Troll ICnoll Subdivision PWS). The sample which tested 8.2 mg/L is over the action level (AL) which is 5.0 mg/L and is only slightly below the maximum contaminant level (MCI.) fbr nitrate which is 10.0 mg/L. Samples that have nitrate concentrations above the AL require a PWS to begin quarterly monitoring for nitrate rather than annnal monitoring. Basically, the Ak, for nitrate is a "health advisory" and requires the PWS, or the State, to become proactive in a preventive manner to additional contamination. A sample that exceeds the MCL is both a public health threat and a reportable violation of the State Drinking Water Regulations. Nitrate levels did show an apparent decline in the Troll Knoll Subdivision PWS from the high of 8.2 mg/L in 1992, to a loxv of 1.91 mg/L in a sample collected August 17, 1994. However, it is important to note, that nitrate levels have steadily increased in the Troll Knoll Subdivision PWS from the low of 1.91 mg/L in 1994, to 4.50 mg/L from a sample collected December 17, 1997. This most recent sample, as well as the overall increasing trend in nitrate levels since 1980, and especially since 1994, is a concern to the Department. The most recent sample is just under the AL for nitrate. Mr. Paul Myers 3 April 2, 1998 iVlichele Brown, ADEC, Commissioner Art Ronimus, ADEC, Drinking Water and Wastewater Program - Anchorage David Johnson, ADEC, Drinking Water and Wastewater Program - Soldotna 0 0 (-1/6u]) a:~e~:l! N Page: 1 Document Name: EN'FERPRISE SERVER PARCEL: 051-481-24-000-98 CARD: 01 OF 01 RESIDENTIAL SINGLE FAMILY STATUS: RENUMBFRED TO/FROM: .... 1 PIRCHER DONNA J & CHUGACH PARK ESTATES KAVANAUGH KELLY JOHN BLK 3 LT 8 LO'I' SIZE: 73,571 ZONE : R6 TAX DIST: 022 GRID HRA # : NOTES PO BOX 670634 0 CHUGIAK AK 99567 0634 SITE 19536 SULLINS DR ---DATE CHANGED ....... DEED CHANGED .... OWNER : 07/02/91 BOOK: 2151 PAGE: 0736 ADDRESS: 06/09/94 DATE: 05/20/91 PLAT: 720188 .................................... ASSESSMENT HISTORY .......................... ---LAND-- FINAL VALUE 1995: FINAL VALUE 1996: FINAL VALUE 1997: EXEMPT VALUF 1997: --BUILDING .... TOTAL--- 24,500 161,900 186,400 24,500 158,400 '182,900 24,500 I68,300 192,800 0 0 0 --EXEMPTION--- ...... TYPE ..... STATE EXEMPT 1997: FINAL VALUE 1997: 0 -COMM COUNCIL- 192,800 CHUGIAK Date: 10/21/97 Time: 09:00:14 AM Page: 1 Document Name: ENTERPRISE SERVER PARCEL: 051-541-21-000-98 CARD: 01 OF 01 RESIDENTIAL SINGLE FAMILY STATUS: RENUMBFRED TO/FROM: .... 1 THORNTON JOHN C V & MARILYN J PETFRS GATE BLK 1 LT 5 LOT SIZE: 56,192 ZONE : R6 TAX DIST: 022 GRID HRA# : 000000 NOTES PO BOX 670581 0 CHUGACH AK 99567 0581 SITE 19639 THORNTON ST ---DATE CHANGED ....... DEED CHANGED OWNER : / / BOOK: PAGE: ADDRESS: 04/24/87 DATE: / / PLAT: 000000 .................................... ASSESSMENT HISTORY .......................... ---LAND-- FINAL VALUE 1995: FINAL VALUE 1996: FINAL VALUE 1997: EXEMPT VALUE 1997: --BUILDING .... TOTAL .... 20,800 89,100 109,900 20,800 90,600 111,400 --EXEMPTION--- 20,800 100,100 120,900 ...... TYPE ..... 0 0 0 STATE EXEMPT 1997: FINAL VALtJE 1997: 0 -COMM COUNCIL- 120,900 CHUGIAK Date: 10/21/97 Time: 09:01:01 AM Actuifer Testing Design and Analysis of Pumping and Slug Tests Karen J. Dawson Jonathan D. Istok Department of Civil Engineering Oregon State University Corvallis, Oregon LEWIS PUBLISHERS 12' Chapter 2 ~ges ~ping er test iou r ~ples AQUIFER TEST DESIGN Proper aquifer test design is essential to the successful determination of aquifer system properties. Without proper placement of observation wells, the selection of an appropriate pumping rate, injection or withdrawal volume, and a sufficient duration of measurement, collected data coald be worthless. C~eful test design may also allow the analysis of test data to be performed with simpler analytical methods. The steps that follow are presented with the assumption that a preliminary stte investigation has been completed. The infommtion collected during this investigation shonld include a description of the geologic materials, approximate fl6cknesses of formations, the identification of potential aquifers, aquitards, and aquicludes, and estimated water levels. 2.1 STEP 1. IDENTIFY SITE CONSTRAINTS In most cases, conditious at the site impose constraints on aquifer test design. These should be recorded prior to the start of the design process. Some examples are: 1. Limitations on the placement of pumping, injection, or withdrawal wells and observation wells due to the locations of buildings, roads, property boundaries, and existiug wells. 2. Limitations on pumping rate(s) for example, to prevent excessive drawdown in nearby wells or to limit tile amount of pumped water to be disposed. 3. Limitations on test duration imposed by the project budget, or by difficulties in scheduling site access, equipment, and personnel. 4. Requirement that existing wells or pumps be nsed. This may place restrictions on the number and locations of observation wells and may introduce additional complexities into the analysis of test data including the effects of well storage, pa~xial penetration of the aquifer by pumping and ohservatiou wells, aud head losses dae to flow through the pumpiog well screen and pump intake. 5. Limitatious on tile placement of pumping and observation wells dne to the kaown or suspected presence of lateral discootimfities in aquifers and aquitards, the presence of aquifer recharge and discharge zones, etc. These features may 'also introduce complexities into the analysis of test data for example, tile need to use image well theory (see Chapter 4). 2.2 STEP 2. LIST REQUIRED AQUIFER SYSTEM PROPERTIES A list of required aquifer system properties is needed to select an appropriate conceptual model (see Section 2.4). Lists of the properties determined by each of the coocepmal models considered in this manual are iu Tables 2. 1 ,'md 2.2. Using the list of 13 Chapter 2 14 14 15 Chapter 2 II Chapter 2 1 6 16 17 I/ Chapter 2 o ~m Chapter 2 18 18 Chapter 2 19 Ch~pter 2 20 ~0 Chapter 2 ~0 21 Chapter 2 22 CI required aquifer properties, one or more potentially useful conceptual models of tbe aquifer system can be selected. For example, consider the design of a pumping test being performed in a confined aquifer bounded below by an aquiclude and above by an aquitard and an unconfined aquifer (a "source bed") (Figure 2.1). During pumping, groundwater flows vertically from the source bed, through the aquitard and into the aquifer where it then flows laterally to the pumping well. Depending on the purpose of the investigation, the pumping test could be designed to determine a number of properties of the aquifer/aquitard/source bed system. If the horizontal and vertical hydraulic conducfivities (mr and Kz, respectively) and storativity tS) of the aquifer and the vertical hydraulic conductivity of the aquitard (K') are required the test will be designed (and the drawdown data interpreted) using a fairly complex conceptual medel (Model 7) (Table 2.1). If fewer properties are required, it may be possible to select a simpler conceptual model, thereby simplifying the design procedure and the cost and complexity of the aquifer test. For example, if the aqnifer in the previous example is assumed to be isotropic, the test could be designed using a simpler conceptual model (Model 4). Similarly if the vertical hydraulic conductivity of the aquitard is not required, tbe test could be designed using an even simpler conceptual model (Model 3). The selection of a simpler conceptual model usually places conditions on the number and location of observation wells, and on the critical times for data collection. For example, consider the choice between Models 3 and 4. The transmissivity (T) and storativity tS) of a leaky, confined aquifer corresponding to the assumptions of Model 4 can be determined using the simpler Model 3 if the observation well(s) are located so that r < 0.05 T¥~/K', where T is the transmissivity of the aquifer and m' and K' are the thickness and hydraulic conductivity of the aquitard, respectively. If site conslraints make this impossible, the more complex couceptual model (Model 4) must be used. Note that many of these conditions iuvolve the values of aquifer system properties and these must therefore be estimated before the aquifer test can be designed. Allowance sbould be made during the design process for uncertainties in these estimates. pumping well water table 1 [ · S I I Kr aquifer Kz aquiclude I I I I Figure 2,1 A list of required aqoifer system properties is needed to select an appropriate conceptual model, 22 Chapter 2 23 2.3 STEP 3. ESTIMATE AQUIFER SYSTEM PROPERTIES As demonstrated in the previous sectioo, estimates of aquifer system properties are essential to proper aquifer test design, Several methods have been developed for estimating these properties from engineering and geologic material descriptions and from correlations between these properties and several commonly measured soil properties. Aquifer system properties can also be determined using laboratory measurements on core specimens. 2.3.1 Estimating Properties h'om Descriptions of Aquifer Materials Typical values of hydraulic coudnctivity, specific yield, and specific storage for a variety of geologic materials am in Figure 2.2, Table 2.3, and Table 2.4, respectively. Unfortnnately, estimates of hydraulic conductivity obtained by this method can vary over several orders of magnitude making test design difficult. Estimates for specific yield and specific storage are nsually more reliable because these properties am much less variable than hydraulic conductivity. Hydraulic conductivity, K (cra/sec) 102 10-1 l0-2 10-3 10-4 10 -5 10-6 10 -7 10 -8 10 -9 l0t 10° __ I ~ I Clean gravel. very coarse sand ow, c,p, s25 s~ Clean gravel and sand mixes Clean sands, coarse Ia med. GW, GP, SW, tiP, GM, SM Med. coarse " "'~ sand and silt s,'mds, SW, SP. SM, SC Silty clays, silty, clayey fine sands silu, clayey silts, clays, clay, t'ock-flours, etc. Sandstone Shale Basalt Coal Hydraulic conductivity, K (fi/day) Figure 2.2 Typical valaes of soil and tuck bydraolic conductivity (adapted from Bowles, 1984 and Waltun, 1988). Symbols OW, GP, etc. are for the Unified Classificallnn System (see e.g., Bowles, 1984). Chapter 2 Table 2.3 Represeutative values of specific yield for several aquifer materials (?roan Walton, 1988). Material Specific Yield, Sy (dimensionless) Table 2.4 Peat 0.30 - 0.50 Sand, dune 0.30 - 0.40 Sand, coarse 0.20 - 0.35 Sand, gravelly 0.20 - 0.35 Gravel, fine 0.20 - 0.35 Gravel, coarse 0.10 - 0.25 Gravel, mediam 0.15 - 0.25 Loess 0.15 - 0.35 Sand, medium 0.15 - 0.30 Sand, fine 0.10 - 0.30 Igneous, weathered 0.20 - 0.30 Sandstone 0.10 - 0.40 Sand and gravel 0.15 - 0.30 Silt 0.01 - 0.30 Clay, sandy 0.03 .. 0.20 Clay 0.0t .. 0.20 Volcanic, tuff 0.02 - 0.35 Siltstone 0.01 .- 0.35 Limestone 0.01 - 0.25 Till 0.05 - 0.20 Representative values of specific storage for various materials (from Walton, 1988). Material Specific Storage, Ss (ft -1) Clay 10-4 Sand and Gravel 10-5 Rock, fissured 10.6 24 24 Chapter 2 2,3.2 Estimating Aquifer System Properties from Soil Index Properties Hydraulic conductivity and specific storage can be computed from estimates of coefficients of compression and consolidation obtained using correlations between these properties and more easily measured soil index properties. Tbese coefficients can also be measured directly on core specimens (see Section 2.3.4). From Terzaghi's one- dimensional theory of consolidation, hydraulic conductivity, K, can be computed from (2.1) where coefficient of consolidation, L2T 1 coefficient of volume compressibility, reciprocal of the constrained modulus of elasticity coefficient of compressibility, T2LM-1 initial void ratio unit weight of water, ML-2T'2 Specific storage, Ss, can be computed from Ss ='Yw + where Tw = unit weight of water, ML-2T'2 O = effective porosity E,¥ = bulk modulus of elasticity of water, ML 2T-2 Es = constrained modulus of elasticity of the soil or rock skeleton in the range of applied effective stress, MLtT-~ It is easy to show that, for small changes in effective stress, the constrained modulus of elasticity can be written (1 + eo) c~' Es - 0.434Cc where eo = initial void ratio o' = effective stress in the field Cc = compression index For small changes in effective sn'ess the coefficient of compressibility cml be computed using (2.2) (2.3) 25 Chapter 2 26 (2.4) where et = initial void ratio o'1 = initial effective stress, ML-IT-2 e2 = void ratio after consolidation under effective stress o'2 = final effective stress, ML'IT-2 Similarly the compression index, C¢, can be compnted using log (2.5) Combining Eqoations 2.3, 2.4, and 2.5 gives 0.434C0 (2.6) where o" represents the effective stress in the field. Equation 2.6 is valid if the change in effective stress during pumping is small. Several empirical equations have been developed to predict tile coefficient of consolidation, cu, and the compression index, Cc, from more easily measured soil index properties (Table 2.5). The compression index for clays and silts commonly ranges from 0.1 to 1.0. Recall that Cc applies to clays under effective stresses greater than their preconsolidation stress. Valnes for Cr, the compression index in the previously consolidated range, are often assumed to be 5 to 10 percent of Cc (Holtz and Kovacs, 1981). Typical values of Cr range from 0.015 to 0.035 (Leonards, 1976). Figure 2.3 gives approximate correlations of the coefficient of consolidation, %, mid the liquid litrdt. Typical values ofcu range fi'om 4 x 10.3 to 9 x 10''~ cm/sec (Holtz and Kovacs, 1981). Values of 'Y,v and E,,, for a range of temperatures are in Table 2.6. (2.4) (2.5) (2.6) ge in idex from 2.3 limit. ;1). 26 Chapter 2 Table 2.5 Selected Empiricol Eqoations for determining tile Compression Index, Cc, from Soil Index Properties*. Equation Applicability Cc = 0.007 (LL(l) - 7) Remolded clays Cc = 0.01 w?) Chicago clays Cc = 1.15 (eo(3) - 0.35) Cc = 0.30 (eo - 0.27) Co=1.15x10wn Cc = 0.75 (% ~ 0.5) Cc = 0.009 (LL 10)** All clays Inorgmfic, cohesive soil; silt with some clay; silty clay; clay Organic soils Soils of low plasticity Undisturbed clays with low to medium sensitivity * Selected [rom Azzouz, Krizek, and Corotis (1976) ** Terzaghi mul Peck (1967) (1) LL = liquid limit (2) Wn = natural water content (3) eo = initial void ralio Table 2,6 IJnit wci~Ibl aad bulk modulas of elasticity of water at varioas temperatures (adapted from Streetcr and Wylie, 1979). Temp Unit Weight Bulk Modulus Temp UnitWeight Bulk Modulus (°C) (N/m3) (x 10? N/m2) (°F) (lb/fi3) (x 105 lb/fi2) 0 9805 204 32 62.42 422 5 9806 206 40 62.43 423 10 9803 211 50 62.41 439 15 9798 214 60 62.37 448 20 9789 220 70 62.30 461 25 9779 222 80 62.22 464 30 9767 223 90 62.11 465 35 9752 224 100 62.00 471 40 9737 227 110 61.86 477 45 9720 229 120 61.71 480 50 9697 230 130 61.55 481 55 9679 231 140 61.38 475 60 9658 228 150 61.20 472 65 9635 226 160 61.00 469 70 9600 225 170 60.80 464 75 9589 223 180 60.58 451 80 9557 221 190 60.36 451 85 9529 217 200 60.12 444 90 9499 216 212 59.83 432 95 9469 211 100 9438 207 27 II Chapter 2. 28 t 0.1 m~' 0.01 © ~o 0.00~ O O O '~3 ~ 0.0001 0.00001 Figure 2.3 ~, = undisturbed samples~ ""\.,_~:' cu in range of virgin -.- ~__ \x.. compression curve -- ,,,, x,.~ 'x~ % cu in the rec°mpressi°n range __% .,, ~' lies above this lower limit x. x... -... __ - completelyremolded samples __ _ c-olies below tbis upper limit __ 20 40 60 80 100 120 140 160 180 Liquid limit (%) Approximnte correlations of tile coefficient of consolidation, cu, v,.ith the liquid limit (l'rom Holtz and Kovacs, 1981). The void ratio, e, and unit weight, ¥, can be measured on core specimens or can be estimated from the material description ('Fable 2.7). The unit weight can be computed by where %(1 + w) (2.7) w = gravimetric water content, dimensionless Td = dry unit weight, MT'2L'2 28 Chapter 2 29 Table 2.7 Typical yah,es of porosity, ','oid ratio, and unit ',veigbt of Peek, ltanson, and Tbo,'nburn, 1974). Material soils (front Void Water Dry Unit Saturated Unit ?orosity Ratio Content Weight Weight n e w (%) Td Tsar (g/cm3)(lb/ft3) (g/cm3)(lb/ft3) Loose, uniform sand 0.46 0.85 32 1.43 90 1.89 118 Dense, unifoml sand 0.34 0.51 19 1.75 109 2.09 130 Loose, nonuniform sand 0.40 0.67 25 1.59 99 1.99 124 Dense, nonunifom~ sand 0.30 0.43 16 1.86 116 2.16 135 Loess 0.50 0.99 21 1.36 85 1.86 116 Very mixed-grained glacial till 0.20 0.25 9 2.12 132 2.32 145 Soft glacial clay 0.55 1.2 45 1.22 76 1.77 110 Stiff glacial clay 0.37 0.6 22 1.70 106 2.07 129 Soft slightly organic clay 0.66 1.9 70 0.93 58 1.58 98 Soft very organic clay 0.75 3.0 110 0.68 43 1.43 89 Soft montmorillonitic clay 0.84 5.2 194 0.43 27 1.27 80 2.3.3 Estimating Aquifer System Properties using Effective Grain Size I [ydraulic condnctivity can also be estimated using con'elations between hydraulic conductivity and effective grai~i size, Dio, obtained by a sieve analysis of a sample of aquifer or aquitard material. Ten percent of the material has a grain size smaller than 1310. Based on tests of clean sand filters, Hazen developed an empirical equation for predicting the hydraulic conductivity of sands with Di0 sizes between 0.1 and 3.0 mm (Bowles, 1984) K = C(D10)2 (2.8) where K is itl units of cra/sec, Dll) is it/ units of cra, and C is a coefficient which varies from 40 to 150 depending on the size and gradation of the sand: C Sand Size and Gradation 40 - 80 Very fine, well graded with appreciable lines 80 - 120 Medium coarse, poorly graded; or clean but well graded 120 - 150 Very coarse, very poorly graded, gravelly, clean Specific yield, Sy, can be compmed fron~ Sy = G~e (2.9) Chapter 2 30 C where the air space ratio, Ga, is defiued as vol ume of air space 1 - percent saturation volume of total void space = 100 (2.10) and e is the void ratio. A correlation between the air space ratio and effective grain size was developeA from field tests conducted in the central United States (Figure 2.4) (Terzaghi & Peck, 1967). The rate and amount of water which drains from a soil under gravity is dependent not only upon pore size, but pore shape, mineralogy, groundwater characteristics and climate. Thns, actual values of Sy may vary significantly fi'om those compared by use of Figure 2.4 and Equation 2.10. 0.9, 0.8. 0.7 0.6- 0.5 0.4. 0.3- 0.2- 0.1- 0 U.S. Standard sieve numbers no. 40 no. 200 I 0.1 0.01 Effective grain size, Df0 (mm) 0.001 Figure 2.4 Relation between elTecti;'e grain size nad the air space ratio, Ga (from Terzaghi and Peck, 1967). 2.3.4 Deternfination of Aquifer System Properties from Laboratory Tests on Core Specimens It is possible to determine aquifer system properties from the restflts of laboratory tests on core specilnens collected fronl a borehole. However, the resubs of these tests mast be interpreted with caution for several reasons: 1. It is difficult to collect undisturbed core specimens during drilling, especially in cohesionless soils and fractured rock. Disturbunce is further increased during tile transfer of the specimen from the core barrel or sampling robe to the ~esting app,xratas. Chapter 2 2. Laboratory tests are sometimes conducted at hydraulic gradients that are much higher than occur under field couditions. This eau result in turbulent flow within the sample or sample compaction during the test. 3. In most cases, large-scale or "effective" values of aquifer properties are needed for design. Core specimens are uecessarily small and may not be representative of geologic materials and structures controlling groundwater flow at the field scale. Because pumping and slug tests "sample" a much larger volume of aquifer material they provide more representative values of large-scale aquifer propmties in heterogeneous systems. Nevertheless, when laboratory data are available they can provide useful pre mi tory estimates of aqt fer system )roperties for use in aquifer test design. I:lydraulic conductivity can be measured direct y on soil samples using standard methods sncb as the constant head test (ASTM D2434 or AASHTO T215) or falling head test (Bowles, 1982). The hydraulic conductivity and specific storage of fine-grained materials may also be determined indirectly from the standard consolidation test (ASTIVI D2435 or AASHTO T216) or the coustant rate of strain consolidation test (ASTM D4186- 82). S marly, the hydraulic conduct v ty of peat samples can be measured by a failing head test (ASTM D4511) and the hydraulic conductiv ty of rock cores obtained from ~esu ts of theflowing air test (ASTM D4525). Figure 2.5 shows ranges of hydraulic conductivity typically appropriate to the various laboratory tests and field tests. l lydraulic couductivity, K (cra/sec) 10 10 10 10 10 10 10 10 10 10 ~ field pumping tests ~.-[~- laboratol~ falling head (slug tests when T< 6700 fl 2/duy) test · '~-- laboratory constant / head test ~s laboratory consolidation test, falling head test with ]10-3 110-4 10 -9 Figure 2.5 Hydraulic condnctivity, K (fi/day) Range of applicability or' field and laboratory tests for measoring hydraulic conductivity. The constant head test is preferred for soils, such as sands and gravels with hydraulic conductivities in the range of I0 3 to 100 cra/sec (about 3 to 3 x 105 ft/d~.~): T!~e falling bead test is preferred for fine-grained soils, usually with hydraulic conducnwt~es m the range of 5 x 10.6 tO 10 3 ClI~/SCC (abotll 0.0l tO 3 ft/day). This test may last up to several days for fine-grained soils, iacreasing the errors dne to evaporation of water from the core specimen, temperature changes, leakage of water from the test apparatus, etc. In very fine-grained materials it is preferable to compute hydraulic conductivity and specific storage from consolidation test results. 3t Chapter 2 32 2.4 STEP 4. SPECIFY TEST CONDITIONS Using the estimates of the required aquifer system properties and a set of potentially useful conceptual models from Tubles 2.1 and 2.2, the test conditions can be specified. These include the type of test (pumping test or slug test), the di~wneter of tbe pumping, injection, or withdrawal well, tim pumping rate or injection or witt/drawal voltlme, tile number and location of tbe observation wells, the depth and semen Iengtb of all wells, and tbe test duration. It sbould be emphasized that aquifer test design is an iterative process and earlier steps may need to be repeated as the result of information gained by later work. After selecting a potential model fi'om Table 2.1 or 2.2, a more detailed model description should be consulted to easure that test conditions match the assumptions of the conceptnal model. In Part I1, ntethods are presented for interpreting pumping test anti slug test data using each of the conceptual models in Tables 2.1 and 2.2. Each cbapter in Part II describes tim methods that are available for a particulm' conceptual model. For example, Cbapter 9 describes tbe methods that can be used to interpret pumping test data for Model 4 while Chapter 24 describes the metbods thut can be used to interpret slug test data for Model 19. The first purr of each chapter in Part 1I contains a list of the assumptions about the geometry, properties, and hydraulic behavior of tile aquifer system on wbicb tile conceptual model is based. The validity of these assumptions should be critically reviewed using the information from the preliminalV site iavestigation. Ifa particulm' assumption seems unreasonable an alternate conceptual model should be selected. Pa~ 11 presents methods of analysis for pumping tests (Chapters 6 to 21) and slug tests (Chapters 22 to 24). Slug tests are nsually preferable in aquifer materials with relatively small transmissivities less dian 6700 ft2/day (Figure 2.5). If the transmissivity is larger titan this value, the piezometric surface or water table recovers too quickly following the injection or witbckawal of wuter fi'om the well casing, making accurate measurements of buildup or drawdown difficult. 