DEQ responds to criticisms

A number of articles, editorials and letterstothe editor recently have appeared in the press regarding the Division of Environmental Quality’s (DEQ) enforcement of regulations pertaining to drinking water testing. DEQ would like to clarify a number of issues regarding this program that might not be clear to the general public.

DEQ is responsible for implementing the CNMI Safe Drinking Water program. This program regulates public water systems, which essentially are facilities that provide water for human consumption (including drinking, bathing, oral hygiene and cooking) to 25 or more people. One of the main goals of the program is to protect public health by assuring that these facilities periodically sample and have their water analyzed for microbiological and chemical contaminants.

The chemical sampling program is important in the CNMI because of the contamination of groundwater that may have occurred in the past or may be happening at present. In the limited amount of testing that has been performed on Saipan to date, numerous man-made industrial solvents have been found. In one case, contamination was found at a concentration greater than 60 times the CNMI Drinking water standard. The potential l risk of adverse health effects, ranging from gastrointestinal disorders to diseases of the liver, circulatory system, reproductive system and cancer, are very real and can no longer be ignored.

The CNMI regulations require public water systems to sample for solvents and other manmade organic chemicals every three years. Within this initial three-year period (