2.4.1 Puml)ing Test Design If a pumping test ,.viii be used, the designer must specify the pumping rate, the pumping well diameter, depth, and screened interval, tile locations and depths of observation wells, und the duration of the test. This section describes tbe design of constant discburg¢ pumpblg tests; the design and interpretation of step discltarge tests is discussed in Chapter 5. Selection of tile punqping rate and well diameter depend upon tile cboice of conceptual model and on Ibc estimated values of aquifer properties. The selected pumping rate should be Itu'ge enongb to insure that drawdown can be measured accurately itl the pumping well and the observatioa well(s) (if used). However, the selected pumping rate should not result itt excessive drawdown. The water table in unconfined aquifers should not be lowered by more than 25 percent siace this is the largest drawdown wbicb can be corrected and analyzed with an anulylica[ solution to the gronndwater flow equations (Ferris et al., 1962). In confined aquifers it is desirable to select a pumping rate that does not resnlt in dewatering of tim aquit'er, altbougb methods are available for interpreting drawdown data when a confined aquifer is partially converted to m~ unconfined aquifer during a punlpb~g test (see Chapter 17). The pumping rate may be selected itl two ways: 1. By LIsing an empirical cqtlation to predict the specific capacity of tile pumping well. 2. By using the analytical solutions it/ Part Il to predict drawdown for tbe pumping and observation well(s) for a range uF assumed pumping rates. 32 Chapter 2 33 tcnfially ted. ag, :he ~ls, and cess and rk. [el s of the nd slug n Part II nple, Model 4 or s about :viewed >tion td slug sivity is llowing meuts ~ts is umping tbe g rate hould tll be ~t does ng :ifer ways: well. ~g and ~nmirical E,J~,lati~ns for Specific Catmcitv Driscoll (1986) presents empirical equations tbat may be used to predict the specific capacity, Q/s, of the pumping well. The equations were derived using Cooper and Jacob's (1946) approximatiou to the Theis solution (Model 3) Q: T (2.11) ( 2.25 ,q s 0.183 log ( rw2S ) where Q is the pumping rate, s is rite drawdown in the pumping well, T is the aquifer transmissivity, t is the time since pumping began, rw is the radius of tbe pumping well, and S is the aqnifer storativity. Driscoll selected the followiug "typical" values for aquifer properties and test conditiuns: transmissivity, T : 30000 da~m. ft confined storativity, Ssm = 10-3 uncoufined storativity, Sy = 7.5 x 10'2 radius, r -- 0.5 ft test dnration, t = 1 day Substituting these values into equation 2.11 tile following eqnations can be derived and Q T for confined aquifers (2.12) s - 2000 Q T ~ = ] 5~'(~ for uncoufined aquifers (~. 13) where the units of Q, T, and s are gal/mtn, gal/(day · ft), and feet, respectively. Similar eqnations can be derived if the test conditions or estimated values of aquifer properties much different than the values Driscoll used. ]However, wlriations ill the value of T, t, rw, and S have relatively small effect on computed values of specific capacity since they are inclnded in a logm'ithmic term in tile equation. For confined aquifers with p~u'tially penetrating wells, J. Kozeny developed the following equation, applicable with any consistent units (Driscoll, 1986, p. 250): Q Q(/-d)(1 +74 r {'g(l- d)h ) si, sm 2(l- d) cos ( '~ ) (2.14) where = drawdown in a partially peuetrating well, L ~P- d = lengdt of well screen, L m = aqui£er thickness, L The equation is based on the assumptions o£ u small well diameter aud no well losses. It may also be inaccnrate for small vulues of aquifer thickness and large ratios of (l - d) to m. Chapter 2 Example 2,1 A confined aquifer has an estimated transmissivity of 20000 gal/(day · ft). What pumping rate is required to produce a ch'awdown of 15 feet in the pumping well after 1 day of pumping? From Equation 2.12, sT 15 (20000) = lS0 8%1 Q - 2000 - 2000 nun Example 2.2 Suppose that a partially penetrating well with a 10qnch (0.83 ft) diameter well is installed in the aquifer of Example 2. h The aquifer is 50 feet thick and the well is screened over 20 feet of its length. From Equation 2.14, ( s0 ](20 ft)f Q ~-~ f5~-~6'~-) -(1 + /0.416 ft (x(20 ft)'~ Sp " mn., 7~/2(_~f~cos(5_.~.5..6_ff_)) ) ~Q = 6.8 gal Sp min , ft If the desired drawdown is still 15 feet, the required pumping rate is Q=15ft(6.8 gal ] 102~ m i n · f() = .D_rawdown Prediclion rising Analvtlcal Solutions Drawdown in the pumping aud obse~wafion wells can also be computed using tbe analytical solutions presented for each conceptual model in Part II. Appendix B contaias computer programs specifically for this purpose but calculations can also be performed nsing tabulated values of well functions in the chapters in Part II. Example 2.3 A pumping test is being designed using a conceptual model for a leaky, confined aquifer (Model 4). The selected pumping rate and estimated aquifer properties are listed below (see Chapter 9): Q = pnmping rate = 50 gal/rain (9626 gal/day) T = aquifer transrnissivity = 20000 ft2/day S = aquifer storativity = 0.0002 m' = aquitard tbickuess = 50 ft K' = aquitard vertical hydraulic conductivity = 0.01 fi/day 34 34 Chapter 2 35 tat I day tis eened the ~ins ~'d Predict the drawdown at al observatioa well located at a radial distance r = 100 ft from tile pumping well. What wonld the predicted drawdown be if the test was designed using Model 3 ? The appropriate well functions are listed in Tables 8.1 and 9.1, computer programs for predicting drawdown am in Appendix B (Programs DP, AW3 and DRAW4). The results are snmmarized in Figure 2.6 and show that differences in predicted drawdown for tile two models are not significant antil after one or two days. 0.4- 0.3- 0.2- 0.1- .1 ~- /~,~'~'*~ Model 4 I 10 100 1000 10000 100000 Time, t (rain) Figare 2.6 Predicted drawdowu at observatlon ',veil. Pumping Well Casing Diameter Selection Once a pnmping rate has been specified, tile diameter of the ,.veil casing can be selected. A preliminmy selectioa of casing diameter can be made using Table 2.8; tile final selection should be made in consultation with the pump manufacturer. 'rable 2,8 Recommended pumping well casing diameters for various pumping rates (after Driscoll, 1986, p. 415). Pumping Rate Well Casing Diameter (~i',',) (in) (mm) mini < 100 < 545 6 152 75-175 409-954 8 203 150-350 818-1910 10 254 300-700 1640-3820 12 305 500-1000 2730-5450 14 365 800- 1800 4360-9810 16 406 1200-3000 6540-16400 20 508 Chapter ~ 36 Obserwflion Well l,oe~lion and Screen l)l~cem~nt Many of tile methods for itucrprcting pumping test data described in Part 11 require drawdown data fi-onr one or more obsmwation wells. The selection of appropriate locations, depths, and screen lengths fei' these wells is au important part of successful pamping test design. Tile following is a list of criteria that can be used to guide observation well placement. l. Predicted drawdown in each observation well should be large enough to be measured accurately. Drawdown can be predicted using tbe analytical solutions in Part II, fl're estimated aquifer properties, the selected punlping rate, and tile distmlce from the pumping well to the proposed observation well(s). Tile calculations can be performed using the tabuhltecl well functions in Pan II or tile computer programs in Appendix B. 2. If possible, observation wells should be located at logarithmically spaced distances from the pumping well (i.e., 10, 100, and 1000 ft) to permit distance-drawdown plots to be used with the matcb point method (see Chapter 4). 3. The only way to demrmine both horizontal and vertical hydraulic conductivities in a confined aquifer is to: a) install a partially penetrating pumping well, b) have pm~ially penetrating observation wells, and c) place the observation wells at a radial dist,'mce r < 1.5 m x/I~)Kz fi'om tile pmllping well, where m is the saturated thickness of tile aquifer aad Kr and Kz are tile horizontal aad vertical hydraulic conducfivities of tile aquifer. Beyond this distance r, flow is essentially borizontal, even in an anisotropic aquifer. Both horizontal and vm~ical bydraulic conductivities may be determined from either fully or partially penetratiug wells in an unconfined aquifer as long as accurate data can be collected through a complete time range (i.e., at the beginning, middle, and end of the test, the aquifer response must conform to the conceptual model and sufficient data must be collected in each of tile ranges to clearly define a curve shape). 4. If the horizontal (plan view) hydraalic conductivity of the aquifer is assumed to be isotropic, tile distribution of tile ol)servation ':,,ells about the pumping well is arbi~ary but an even distribution is desirable sc) that &'awdown measurements m'e representative of as large a vohnne of aquifer as possible. If the horizontal hydraulic conductivity of tile aquifer is assumed to be anisotropic, drawdown data will be analyzed using tbe conceptual model ia Chapter 16 (Model 11) which requires that no two observation wells be radially aligned with the pumping well. 5. If the test site contaius known or suspected lateral discontinuities in the aquifer, observation wells can be placed either to minimize the effect of the boundary on drawdown data or to more precisely identify tile locatiou of tile discoutinuity. The metbod of image wells (see Chapter 4) can be used to predict the effect that aquifer discontinuities, recharge zones, or other pumping wells will have on drawdown at a proposed observation well location, ri'he radial distance beyond which the effects of an aquifer boundary or a pumping well on measured drawdown in an observation well are negligible can be estimated for the Tbeis conceptmd model (Model 3) using ~ exluation developed by Walton (1988). The following equation assumes that drawdown is negligible when a (= r2S/(4TI)) is greater tbaa 5 (i.e., W(u) < 0.001) r= 42(S)-~ (2.15) 36 Chapter 2 37 require ocations, ng test 1 asumd [, the he 'fom~ed ndix B. vn plots ;ina ~rtially :ante ~fthe f tile ~tropic :ither data can end of ent data ) be :bitra(y sentatlve :ivity of ; the ltion The lifer nata :ets of all well ,are eqnation ~is (2A5) where r = distance between observation well and image well beyond which boundary or other pumping well impacts are negligible, L T = aquifer transmissivity, L2T4 t = time after pumping started, T S = aquifer storativity (either confined or unconfined), dimensionless Example 2.4 Given tile soil profile in Figure 2.7, design a pumping test to determine the properties of the clean sandy gravel layer and the fine sand layer. Soil properties have already been estimated fi'om hydrogeologic information. Them ,are no other wells in the ,area. However, a rock ridge cuts through tile soil layers approximately 500 feet from the proposed site of the pumping well. clean coarse gravel 100 ft K = 25000 ft/day Ss~= 0-6ft-I Layer ~ ////////////////~ ~s~= ~x~u ~[ ~/////////////, , 7,, ~ 5~ (t+2&X&2&2&2& s~= 5 x ~0-6 ft K~+~&~&222222~::~ ~ ~ Figure 2.7 Soil profile for Example 2.4 with estimated hydraulic eonduetlvities, K, and specific stm-age coefficients, Ss, The 1. steps oatlined in this chapter are discussed below: The properties of interest are K2, S2, K3 and S3. Later in tile analysis, the analyst can determine if the horizontal and vertical hych'aulic conducfivities of both layers ,are required. The only physical constraint at the moment is the flow boundary approximately 500 feet awa?. Later, to reduce costs, the analyst might add the consn'aint of a partially penetrating well. For now, assume fifll penetration. The very stiffclay of layer 4 is much less permeable than layer 3, so it can be considered impermeable. Layer I may be considered as a source bed, while layer 2 is an aquitard and layer 3 is an aquifer. Check these assumptions later. Chapter 2 38 I The soil properties have been estimated for us. The conceptual model appears to match the description of Model 5. Refer to Chapter 10 to eusure that the example system conforms to the assnmpfions in Model 5. First, there is negligible source bed drawdown when 100Taquifer -< Tsource bed (Neuman and Witherspoon, 1969b). Second, it is correct to assumethat flow is vertical tlu'ough the confining bed and horizontal through tile aquifer if K/K' > 100 nVm' (Hantush, 1967). Botb of these conditions are met. Next, check the design tables for the possible use of a simpler model. Table 2.1 shows that storage in the confining bed can be neglected widen [ KSs r < 0.04m '~K~Sss, Thus, Model 4 could be nsed to find all tide desired properties except S2 if tile distance to observation wells is less than r, where ~/(500 fl/day)_ (5 x 10,6 ft-1) r= (0.04) (50 ft) ' (5 fl/day) (5 x 10-s ft-I) =6.3 ft Now tile analyst mnst decide whether to use Model 4 with observation wells within 6 feet of the pumping well, or to use Model 5 and have a greater latitude for well placement and a possible method for determining S2. Equilibrium is reached for Model 4 when t _> 8 m'S/K (Table 2.1). For this example, 8 (25 fl) (5 x 10,6 ft-t) (50 ft) t>_ (1440 mtn) = 14 mtn Table 2.1 shows that early data is needed for a unique solntion. It is unlikely that the data from the first few minutes will be of sufficient accuracy to use this model. Let us examine Model 5 to determine the required time range for the test. The early- time solution is applicable when m'S' (25 fl) (5 x 10.5 ft-t) (25 fl) = 1 mtn t-<lOK,- 10(5 d.faty)~ 1 day '~ (1440 mini Obviously, the early-time solution will not be applicable to any data unless our estimates of soil properties are wrong by orders of magnitude. Since tbe late-time solution is indetermiuant for Case B, the equilibrium ¢h'awdown from at least three obse~wation wells must be used to determine soil prope~xies. Thus, it is likely that S2 (S' in Model 5) will have to be estimated from laboratory tests or hy~ogeologic observations. Check the time for equilibrium drawdown by Model 5. From Chapter 10 the time mqnired to achieve equilibrium is (Equation 10.34) 39 38 Chapter 2 pter and ;h the stance within 1 at the ~e early- me iree bat S2 ic time S' 8 (2.5 x 10.4 + 1.25 x 10-3 3 +0) = 38 rain 8(S +3-+ S") t= K' K" Therefore, the test should be run for at least 40 minutes or until equilibrium is observed. Finally, cbeck to see if the boundary will affect the placement of observation wells. The minimum distance between an observation well and image well required to insure that the effects of the boundary will be significant is given by Equation 2.15. Though the equation is meant to be used when conditions confm'm to those of Model 3, it can be used itl this case as a roagh approximation. Applying Equation 2.15 with a test duration of I hour gives (20) (500 dtf~) (50 ft) (1 hr) ~24 h_rJ = 2.5 x 10-4 -- 9129 ft Obviously, Ibe designer woukl not place obse~watiou wells at this distance from the pumping well, so image well theory will be used in tile analysis of results. 6. A pumping rate can be chosen by applying Cooper and Jacob's (1946) empirical equation to the desired drawdown at the pumping well. Try a drawdown of 10 feet at the pumping well. From Equation 2.12, 2 (7.48 gal'~ (25000 ~'~ (10 fi) ( 1 ft3 J 2~ Ts k~ ay) -- - =935 . Q = 2000 2000 mtn From Table 2.8, au acceptable casing diameter for this flow rate is 16 inches. This approxiumte casing diameteF should be used to estimate well storage effects. Table 2.1 shows that tile effects of well stoFage in a leaky aquifer (Model 9) will have dissipated wheu 2.5 x l0s r,:2 2.5 x 103 (8/12ft)2 =64rain t> = T 5 0 ft2 (_day 2.00 d~ (1440 rain) where i'c [s [he radius of the well casing. This time is slightly larger than the time estimated to reach equilibrium for Model 5. However, the test will still be run ti) equilibrium with a minimum of three observation wells. Chapler 2 40 ( Finally, the pumping rate sbould be used to compute tbe estimated drawdowns at eacb observation well. This will ensnre that there is measurable drawdown at all wells and identify critical times for measurements. Example 2.5 Assnme that tile pnmping well of Example 2.3 can only partially penetrate the aquifer. Table 2.1 sbows that Model 5 can still be used as long as either: 1. All observation wells fnlly penetrate the aquifer 2. All observation wells are placed at a distance, r, at least 1.5 m pumping well. rf zfrom tide Typically, the horizontal hy&'aulic condnctivity is at least ten times greater than the vertical bydraulic conductivity. If this typical value is used, then r ~> 1.5 (50 fl) ~10 = 237 ft Thus, Model 5 can be nsed if all observation wells are more than 237 feet from the pumping well. However, at this distance, equilibrium drawdown is less than one foot when pumping at 935 gal/min. Drawdown at two otber wells spaced logarithmically, for example, at 350 and 500 fee~ from the pumping well, will have maximum drawdowns less than 6 incites. Tbese are such small drawdowns and the spacing must be so large that it is preferable to use Model 7 and acconnt for partial penetration. 2.4.2 Slug Test Design If a slug test will be used, the designer must specify tbe injection or withdrawal volume, and the well diameter, depth, and screened interval. Selection of tbe injection or withdrawal volume and well diameter depends upon the choice of conceptual model and on tbe estimated values of aqnifer properties. The selected volume should be large enough to insure that buildup or drawdown can be measured accurately, bnt small enough so that buildap or drawdown does not resnh in significant changes in aquifer saturated thickness. The injection or withdrawal volume is most easily selected by using the analytical solntions in Part Il to predict bnildnp or drawdown for a range of assumed aquifer properties. Example 2.6 An unconfined silty clay nquifer is bounded below by a stiff clay layer of great thickness. TIDe saturated thickness of the silty clay is 20 feet and tide estimated hydraulic conductivity is 4 ft/day. The stiff clay has an estimated bydraulic conductivity of 10.2 ft/day. Design a slug test to determine the hydraulic conductivity of the aquifer. The estimated aqnifer transmissivity is (4 ft/day)(20 ft) = 80 ft2/day, and referring to Fignre 2.5, a slug test is appropriate. The estimated hydraulic conductivity of the stiff clay is more than two orders of magnitude smaller than the silty clay and this layer will be considered to be nn aqniclude for purposes of test design. RefmTing to Table 2.2, tile appropriate conceptual model for this situation appears to be Model 18. To begin, specify a well with a 2-inch diameter (ri = 0.08 ft) casing installed in a 4-inch diameter augered hole (r,~ = 0.17 ft) and back filleA with a coarse sand (porosity = n: 0.40). The well is screeued over the entire saturated thickness of the aquifer (l = l - d = 20 ft). Design a withdrawal test based on an initial water table drop of 4 40 Chapter 2 41 is at I wells ertical ~ot y, for ns less at it is ,val on or ~d mt ugh to hat kuess. )lutions ~at :relic }-2 erring ; stiff ,,ill be )pears ;e sand e 'op of 4 ft. The analytical solution is in Equation 23.6. The effective radius of the well casing, rc, is rc=~ri2 + n (rw2- ri2) =q(0.08 ft)2 + 0.4 ((0.17 ft)2 - (0.08 ft)2) = 0.12 ft Fora fnlly penetrating well, read "C" from Fignre 23.1, with (l-d)/rc = 20 ft/0.12 ft = 167 and obtain C = 5.8. Using Equation 23.10 ln(R)=(_ + s.8 ( 1 ft ~ ( 20 ft (rw) L1n 16.6 To know how long it will take to recover all but one foot of head drop (so that H = 1 ft), rearrange Equation 23.6 as (re)2 in (R/rw) In (Ho/Hw) t- 2K (l - d) (18 ft'~ (0.12 ft)2 (16.6) In [ 1 f~J t - = 6.2 rain 1440 mini If a pressure transducer or air flow system with continuous readout is available for measuring the depth to water, a sufficient mnnber of accurate measurements can be taken in a 2-inch diameter well with full penetration. However, if a less accnrate measuring system is used, the designer may wish to install a casing of larger diameter to increase the test duratiol/. I,,U ,~,EPA WH-550 United Sta~es Environmental Protection Agency Washington DC 20460 Official Business Penalty for Private Use $3O0 Groundwater Contamination & your septic system Many people living in rural areas have a well and septic system. These are excellent substit~tes for public utilities. Maintenance costs are low and the systems are dependable. Best of all there are no monthly bills. However, neither a well nor septic system is foolproof. If they are not working cor- rectly they can contaminate ground water. This can spread to nearby wells. Simply put, sooner or later you (or a neighbor) will drink what you flush. A septic system has two main parts. Wastewater first passes through a septic tank where solids are removed. The liquid waste is then piped into a drainfield. 'Itte ch-ainfield is a series of gravel filled trenches with pipes that '. can~ wastewater. In the drai~ffield, the partially treated wastewater is re- . leased into the soft. The soil and naturally occurring bacteria cleanse the · . ~ra~ewater. The cleansed water is then returned to the environment. The · " seplffc system does an outstanding job of treating organisms fom~d in sew- age. That's what it was designed to do and it does it well. 'I"ne problem is a septic system cannot clean chemical wastes from sewage. We're not referring to the normal use of cleansers and bleach or the occa.. sional use of a drain cleaner. Some problem chemicals are used engine oil, gasoline, pesticides,.paints, solvents and photographic chemicals. Even small quantities of these can create problems when introduced into a septic system. - over - MFJ4ORANDUM DATE: June 1, 1993 TO: On-site Wast.ewater System Technical Review Board FROM: D.N. Bolles, On--site Services ~ SUBJECT: Nitrate and Bacterial Contamination of Potable Wells Since mid-1987, DHHS has been engaged in compiling information and investigating nitrate contamination in area wells. By 1988 it had become clear that bacterial contamination was also a factor in many of the same areas exhibiting elevated nitrate. Whereas immediate health risks are of prime concern, the data suggests a different approach concerning the way in which we view wastewater disposal. In reviewing USGS data for the past 40 years, the incidence of nitrate and bacterial contamination was found to be very low for the Anchorage area. By way of interviews with se+eral federal and state personnel, it became evident that most thought that nitrate contamination was virtually non-existent and only rare isolated cases were known to exist. This was due in part to the wells monitored. Most of these wells are below 400 feet in elevation and thus draw from soil and bedrock aquifers with large recharge areas. This factor could lead to natural attenuation of possible contaminants. Most wells sampled within the Anchorage, Girdwood and Eagle River areas lndicate nitrate concentrations average below 1.0 mg/1. It is notable that samples obtained in the mid-to late-1960's for some of the areas which now exhibit nitrate and/or bacterial contamination, indicated isolated wells with elevated nitrate concentrations (USGS 1975 Open Report). At the time of the 1975 USGS report, concern was expressed about future development of the Anchorage and Eagle River hillside areas. The possible contamination of potable groundwater was of prime concern. The report noted housing density at that time was approximately 100 homes per square mile and expected a maximum density of four to six times that amount when the area fully developed. At the time of the DHHS Huffman DeArmoun investigation the three quarters of a square mile affected had a density of 408 homes (1988 Stock Housing Maps). Page 2 Other studies have expressed concern over on-site sewer developiaent and the soils' ability to attenuate septic effluent. This was noted in the EPA's review of the Hillside Wastewater Management Plan. EPA's review noted that the Hillside plan did not solve the problem of wastewater disposal on lands judged unsuitable for on-site treatment. It was also observed that the Municipal 'Wet Lands' designations did not agree with the USGS ~eport of 'Water logged' areas. Jones and Stokes Associates, in their review of the Hillside Wastewater Management Plan, reported that 5,840 acres of land were deemed unsuitable for on-site treatment of wastewater. This acreage accounts for 35% of the Anchorage hillside. Considering the push for development in the hillside area the concerns expressed by EPA would seem to remain valid. The report stated: "land owners are likely to exert strong efforts to demonstrate suitability of some type of innovative system on their property". The report further suggested that development may occur "largely independent of suitability designations." EPA also agreed with the USGS 1975 report in that the likelihood of pollution of surface and ground waters would increase as a result of continued development by on-site wells and sewage disposal. In August 1984, the EPA's Office of Ground Water Protection issued "A Ground Water Protection Strategy for the Environmental Protection Agency". Within the EPA Strategy there is provision made for classification of groundwater. The classifications range from Class ]~ to III. Class I is designated as: i_Special Ground W~t~ - ground waters that are highly vulnerable to contamination because of the hydrological characteristics of the areas under which they occur and that are also characterized by either of the following two factors: irreplaceable, in that no reasonable alternative source of drinking water is available to substantial populations, or ecologically vital, in that the aquifer provides the base flow for a particularly sensitive ecological system that, if polluted, would destroy unique habitat." M6'~' of ~h~ g~$h~'dwa6e'~s uude~lyf~*¢- the Anchor~% ahd Eagle .... River hillsides would fall within this Class I category. These waters are irreplaceable in that no reasonable alternative source of drinking water is available for substantial populations. As such, under EPA's Strategy, these areas require the closest monitoring of development for both private and commercial systems. As of this date the Municipality has yet to address the classification of water resources within its jurisdiction. Page 3 Public Health ImK~cts The potential for localized groundwater contamination in the Anchorage and Eagle River hillsides is relatively high. The work performed by USGS (1975) and Arctic Environmental Engineers (1981) indicates a high potential for groundwater contamination exists due to shallow bedrock and groundwater, steep slopes and highly permeable soils. USGS (].975) noted that the estimated daily domestic wastewater discharge rate for the study area alone was ]..2 million gallons. Based on available data the current daily discharge rate for the same area could well exceed 3.6 million gallons. Given such a high loading rate, and data showing bacterial contamination in the Toilsome Hill, Mountain Park Est. and Scimitar subdivisions, it is apparent that negative health impacts already exist. Bacteria Canter, Knox and Fairchild (1988) pointed to highly permeable soils as a major reason for groundwater degradation. Open or gap graded soils permit the passage of biological, inorganic and organic contaminants to bedrock or groundwater virtually unchanged (Gerba; Rahe et al; & Viraraghavan). While adsorption accounts for the majority of bacteria removed temperature, pH, and soil moisture also play key roles. It is possible for bacteria to survive for extended periods in favorable field conditions. The availability of Organic matter seems to be the key in survival beyond a few days. Peterson and Ward noted that some pathogenic enteric bacteria have the "potential of being transported great distances" by virtue of reducing their volume in nutrient poor environments. Thus viable dwarf cells may pass through soil pores which ordinarily would filter out the organism. Nitrate Since nitrate possesses a negative charge it is not readily attracted to soils which also possess a negative charge. AS such nitrates are highly mobile in both saturated and unsaturated soils. Nitrate ions can thus move with the groundwater, migrating long distances. Walker et al, indicated the total nitrogen produced by a family of four to be between 70 and 75 pounds annually. They also noted that the "minimum area necessary" to properly attenuate 10 pounds of nitrogen, annually, to less than 10 mg/1 nitrate-nitrogen was 0.5 acres. At that rate the average lot size needed per household is 3.5 acres. As previously noted, many of those areas served by on-site septic systems, have a far greater density. Indeed most lands subdivided prior to the May, 1986, changes to Title 15 permitted development of lots less than one half acre. Hallberg and Hoyer (1982), reviewed over 16,000 test results from northeast Iowa. Their findings noted that while bacterial contamination was random as to well depth and geologic setting, nitrate contamination was significantly and systematically related to geologic settings. Page 4 Recent studies have shown that nitrate levels can be predicted with considerable accuracy. Hantzsche and Finnemore (1992) utilized known housing density, the daily discharge rates of household wastes and water recharge availability, in simplified mass balance equations to accurately predict the level of nitrate contamination in three California communities. If the same type of mass balance studies were to be applied in the Anchorage and Eagle River hillsides, a comprehensive development plan could be established. Such a plan would enable development of affected areas while maintaining some assurance of continued potable groundwater. Conclusion: Existing data indicate that an excess of 240 single family homes are currently affected by nitrate and/or bacterial contamination. The areas of contamination have been determined and several proposals have been given to head off further spread of these contaminants. Thus fay the response has been to handle each contaminated well on an individual basis. This approach has done little to control the situation as the contamination exists over wide geologic areas. Rather it has resulted in some negative impacts. These impacts are: 1) Although the contamination is an area wide problem, costs to obtain clean water are born solely by the home owner. In one instance a family in Scimitar Subd. paid $20,000 for a dry hole and could not obtain financing for their home. 2) The department has signed off on Health Approvals allowing people to purchase property which, in the near future, may not be marketable. It could be argued that the Municipality bears some liability. An additional property in Scimitar Subd. was unable to obtain refinancing due to elevated nitrate levels. 3) The continued usefulness of existing polluted aquifers, underlying the sixty known subdivisions, is now in question. These areas could face forced public water service. 4) There is a growing threat to public health. In evidence, a well[ in Toilsome Hill Subd. exhibited no bacteria but had 17 PPM nitrate in 1987. Several other wells in the area also exhibited elevated nitrate levels, some above 10 PPM. One well in Mountain Park Est. #2 exhibited bacteria and nitrate contamination. In October of 1992, the well in Toilsome Hill, exhibited bacteria in numbers too numerous to count. A neighboring well also exhibited some bacterial contamination. In Scimitar Subd. two wells were found to have both nitrate and bacterial contamination. The solution was to treat each property as an individual problem. In February, 1993, a third lot, near Scimitar Subd., exhibited bacteria in its well water. Page 5 The incidence of known nitrate and bacterial contamination should not be treated lightly, as if they were isolated or unrelated. Nig]f'density, coupled with porous'~soils overly'ing shallow bedrock, makes for an extremely fragile environment in which to dispose of wastes and withdraw potable water simultaneously. Contaminated aquifers, in the DeArmoun-Huffman and Delucia-Scimitar areas, now contain bacteria. Residents from these areas are now having to face the consequences of septic contamination'. Within DHHS files there exists sufficient evidence to prove contamination of potable aquifers. Those same files further show septic systems which either lack adequate separation to, or were constructed into, groundwater and/or bedrock. The municipality at present still has the opportunity to act on this situation. The solution in some cases may be to provide public or community water and/or sewer; other areas require upgrading offending septic systems or sealing contaminated wells or aquifers. Another possibility would be to identify those areas of shallow bedrock and/or groundwater, there after requiring a manditory sand filter for all septic system installations. I sincerely hope you will encourage the department to take the lead in the development and implementation of a plan to alleviate the negative impacts of on-site sewage disposal in the Anchorage and Eagle River hillsides. ~ferences: L.W. Canter and R.C. Knox. QJC_OuDd water Oualitv Protection. 1988, Lewis Publishing, Inc., Chelsea, Michigan. N.H. Hantzche and E.J. Finnemore. Predicting Grouud-Wate% Nitrate Nitroqen I~pacts. Ground Water Vol 30, Humber 4, July/August 1992. T.C. Peterson and R.C. Ward. Bacterial Retention in $0i1~ Journal of Environmental Health, Vol 51, Humber 4, April/May 1989. B.H. Keswick and C.P. Gerba. Viruses Environmental Science and Technology, November, 1980. in Groundwatel Vol 14, Number 11, R.J. Perkins, Ph.D., Septic TuDks, Lot Size and Pollution Df Wate~ Table Aquifers.. Journal of Environmental Health, Vol 45, Number 6, May/June 1984. Page 6 American Society of Agricultural Engineers. On--$i%e Wastq Water Treatmen_j2. Proceedings of the Fifth National Symposium on Individual and Community Sewer Systems, December 14-15, 1987. NSF and EPA. Individual 0nsite Waste Water and Third National Conferences. Ann Arbor Science Publishers, Inc. 1977, 1978. Second Arctic Environmental Engineers. Hi_llside W$$tewateL Management Pl~ Technical R~pork, 1982 Municipality of Anchorage. Plan, February 1982. ~illside Wastewater Manage~en~ U.S. Dept. of tile Interior, Geological Survey. ~R_e~p/>rt 75-105, H_yd_r!l!D_g2i_For Land-Use Planning: .Area, Anchorage, AK, 1975. QP-~D ~'il~ Hi 11 side U.S. Environmental Protection Agency, Region 10. ~rLyJ_ronmeDtal Impact Statement, Muni¢ipali%y of Anchor~g_q Sewage Facilities EXPA!ntio~, November 1982. db/193 rev. 4/93 On nitrates, drinking water, and human health Bruce Chandler, MD, MPH April 1997 Nitrates in the environment The Earth's atmosphere is about 78 percent nitrogen and contains about three-fom~ths of the nitrogen available in the environment. Most of this nitrogen is in the form of elemental nitrogen gas, but compounds of nitrogen and oxygen also are present. Some of these compounds are produced by chemical reactions in the atmosphere, and a substantial amount are released into the atmosphere fi'om the combustion of fossil fuel, such as coal and gasoline. Nitrogen compounds in the atmosphere undergo transformations that eventually leave the nitrogen in the form of nitrate. Nitrate can dissolve in rainwater or snow and then can reach streams or ground water in runoff or seepage. Naturally occurring nitrates are a major factor in plant growth. They are absorbed by growing plants and under normal conditions are metabolized rapidly to produce protein. Although nitrate occurs naturally in drinking water, elevated levels in groundwater may result from human activities such as overuse of chemical fertilizers and improper disposal of human and animal wastes. These fertilizers and wastes are sources of nitrogen-containing compounds which are converted to nitrates in the soil. The dry fertilizers ammonium sulfate and ammonium nitrate, for example, have a nitrogen content of 21 and 33 percent, respectively, while the widely used liquid fertilizer, anhydrous ammonia, has a nitrogen content of 82 percent,t Surveys in midwestern agricultural states such as Iowa, Kansas, and South Dakota have shown that 25% or more of private wells exceed the drinking water standard (10 ppm) for nitrate nitrogen. In Nebraska, 17% of domestic wells and 14% of public supply wells exceed this standard.2, 3 The movement of contaminants in groundwater is a complex process influenced by many factors; some of these are the amount, size, and solubility of the contaminant; the physical, chemical, and microbial character of the soil and rock; nature of overlying vegetation; the depth of groundwater; rate of groundwater flow; and the amount of precipitation. Microbiological contaminants such as bacteria and viruses usually travel a short distance through sandy loam or clay, but may travel large distances through coarse sand and gravel. Chemical contaminants, being of much smaller size than bacteria or viruses, tend to travel much farther in underground aquifers.4 Once nitrate is formed, its movement in soil and its potential for contamination of ground water depend on several factors including the soil characteristics, location and characteristics of the underground water formations, and climatic conditions. Nitrates are extremely soluble in xvater and can move easily through soil into the drinking water supply. The potential for nitrate contamination of drinking water also depends on the depth and construction of wells. Because nitrates move with the flow of groundwater, the source may be located at considerable distance from the well. In many cases, the time needed for nitrate to pass through the soil into groundwater is difficult to predict due to many variables including application rate, the soil type, and the depth to the water table,s identifying the source of nitrates or other chemical contaminants for an individual well is often very difficult; comprehensive hydrogeological studies and monitoring wells to trace the migration of the contaminant in the groundwater may be necessary, because nitrates and other chemicals may travel great distances in underwater aquifers and groundwater contamination with nitrates or other chemicals may persist for decades or longerfi Human nitrate intake Nitrate is a normal component of the human diet. The major source of nitrates taken into the human body is usually food rather than water. Nitrate is present in all plants; vegetables are a major source of nitrate in the diet. Over 85% of nitrate intake in a typical adult diet comes from the natural nitrate content of vegetables. Celery, potatoes, lettuce, melons, cabbage, spinach, and many of the root vegetables contribute both nitrates and nitrites to the diet.* There has been no significant upward trend in the nitrate content of vegetables to parallel the substantial increases that have occurred in fertilizer usage. Other major dietary sources of nitrate are food-stuffs such as cured meat products and certain types of cheese to which nitrate (or nitrite) has been added as a curing agent or preservativefi The contribution from drinking water is usually quite small (3% or less) unless the water supply contains nitrates in elevated concentrations. Persons who drink water with 10 ppm nitrate nitrogen have on average twice the nitrate intake of those drinking nitrate-fi'ce water; at 20 ppm, daily nitrate intake increases approximately tln'ee-fold.° Where drinking water is contaminated to a level of 50 mg/1 (5 times the EPA Maximum Contaminant Level), it may supply as much as half of the total daily nitrate intake.~° Infants in the first few months usually consume few vegetables; their primary source of nitrate is from water used in the preparation of formula. Human breast milk is not a significant source of nitrate to breast feeding infants. Nitrate toxicity The toxicity of nitrate is due primarily to its conversion to nitrite; nitrite oxidizes the Fe(+2) form of iron in hemoglobin, the molecule in the red blood cell which distributes oxygen to the body's cells, to the Fe(+3) state. This compound--methemoglobin--does not bind oxygen, resulting in reduced oxygen transport from lungs to tissues. Low levels of methemoglobin occur in normal individuals. Concentrations above 10% methemoglobin may cause a bluish color to skin and lips, while values above 25% lead to weakness, rapid pulse and tachypnea. Untreated, severe methemoglobinemia can result in brain damage; death may occur if methemoglobin values exceed 50-60%. The human health risk of greatest concern for nitrates is methemoglobinemia among infants. Conversion of nitrate to nitrite is nrostly mediated by bacteria in the gastrointestinal system. Consequently, the risk of methemoglobinemia fi'om ingestion of nitrate depends not only on the dose of nitrate, but also on the number and type of enteric bacteria. Conversion of nitrate to nitrite may occur in the stomach if the pH of the gastric fluid is sufficiently high (above pH 5) to 2 permit bacterial growth. This is of concern in adults with certain diseases snch as achlorhydria or atrophic gastritis in which acid production in the stomach is reduced. It is also of concern in infants, since the infant gastrointestinal system normally has a high pH that favors the growth of nitrate-reducing bacteria. Risk is especially high in infants who are exposed to water that is contaminated with bacteria, since this tends to promote high concentrations of bacteria in the stomach and intestines. In addition, the red blood cells of newborn infants contain fetal hemoglobin, which is much more susceptible to oxidation by nitrite than is adult hemoglobin. ~ Methemoglobinemia in infants under six months of age is the only illness which is clearly caused by the intake of drinking water with elevated nitrate levels. The relationship between infant methemoglobinemia and drinking water containing more than 10 mg/1 of nitrate nitrogen was first described in 1945. Snbsequent epidemiological studies have demonstrated a dose dependent relationship between nitrate concentration in tile drinking water and raised methemoglobin levels, for infants consuming water with 10 rog/1 nitrate nitrogen or higher. A comprehensive study of infant methemoglobinemia in the United States in the 1940s and 50s by Walton found that only 2 percent of the cases of nitrate water-induced infant methemoglobinemia occurred in association with nitrate nitrogen concentrations of 20 mg/1 or less, while slightly over 80 percent of cases were correlated with nitrate nitrogen concentrations of 51 mg/l or greater,t2 Cases reported at levels of 11-20 mg/L nitrate-nitrogen were usually associated with concomitant exposure to bacteriologically contaminated water or to excess nitrate from other sources. Repeated studies have shown that infant methemoglobinemia does not occur at drinking water levels of 10 mg nitrate-nitrogen or less.t~ Similarly, water with high nitrate levels normally poses no risk to older children or adults. For example, one study of over 100 illinois children 1-8 years in age ingesting water with nitrate nitrogen content ranging from 23-204 rog/1 found no elevation in methemoglobin levels in the children and no relationship between ingestion of high nitrate water and the measured methemoglobin level.~4 Because ingestion of excessive amounts of nitrate can cause adverse health effects in very young infants and susceptible adults, the United States Environmental Protection Agency (EPA) has established a maximum acceptable level, known as the Maximum Contaminant Level (MCL), for nitrate in public drinking water supplies. This level is 10 milligrams per liter (mg/l)--often expressed as 10 parts per million (ppm)--measured on the basis of the nitrogen content of nitrate. This standard of 10 ppm nitrate-nitrogen was set to prevent the occurrence in infant methemoglobinemia with a reasonable margin of safety?~6 While associations of nitrate contamination of ground water with a number of other health effects (including hypertension, clinical methemoglobinemia in older children, increased infant mortality, and central nervous system birth defects) have been reported, only the association between ground-water contamination by nitrates and infant methemoglobinemia has been proven. '? There have been concerns that nitrate-containing compounds might cause cancer or birth defects. Conclusive proof of a carcinogenic effect in humans of nitrate compounds is currently lacking. The results of epidemiological studies are contradictory and inconclusive.19.=° The majority of evidence by which nitrate exposure has been associated with an increased cancer risk is derived from correlational studies which, by their nature, provide only weak evidence. At the present time, nitrate exposure in drinking water cannot be implicated or excluded as a causative factor for certain types of cancer? Animal data has not shown evidence of birth defects or malformations attributable to nitrate or nitrite ingestion. Adverse animal reproductive effects in the form of increased fetal loss have been reported only in doses that were 1,000 times and higher than the estimated human intake. The results of epidemiological studies to date are contradictory and inconclusive. At the present time, there is no evidence to show that human exposure to nitrates produces adverse reproductive effects or congenital malformations.22.23,24.25 Siimmary: 1. Nitrates occur naturally in air, soil, plants, and groundwater. 2. Elevated nitrate levels in groundwater may be the result of human activities such as overuse of chemical fertilizers and improper disposal of human and animal wastes. 3. The delineation of the sources of nitrates iii groundwater is often difficult, because: · nitrates are small molecules which are highly soluble in water. · nitrates may move great distances from their point of entry into an underground aquifer. · nitrates contamination in underground aquifers may persist for decades. 4. Methemoglobinemia in young infants is the primary human health risk posed by consumption of nitrate-contaminated water. This dose-dependent outcome has been observed only among young infants who consumed water containing more than 10 rog/1 nitrate nitrogen. 5. Consumption of water with less than 10 mg/l nitrate nitrogen poses no identified health risk for humans of any age. 4 Holmes T, Jensen EL, Conway JB. Nitrate contamination of domestic potable water supplies: a social problem? American Journal of Preventive Medicine 1985; 1:51-7. Weisenburger DD. Potential health consequences of ground-water contamination by nitrates in Nebraska. Nebraska Medical Journal 1993; 7-10. Kross BC, Hallberg GR, Brunet DR, et al. The nitrate concentration of private well water in Iowa. American Journal o1' Pnblic Health 1993; 83:270-2. Salvato JE ed. Environmental Engineering and Sanitation, 4th ed. New York, Wiley-lnterscience, 1992:218-284. Hobnes T, Jensen EL, Conway JB. Nitrate contamination of domestic potable water supplies: a social problem? American Journal of Preventive Medicine 1985; 1:51-7. Salvato JE etl~ Environmental Engineering and Sanitation, 4th ed. New York, Wiley-lnterscience, 1992:218-284. Holmes T, Jensen EL, Conway JB. Nitrate contamination of domestic potable water supplies: a social problem? American Journal of Preventive Medicine 1985; 1:51-7. Cbilvers C, lnskip H, Caygill C, et al. A survey of dietm3~ nitrate in well-water users. International Journal of Epidemiology 1984; 13:324-330 Weisenburger DD. Panel discussion: health consequences: panel consensus of potential health coosequences o1' elevated nitrate levels. Nebraska Medical Journal 1993; 11-2 ~o Chilvers C, Inskip H, Caygill C, et al. A survey of dietary nitrate in well-water users, international Journal of Epidemiology 1984; 13:324-330 n Holmes T, Jensen EL, Conway JB. Nitrate contamination of domestic potable water supplies: a social problem? Americao Journal of Preventive Medicine 1985; 1:51-7. ~ Holmes T, Jensen EL, Conway JB. Nitrate contamination of domestic potable water supplies: a social problem? American Journal of Preventive Medicine 1985; 1:51-7. ~ Weisenburger DD~ Panel discussion: health consequeoces: panel consensus of potential health consequences of elevated nitrate levels. Nebraska Medical Journal 1993; 11-2 ~ Craun GF, Greathouse DG, Gunderson DH. Methaemoglobin levels in young children consuming high nitrate water in the United States. International Journal of Epidemiology 1981; 10:309-17. ~s Weisenburger DD. Panel discussion: health consequences: panel consensus of potential health consequences of elevated nitrate levels. Nebraska Medical Journal 1993; 11-2 ~ Kross BC, Hallberg GR, Bruner DR, et al. The nitrate contamination of private well water in Iowa. American Journal of Public Health 1993; 83: 270-2. ~7 Weisenburger DD. Potential health consequences of ground-water contamination by nitrates in Nebraska. Nebraska Medical Journal 1993; 7-10. ~a Fan AM, Willhite CC, Book SA. Evahlation of the nitrate drinking water standard with reference to infant mefl~emogiobinemia and potential reproductive toxicity. Regulatory Toxicology and Pharmacology 1987;7:135-148. ~9 Tsezou A, Kitsiou..Tzeli S, Gourgiotis D, et al. High nitrate content in drinking water: cytogenetic effects in exposed children. Archives of Environmental Health 1996;51:458-61. 2o Kleinjans JCS, Albering HJ, Marx A, et al. Nitrate contamination of drinking water: evaluation of genotoxic risk in human populations. Environmental Health Perspectives 1991; 94:189-93. 2~ Weisenburger DD. Panel discussion: health consequences: panel consensus of potential health consequences of elevated nitrate levels. Nebraska Medical Journal 1993; 11-2 22 Weisenburger DD. Panel discussion: health consequences: panel consensns of potential health consequences of elevated nitrate levels. Nebraska Medical Journal 1993; 11 ~2 ~3 Fan AM, Willhite CC, Book SA. Evaluation of the nitrate drinking water standard with reference to infant methemoglobinemia and potential reproductive toxicity. RegulatmT Toxicology and Pharmacology 1987;7:135~148. 24 Fan AM, Steinberg VE. Health implications of nitrate and nitrite in drinking water: an update on methemoglobinemia occurrence and reproductive and developmental toxicity. Regulatory Toxicology and Pharmacology 1996;23:35-43. 2~ Kleinjans JCS, Albering H J, Marx A, et al. Nitrate contamination of drinking water: evaluation of genotoxic risk in human populations. Environmental Health Perspectives 1991; 94:189~93. 5 0?/07/97 ~ON 09:19 F~% 907 343 4885 MOA OPERATIONS ~GR ~ee HHS ~01 TQ: I-~ [~J Ad Hoc: Meeting 7-1-~ Assembly Policy and Budget UN - 7 1997 Assembly Work $~ssion (requires agreement by a minimum of ~ix Assern~lyrnA~b~r~ - $ee / ~etow) / D Abney ~ ~Clemen~on ~ Vo~ Gemmingen / = Camp==ll = Mu~y ~_ Suggested St~ Person(s): Mark Begich (;,hair Date Received: ~pproved to attend: Larry, D. CrE'wforcf Municipal Manager, DIRANI~61t Fax Transmittal Cover Sheet R[~CEIVED Mun oipa ity of Anchorage Dopt. Hoalth & Human 8orr To: On-Site Water Jim Cross, - Dept. Health and Human Services From: Emily M. Davies, Your Company Name Fax Phone Number: (907) 688-5590 Date: Mon, Aug 27,1956 . 4:08 PM Transmitting (6) pages, including cover sheet. If there is difficulty with this transmission, please call: (907)688-5590 Note: "/our Cornpaay Name - [907) 688--5590-Created:M°nday, Au§ust 2t',19563:33PM- Fage i of 5 Dr, Shcila Ann Sclkrcgg, Director Community Planning and Development ILO, Box 196650 Anchorage, AK 99519-6650 August 24,1997 Dear Dr. Selkregg: I am writing Peter's Creek general, and with regard to the proposed Dcnali Vicw Subdivision in the area. I have concerns about the decision making process in specific concerrts about water and road/access issues. .Es ~hlJ.¢ Proces& I became involved with this project as an interested citizen; I wish to encourage aud snpport the ~i.O.A. aud State ageucies in making pro active, rather than re-active, decisions regarding responsible development in our commnnity. I can appreciate that yon and your staff frequently encounter citizen groups opposed to Olle action ot another and that you must discount "NIMBY" opinions as a matter of conrac, ltowever, in this case I believe there are fundamental principles of clue process and responsibility invoh, ed which need to be addressed. ,Specifically I wonder: 1. Whose interests does the Municipality most represent, commtlllity interests or those of individuMs (in this ease developers desiring to make prof t)? '2. When these interests directly' conflieL what role and posilion will.~should the Municpality take? 3. Where does the burden of proof (as to impacts and mitigating measures) lie',) A corollary here is who bears the financ:al burden of documenting such impacts., the developer, city and state agencies or affected public/homeowners? the 4. 135, what process/Froccdnre is submitted information dctcrmincd to be adeqaate, sufficient and;or In a letter dated August 19,1997, Mr. Dee Itigh clearly asserts that the burden of proof in the case of Denali View Subdivision rests with the commuuity/homeowners who have qnestioned the projected impacts and Your Company Name - (§07} 688-5590 - Created: Monday, August 2 ~, 1956 3:33 PM - Pa§e 2 of S conclusions provided by Mr Myers and his employees. I strongly disagree with Mr. High. Residents of three subdivisions surrounding Denali View (Scimitar, Chugach Park Estates and Petersgate Subdivision) have spent $7000+ trying to ensure that our conceras are addressed. After the Chugiak Community Council Meeting on July 17, community members hired Terrasat, Inc. to prepare an independent hydrology study because we stongly believed the hydrology and nitrate studies prepared by Mr. Muntcr for Mr. Myers were biased and inadequate. We were essentially forced into this action because, despite numerous and serious questions raised by the public at the Chugiak Community Council Meeting, Mr. Cross asserted that unless information to the contrary was brought forward he would accept the Bristol Environmental report and recommend the project be approved. It was gratifying that two reviewing state agencies: D.E.C. and D.N.R_ indepeudently echoed many of the same concerns raised by the "non- professional" public. (I can't help wondering why Mr. Cross didn't identify these areas of concern himself...?) To reiterate, the purpose of hiring a consulting hydrologist was to: a) get a clearer picture of the existing water situation than that provided by Mr. Muuter's report; b) to acertain whether out fears of uegatlve impacts were warrented; and c) by seeking "professional expertise" to ensure that our concerns were taken seriously by decision-making authorities. The results of our expenditures is a hydrology report that challenges and/or contradicts many of the conclusions put forward by the developer. It seems to me that we have made onr point- that this project deserves more careful scrutiny before being approved. It also raises ethical and legal questions about whether a community sbould bare to pay an iudependent consultant to represent their interests when we have public (???) agencies presumably mandated to safequard exactly these interests? Mr. Cross, in a telephone conversation on August 22, equated our expenditures with those of Mr. Myers, who "has also spent a great deal of money on this process," I contend these expenditures are vc~ different: Mr. Myers anticipates a profit at the end of this anti at the x,e~5: least can write it off as a business expense. We cannot. The question of who is responsible and who pays is a very serious policy issue and needs to be addressed directly and with care. I am very concerned about the precedent this case sets for future situations. Your Cornp~nyName-(907) 688-5591)-Created:Monday, August 27, '~9563:33 PM- Pe§e 3 of S Returning to Mr. High's letter, he wrote: "By working with tire appropriate Departments of Ihe Mnnicipality, the Myers (owners) have clearly demonstrated, through "systematic evaluation", that the problem is not the lack of water, water quality or the effect of one well on another." 3_.5.et at ~a meeti~lg otl l~3lly ~M[:, Jim Cross~, all__parti~s- illClltding MIx Higll ~nd Jim_Munter- agreed that the_well _pum~_t~lt~ucted ~y Bristol Environmental weye "in~/l~lXt~tc" to concludL.~dmOer sufficient B~tter ~ks~ for th¢__entir~_ subdivion_~h~th_e~_ long run,_~xarl whedkex_surromzdiag wells 3~J3. lint he adversely imlx~etetL. Mr. High's statement regarding Mr. Cross's reqnest that homeowners provide flow and nitrate tests of their wells is misleading (Paragraph 2, line [ and paragraph 2, lines 6-7). I was at both community council nreetings in question; Mr. Cross did request any flow and nitrate data available, noting it would be very helpful in the assessment of this project. A formal water flow and nitrate test, condncted by a 'professional' hydrologist: costs around $400 per household. I am sure Mr, Cross would be the first to admit he has no authority to insist or require such expenditures, Ironically many homeowners did consider conducting these tests and obtaining this information. But because: 1.) we were not confident that our interests would be justly represented within the Mnnicipality; and 2) we were not certain how the data would be used; and 3) many of us have experienced responses ~anging from cool to opeuly dismissive from staff' members involved in this project, we chose the alternative of hiring a hydrologist who was capable of interpreting the data and representing us on the "professional" level Again I assert that this should not have been necessary if city employees had been conscientious about doing their jobs. Other comments regarding Mr. High's letter: Paragraph 2; line 2: I never heard Mr. Young (the homeowner's hydrologist) direct anyone not to provide flow rate and nitrate information flow rate and nitrate; quite the opposite, he solicited any and all existing available information, With respect to Paragraph 3, line 1, I'm not clear what "position" Mr. High refers to. I understand 'the homeowner's' position to bc that thc developer shoald be required to provide adequate information to assure residents that there is snfficient water for the proposed subdivision and that current residents' water quality and quantity will not be adversely impacted by the development of Denali View, This position is supported by applicable codes and laws, Furthermore, it is our position that the developer to date has ~mJ. provided this 'adequate information'- or "real data", to use Mr. Yo~Jr ComoanyName- ~g07) 688-S$90-CreaLed:Monday, August 2T, 19563:34PM- Page4of S High's own words, Mr. High himself concurred a day after writing this letter that the "hard f'actual data" provided on behalf of ]lis client was "inadequate" to conclude that a long term supply of clean water exists for tile proposed subdivsion and surrounding neighhborhoods. Furthermore, the honreowners' position is supported b5 an indepel~dent hydrology report and by two state agencies, D,E,C. and D,N,I(, Therefore Mr, High's assertion that ~ve should be requirt~d to conduct l]ow data and nitrale tests to support our position is ludicrous. It also raises softens questions about public process and burden of proof which should be clarified immediately. I believe tile controversy ts vcell documented in other correspondance. My question is: How will tile Municipality deal with conflicting opinions from two professional hydrologists? Will the Municipality require definitive data to resolve t!le conlqict. And who is responsible ['or paying for obtaining this information ~xoad Another controversial issue associated Desalt View is road and trail access lip Bear Monntain. Some residents of Scimitar Subdivision have petitioned to exclude right-of-wa~s fei a Seika-Knllberg road connection, but residents in Chngach Park Estates and Peter's Gate Subd. strongly desire the right-of-way to be dedicated to leave future options open. V~e are supported in this by Ted Kinney, our Road Board representative. Another road/trail access issue involves the upi>er Kullberg Sullins trail, which is used hy pedestrians and school childreu needing to get to bus stops in Scimitar Ssbd. (Chugach Park Estates and Peter's Gate Subd. have no school bus service because of narrow steep roads.) Within the last week or so trees have been felled ,qnd "No Trespass!ns' signs posted along the Seica-Kullberg attd Kullberg-Sullins trails. I question the legality of this act- prohibiting access along historical roadbeds and traditional trads when no significant modification to the property has been (or will imminently be) a¢compl;~shed. But regardless of the legality, this is au example of the kind of behavior which has eroded trust in Mr. Myers' good faith and concern for community welfare. School starts ill a week and a half. Given we have no school bus service iu Chugach Park Estates and Peter's Gate Subdivisions, how does Mr. Myers propose the children on the mountain get to their hus stop in Scimitar? By walking att additioua! two miles along narrow dangerous roads? Judging from his actions Mt. Myers does not propose any solution. Therefore, the question reverts to ~ou: ttow does the Municipality propose to safequard Your Coml)any Name - (907) 688-5590 - Created: Nenday, Auoust 27,!9563:34PM- Pa§eSof 5 our children, beginning Scptcmbcr 2 and continuing if Dcnali View Subdivision is approved? This circumslance snpports onr conlention that the road access issue needs to be formally resolved before approval of the plat and not left to the discretion of the developer. In conclusion, gives the significance of many of the conflicts in this case, 1 very strougly oppose any phm to approve the preliminar> plat for Denali View, contingent upon completing further pump tests etc. Such an action would end the public process aud conscribe the ability for citizens to comment and review dccisious that may have serious impacts on their neighborhoods. Given that serious policy issues are at stake, this would set a very dangerous precedent. Water, road access and procedural issues must be resolved before the public process is closed and before the development is approved. Thank you for ),out' serious consideration of these matters. I would be happy to discuss them further at any time. Sincerely yours, Emily M. Davies P.O. Box 671264 Chugiak, AK 99567 907-699-5590 CC. The Platting Board Margaret O'Brien, CP&D (fax) Jerry Weaver, CP&D (fax) Elaine Christian, DHHS (fax) Jim Cross, DHHS (fax) Kevin Klewano, ADEC (fax) Gary Prokosch, DNR (fax) Sharon Minsch, Community Council August 6, 1997 Jim Cross MOA On-Site Director Jim: R[C[IVED Munloipalily of Atlohoroflg Dept. Health & Human As you arc aware I have beeu involved with the platting action on Dcuali View. I am President of the Chugiak Community Council, a member of the Ou-Site Tech Board and a Realtor with ReMax ef Eagle River. I have a substanlial personal and professional commitment to protect and preserve our groundwater resources as well as the integrity of our wells aud septics. I have logged cmmtless volumeer hours oil behalf of my Community in the pursuit of these goals. i have read tile report ou Dcuali View done by Bristol Environmental Services. In addition I just completed reading the repro1 eutitled, "Evaluation of Nitrates in Drip,king Water and Development of a Groundwater Prolcction Program." l raise the following issues aud concerns for your comment: 1. I think it is necessary to delay the secoud phase of tile nitrate study until the first phase is reviewed aud commented on by an iudependent qualified person or firm who is currently working ill the field of nitrate research and treammnt. 2. Additionally, it appears prudent to ask DNR and DEC to provide written evalnation and comment on the report based on the information and docnmentation they have. It would be helpful to kuow if they concur with the conclusions or not and why. I believe that DEC is where the flmding was located for the project. Getting their professional opinion outside of the grant administration would be hclpfld. 3. Concerus have been raised about Mr. Munter being a member of the Tech Board and doing work £or MOA. l have expressed my coucern about the potential for a co~ffiict of interest over the uitrate issues to you previously. Mr. Munter's Tech Board seat is as a member of the Hillside Comnmnity who lives with on-site well and septic. Since Mr. Munter did the report on Sonth Anchorage he is placed in a positiou of appearing to defend his work oil aitrates possibly to the detriment of the Hillskle Community he represents. 4. Are you concerned that the apparent differences ill thc couclasions of the two reports compromises the ability of the public to have complete faith in the outcome of the second phase of the study? Mr. Munter's report oil Denali View was pcd'ormcd for a developer who hired him to prove there is not a nitrate problem ill Denali View. The goal is finaucial gain. The report on South Anchorage was paid fei' with tax payers funds to provide an accurate evaluation of elevated nitrate levels. The goal is to protect the public. It appears there is a couflict between the purpose aud Ihe outcome oflhe two reports the pablic is already concerned about. 5. Residents involved in the Denali View plattiug action feel Mr. Muuter's conclusions regarding Denali View Subdivision seriously compromise his ability to be impartial on the second phase of thc stndy. His conclnsions ou Denali View make it difficult, if not impossible, to reach a different conclusion in thc second phase of the study, ( other thau what he concluded in the Denali View report ie no nitrate problem ). While there lnay uot be a colfflict of interest ill your opinion, the pablic perception (adinittedly heightened by tide Denali View action) is a cmtflict exists. August 8, 1997 page 2 Jim Cross 6. Resideuts expressed coucern that Mr. Munter's work ou Deuali View in betweeu the two stndies of our areawide nitrate concerus bas serioosly compromised his ability to appear impartial to the public. A nmnber of Council members discussed these concerns after the Denali View Plat was postponed ou Wednesday. It is critical the public have absolute faith in the data being put out for public consumption regarding nitrates. 7. Since Mi'. Munter's report questions the accuracy and age of tile data used for his project it makes no sense to use the same data and do the same report in pllase two. Wouldn't determining the canse of the elevated nitrates and how the nitrates am gettiug into some specific wells be a more productive use of the rituals? Answers to these qnestions would go a loug way itt telliug us how to deal with the problem itt the future and possibly how to help homeowners already impacted with elevated uitrate levels. 8. How can you not be cmwinccd that tim elevated nitrate lcvcls we are seeing itt private and public wells is not being caused by on-site septic systems? If it is not being caused by the septic systems then what is causing it? How do we get the answers so we can preveut any fltrlher financial heart ache to home owners? We must address this issne from a financial and euvirmunental staudpoiut before there is some "emergeucy" and it becomes to late to protect our precious water resonrces. 9. Is there a process for a DHHS, Tccb Board or peer review of Mr. Munter's findings and conclusions in either report ? Does DHHS have a process to accept or concur with the reports? Approval of the Denali View plat by DItHS will be viewed by the public as DHHS concurrence on the Denali View and South Auchm'age repro'ts. Does DI-tHS concur with both reports? 10. I ant greatly concerned with the last paragraph of lhe DHHS 7/25/97 response to Community Planuing. Do you believe the plat note is enfomeable? It conld be 10 years before any homes sell due to the water problems. Iu that time there could be substantial coataminatiou of the bedrock aquifer before DHHS has any indicatiou. Your letter states "....DHHS will require nitrate rcdnciug septic systems for arty newly developed lois." Nitrates would be craning from the existiug septic systems which the plat note does not address. What will DHHS do abmtt thc existing scptic systems if there is "....any indication of elevated nitrates within or due to development in Denali View? How will DHHS repair the contaminated well? What level will DHi-IS consider "any indication" to be? I do not understand the point of requiring the plat note that only addresses lots to be developed. Once the nitrates show up itt Scimitar wells aftcr Dcuali Vicw bas been dcvcloped it will be too late to require nitrate reducing septic systems. What method will DHitS use to prove where the nitrates are comiug? Sittce DItHS does not have attlhority to require dye testing of septic systems ou private properly I am concerued how this would be dealt with. i thought lack of fltnding for etfforcemeut was why DHHS does not pursue areas with kuown nitrate levels. What can DHHS do after the fact ~o correct the probletn when the nitrates show up? I think if the State aud MOA work together with the Commnnity the ability to require systems that will prevent the problem will be made available. Installing nitrate reducing systems after the wells are coutaminated, moving septic systems or providing treatmeut has not been proven efficient or aflbrdable. UNITED STATES ENVIRONMENTAl. PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, Washington 98101 Reply To Attn Of: OW-136 14 May 1997 Sharon Minsch 16600 Centerfield Dr. Suite 201 c/o Remax Eagle River AK 99577 Dear Ms. Minsch: Thank you for your inquiry regarding Nitrate contamination of wells. You express concern that the Nitrate level in numbers of wells seems to be increasing over time and suggest a proactive approach to avert health hazards. I am enclosing several publications that might be helpful to you. These include a series of short articles that appeared in a water supply trade journal, (WWJ) in ].988, an Article from a South African Journal that is slightly more recent and a fairly comprehensive review from the National Research Council which was completed in 1995 and represents the current thinking on Nitrate and Nitrite in drinking water. I have also enclosed copies of two EPA fact sheets, one intended for the general public and one slightly more technical. I hope that these materials will be useful to you. Please call me at (206) 553-1389 if you have questions. Sincere/ ~ Gene Taylor, Ph.D. Drinking Water Unit O Prlnted on Recycled Paper United States Office of Water Environmental Protection 4601 Agency EPA 811 -F-95-002 October 1995 &EPA National Primary Drinking Water Regulatio'ns Nitrates and Nitrites This is a factsheet about a chemical that may be found in some public or private drinking water supplies. It may cause health problems if found in amounts greater than the health standard set by the United States Environmental Protection Agency (EPA). WHAT ARE NITRATES/NITRITES AND trow ARE '~HEY USED? WHY ARE NITRATES/ NITRITES EEING REGULATED? ' WHATARETHE HEAL TH EFFEC TS ? HOWMUCHNITRATES/ NITRITES ARE PRODUCED AND RELF~SED~O?'HE EN~RONMENT~ MCLO MCI. i Nitrite: DRINKING WATER STANDARDS Nitrates and nitrites are nitrogen-oxygen chemical units which combines with various organic and inorganic compounds. Once taken into the body, nitrates are converted into nitrites. The greatest use of.nitrates is as a fertilizer. In 1974, Congress passed the Safe Drinking Water Act. This law requires EPA to determine safe levels of chemicals in drinking water which do or may cause health problems. These non-enforceable levels, based solely on possible health risks and exposure, are called Makimum Contaminant Level Goals. The MCI.G for nitrates has been setat 10 parts per million (ppm), and for nitdtes at 1 ppm, because EPA believes this level of protection would not cause any of the potential health problems described below. .. Based on this MCLG, EPA has set an enforceable standard called a Maximum Contaminant Level (MCL). MCLs are set as close to the MCLGs as possible, considering the ability of public water systems to detect and remove contaminants using suitable treatment technologies. The MCI. for nitrates has been set at 10 ppm, and for nitrites at 1 ppm, because EPA believes, given present technology and resources, this is the lowest level to which water systems can .reasonably be required to remove this contaminant should it occur in drinking water. These drinking water standards and the regulations for ensuring these stan- dards a~e met, are ca~ied National Primary Drinking Water Regulations. All public water supplies must abide by these regulations. Short-term; Excessive levels of nitrate in drinking water have caused serious illness and sometimes death. The serious illness in infants is due to the conversion of nitrate to nitrite by the body, which can interfere with the oxygen-carrying capacity of the child's blood. This can be an acute condition in which health deteriorates rapidly over a period of days. Symptoms include shortness of breath and blueness of the skin. Lo~ Nitrates and nitrites have the potential to cause the following effects from a lifetime exposure at levels above the MCL: diuresis, increased starchy deposits and hemorrhaging of the spleen. Most nitrogenous materials in natural waters tend to be converted to nitrate, so all sources of combined nitrogen, particularly organic nitrogen and ammonia, October 1995 Consumer Version Pdnted on Recycled Paper __ RELEASES TO WATER AND LAND: 1991 TO 1993 Water Land TOTALS (in pounds) 59,014.378 53,134,805 Top Fifteen Stales* GA 12,114,253 12,028,~85 CA 0 2'1,840,999 AL 3,463,097 6,014,674 LA 8,778,237 .2,250 MO 6,g85,890 206,181 MS 6,952,387 0 KS 5,140,000 877,095 VA 5,091,764 0 NV 0 4,977.482 FL 1,056,580 1,835,736 AR 1,206,610 1,058,294 MD 1.802;219 138,819 IA 1,500,340 132.042 OK 1,436,348 14,199 UT 0 1,045,400 MaJor lndus~fes* Nitrogenous fertilizer 41.584,611 8,607,376 Misc. Ind. inorganics 4,113,312 29.676,919 Misc. Metal ores * 0 5.764,976 Misc. Ind. organics 5,091,764 0 Fertilizer mixing 480.000 4,554,916 Explosives 850.921 1.297,590 Paper mills 1,727,061 0 Pulp mills 1,321,500 3,350 Canned foods 0 1,056,794 Phosphate fedilizers 1,000,000 0 · State/Industry totals only include facilities with releases greater than 10,000 lbs. should be considered as potential nitrate sources. Primary sources of organic ni- trates include human sewage and livestock manure, especially from feedlots. The primary inorganic nitrates which may contaminate drinking water are potassium nitrate and ammonium nitrate both of which are widely used as fertilizers. According t6 the Toxics Release Inven- tory, releases to water and land totalled over 112 million pounds from 1991 through 1993. The largest releases of inorganic nitrates occurred in Georgia and California. Since they are very soluble .and do not bind to soils, nitrates have a high potential to migrate to ground water. Because they do not evaporate, nitrates/nitrites are likely to remain in water until consumed by plants or other organisms. The regulation for nitrates/nitrites became effective in 1992. Between 1993 and 1995, EPA required your wate¢ supplierto'collect water samples at least once a year and analyze them to find out if nitrates/nitrites' are present above 50 percent of their MCLs. ' If it is present above this level, the system must continue to monitor this contaminant every 3 months. If contaminant levels are found to be consistently above their MCLs, your water supplier must take steps to reduce the amount of nitrates/nitri[es so that they are consistently below that level. The following treatment methods have been approved by EPA for removing nitrates/nitrites: Ion exchange, Reverse Osmosis, Electrodialysis. If the levels of nitrates/nitrites exceed their MCLs, the system must notify the public via newspaper~, radio, TV and other means. Additional actions, such as providing alternative drinking water supplies, may be required to prevent serious risks to public health. WHATHAPPENS TO NITRATES/NITRITES WHEN THEY AR~ RE- LEASED TO THE ENVIRON- MENT? NITRATES/NITRITES BE DETECTED IN AND REMOVED FROM MY DRINKING WATER? How WILL I KNOW IF NITRA TES/NITRITES ARE IN MY DRINKING WATER? Learn more about your drinking water! EPA strongly encourages people to learn more Your state Department of Health/Environment is also a abouttheirdrinkingwater, andtosupportlocalefforts valuable source of information. to protect and upgrade the supply of safe drinking For help in locating these agencies or for information on water. Your water bill or telephone book's govern- drinking water in general, call: merit listings are a good starting point. EPA's Safe Drinking Water Hotline: (800) 426-4791. Your local water supplier can give you a list of the For additional information on the uses and releases of chemicals they test for in your water, as well as how chemicals in your state, contact the: your water is treated. ,. Community Right-to-Know Hotline: (800) 535-0202. October 1995 Consumer Version Page 2 The Nitrate Problem drilled ~l~he ~ell you Just may · . contain the mostcommon eon- tamlnant of ground water -- dis- solved nitrate. Excess dissolved nitrate tn smnples of well water have been documented as causing nitrate poisoning ofinfm~ts (Infant cyanosls or methemoglobinemla). This disease, which can be fatal, occurs when an' Infant consumes formula or breast milk high irt dis- solved nitrate. It is not, however, a problem for older children or adults unless nitrate is present at very high concentrations, In 1975 the U.S. Environmental Protection Agency established a maximum limit of nitrate (as nitro- gen) in drinking water of 10 mg/L, Based on the lack of documented health problems at low concentra- tions, some believe this limit Is unnecessarily iow. Nitrate is a common contam- inant because it comes fi'om many sources. The input of nitrate into ground waters is a result of natural processes and a direct or indirect effect of man's activities, The nat- utral processes include precipita- ti_on, mineral weathering, and decay of organic matter, Nitrate sources resulting from man's activities include runoff from barnyards, pastures, and livestock feed yards; effluent from s. ewage lagoons, pri-, ~e..~:.s, ,and septic s}rstem,s; excessive nitrogen fertilization; deforesta- tion; and the change in the soil organic matter regime resulting 4 AUGUST '88/WWJ By Jim Hendry from crop rotation, The problem with nitrate is that it is a very mobile..,pollutant in gr--~b-fl"ffa"-~t~rs. It does not adsorb on aquifer materials nor does it precipitate as a mineral. These two factors allow large quantities of dissolved nitrate to remain in the ground water. "Nitrate is a common contaminant bec:au.se it comes from mcmy SoItrces, "' The only control on nitrate In the subsurface is nitrate reduction or denltrifleatlon, Nitrate reduction is a naturally occurring reaetlon in which the harmful nitrate Is re- duced to harmless nitrogen gases by bacteria. Nitrate reduction has been shovm to occur in shallow. unconfined sand aquifers underi~- lng agricultural land, thus prevent- ing nitrate from contaminating deeper aquifer systems. Where nitrate reduction is not occurring, nitrate will persist and water sup- plies are at risk. High risk areas include aquifers under intensive agriculture or in the vicinity of dense septic fields, There are three options availa- ble to attain acceptable nitrate con- centrattons in water-supply wells that produce water with unaccep- tably high nitrate concentrations. These are (i) drill a new well: (2) mix the well water from mmther source that has a low nitrate con- centration thereby reducing.'the final nitrate concen{rations to acceptable limit; and (3~I~e nitrate from the water supply. Most removal processes utilize ion ex- change resins or reverse-osmosis, but none are in common use. There has been only one infant death recorded during the past 20 years in the United States attrib- uted to Infant cyanosls. It occurred in South Dakota In 1986 and was due to well water containing more than 100 mg/L of nitrate (as nitro- gen). Regardless of this seemingly safe record, one should not become complacent about the potential health hazards of dissolved nitrate. With more than 500.000,000 tons of fertilizer applied annually and 23,000.000 septic tank systems in Yhe United States. a g~addaT in- crease in the nitrate concentration In shallow aquifer waters is With the trend toward using In- creased amounts of nitrogen fertll-N izers and l~s_talllng more septle,/7 systems, It could be onlya matter time belore the health hazar---~,,i, related to nitrate contamination are felt. While the negative impacts of nitrate contamination are debat- able, no one questions the fact that high nitrate concentrations have no redeeming value. ~! ._~Bg the time we realize that the con~rninatlon of our ground water res'ources by nitrates (as well as ot-~er cont~arninants) is a problem ~c~-aln areas, it may be too late t_o repair t. be damage done to the aquifer. By t__.~heir ve,ry nature aqui- fers are slow to become confiaml- n--~d but once contaminated, dlf- ~'~ to re_turn to potability. We must maintain nltrate at acceptable levels. Controlled agri- culture and domestic land use throughout the basin being im- pacted is perhaps the best available alternative to maintain low nitrate concentrations in ground water. e This type of preventive approach can limit the amount of nitrate leached from the soil zone in agri- cultural areas or septic fields to the aquifer. Controlled land use is presently being advanced and implemented by many European · countrles to limit the infiltra- tion of nitrate and o,th,fi~ agricul- tural chemicals. :t- {x As is the case with mo.st regional ~e~ control programs, these programs .n require distasteful political and 'bureaucratic intrusions into the st free access of our lands. They can create economic hardships· How- nt !0 b- ~d ne re. ns nd in on tic :of 'ds ever, we have spent megadollars on Superfund projects to correct our historic contaminant problems: it seems to make economic sense to spend some money to prevent a problem. Based on our lnabilit7 to decontaminate manypolnt-source c~ontaminants with Supenuna proj- .ects. our Chances of successlhll~, decbntaminating an entire aquifer Our only option to avoid future .:nitrate c0hta~-~ation of shallow, susceptibleaquifers is t6 b~gin sen- - slble land-use controls. · dim Hendry is dlrector of research for the National Water Well Association. Hendry received his M.Sc. and Ph.D. degrees in hydrogeology from the Uni- versity of Waterloo and was formerly head of the Ground Water Section for AIbertaAgriculture. His current research interests deal with chemical evolution of ground water. PITLESS HANG T Do your present small brass pitless adapters hotd 2000 lbs.? The LD-S-10 (up to 1000 ft.) and LD-S-12 (up to 750 ft.) do. Do your present big brass pitless adapters hold 5000 lbs.? The 2-10 (up to 2500 ft.), S-12 (up to 1700 fi.), and S-20 (up to 1000 ft.) do. Get "The No-Call. Back-Line", demand Dicken For more information contact Circle card no. 23 Asheville, NC 28804 FAX (704) 254-8142 (800) 438-5851 SINCE 1893--The name Orangebu rg has stood for QUAL Now.in 1988, for water well drop pipe, lateral supply lines, jet pump piping, or heat pump piping applications, you can still count on Orangeburg flexible piping pro- ducts and accessories to provide years of dependable service, SUPER-POLY PE-3406 high malecular weight polyethylene pipe ***The premium polyethylene pipe So dependable, we give it a 50-year limited warranty BLU-MAX PB-2110 blue polybutyiene water well pipe '*'Resistant to freeze and pump torque damage, flexible in cold weather, minimal stretching for hanging submersibles. POLY-XTRA PE-3408 high density poly- ethylene pipe **'Maximum performance at a competitive price Permanently indent identified GeoThermal products for "earth-coupled" water source heat pump piping '**HDPE fusion pipe, butt-fusion fittings including "U" bends, butt-fusion tools Circle card no. 32 AUGUST '88/WWJ 5 The Problem with Nitrates ~, long with PCBs and ,&~,E. Coll bacteria, nitrates have rapidly become a common topic of many discussions concerning ground water. From Arizona to the Corn Belt and beyond, nitrates are. ,affecting[ g..round water to such an By Scott Hurlburt (NO3N) has been around roi' nearly 30 years. The evohJtlon of the EPA stand- extent t_.[~twldesnreal! monitoring ards for nitrates can be traced to '~tnd sampling surveys l~ave become - the early i900s, In 1914, the first commonplace, and somewells with ~xcessively high levels have been ordered shut down nntll the prob- .leto is corrected, Nitrates originate from many sources, including nature ones, but man's agricultural activities m/e a major contributor. According t.o a recent Department of Agricul- ture report, approximately 10.6 mil- lion tons of nitrogen fertilizer is used annually in the United States. Although debate exists as to what constitutes safe drinking lev- els, the recommended Environ- mer~tal Protection Agency (EPA)- established level of 10 parts per million (ppm) of nltrate nitrogen 'standards for water quality were developed by the United States Public Health Service. After minor revisions in 1925, 1942, and 1946, major revisions were made in 1962 by an advisory committee.The pol- icy of the committee regarding chemical standards was "to set lim- its which are not so low as to be impracticabl~ nor so high as to encourage.pollution pf water." The 1962 advisory committee standards introduced for the first time a recommended limit for nit- rogen in water supplies, establish- ing 45 milligrams per liter (rog/L) nitrate (10 mg/L of nitrate-nitro- gen) as the concentration limit. Following the Water Quality Act of 1965 and the passage of the Fed- eral Water Pollution Control Act .Amendments of 1972, the Safe Drinking Water Act was passed in December 1974, This'act autho- rized the EPA to regulate contami- nant levels in public water sysienis, which were defined as any system with' 15 or more connections and serving 25 or more persons. States were allowed to submit their own proposed standards, but the act required that state regulations must be at least as stringent as the federal standards. Much of the attention concern- ing nitrates came from the incidents of methemoglobinemia among infants In various parts of the country. It was in 1945 that Dr. Hunter Comly first reported clinical evidence of two cases of infantile methemoglobinemia in Iowa where nitrate-enriched well water was found to be the causatlve factor of the disease.The two farm wells in AUGUST '88/WWJ ' 37 question had nitrate-nitrogen con- centmtions of 140 mg/L (31 ppm N) and 90 mg/L (20.3 ppm N). Comly suggested at the time that anywater containing more than 10 ppm nitrate-nitrogen should not be used for infant feeding, Research was undertaken in the following years to determine the extent of nitrate-related methemo- globinemia. One report by the~ ~nerican Public Health Associa-. trated below or near the area of realizes that the problem has ex- waste accumulation or disposal of isted for a long time."I suspect that manure piles, septic tanks, eess- probably point sources of ground pools, etc,, and fertilized agricul- water contamination for nitrates tural acreage have been around for as long as w~,,,~v-r ~lue to its soluble ha- I animal wastes have been accumu- · . ~ic'X~ lated in one location," he says. l ~tes have a propensity t~ ~ Dr. Gflharn, director oftheWater- travel significant dishes in the hloo Center for Ground Water Re- I ~ubsuriace, speellically, in'-h-ig'g-~v_J.~-/search, andprofassorinthedepart- ~Freeze and Cherry 19~---.//N associatedwith nitrates in the mi and based on data from 49 - ~alle point-source contamina- '60sduringthestudyofawatershed tsit~tnes pointed out that: ~ tion originates from distinct sour- ]~ areaofabarnyard. Nltrateconcen- ,, - ..... D/ eessuchasseptictanks,~tx~ trations in a neart~y stream, while .., most oI the cases stualecl~k~ '~,,,r,., ~on;mrnina~-"~'~--~n deals witlf'~ lowrelativetodririklngwaterstan- were associated with nitrate-nitro- [~'~ ~r~eer~ areas, such as crop~d I/l' dards, were higher than normally gen concentrations in excess of 40 ~J~ ,,,here fertilizers have been applied,-~' found in stream water, In the sub- ppm. But. that it is impassIble atZ]-~ a .... ~1 ,,~ nt S DeJ'~ uent search for potential so r- this time to select any precise con- ~ ....... l-~, to a reee U. , -- seq · partment of Agriculture report that ecs of nitrates, Dr. Gflham and his centration of nitrates in potable water-fed infants which definitely will distinguish between waters which are safe or unsafe." Many agencies and individuals recognize that difficultias persist in determining what levels and to what extent nitrates are truly harm- ful, so the 10 mg/L level that was first suggested in the 1940s and subsequently adopted by the EPA has been widely adhered to, if not entirely accepted, by those who con- sider it to be too conservative. Nitrates develop from nitrogen, which is an essential element in most substances making up living matter. Nitrogen in its reduced form, ammonia (Nt-I3), is the start- ing point for a nitrification process, which has two distinct steps: the oxidation of ammonia to nitrite NO2, and (2) the conversion of nitrite to nitrate (NOa) (Hlggins and Bums 1975). Under anaerobic conditions, nitrates and nitrites are reduced by aprocess called denitriflcation. It is presumed that nitrates am reduced to nitrites, and then reduction of .~cttrites occurs. (Nitrates in Sur- ce and Ground Water, Miller, Canter 1980). High concentrations of nitrates in ground water can emanate from a number of sources, including animal excreta, human waste, nit- rogen fertilizers, naturally occur- ring deposits of nitrate-containing materials, feedlots, crop residues, and decomposing animal or plant tissue. Nitrates are most concen- focused on agricultural counties. and based on collected data from the U.S. Geological Survey, DRAS- TIC (a standardized system for eval- uating ground water pollution using hydrogeologic settings), and fertfllzer use data. ground water contamination from nitrate-nitro- gen appears to be concentrated in the following areas: · Central Great Plains · the palouse and Columbia Basin in Washington · portions of Montana · southwest Arizona · the irrigated fruit, vegetable, and cotton growing areas of Cali- fornia · portions of the Corn Belt · southeast Pennsylvania · parts of Maryland and Delaware. The report adds that within these regions, Kansas, west Texas, and southern Arizona have the highest recorded concentrations, with 25 percent or more of sampled wells having nitrate-nitrogen levels exceeding 10 mg/L The following comments from individuals throughout the United States and Canada give a brief overviexv of the previous and cur- rent situations concerning nitrates in ground water. Dr, Robert Gilhan~ University of Waterloo, Alberto, Canada Though Dr. Gilham of the Uni- versity of Waterloo has been study- ing nitrates since the mid '60s, he team found "particularly high" .nitrate concentrations in well water on that farm. Gllham notes that ground water contamination from the barnyard was most likely a minor contributor to the nitrate levels in the stream, but the high nitrate levels of wells in the immediate vicinity were probably more directly affected. The stone cribbed well "could not have been, positioned in a worse loca-.<~ tion, he says, so proper planning /~P and we"Il con~ction methods, in ~nost chs-~s, would have resolved the nitrate problem. In this particular case, however, the shallow, uncon- fined aquifer was contaminated to its entire depth and the well would still have been draxving contami- nated water had it been placed anywhere within the vicinity. "If a wellwent through the aquitard into a lower aquifer, then the problem could be avoided," explains Dr. Gilham. A few years later, Gilham again became involved in nitrate contam- ination from distributed sources, such as fertilizers. The concern that prompted these studies by Gilham and other groups involved the amount of contamination and nutrients accumulating in Lake Erie and Lake Ontario, and whether the nutrients were getting into the lakes from land areas (sewage ef-.~ fluent, agricultural sources, etc.). Whatever the source, the process was basically fertilizing the lakes and creating an abundance of algae len rtl ng to eutmph lcatlon of the lakes. 38 AUGUST '88/WWJ Gilham says that the study was less concerned with ground water contamination or potential health problems, and more with looking at ground water as a possible means of transit of nitrate from agricultur- E areas to the Great Lakes snrface waters. One interesting finding (from the sampling of watersheds} was indications of substantial de- nitriflcaLion, or the transformation of nitrate to nitrogen oxides and gaseous nitrogen. "So a good deal of nitrogen-nitrate thatgot into the aquifer was subsequently denltri- fled and lost in'the aquifer," he says. "Our observation is that there seems to be extensive denit~tflca- Lion where {organic) carbon is being leached naturally into the ground water zone," Gilham notes. "It fol- lows logically (rom that that if we could somehow introduce carbons, then we might enhanee denitrlfl- cation and reduce the problem. "As to how to go about doing that, I don't have any good ideas, but it's apotentiallyuseful concept," _While the problem of nitrates have existed for many years, Gll- h~n'-no t e s~ a t an awareness of the pr"fdb e-l~ s j~t dev~iop[ng. Part of'- the reason far this aw~'~ees lies in such regions as southern Onta- rio: !'In our experience, all the sandy aquifers that we've lo6ked at in agricultural areas are contami- nated by nitrates to some extent, and quite frequently to levels In excess of the drinking water level," Gilham says. No such records have been kept in Canada but Gllbam comments that in other countries, "the degree of contamination seems to parallel the increase in the use of nitrogen fertilizers. There seems to be very littlE question that nitrogen ferti- lizers are the main contributors to nitrate contamination." Gilham adds, "Concern is cer- ;tainly being expressed, but there is very little action at this point to 'reduce and prevent nitrate con- tamination," For instance, there are no limitations on nitrogen fertilizer applications, Gilham notes; how- ever, he does not necessarily sug- gest that there should be. "If we limit the application of nitrogen fertilizers, then we limit the ability of agriculture to compete and to survive," he says, "so I think there are competing Issues... that have to be considered." The development of slow-release nitrogen fertilizers could be a par- rial solution, whereby nitrogen could be released to the soil at the appropriate time. "That could help the problem substantially," he com- ments. "But at the moment, it's fairly common practice to apply nitrogen in excess, knowing a cer- tal n amount is going to be leached." Gilham also suggests that the de- "We do have some areas within our district that show more than l O pp m " velopment of domestic nitrate re- moval systems mayalso be an effec- tive option. While noting that much work needs to be done with pesticides in Canada, Gilham says that his main concern lies with nitrates, "Nitrate levels in aquifers in Canada. the United States and Europe are in- chief engineer of the Martcopa Department of Health Services, most of the nitrate problems In Maricopa County, Arizona. appear to have agricultural origlr!s. "No one has done any studies to dearly set agriculture as the cause, but we certainly suspect that it is," says O'Connell, "and the high nitrate · water seems to follow the agricul- tural areas, or those areas that have been under cultivation in the past and are now probably subdivisions." In an Aprll article In the Phoenix Gazette, two wells near the town of Surprise with high nitrate levels and apotentlally cancer-caus- ing pesLiclde were reported and county health officials ordered that the wells be either shut down or cleaned up, Nitrate levels of 22 mg/L were found in one well and while streaslng that there was no Imme- diate danger at the time, O'Connell cautioned against making baby formulawith the high-nitrate water. At this writing, no legal action had been taken, pending the toum look- lng Into possible solutions to the water quality problem. O'Connell comments that most wells in the county with excessive nitrates are les§ severe -- in the range of 10 to 20 mg/L. The lmme- diacy of the health department's action is indicative of the county's approach to such prohlems. '~Ve don't really rank them -- we treat any MCL (maximum contaminant creasing," he says, noting that ! level'violatlonas ' /I ~ a violation m~d we munlclp~productlo_nwells, inEur- ii- ursue .... ~ ' -- - ~ p leach one~ to get some mrm o, pe have shown steady lnerea~':~t[7 ofcorre "' , ---~'tl etlon, ne says, ,4~(,since the .e..arl_l_l_l_~ 50s and alan,y._9~ D~ t,.h--~'~"~'~' will soon be over th.~.e/~ I While mentioning there are .current drinking water limits. · manyareas of the countywlth cases Along those same lines, Gilham also expresses concern that "very little has been done, to my knowl- edge, on long-term health effects of relatively low concentrations of nitrate, "It seems to' me that until the studles show that there are no long-term effects, then nitrate has the potential to be an extremely serious problem because it is so widespread in so many of the shal- low aquifers." Jerry O'Connell, Arizona According to Jen'y O'Conne~l, of high nitrates, O'Connell says that when possible, those wells (mostly drinking water) will be taken off line if the water system can still operate on the remaining wells. Other options Include hlend- lng with other water, or providing bottled waten Nitrate problems also exist in private wells, but O'Connell notes that it is uncommon for people to bring in water samples for testing. He says that most people using private wells assume that the water is good, The nlirate problem Itself has n__ot n e c~,,~y increased but urb~ AUGUST '88/WWJ 39 ~d suburban ..d. evelopment Paul Mann. Nebraska [~ O,Connellsays. Water system wells ¥ Nebraska is divided into 24 bein d~ "are picking up thee natural resource districts (NRD), 'nitridtes that have been put on the_ which were established in 1969 to 'land tot ih--~Tast 50 year~,," he says. Don ~, public health engi- neer, Maricopa Department of Health Services, notes that wells in certain areas of the county that had been showing 7.9 to 8.5 ppm nitrate levels have risen markedly within the last 18 months. "Our water table has been rising for the last six' or seven years, so what may be happening is that the water is going up and the contamination is work- ing its way down," he says, "and they're finally meeting each other." As far as O'Connell is aware, the last reported infant deaths attrib- uted to methemoglobinemia oc- currad more than 20 years ago. And Conroy comments that "It was never substantiated that the prob- lem (occurred) bemuse of the wells," He explains that studies showed that.for infant methemoglobinemia to occur, high levels of nitrates along with high levels of bacteria would have to be present in the water, which was not the ease. So, the cause of the illnesses "was never proved one way or the other," says Conrsy. O'Connell says that a "whole raft" of ground water protection regulations ara now.in force, both at the state and county levels, in- eluding ground water protection permits and permits for septic tanks larger than 2000 gallons. '%Ve have limits on the amounts of ef- fluent that can be disposed of on.~ land -- specifically for nitrate con-f/~ rumination -- directed at all type~ of waste water," he explains. "How- ever; the agricultural field is wide open here--there are no restrictions at all on agriculture; and to me, that's the biggdst problem." As for thee possibility ofregulatklns on fer- tilizers in the future. O'Connell says that the state will probably not act on its own but ratherwill follow any lead set by the federal government. In any case, O'Connell points out that "there are very few water systems operating with high ni- trates, because we consider it ~ potenti.all, y hazardous contaminanl4 add we 11 move Very quickly to fgrce_c~ ~ompliance.' A0 AUGUSI '8$/WWJ address the land and water re- source needs of individual areas within the state; monitoring and protecting ground water is a major purpose of each of those districts. From numerous spot checks, ground water in some areas of the Upper Elkhorn NRD were found t9 possibly have high levels of nitrates. In response to that, the NRD, in cooperation with the University of Nebraska, monitored 308 wells in Holt County in 1976, with 20 per- cent of the wells showing more than 10 mg/L of nitrate-nitrogen con- centrations. The monitoring pro- gram continued in the years follow- ing to a lesser degree, but since "Nitrogen and irrigation management programs have to be set up." 1984-5, has increased significantly, according to Paul Mann, general manager, Upper Elkhom NRD, '~vVe do have some areas within our district that show more than 10 ppm, generally between 15 to 25 ppm,' Mann says, "and you'll find isolated spots that could run over 30 ppm." The areas are basically non-point source and though the district does sample domestic wells, the program concentrates primar- ily on the deep water of irrigation wells for its data base, W~nen you talk point source, you get into an- other ball game," says Mann, ex- plaining that such wells may be of faulty construction or drilled inad- vertently near an abandoned feed- lot or leaking septic ~.~nk. "Ne check that t~ let people know they do have a problem.., and tell them what they might need to do to clean the, water up, but for our own data, we're more concerned with the~ea_ as a whole." In the face of high levels of nitrates and other contaminants, the county has taken steps to deal with the sl}uation. In one project nearing completion, 55 wells were tested for nitrates, herbicides, and pesticides -- "the whole gamut in tire water quality arena," says Mann. "It's a more detailed study than we've had before." In addition, nitrogen and irriga- tion management programs have been set up whereby specific plots are monitored throughout the grow- lng season to determine optimal levels of fertilizer. Fertilizer appli- cations are varied; for example, 50 pounds less than what is recom- mended (or what deep soil tests indicate) will be applied to a plot (2 to 3 acres). Some plots receive 50 pounds more than recommend ed. '~Vhat we're trying to do with this is to show the irrigator exactly what's happening with his fertil- izer, and show him that maybe he doesn't need to put on as much as he thought." Mann says that during last year's program, plots that were over- fertilized yielded only a couple bushels more than the other plots. In one ease, "it just so happened that a plot with the lesser amount of fertilizer gave us the best yield." he notes. "Basically, it came down to no difference in the yield where 50 pounds more or less fertilizer was put on." The NRD prefers that farmers apply the fertilizer through ilTiga ti0n systems for the most efficiency. as opposed to anhydrous methods. "That way, they can put on maybe 10 or 20 pounds (fertilizer] three or four times during the season and it's not lost when they put it on; the crop uses it." Mann explains that with anhydrous applications farm- ers tend to apply too much fertil- izer, and a heavy rain will cause it to leach down through the soil. Because many areas are sandy and/or gravely, irrigation is a m us t: but the soils are conducive to leach- ing as excessive fertilizers are ap- plied. Under a Ground Water Qual- ity Management Plan, certain areas are assessed according to the sev- erity of the nitrate problem. In a Phase I area, for instance, where nitrate levels average between 0 and 12,5 Ppm, fall and winter appli- cation of nitrogen is banned in sandy soils. Mann says that mandatory measures are generallya last resort, but "if we do see we have a real big problem, we can go in and institute rules and regulations," he says, "but we'd prefer they (farmers) do it voluntarily." The situation has improved since five years ago, Mann com- ments, "I think there's been enough pressure and enough emphasis on water quality that farmers want to do what they can to help protect the ground water," he says In 1986, the Nebraska Chemigation Act was passed, requiring check valves to be incorporated into any water sys- tem used for irrigation purposes. "It~took a long time to (contaml- ·nate the gro_u_ud_-water) e_nd It's~ gp~g to t~__~.just as lon_.g or lonlger to._._elean it up because there is so much that leaches down everyyear, ut we re gaining on it all the time, ~n says..--rdjust be tickled if We could get It stabilized at the present time," Well 'drilling contractors have also contributed to the solution. Recent legislation has improved well construction specifications, and drillers are more conscious of sealing off the upper (sometimes contaminated) aquifer from the lower one. "They've been real coop- erative in doing that and working with us," Mann says. As more nitrates are found, the more the general public becomes involved.Though nitrates are not a problem in each county of the dis- trier, "a lot of concern" has been expressed by residents; subse- quently, water quality has become the "nu.~m__ber one priority in our district,' says Marffi', Dr. Roy Spalding, University Of l~ebraska Dr. Roy Spalding, principal hy- ~rochemist of the conservation sur- vey division at the University of Nebraska, explains that mostofthe problems with agricultural leach- ares occur in the irrigated coarse- textured soils of western Nebraska. In a recent paper, Spalding says that much ground water contami- nation of agronomic sources of nj- trate "has occurred in cropped areas underlain by well- to exces- sively well-drained soils with short distarmes (5 to 30 fcetl to ground water." (Spalding, Kitchen; Ground Water Monitoring Review 19881. In Nebraska, problem areas also exist in the eastern part of the state where there are many old farm- steads. Outdated and fanlty well constructionl along with tlnprol2e_r.r siting for wells, are the main causes of nitrate contaminat?n. Recent studies are showing that flnelygrained soils are not enough to avoid nitrate leaching when exces- sive nitrogen fertilization is applied "It took a long time to contami- nate the ground water and it's going to take just as long to clean it up." in lmgated areas. Spalding and Kitchen concluded' that "...even in the heavy soils of southeastern Nebraska significant loss of fertil- izer via leaching may be the rule and not the exception," Recent sarnplings/prq}ects in the areas of Beatrice (south of Lin- coin), and Sidney, Nebraska, show at least two municipal wells exceed- ing the 10 ppm MCL standard. Though levels are only 2 or 3 ppm over the standard, there is still rea- son for concern. As Dr, Spalding says, "This is tlapical of non-point ~ concentration; It goes up very gra.~k ually in small 'increments,; an4'it_.L.t~ k._eeps going up each year.' In Sid~ fiey, in the western part oi the state, the major source has been found to be non-point contamination from the leachate of manure applica- tions, and in Beatrice, indications point to fertilizer leachates, says Spalding. Sidney is currently looking into the possibility of ground water management programs and Bea- trim is already under a program administered through tile Depart- went of F-nvimnmental Control. In the Ceatral Platte r/~gion, which eXtends for 160 miles along the north side of the Platte River, the nitrate problem has also wors- ened. In 1974, a study of Water quality in 511 wells indicated the presence of large areas Where nit~te-nltrogen levels eXceeded the 10 mg/L MCL (Exner and Spalding 1976). The high-nitrate zones are characterized by well -- to exces- sively well-drained soils and a thin (less than 30 feet) intermediate vadose zone, A decade later, 78 per- cent of the same wells were re- sampled for nitrate (Exner 1985), In general, "dramatic increases" in the spatial distribution of nitrate in the non-point contaminated areas was evident. Spalding says that there was an increase in average concentration and there was an increase i~. the random frequency of occurrence. In fact, where there were two separate zones with an average concentra- tion of approximately 16 mg/L in 1974, the 1984 study showed one continuous zone with an average of 22 mg/L of nitrate-nitrogen cop. cen- tration, "Farmers are very concerned about this; they have to live out there," comments Spalding, "They don't particnlarly want to drink broadleaf herbicides and nitrates either." The possibility of more ground water management areas -- imple- mented bystate or local agencies -- is "highly probable," says Spalding. "All indications are that we have a definite increase in contamination throughout the whole agricultural region," he says, The future for ground water looks promising, however. Because of the short distance to ground water and the coarse-textured, un- saturated zone, any accumuJations in that zone shonld be leached rela- tively rapidly, says Spalding. With the Central Platte region, "we think it could possibly be stabilized fairly rapidly." Some Solutions With increasing concern over' nitrates, pesticides, and the quality AUGUST '88/WWJ 4~1 0fgroundwater, legislation address- lng these issues is on the upswing. To not only protect ground water but to reverse the effects of decades of fertilization and mismanage- ment, at least some regulation seems probable. For example, a bill (S. 2091) introduced by Sen. David Duren- berger, (R:Minn.), would establish ~ national non-degradation policy and prohibit EPA from implement- ing its classification system for ground water. Under S, 2091, states would be required to establish EPA- approved water well drilling pro- grams {including the licensing of well drillers, completion ofwelllogs, etc.) in order to receive certain grant money, EPA's Marian Mlay, director of the Office of Grour/d Water Pro- tection explains that the bill would also require numerous federal reg- ulatory activities affecting the use of pesticides and fertilizers on the land. If successful, Sen. Durenberger's efforts would also "substantially shi~ft ground water resp onsibility to ~ment," Mlay says. 1 Though there is some impression_ ~ that the trend is actually towar_d~ action by the individual state, Mla-f ,t s~ys Just the opposite is actually the case. '~1'he rhetoric is, 'Let the states do it.' The reality is that the shift is in the other direction." Mlay says that the Durenberger statute would create federal quality standards for ground water, essen- tially mandating how clean all ground water should be .and virtu- ally all sources of contamination would have to meet it or use best technologies. The use of fertilizers would, therefore fall under this approach. "From what I can see, this bill would have the federal government taking a strong stsn- dard-setting and oversight role, with states,' as usual, responsible for implementing the program," she Another bill (S. 20), also in the Senate, seeks to establish a drink- ing water standard for ground water protection. "It would require the federal government to develop criteria, as it does under the Clean Water Act, for various contami- nants,' says Mlay, "and then re- quire the states to adopt a ground 42 AUGUST '88/WWJ water standard which is at least as drinking water standard -- stringent as the drinking water which is whai we use in ground standard." In another effort, the EPA is launching a two-year nationwide survey to test for pesticide residues, as well as nitrates and nitrites, in private and community wells. The samples are intended to provide statistical representation of the more than 13 million private and 51,000 community drinking Water wells in the United States. Mlay adds that, unlike some generic studies that are under- "Durenberger's efforts would stantially shift ground water responSibility to the federal government." taken, this survey focuses on spe- cific contaminants and particular sources. "Generic studies aren't necessarily going to give you useful information," she explains, '~'ou might refine what you know about something, but that information isn't going to radically change what ' you re doing already." Occasionally information is collected with little purpose other than collecting data. Mlay says that some people take the approach that "'If we just filled this big black box full of data then we would know everything. · .' That's just not true." She adds that it is, of course, always alarming to realize how many wells are contaminated, but says that many of these wells are contaminatedin ways that are fairly predictable, such as the case with dug wells, l~mproperlygrouted weOs, or wells drilled near feedlots or s_.[.~ep- tic tanks. "~'-'i'-~'survcy goes after specific information from the beginning: "At the end of the survey we will know two things: number one, we will know which pesticides to write water protection, as well a~ the tap; and number two, we will also know which pesticides to go after in our registration programs. '~Ve will have very specific infor- mation that is really geared toward a decision." One aspect of the survey will hopefully explain whether a corre- lation exists between pesticide and nitrate contamination. "If there is a real high correlation, you could find fertilizer contamination a lot easier than you can sample for a lot of esoteric pesticides -- it's also cheaper," she says, 'We're looking for a 'cheap screen' for pesticides contamination," Mlay comments that the federal government has done a lot of work in the area of pesticides, Currently, a proposed pesticide strategy deal- ing with agricultural chemicals in ground water is out for public re- view, and will include individual states in much of the decision- making precess. Awareness of pesticides and herbicides has increased slgnifl- cantly in recent years and progress is good qonsidering that much of the problem was discovered only a decade ago, Mlay says, adding, '~Ve think we're getting a handle on it, although there's still more to do." Although there are currently no federal regulatory requirements on fertilizers, Mlay says that picture is changing for the better." Certainly The Fertilizer Institute is figuring out that there really is a problem and it's becoming sensitive to iL" She adds that farmers share in that sensitivity and are becoming in- creasingly involved. Wv"nether there would be addi- tional steps in that area needed to reduce nitrogen loadings, that's cer- tainly up for debate," she says. Despite the overwhelming na; ture of the problem, Mlay remains optimistic, Citing awareness as a key factor at all levels, Mlay says, "[ think there's a lot more action at the local level on things like nitrates because they're the devil to get out of drinking water sources, And public water suppliers get pretty ornery about having it in there to deal with -- as well theyshould.' · Nitrates in drinking water &R. Self and' R~M. Waskom Quick Facts Nitrate is a colorless, odorless, and tasteless compound that is present in some groundwater in Colorado. Nitrate can be expressed as either NO3 (nitrate) or NO3-N (nitrate-nitrogen). Nitrate levels above the EPA Maximum Contaminant Level of 10mg/1 NO3- N or 45 mg/l NO3 may cause methemoglobinemia in infants. Proper management of fertilizers, manures, and other nitrogen sources can minimize contanfination of drinking water supplies. Introduction Nitrate (NO3) is a naturally occurring form of nitrogen found in soil. Nitrogen is essential to all life, and most crop plant~ require large quantities to sustain high yields. The formation of nitrates is an integr~l part of the nitrogen cycle in our environment. In moderate amounts, nitrate is a harmless constituent of food and water. Plants use nitrates from the soil to satisfy nutrient requirements and may accumulate nitrate in their leaves and stems. Due to its high solubility, nitrate also can leach into groundwater. If humans or animals ingest water high in nitrate, it may cause methemoglobinemia, an illness especially found in infants. Nitrates form when fertilizers, decaying plants, manures, or other organic residues are broken down by micro-organisms. Usually plants take these nitrates up, but sometimes rain or irrigation water can leach them into groundwater. Although nitrate occurs naturally in some groundwater, higher levels are thought to be the result of human activities in most cases. Common Sources of Nitrate Fertilizers and manure Animal feedlots Municipal wastewater and sludge Septic systems N-fixation from atmosphere by legumes, bacteria and lightning Health Effect of Nitrates Humans Ni ra'te in Drinking Water WHAT IS NITRATE? Nitrate is a chemical containing one atom of nitrogen and three atoms of oxygen. Nitrate is found in many foods, such as some meats but especially vegetables, as well as in drinking water. It is expressed as rog/1 (milligrams per liter) or ppm (parts per million). Nitrate is often used as an overall indicator of water quality because when elevated levels of nitrate are found, it indicates that the groundwater is "vulnerable" to contamination. Other pollutants, which may be more difficult and expensive to test for, may be present. HOW CAN NITRATE GET INTO DRINKING WATER? Nitrate can be found naturally in drinking water but when it occurs at higher concentrations it usually means that some kind of human activity is the cause. Nitrate in water is most often linked to septic systems, animal waste such as manure, and, fertilizers. Nitrate from these sources can be carried by rainwater into the soil and eventually into the gronnd water if care is not taken. This can be a particular problem in areas with sandy or gravelly soils or when wells are poorly designed or constructed, allowing surface water to "leak" into groundwater supplies. WHAT DOES THE NITRATE TEST NUMBER MEAN? Natural levels of nitrate are generally less than 3 ppm. If your water sample is over 3 ppm, it means some kind of human activity, such as septic systems or manure storage or spreading, may be impacting your well's water quality. If nitrate in your water is greater than 10 ppm, it exceeds what the State Department of Health considers to be "safe" levels. Tiffs safe level is referred to as a maximum contaminant level 0ViCL). Ifa sensitive individual consumes water with a nitrate level greater than 10 ppm, they may experience health problems. In addition, be sure to remember nitrate's special role as an indicator of water quality; when elevated nitrates are found, it is possible that other kinds of contaminants may also be present. WHAT ARE THE HEALTH CONCERNS? The nitrate standard is an acute standard. This means that there may be health effects occurring within a very short time if an individual consumes water with a nitrate level greater than the MCL. For nitrates, the sensitive populations are infants, individuals with reduced gastric acidity, individuals with a hereditary lack of methemoglobin reductase, and women who are pregnant. The primary acute illness caused by high nitrates is a blood disorder called methemoglobinemia, or "blue baby disease". Although methemoglobinemia can affect any age, nitrate contaminated water principally causes this illness in children under six months. SYMPTOMS OF METHEMOGLOBINEMIA An infant with mild to moderate methemoglobinemia may show little distress, other than diarrhea and vomiting. Most often the disease is only recognized in acute cyanotic stages, when the infant turus a brownish-blue color (can be missed in dark skinned infants) and has trouble breathing. TREATMENT If the condition is not life-threatening, no treatment is needed other than a switch to uncontaminated water. The symptoms will improve within two to three days. For severely affected infants, intravenous treatment with methylene blue wilt convert the methemoglobin back to hemoglobin and bring rapid recovery. ~4MM CONTRACT]Nfl PHONE NO. : 6881238 Now, 12 1997 05~12PM P3 Spodtlc Commonts August 5, 1997 1, (,pg, 2) Figtwe 1 sho'uld be ch~arly label~ with ali s~bdivisio~, ~ ~ age of ~e e~ing ~e~ier dx~p~ sy~ma, 2) '~ ~il . ~e~x ~&v J. M~, it may ba~e ~ he p~ to l~nfi~ and 1 ~t ~eM~ wells ~M Ia ~iat~t ~th ~ ~ ~Y. it may ~ / MMM CONTRACTING Mt. Dec High, P,E. 4, (Pg. 3) PHONE NO, : 6881238 Nov, 12 1997 ~5:12PM P4 lo~k for ~imilar .ells to thc sou~ spch ~ Chugnc,b l~k EsWe~, for ~u~c~". ~b ~mcnt ~d ~ ~poded by th~ ~t~ an~ysis. ~c "significant' should b¢ d~fined. Acco~d[n~ to thi~ relmrt, "ExJstk,~ information ind~ca be~lrock aquila' may need to be up m 700 fe~t deep ir quantities for domestic u~". :es that wells rapping ~ ruder to yield suffici*nt and r ~mablc ' 6. (Pg, 6) While thc ~oaclu~ions portrayal in this report may be v~lid, thc information ~p.!~_'dod. within ~ r;'?on md tho Analysis of Nilrat~s in t?~..Well Wm*r r~pOrt "~imer~t ~q'xlr~mi~ m-'-~lv,*d ~--8-th~ff6n o-~fftl~ ama groundwawr suppll~, tag(k- G4L/F- "~ C~Ser~tl~- ~myd~crminatonth~ismadcrcgardingtheDcn~[iViewSubdlvislonWill ' 7 '~ ~u for st ppl¢~ ~ese rMom m the DEC for o~ ~vi~. If you hve ~ qtmffio~ ~ Denali View Notes; Art P,.onimus, October 27, 1997 I have read through all the reports and spoken to all the "stake holders". Denali View is a proposed Sub-Division (SD), 11 residential lots (1.2 to 7.63 acres) on about 35 acres. The concerns are; potential impact of the septic taak effluent on groundwater Nitrate levels from the new Denali View homes and from existing and new homes in the adjacent SD's. (Several hundred acres around the proposed 35 acres) whether there is adequate water for the l 1 new homes without materially affecting the availability of water for the existing homes. Also a concern about new homes in the adjacent SDs. ]:s the process that MOA uses to approve SD's favor the developer at the expense of Public Health protection, property values, etc? ADEC's role is unknown. The level of debate has reached elevated heights of emotions, rhetorical claims, im~uendo, perception, loud and vehement expressions of concern over potential future WQ impacts, questions asking about the integrity of individuals involved in the process, plus others not printable in the record. The MOA SD approval process is quite thorough. The planning and review of the potential SD covers many areas. Decisions about potential impacts of future water and sewer service on the groundwater are made based on the best judgement of the planners, engineers, and hydrologists. All available data on Nitrate levels for the existing homes has been plotted. (We have the map). After reviewing the data, in my opinion there is not wide spread Nitrate ground water contamination. Individual homes have some high values, but there is not a pattern of widespread high Nitrate values. Some of the data is old and some recent. Many of these homes have been there a long time too. These new homes for Denali SD may be required to install Low Nitrate treatment systems which cost about another $3,000 in addition to the usual on-site cost. In addition there are about 44 existing undeveloped lots in the adjacent SD which might be required to install these more expensive systems, and there is the possibility that all future sales of existing homes will have to upgrade there existing septic system to a Nitrate reducing treatment system to receive a MOA Health Certificate. The implications are substantial if there is to be an area wide initiative to control Nitrate levels. Does the MOA hold the developer to a higher treatment standard as compared to existing and other proposed homes? Dra_~_~C~qo~ents in Response to ADNR, ADNR memu to Gary Prokosch, July 30, 1997 Responses to comments: The sand and gravel well was test pumped because Dill-IS was more concerned with well impacts from that area of the subdivision. We tried to drill and test pump the area that was most likely to cause problems. It was unexpected to encounter a sand and gravel aquifer at that location. It is of limited areal extent, and is not present where other wells tap bedrock. The bedrock well is located more than 500 feet from wells in Scimitar that people are concerned about. We would not expect to see any response in an aquifer test of a few days duration. See subsequent comments on the feasibility of aquifer testing.~¢k--~,~ A_DEC letter to DHI Consulting Engineers, Angust 5, 199~--~~- Responses to general comments: None Responses to specific comments: Analysis of Nitrates in Well Water 1. No comment. 2. No conunent 3. The conclusion that the data do not demonstrate the presence of a clear increasing or decreasing nitrate trend does not suggest~that the data are insufficient to draw sound conclusions. Wi~khth the data collect~ed to d_al~/~ if' a strong area-wide trend was present, the data should show it. The absence of an clear trend is a sound conclusion. Any trend that ~s presen~_--~ therefore must be weak or variable from place to place or both. ~ 4. A pattern has been identified. Thee pattern is that nitrate trends are weak or spatially, v__a!'i.'able or both. The conclusion of the work is that this pattern should be expected to continue with the proposed subdivision. Comments 3 and 4 seem to imply that the there is a strong trend of increasing nitrates throughout the neighborhood, we just haven't found it with om' limited data. In contrast, the data show that we have been looking, but that it does not seem to be'-"-~"-----' there as surmised, f----- Aquifer Test Results and Hydrogeologic Review. No Comment. The aquifer test results can be used to project long term aquifer yield, at least in a general sense. The test data allow calculation of a specific yield for the pumped well of 4.1 gallons per minute/foot of drawdown. The pumped well has approximately 28 feet of available drawdown from static conditions. A simple calculation using these values not consider/rig DRA / ,quifer botmdaries would provide a possible well yield of 115 gpm. A similar calculation using the Theis method yields an estimated dmwdown of 25 ft after pumping for 100 days at a rate of 50 gpm assunfing an effective well radius of 1 foot and an aquifer storativity of 0.0001. This calculation assumes no aquifer boundaries and no recharge. These calculations are more than an order of magnitude lfigher than the sustainable rate of 3.8 gpm projected in our report. This large difference is the reason why the long-term yield estimate is reasonable to make considering the geolbgic uncertainties at the site. Terrasat reviewed the field data and our conclusions and concluded that the aquifer "is capable of sustaining a long-term pumping rate of up to several gallons per minute." This provides support that the estimate is reasonable. I would be pleased to provide copies of the data to ADEC should ADEC wish t,9 prepare,~m independent estimate of long-term aquifer productivity.. ~t~/~k~ We looked for wells as anggested and found none. ,~ It is not clear how "the nitrate analysis" supports the statement. "Significant" in this instance means that typical aquifer tests are too short term for defining the degree of hydraulic separation between the two aquifers. The determination of "unduly affected", as stated, is established by statute, regulation, and practice under the authority of DNR. Other entities may rely on other means of addressing water availability conflicts, however, I am not aware of any other regulatory framework in Alaska that addresses these complex issues. Entities that use other means to address water availabihty conflicts may contradict established DNR procedures and create greater entanglements. It is not clear why ADEC is reporting on discussions regarding the phrase "unduly affected" arid defining the basis for decision-making. Does ADEC bare regulatory procedures in this area? -.~.~, We disagree with this comment, and believe that the information presented in the two reports is sufficient to support the findings that have been presented. The proposed development has not been shown to have a significant adverse effect on area groundwater supplies. The proposed lot sizes and development plans ~urrounding lots results in reasonable protection for groundwater in the area. (~We also believe that a substantial amount of- hydrologic work has been accomplished that supports proceeding with the development and that sound, responsible, and reasonable decisions that adequately address the interests of all parties involved can be made with existing information. However, in order to address the concerns presented, we have tmdertaken additional hydrologic work to further substantiate that this subdivision merits approval. These findings are presented below. TERRASAT, INC~ Letter to Margaret O'Brien, August 1, 1997 Comment 1. (p. 1) Anecdotal data from citizens is not presented in this report and has not been made part of the public record. The £mdings of tl6s study cannot be substantiated without access to those records. 2. (p.2, paragraph 2) It is not clear how stable trends in some of the 17 of 22 wells with multiple nitrate data lead to the conclusion that nitrates are potential concern for nearly 80 percent of 2 **:~ TX REPORT *** TRANSMISSION OK TX/RX NO CONNECTION TEL SUBADDRESS CONNECTION ID ST. TDfE USAGE T PGS. RESULT 0521 919073762382 ADEC MSPS0 08/26 14:33 02'04 6 OK 0fl/21/1S97 10:47 CHU~3I AK ELF.$iENTP~R,¥ pAG~ To: Kevin Klewano From: Jennifer Carl~n Re: Telephone conversation 8/21/97; 9:40 am 8/21/97 My hu~and and I built a home on lot 3 block 1 of P~Aer's Gate ~ulc~dlvtsion during the summer o! 1993, V~nen our well was drilled during that summer it produced 14 gallons of water per minute, it was ellesian at the time. Throughout the four years that my family of four has lived here we have had plen~ of water, On Friday, 5/2.~/97 a test well was ddlled acrom the street on the proposed Denali View subdivision. On SundaY, 5/25,/97 there was rio Water c~mi~g into our home. The nexX day our pump was replaced. It's motor had burned out. The pump wa~ only four years old. It Is my u,dersl~ndlng t~at it ~hould have lasted ten years, It Is my belief ~hat the water level in my well dropped at the result of the new well, The pump was forced to work c~nstantly to keep the ~atlc level up top where it should be. Furthermere, upon returning 7/~5 from a vacation duri~l the month o! June we discovered a significant amount of silt Irt our Water. Our hot tub ha~ been cleaned out and refilled by the house sit, er and after refilling R there was a thick erlough layer of silt in the botlorn for my daughter to wr'~e her name in it. Silt is now noticeable In all water reoeptaclee o! our home. Thanl( you for your time, Jennifer S, Cartstm CoJOopt. August 6. 1997 Jim Cross MOA On-Site Director Jim: ENViROi'IMEiN'FAL HEALTH RECEIVED As you are a~xare I have been involved with the platting action on Denali View. [ am President of the Chngiak Commuuity Council, a member of the On-Site Tech Board and a P, ealtor with ReMax of Eagle Ri',er. I have a substautial personal and professional commitment to protect and preserve our grouudwatcr resources as well as the integri .fy or our wells and septics. I have logged countless volunteer hours ell bcllalf el' my Comnmnity in the pursuit of these goals. [ have read tile report on Dcnali View done by Bristol Environmental Services. hi addition l just completed readiug tile report entitled. "Evaluatiou of Nitrates in Drinking Water and Development of a Groundwater Prolection Proaram." [ raise tile l'o[]ov¢ing issues aod concerns for yonr colnnlent: 1. I il'fink it is necessary to delay tile second phase of the nitrate study until the first phase is reviewed and commented on by an independeut qualified person or finn who is currently working in tile field of nitrate research and treatment. 2. Additionally. it appears prudent to ask DNR and DEC to provide whiten evaluation ,'md comment on the report based on the information and docmnentatioa they have. It would be helpful to know if they concur with the conclusions or not and why. I believe that DEC is where the funding was located for the project. Getting their professional opinion outside of the grant administration would be helpfld. 3. Concerns have been raised aboat Mr. Munter being a member of the Tech Board and doing work for MOA. I have expressed my concern about the potential for a conflict of interest over the nitrate issues lO > oil previously. Mr. Mumer's Tech Board seat is as a member of the Hillside Communi .ty who lives with on-site well and septic. Since &Ir. Mumer did the report on South Anchorage he is placed in a positiou of appearing to defend his work on nitrates possibly to the detriment of the Hillside Coumnmity he represents. 4. Arc you concerned that tile apparent differcuces in the conclusions of the two reports compromises the ability of the public to have complete faith in the outcome of the second phase of the stud>"? Mr. Mnnter's report on Denali View was performed for a developer who hired him to prove there is not a nitrate problem in Denuli View. The goal is financial gain. The report on South Anchorage ,,vas paid for xdth tax payers hinds to provide an accurate cvuluation of elevated uitrate levels. The goal is to protect the pnblic. It appears there is a conflict between tile pnrpose and the ootcome of the t~xo reports tile public is alrcad3 couccrned about. 5. Residents invoh'ed itl tile Denali View platting action feel Mr. Muuter's couclusions regarding Deuali View Subdivision seriously compromise his ability to be impartial on the second phase of the stud~,. His conclnsions on Denali View make it difficult, if not impossible, to reach a different conclusiou iu the second phase of the study. ( other than what he coocluded ill the Denali View report ie lie nitrate problem ). While there may not be a conflict of interest in )our opinion, the pnblic perception /admittediy heightened bb' the Denali View action) is n co~fflict exists. August 8, 1997 page 3 Jim Cross Hudson's borne, ( lot 8 Block 3 Scimitar #2) is a perfect exmnple of the unnecessary high costs related to elevated nitrates. With the neighboring homeowner they have spent over $25,000.b0 moving two septics and still have nitrates at 15.9 mgl four years later. At DHHS's, direction Hudson's moved their septic. Under threat of condemnation of their septic ~'stem by DHHS rite neighbors also moved their septic system (,'filer a HAA was issued and tile sale closed). As yon know, dye from the septic system on both lots showed up in Hndson's well. Tile dye frmn Hall's system on lot 13 blk 13//2 showed ap ill lots 3 and 8 block 3 Scinfitar #1. (see MOA letter 6/2/93 from Dan Bolles attached.) I suggest that DEC. DNIL MOA as well as members of the public and engineering commualty sit down and work out a hands on scope of work for phase two of the nitrate stndy. Based on the conclusions of phase one it would semn a different approach is reasonable and a more responsible expenditure of poblic fuods. I am convinced that there is clear and couvincing evidence our Community is experiencing elevated nitrates due to on-site septic systems. It appears maay engineers as well as private cit/zens agree. I believe it is clear in order for Denali View to be developed, nitrate reducing septic systems be required by DHHS from tile beginning, not after the fact. The issue of proving potable water becomes mute ( if you believe there is enough water) if it becomes contandaated with nitrates. $25,000.00 per home for public water is a very expensive price for a Ilo nemvner to pay if DH/-IS s wrong. What will file response be fi'om DHHS when homeowners itl Denali View or Scimitar have water quality or qnantiD' proble~ns in the future? I know that you do not necessmSly concur with my comments, thoughts or op lfions. We must take a proactive approach to establish long term solutions and prevent fi~rther contmnination of onr groundwater. There are numerons methods that can be put ill place at substantially lowers costs than public ~vater and sewer. I am certain that file DeparUnent would meet xx5th less public resistance ifMOA and DEC would be proactive thstead of just reactive. Protecting the integrity of our wells and sept cs is critical to the environmental and financial health of our entire Couununity. It is the responsibility of DHHS to educate the public and bring about public awareness of methods to protect our groundwater and the integrity of our on-site systems We cannot afford to put the public at risk if DHlqS does not have all the answers ,'md cannot assure the public that they need have no fear. The pnblic xxSIl certainly expect DHHS to accept responsibiliLy when there are problems in the future with Scintitar and Denali View. I look funvard to 3'our response and d fcc on o rmv to proceed. I want to be part of the solution and work with DHHS and DEC. Sincerely. Sharon Minsch 694-4200 ext 226 cc: Interested residents. Community Conncils. DEC. MOA, Ted Carlson P, 02 TONY KNOWLE$, GOVERNOR INFECTIOUS TUB~RCtJI.G.qkq IMMUNIZATION CHRONIC DIABETES iNJURY CONTROL (907) 269-800<) FAX S62.7802- M_]~I 0 R A N D U.~51 DATE: April 10, 1997 TO: Catherine Schumachcr, M,D., M.S.P.H. FROM; Loft A, Feyk, Ph.D. UBOEC r. Health ImpUcadons of Nitrates in Drirddng Water The following is a shor~ summary' of the information obtained from the TOMES data base (thanks for being patient!) I have more detailed tr~ol'mauo , including refereuces, if you need iT. Just let me know! Toxicity Nitrate toxicit7 is &m primarily to its conversion to nitrite, which oxidizes the Fe(+2) form of iron in hemoglobin to the Fe(+3) state. This compound (merhemoglobin) does not bind oxygen, resulting ia reduced oxygen transpor~ from lungs to tissues. Low levels of me(hemoglobin occur in normal inttividuals. Concemradons above 10% me(hemoglobin (of total hemoglobin) may cause a bluish color to skin and lips (cyanosis), while values above 25% lead to weakness, rapid pulse and tachypnea: Death may occur if me(hemoglobin values exceed 50-60%. The most sen,itive human health endpoint of concern for nitrates is methemoglobinemia In infants. Couversion of nitrate to nitrite is mostly mediated by bacteria in the gastrointestinal system. Consequently, the risk of methemoglobinemia from ingestion of nitrate depends not only on the dose of nitrate, but also on the number and type of enteric bacteria. Conversion of nitrate to nitrite may occur in the stomach if the pH of th~ gastric fluid is sufficiently high (above pH 5) to permit bacterial growth. This is of concern in adults with diseases such as acblorhydria or atrophic gas(rids, It is also of concern in infants, since the infant gastrointestinal system normally has a high pH that favors the 2[rowth of nitrate<educing bacteria. Risk is especially high in infants who are exposed, to water that is cont~uninated with bacteria, sluce this tends to promote high concentrations of bacteria In the stomach and intestines. hPR-14-98 TUE 10:~6 P, 03 Catherine Schumacher, M.D., M.S.P.H. April 10, 1997 Page 2 Niu'ate is a normal component of the human diet. Over 85% of nitrate intake in a typical adult comes from the natural nitrate cement of vegetables. The comribution from drinking water is usually quite small (about 2 -3 % of total), unless the water supply is contaminated. Some adults consuming high levels of vegetables along with wamr containing high levels of nitrate could receive total doses of tfitrate approaching the recommended maxhnal daily intake. The Reference Dose for drinking water is 10 mg nitrate-nitrogen/L, This level should not be exceeded in drinking water. Tim mlmber expresses the amount of nitrogen within the nitrate molecule, wblch is what is typically measured. There is a h/gh degree of confidence in this number, whkh provides protection for the most sensitive human health endpoim. Calculations were made considering the ingestion of dri ~nking water used to prepare k~fants' formula. Methemoglobinernia has been observed in infants when this level has been exceeded. Cases reported at levels of 11- 20 mg/L nitrate-niu'ogen were usually associated with concomlm~n~ exposure to bacteriologically contaminated water or to excess nkrate h'om other sources. Repeated studies provide convincing evidence ~at infantile methemoglobinemla does not occur at drhnking wa[er levels of 10 mg nitrate-nitrogen or less. Marker of Fecal Contamination? My impression from the available information was that nitrate is not necessarily a marker of fecal contamination. I think that high levels of fecal coliform bacteria (E. cell) are a better marker for that. However, fecal contamination in drL~Adng wa~er would defi~fitel¥ h~crea~e the hazard associated with concornimntly high nitrate levels in driniSng water. Carcinogenic Potential Some ehernicaB in the class called "nitrosamines" are known mmumalian car¢inoget~s. A potential pathway for the i~rmation of such chemicals is the nitrosation Of secondary amines that are naturally preseut in the diet. The source of the nirroso group is nkrite, mos~ of' which is produced m'Aogenously in humans from ~trate. However, while endogenous exposure to such nitroso eompounds appears to be fairly ubiquitous, thek relevance m the development of human neoplasia is questionable. To my knowledge, recommended intake levels of nitrate have not been based on this endpoint, and the information ~uxmu=ding it is much less certain than that for l~fant methemoglobinemia. Just wanted to make you aware of the subject. Let me know if you need more info! Nitrate - Il-LIS - Integrated Risk Infonnation ... Page 1 of 9 iNitrate IPdS - Integrated Ytdsk Information System Inn'oc~ucti~>_ IRIS' Acroqvms' am~?bbrev~ar~ons Glos&a~d_~?f Rf.~k ~~aed Tet'ms Bac~'outtd~O.¢~w~ent lA -- R~fetX~ Dose [~r~pt~n and U6'e iz~.[~k A,y,essma~l.~ Bac~g~fl Document Z=3~P,(~oach.tbr Asse%~.the Rix~ Associated with Chronic Document Outline 0076 Nih'ate; CASRN )dU. 9_7-A~ (10/01/97) Health assessment infmmation on a cMmical substance is included in IRIS only after a comprehensive review of chronic toxicity data by U.S. EPA health scientists fi'om several Program Offices and the Office of Research and Development. The sunm, aries presented in Sections I and II represent a consensus reached in the review process. Background h~formation and explanations of the methods used to derive the values given in IRIS are provided in the Background Doemnents. STATUS OF DATA FOR Nitrate File On-Line 01/31/87 CategOry (section) SCa~8 O~al RfD Assaa~mant: (I.A,) oil-line Inha3. ation RfC A~sessment (I,B,) I10 data Carcinogenioity As~essnlent (II,) no data Las~ Revised ~0/0~/~ 1. Cttt~ONIC HEALTH.ttAZ~.ARD ~~NTS FORI~D,NCAR.C.I~OGENIC E~FECTS ~ I,A. REFERENCE DOSE FOR CHRONIC ORAL EXPOSURE (RID) Substance Name -- Nitrate CASRN -- ]21707-55-8 Last Revised -- 10/01/91 The oral Reference Dose (RfD) is b~sed on the assumption that tkresholds exist for certah~ toxic Tuesday, April 14, 1998 11:41 AM Nitrate - IRiS - Integrated Risk hut'ormation .. Page 2 of 9 effects such as cellular neerods. It is expressed in units ore,kg-day. In general, the RfD is an est[maTe (with uncertainty spanning peflmps an order of magnitude) cfa daily exposure to the human population (im'.ludiug sensitive subgroups) that is likely to be Mthout an appreciable risk of deleterious effects during a lifetime. Please refer to the Background Document for an elaboration of these concepts. RIDs can also he derived for the noncareinoge~fie health effects of substm~ces that are also carcinogens. Therefore, it is essential to refer to other scm'cas of inibrmation concerning the carelnoge~ticity of this substance. If the U.S. EPA has evaluated this substance for potential hmnmx carcinogenicity, a sununary of that evaluation will be contained hx Section II of this file. I.A.1. ORAL RID SUMMARY Early clinical signs Of methe~o~lobinemia in exceSS of 10~ (0-3 monehs old infants formula) Human Epidemiolo~ical Surveys Bosch et al.. 1950; Walton, 1951 Experimental Do,em* NOAEL: 10 mg nitrate- 1 1 nitrogen/L (1.6 mg/kg/ mg/kg/day day) LOAEL: 11-20 nlq ni¢rate- nitro~en/L (1.8-3.2 mg/kg/day) *Conversion Factor: Expressed as the amount of nitrogen witlxin the rdtrite molecule commonly shox~qa as mg nitrate-nitroge~ffL (1 mg nitrate.nitrogen ~ 4.4 mg nitrate). Doses based on ingestion of ~inking water used to prepare infants' formula: 0.64 L/day by a 4 kg i~fant (0.16 L/kg/day) (Davidson et al., 1975). 10 mg/L x 0.64 L/day divided by 4 kg = 1.6 rog/kg/day. I.A.2. PRINCIPAL AND SUPPORTING STUDIES (ORAL Rtl)) Bosch~ H.M., A.B. Rosefield, R. Huston, H.R, Shipman and F.L. Woodwmd. 1950. Methemoglobinemla and Mirmesota well supplies. J. Am. Water Works Assoc. 42'. 161-170. Walton, G. 1951, Survey of literature relating to infant methemoglobinemia due to n~trate-contaminated water. Am. J. Pt, blic Health. 41: 986-996. Most cases of infant methemoglebinemia are associated with exposure to nitrate in dri~ffAng water used to prepare infants' formula at levels >20 mg/'L of nitrate-ni~ogcn (Bosch et al., 1950; Walton, 1951; Sattelmaeher, 1962; Simon et al., 1964; ECETOC, 1988). Cases reported at levels of 11~20 mg/L nitrate- nitrogen are usually associated with concomitant exposure to bacteriologically contaminated water or excess intake of ~fitrate from other sources. Bosch et ,'d. (1950) evaluated 139 cases of eyano~is due to methemoglohlnemia reported by physicians in Minnesota. All of'[he cases were in young chi(ken (ages 8 days to 5 months), with 90% occurring in iathnts <2 maud, s of age. A study of the nitrate concentration of the wells (a total of 129) used to supply water to the children with methemoglobinemia was performed, None of the wells contained <10 mg/L nitrate-nitrogen. Two wells (I .5%) contained 10-. 20 mg/L, although the diagnosis of mcthemoglobinemia was considered questionable in both these cases. There were 25 wells (19%) that contained 21-50 rog/L, 53 (41%) that contained 51-100 rog/L, and 49 (38%) that contained >100 ~ng/L ni~ate-nitmgen. Nearly all the wells were shallow with inadequate protection from surface contamination. Coliform organisms were detected in 45 of 51 smnples (88%) tested for bacterial contamination. Tuesday, April 14, 1998 11:41 AM Nitrate - IRIS - Integrated Risk hd'onnation ... Page 3 of 9 Walton (1951) described a sm-vey pcrfm~ned by the American Public Health Association to identify clinical cases of'irufantile methemoglobinemia that were associated with ingestion of nitrate-eontmninated water, A total Of 278 cases of mahenmglobinemia were reported. Of 214 cases for which data were available on tfitrate levels in water, none occurred in hff'ants consuming water conlaining <I 0 mg nitrateqSn'ogen/L (1.6 mg nitrate-nitrogen/kg/day), There were 5 cases (2%) in infants exposed to 11-20 mg nitratemitrogerffL (1~8~3.2 rog/kg/day), 36 eases (17%) in infants exposed to 21-50 mg/L (3.4-8.0 rog/kg/day), and 173 (81%) in infants exposed to >50 mgf£ (>8 mg/kg/day). Data on the ages of the infants were not provided. Cornblath and Hartrnann (1948) supplied nitrat,-containing water to eight healthy infants (ages 2 days to 11 mo~ths) at doses of 50 or 100 mg NO3/kg/day (11 or 23 mg nitrate-niu'ogerdkg/day). Assuming average consumption of about 0.16 L&~day, this corresponds to concentrations of 70 or 140 mg nitrate- nitrogen/L. No cyanosis was evident in any infimt, and the highest concentration of mcthemoglobln xvas 7.5%. These authors also administered doses of 100 rog/kg of nitrate to four he~thy infants (age 2 days to 6 months) and to two infants (age 6 and 7 weeks) who had been admitted to the hospital for cyauosis. No cym~osls was produced in the healthy infants, but eyanosis did occur in the individuals ~4th a prior tdstory of cyanosis. Examination of tile saliva, gastric juice and stool~ of these infants revealed the presence of bacteria that readily redfaced nih'ate to nitrite. The gastric pH of these infants was >4 in both cases. Donahoe (1949) reported five cases of moderate to severe eyanosls in infants (age 1-7 weeks) in South Dakota. In fern' of the live cases, the water used to feed the iltfants was from shallow wells and was shown to be heavily conlaminated with bacteria. Nitrate levels were measured in nyc case~, with values of 50 and 177 mg/L (12 and 41 mg nitrate-nitrogen/L), respectively. This con'esponds to doses of 8 and 28 mg ninme-nitroge~rkg/day. 8tmon et al_ (1964) measured methemoglobin levels in 89 healthy infants who received nitrate-free water, 38 infmat~ who received water containing 11-23 mg idtratc-nitroge~L (1,8-3.7 mg nitrate-nitrogen/kg/day), and 25 i~fants receiving water containing >23 mg nitrate.-nitrogerdL (>3.7 rug nitrate- nitrogen/kg/day). For infants age 1-3 months, mean. methemoglobin levels in these three groups were 1.0, 1.3 and 2.9%, respectively. For infants age 3-6 months, values were 0.8, 0.8 and 0.7%, respectively. No clhfical signs of methemoglobinemia were detected in any of the infants. Toussaint and Selenka (1970) supplied. 34 healthy infants (age 1-3 months) with tbrmula prepared with water containing 150 mg nitrate/l, (34,5 mg nitrate~ nitrogen/L, corresponding to 5.5 mg nitrate-nitroge~vltg/day). Average metteraoglobin levels rose from about 1% to about 2-3% within 1-2 days, and then tended to stay steady for up to 10 days. No clinical signs of methemoglobinemia were reported. I.A.3, b~NCERTAINTY AND MODIF'kq[NG FACTORS (ORAL RfD) IFF -~ An uncertainty factor of 1 was employed because available data define tile no-observed-adverse~effect level for the critical toxic el'feet in the most sensitive human subpopulation. MF - None LA.4. ADDITIONAL STUDIES / COMMENTS (ORAL RfD) Nitrate toxicS .ty is due primmSly to its conversion to nitrite, wkich oxidizes the Fe(+2) form of iron in Tuesday, April 14, 1998 l 1:41 AM aPR-14-98 TUE ?, O? Nitrate - IRIS - Integrated Pd~k Inibrmation ... Page 4 of 9 hemogiobin to the Fe(+3) state. This compound (methemoglobin) does not bind oxygen, resulting in reduced oxygen transpor~ from hmgs to tissues. Low levels of methemoglobin occur in normal individuals, with typical values usually ranging fi'om 0.5 to 2.0% (NAS, 1981). However, due to the large excess capacity of blood to eax'ma' oxygen, levels of methemoglobin up m around 10% are not associated with My significant clirfical signs (Walton, 1951; ECETOC, 1988), Concentrations above 10% may ca~e a bluish color to skdn and lips (cy~mosls), while values above 25% lead to weakness, rapid pulse and tachypnea (Jones et al., 1973). Death may occur if methemoglobin values exceed 50-60%. Conversion of nitrate to mtrite is mostly mediated by bacte~a in the gastmint{:stiual system. Consequently, thc risk of methemoglobinemla from ingestion of nitrate depends not only on the dose of nitrate, but also on the number .and type of enteric bacteria. In healthy adults, available data suggest about 5% of a dose of alu'ate is reduced to nitrite by bac:ceria in fl~e mouth (NAS, 1981). Conversion of nitrate to nitrite may also occur in the stomach if the pH of the gastric fluid is sufficiently tfigh (above pH 5) to pem~it bacterial growth. This is of concern in adults with diseases such as achlorhydrla or atrophic gastritis. It is 'also of concern in infants, since the infant g~trointestinal system nomxally bas a high pH that favors the growth of nitrate-reducing bacteria. For this reason, infants (especially age 0-3 months) are generally ree%mJzed as being the sabpopulation most susceptible to nitrate-induced methemoglobine~rda. Risk is especially tfigh i~ infants who are exposed to water tl~at is contaminated ,~th baoteria, ~nce this tends to promote lfigh concentrations of bac.teria in the stomach and intestines. Nitrate is a no~znal compone~t of the hi,man diet. A typical dally intake by an adult in the United States is about 75 ms/day (about 0,2-0.3 mg nitrate- nitrogen]kg/day) (NAS, 1981). Oft?ds, over 85% comes from the natural Bitrate content of vegetables such as beets, celery, lettuce and spinach. Daily intakes of nitrate b7 vegetarians may exceed 250 ms/day (0.8 mg nitrme- nitrogerdkg/day) (NAS, 1981). Thc contribution frotn drinking water is usually quite small (about 2-3% of the total) (NAS 1981), but eottld reach 85 ms/day (0.29 mg nitrate-nitrogen/kg/day) if water coutalning 10 mg nitrate-nitrogerdL was consmned. Thus, some adults consuming high levels of vegetables along with water containing high levels of nitrate (up to 10 mg nitrate-nitrogen/L) could receive total doses of nitrate approaching the RID of 1.6 mg nitrate- nitrogen/kg/day. Two epidemlologieal studies have been perfiwmed on the adverse effects of nitrate exposure, bu~ the results are internally inconsistent or inconclusive. Dorseh et al. (1984) found a statistically slgrdficant inerease in ri~k of birth defects in children of women consuming grom~dw'ater (which contained 5-15 mg/L of nitrate) compared with women ¢onsmning rainwater (which contained <5 mg/L nitrate). These authors emphasized that their results are limited by a number of factors, and stated that "it would be premature to interpret our case-control findings exclusively in terms of water nitrate exposure." Arbuckle et al. (1988) reported nonstatistically siguificant increase in the odds ratio for birth defects in children of women exposed to well-water (26 mg/L nitrate, equivalent to 0.2 mg ~fitrate.nitrogen/kg/day) compared with rain water (0.1 mg/L nitrate, equivalent to 0.0008 mg nlm'ate-nitrogen/kg/day). However, decreased odds ratios (also not statistically significant) were noted for exposure to ~itraw in spring water (17 mS/L, equivalent to 0. I3 mg nitrate-nitrogen/kg/day) or public water (26 rog/L). Craun et al. (1981) conducted a epidemiologie study of 102 children aged 1-8 years in Washington County, Illinois. Sixty-.four e~ldren were selected from fmnili~s consuming high-nitrate water (22--111 mgFL nitrate-nitrogen) and 38 ctfildren (controls) were from families consuming water eontaimJ_ng <10 mg/L nih'ate-nitrogen. Ingestion of high-nitrate water was not found to result in · 'r,,,~,,,A,:,, txn~41 lA l(IqR lI:41AM Page 3 oi9 above-normal methemoglobin levels in exposed ctfildren. Assm~ing ingestion of 0.1 L/kg/day by older children, these concentrations correspond to doses of 2.2-11 mg nitratemitrogen/kg/day. This study indicates that older children are much less susceptible to nitrate-induced methemoglobinemla than are infants. The Food and Drag Administration sponsored extensive tests of the reproductive and developmental effects of NaNO3 and KNO3 in mice, rats, hamsters and rabbits (FDA, 1972a,b). Groups c~f 20-26 mice, rats or hamsters and 10-13 rabbits were treated by garage on days 6-15 (mice, rats), days 6-10 (hamster) or days 6-18 (rabbils) of gestation. Fetuses were delivered by Cesarean section and examined for visceral and skeletal malformations. Dose levels (expressed as mg nitrate-nitrogen) ranged from 0.6-66 mg/k~day for mice, from 0.3-41 mg/kg/day for rats, from 0.4-66 mg/k~Jday for hamstem and from 0.3-41 rog/kg/day for rabbits. No significant effects were detected regarding maternai reproductive parameters (percent pregnant, abortion frequency, nmnber of litters), fetotoxicity (percem fetal resportions, live fetuses per dam, average fetal weight) or fetal malformations up to the maximum doses administered to each species. These studies identify a reproductive/developmental NOAEL of 66 mg nitrate.nitrogen/k~day for mice and hamsters and 41 mg nit,'ate.nitrogen/kg/day for rats and rabbits. Sleight and Atallah (1968) studied the effects of'nitrate on reproduction and development in guinea pigs. Groups of 3-6 females were exposed to drinkh~g water containing 0, 300, 2500, 10,000 or 30,000 ppm KNO3 for 143-204 days. This resulted i~ average doses of 0, 12, 102, 507 or 1130 mg nitrate- nitrogen/kg/day. Normal conception occurred at all dose levels. No significant effect on reproductive peribrmance was detected except in the high-dose group, where there was a decrease in number of live births. The authors attributed the fetotoxic effeeB to hypoxia due to maternal methemoglobinemia, although data on this were not provided. No fetal malformations were observed at any dose. This study identifies a reproductive NOAEL of 507 and a LOAEL of 1130 mg nitr ate-nitrogen/k~day. No multi-generation studies were located on the reproductive effects of nitrate. In the absence of such data, observations from m~imals exposed to nitrite may be used as a conservative estimate of nitrate toxicity. Hugot et al. (1980) performed a three-generation study in rats. Female animals were administered sodium nitrite in the diet at doses erg0 or 160 mg nitrite-nitmger~kg/day. Thom were no effects on a number of reproductive parameters. Some pups showed small decreases in birth weight and growth rate dm'tag lactation, and changes in organ weights at we~ming. This study identifies aLGA.EL of 90 mg nitrite-nitrogen/kg/day. Assmning that a maximum of 10% cfa dose of nitrate is converted to nitrite by an adult human, this would correspond to a LOAEL of 900 mg nitrate-nitrogel~kg/day. Druckrey et al. (1963) supplied rats Mth NaNO2 in drinking water for tlu'ee generations at a do.'ie level of 100 rog/kg/day (20 mg nitrite..nitrogen/kg/day). No teratogenic effects or adverse effects on reproduction were detected in any generation. Assmning that a maximm~ of 10% of a dose of nitrate is convetced m nitrite by an adult human, this would correspond to a NOAEL of 200 mg nitrate-nitrogen/kg/day. No studies were located on systemic elTects of filtrate in hmnmm or animals. In the absence of such data, observations from animals exposed to nitrite may be used as a conservative estimate of nitrate toxielty. Drue 'krey et 'al. (1963) exposed rats for their lifetime to NaNO2 in dri~xking water at a dose of 100 mg/kg/day (20 mg nitrite-nitrogen/kg/day). No treatment-related histologie or hematologic Tuesday, April 14, 1998 11:41 AM ~PR-14-98 TUE I1:01 P, 09 Nitrate - IRIS - Integrated Risk Information .,. Page 6 of 9 effects were noted except for elevated methemeglobin levels in the treated animals, Til et al, (1988) supplied rats with drinking water containing up to 3000 mg/L of KNO2 (500 mg nitrlte-niti'oget~L, equivalent to 50 mg nitrite- nltrogmgl%/day) for 13 weeks. No histological effects were detected except for a very sligN to slight hypertrophy of the zone glomerulosa. Tlds was probably due to reduced water intake, and is no~ judged to constitute an adverse healfl~ effect. This study identifies a NOAEL of 1.7 and a LOAEL of 50 mg nitrite-nitrogen/kg/day (based on methemoglobin levels). Assuming that a m~innm~ of 10% of a dose of nitrate is convexted to nitrite by a~ adult human, this would em~res!oond to a NOAEL of 170 and a LOAEL of 500 mg nitrate- nitrogen/kg/day. Shuval and Crmener (1972) exposed rats for 24 months to water containing 0, t00, 1000, 2000 or 3000 ppm of sodimn nitrite (0, 2, 20 4-0 or 60 mg nitrite- nitrogen/kg/day). Histo]ogical examinalion of the lungs revealed dilated bronchi, fibrosis and emphysema at 1000 ppm or above. Histological examination of the hem~t revealed an increased percentage of coronm~ arteries that were characterized as "thin and dilated." This effect appears to be at least partly due to the absence of corm~ary artery tkiekening and narrowing that normally occurs ix~ aged rats, so it is not certainthat these changes are inherently adverse. Based on effects on the lung tlfis study identifies aNOAEL of 2 and a LOAEL of 20 mg rdtfite-nltrogen/kg/day. Assuming that a maximum of 10% cfa dose of nitrate is converted to nitrite by an adult hmnan, tiffs would correspond to a NOAEL of 20 and a LOAEL of 200 mg nitrate- nitrogcpfkg/day. I.A,$. CONFIDENCE IN THE ORAL RID Study -- ttigh Data Base -~ High RID -- High The studies of Bosch et al. (1950) and Walton (1951) provide convincing evidence that infantile methemoglobinemia does not occm at drhtldng water levels of' 10 mg ~fiu. ate-aitrogen/L or les~. This is supported by a large number of additional epidemiological mhd case studies in humans (e.g,, Comblath and Hartmmm, 1948; Simon et al., 1964 Toussaint m~d S elenka, 1970; C;raun et al,, 1981; see U.S. EPA, 1990 for descriptions of additional studies). I.A,6. EPA DOCUMENTATION A/ND REVIEW OF THE ORAL RID Source Document -- This assessment is not presented in any existing U.S. EPA document. Other EPA Documentation -- U.S. EPA, 1990 Agency Work Group Review -.. 11/21/85, 02/05/86, 02/26/86, 06/20/90, 07/25/90, 08/22/90 Verification Date -~ 08/22/90 I,A,7. EPA CON'rACTS (ORAL RfD) Please contact the Risk Information Hotline for all questions concerning this assessment or iRIS, iu general, at (513)56%7254 (phone), (513)569-7159 (FAX) or RIH.IRIS~,~EPAMAIL.EPA.GOV (interact address). REFERENCE CONCENTRATION FOR CHRONIC INIIAL TION Exmosum (RFC) 11:41 AM Tnv,~dav. A'oril 14, 1998 Nitrate - I1~IS - Integrated Ri~k hfformation .. Substance Name -- Nitrate CASRN -- L4~797-55-8 Not available at this time. Page 7 of 9 II, CAi{C~.L~LTY ASSESSI~ LIFF~/T_I.3~I}~POS_I~ Substance Name -- Nitrate CAS~ -- ~797-55-8 Not av~lable at this time. YI, B~LIOGRAPItX Substance Name -- Nitrate Last Revised ~- 05/01/91 VI,A. O~L RID REFE~NCES ~bu&le, T.E., G.J. Shem~an, P2g. Cnrey, D. Wakers and B. Lo. 1988. Water ~trates and CNS bi~h defects: A population-b~sed c~e-con~ol study. ~eh. Environ. Health. 43 (2): 162-167. Bosch, H.M., A.B. Rosefield, R. Huston, ~I.R. Slfipman and F,L, Woodw~d. 1950. Meflmmoglob~emia and Mi~esota well snpplies, J. Am. Water Works Assoc. 42: 161-170. Comblath, M. ~d A.F. Ha~mann, 1948. Methemoglobinemla in young ~m~ts. J. Pedlar. 33: 421-425. Craun, G.F., D.G_ Grea~ouse m~d D.H. Gunderson. 1981. Methaemoglobin levels in young ehil~en consuming ~gh ~ate well water ~ the U~ted States. Int. J. Epidemiol. 100): 309-317. David~on, S., R. ?nssmore, J.F. Brock and A,S, Tmswcll. 1975. Ht~m~ Nutrition ~d Dietetics, 6th ed. Ch~chill Livingstone, New York. p. 644- 645. Donahoe, W.E. 1949. Cy~osis in i~ts with nitrates in dfi~ng water as cause. Pediatrics, 3: 308-311. Dorsch. M.M, R.K.R. Scrags, A.J, McMichael, P.A, Baght~st ~d K.F. Dyer. 1984. Congenital malformations ~d maternal drying water supply ia rural South Australia: A case-control s~dy. J. Epiden~ol. 1190): 473486. Dmc~ey, ~., D. 8tei~off, I4. geuflmer, H. Sclmeider ~d P. ~arner. 196g. Screening of nit~te for c~onic toxicity in ra~. ~meim~ Forsch. 13: 320- 323. (Ger. wi~h Eng. sm~m~) ECETOC (European Chemicfl Indust~ Ecology ~d Toxlcolo~ Cemer). 1988. Ni~ate m~d&i~ng water. Tee~ic~ Repog No. 27, NiZam ~d DriVing Water. Brussels, Belgim. FDA (Food and Drag A~h~stration). 1972a. Teratologlc evaluation of FDA 71- 7 (sodium nitrate), Food ~d Drag Admi~stration, W~hlngton, DC. PB 221775. FDA (Food ~d Drag Ad~t~stralion). 19'72b. Tera~ologic ev~uat[on of FDA 71-8 ~fitm~e). Food ~d Drag Ad~stration, Was~ngton, DC. PB 221774. Tu~day, April 14, 1998 11:41 AM ~pR-t4-98 TUE t1',02 Page 8 of 9 Nitrate - IRIS - Integrated Risk Information ... Hugot, D., J. Causeret and C. Pdchii'. 1980. The influence ot! large amounts of sodim~ nitrite on the reproductive perfon,nances in female rats. Ann. Nutr. Alim. 34:1115-1124. Jones, J.H., ?I.T. Setlmcy, O.W~ Schocnhals, R.N. Granthmn and H.D. Riley, Jr. 1973. Crrandmother's poisoned well: Report of a case of methemoglobir~emia in an infant in Oklahoma. Okla. State Med. Assoc. J. 66: 60-66. NAS (National Academy of Sciences). 198l. The health uffccts of nmate, nitrite and N-nltroso compounds. Nation~ Academy Press, Washington, DC. Sattelmacher, P,O. 1962. Melhamoglobinamie durci~Nitrate im Tfinkwasser. Schritlemelc Vcrein Wasser Boden LuftSyg. Berlln-D~flem, ~o. 20. Gusta¥ Fischer Yerlag, Stuttgt'm. (Get) Shuval, t4.I. and N. Gruener. 1972. Epidemiolog[eal and toxicological aspects of rdtrates and nilfites in the environment. Am. J. Public Fiealth. 62(8): 1045-1052. Simon, C., H, Mm~zke, H, Kay and G'. Mrowcm 1964, Ocem~ence, ¢athogenesis, and possible prophylaxis of nitrite induced methemoglobi~emia- Zeitschr. Kinderheilk. 91: 124-138, (Ger.) ' ~ and O.A. Atall~a. 1968, Reproduction in the guinea pig as affected by chronic Slmght, o.D, admh-dslJ'afion of potassium ~fitrate and potassium nitrite. ¥oxicol. Appl. Pharma¢ol. 12: 179-185. Til, H.P., FI.E, Falke, C.F. Kuper m,d M.I, Willems. 1988. Igvaluatio~ of the oral toxi¢i, ty of potassim~ nitrite in a 13-week drinking-water study in rats. Food Chem. Toxicol. 26(10): 851-859. Toussaint, W. and 1~. Selunka. 1970. Mcthemoglobin formation in i~/'ants. A contribut[oa to drinking water hygiene in p, hine-Hesse. Mschr. Kinderheilk. June: 282-284.. ' C' U.S. EPA. 1990. Criteria Document for Nitrate/Nitrite. Office of Drinldng Wa~er, Washington, D .. Walton, O. 1951. Survey of literature relating to infant methemogiobinemia due to ' :. 1- 0g6-996- nitrate-sontfu'ninated water. Am. J. Pubh¢ Fl~alth. 4 .. VI.C. C~,CINGGENICITY ASSEssMENT R~ None Substance Name -- Nitrate CASRN 03/0[/88 III,A, Dos~rip~ion ................................. Regulatory A~ion ~e~io~ on-line Health Advisory added 11:41 AM ~PR-14-88 TUE 1]:03 Nitrate - IRIS - Integrated Risk Information ... o~/oz/~o z.~. o~/o;,/9o z,~. o5/oz/~ os/oz/9~ o~/oz/~z zo/oz/~z 01/01/92 Oral tlfD mummery noted a~ pmmding change Withdrawn; new Oral RfD verified (in preparation) 0ral RfD sunm~ary replaced (RfD changed) Bibliography on-line Keal~h Advisory notmd am being revimed Uncertainty fac%or text clarifie¢[ Regulatory action~ up4ated P, 12 Page 9 of 9 ~_ONY_M~ ~, Substance Name -.- Nitrate Last Revised --~ 01/31/87 Nitrate Nitfio acid, bn(10 Tuesday April 14, 1998 11:41 AM L E T T E R S AnchorageOaily,News tion) have been made because of deep and damaging budget cuts imposed by the Legis- lature. While I agree the public is asking the legis- lators to get a handle on the budget, they are not asking them to decimate programs that protect public health., Drinking water and on-site systems must be regulated and have oversight that'is ap- plied to everyone. Pratecting our ground wa- ter from septic systems and other forms of pollution is critical to the 3nvn'onmontal and financial health of out' entire state. Cutting get for these programs pdts en- cities that are ~ed to hhndle'it ~ or !ly. iThat :le,Sves land otliers, lay it becomes more crifidal. alize that water does they fis~d to hav&;t didn't take care of it ter supplies.· We are a youna tion. We have the chance earn mistakes of others before if ia t6o 1~ preserve out' : t,~ .~ Programs that ' Water 'statewide' ar~ the ' known. Even. so, the U.S. mothm~ is'~t~Sfi{ii, e a~ uses formula. I hope 'ADEC; Mak~g sure:they pneers neglected to pre- Sen. Ellis 'maRes wayes with his legislation;~. ;ntal ~mpact statement, but m the memmme don t smash women,~o in a recent option piece ,: just arqn't hble tb"do'tt'or ~ho 8~oSe nta~ ~p~ct stu~s~re ~.: . '-';:, ,~ 7.7 . ~: ', :,,, "~'Kqllie D~', and do the job mght the equtsne mr majm aevet- .., · '" ' ~) ¢,: ', ",':;"" "'~ 5 Chugia~~ Caii until we lose the i ~tatedinNovembe~1996 ' ' ~':? ' ' "': · .... ; -- '-; ' - . . ~..: . - . ' ..;,~:m:;~.,.~ ' · .::: :,:, ,'-;: ,. ,aba septics statewlae. tal mlpdct review would, c a , ',' ' ' a ' · ? ' ,' ~ . · . . ,. .~ .,,,, .gOe~ tram m thc 8o~d .,, ,,.~en we cannot fins men' nme nne ~[ r~'~" .. Hi ¢9'nhMeisElii-Matkin. I'm.10 and'~, ~Etp~itrom our. wens m ': ' -- - - - .-: . mothm: and' fath~-fibe;whale b;ologlits, so .'.ks ;t,will. betoq late. We su~g~rs t~ar we {no33}a they go ~ut to the s6und fill thd time We~hls6 p6rt'ADEC M. ~ta mandat ~j~ ~~[r~: live in Homer, ~o,~hen we g0to 'the. S3uhd it. pr~seLve ~nd protel .~ r~ - ~ ~o~u ...... ; is very very' furl t$(ride on ili~tr'hi~ :so .I" people do not feel th h .... nm'ie~ ,ma nhvsiohl wquld hke you to please, please please keep"; holes in. it Is a~acc ;[= 2¢722¢2~ %7 5=5~E2 the train becahse I-.WoBId not'like the road at' system rot rum or t . .. ~ all: , ....: ,, -.,- ~, . ............ . Peel free,.to corn ttle Aflce' su lgestlng we '~ ),' : ' "" ' ' ....' the ,ower 48~ :rrhey ~end- the e can our I'l driWrs ' '.;t6 w0r~ hard provid- n6 lm,.v to ilo ,r {50 ~)00 Uri>ml~ Assault:, [thc only, thing he said that ! tim alllcV,~lt, n },s , spe~lds apprpxuuate~¥ o}~xp~ ~}~ ':, ~f,,-;,;~ l-g{- massfit~a;' ' "'o~s don't kill peoRle ~thoy pre~nt pe.op~o, [ ~f student as tim Umt~u . : ....... ~v~ ,;,,~ fi'xia' to '; r~0m killin-'~)eople . , ' ' ': :'... ',~";,, ~ 2: i Mi'. Smdle~; ~te~'.,e~,ucatmn..:ye~i~ . : , i '~ ........ 0'fit on ;." ~-~e'~ it souSd as if t my ire goih'g, to' pull up hara' O I)~' ieve. ,.: ,,(J~ ?~.. / .' ,}')2'.-.: (',~.,~}{"~i' ........ "" ":" ~o ~ehool,,ards in an ~ce-cream truck tull ,of, ;.,. ~ I called'the German Informat~Qa.G~p[~,-.. ~ t~t ~' ~o,~i ou~"~n" ¢r~nade i~unchers and-50 cals, ana Big Bn d~,!,New York and recm~e~ from ~..,¢~a~[s~¢ ~0n ~ ..~ ~ ~ . ','~ J" ~ going t6 hop out and start pas~ing them ~Ut.;}. f;t:~ation'"i~ublChed By'the, G,m.m~j~9~'~ )kifi out for h~r slm sure That $100 million is for education and safety ,, Mihistiyof~Education, ~cience, Rca;catch'and ~ ' - ' ' ~s : '~ '''"''*:'' ;~ ' : ': Teclm610gy. In 1,994 tl]e~hms~ re~e~}t:yeat~ ' ~lmmn the NRA for disturbed children, Which data is (ompiled, German~ spent 81.2 · ~ ~ Stu Kingsley t . . go. , · · -,-:- *~'h-~-.~inb' thc~:; ..... ~i ,~;'-,m{marks,~ on schools serv:, formula.,f read that Sen. Jo tony Llhs sponsible gnn owners. The NRA and other to the 1998World Almanac, U.S, spending per on to cbange the statelaws similm' groups have been pushing trigger student in 1~93-94 was $5.767. · ' 'e anti breast-feeding. Lisa locks and gun'iafes' for years. Besides, in The only way Gerald Bracey could have hei: article that breastifed Don's own words. "Bad kids have homemade obtained a higher per capita education spend- der, bond better and are pieces fashioned em of short lengths of pipe." lug fignre for Germany than for the United Ileyhavebeeubreast'fed'A Well. nowadays schools have shop classes, States would have been to include all other minate on the facts arid be :ientific were the studies? but the riskof a kid making one there is great education spending by the German govern- enough that we should outlaw them as well. menr, such as day care, colleges and nniver- dies say? ~d me the same thingOabout ~xcept they might turn to archery instead, so sities and continuing vocauonal education,~ eliminate bows and arrows but that leaves and compare all this with U.S. spending on K- ~s, and I madea quixotieat- knives and rocks. OK, let's just figm-e out 12 alone On t ~is basis, German per, capita ty fourth child. My nipples how to amputate children's arms 'until they spending in'199~'w~g 2,019 DM;--'$1 ~09 at~ · s from feed~g. A horrid o~, ~,-ovethev are resnonsible enough to own the present ' exchange rate. American 'Per um depresston ,aevmup ~ them " , , capita spending for K~12 alone that year wt[s . husband'could do to mak ~. It'~ i6o b&d Don wasn.t an a'~ult during $1,029. ~,- ~ ', ~::'~;,.-.T''~ '~; 500 calories a day. I relue; World War II The Third Reich could have The main p6int of my March~8 let~er:~as. my baby tO.mefOrmulada s laterathe '~ u~ed his taleni for distorting the. facts. '~ ' that many countries such as Germany Bave,. ghtcheckn' ' Y ',':,,. ~ . . · ~MatthewKiser school choicd, including th'e~ fih'oic6 nces. At 3 months of'age he .. :~ ~.. [, · ' , ' , parochial schools and highly successful pu~-' ds breasf-fed sister~: were ' ..,':~' ',~ . ~ .., , :' , . Valdez lie school systems. The'refor6, %e ~an:~afely ......, pounds moredver_at b~thlsecure )' MYwe ~tS:"' tO' ~ blaffie [0[' ~ate~ woe8 d~s~mss th'e alaYmlst claims, that'school', . .,-fih0ice' f statue an y · .. . undermine pubhc eduction ~n ~m d unffi I regained my'ener- ' ~.Th~ poli~y changes affecting the Alaska a. (~J"7:" '. ', ~ - ' . . f ' ' .-~. Depm~ment of Environm'en~hl Conservation . > ,., :,~? : '~r ~'.> e mother breast-feeds isn't, oversight of wells and septics ~e~tioned in c :~: ~ ' ..... , ~ Larry Frmberger~,. ~'~,,.-,~ : · "' ', An,chorag~,, ~r than another bab~ Whose.: Cla~ Ramsey's April 5 column (Business sec- . : ,~,.,: ' .~.}.,,[ ,... ,~ ,.~ ,~ -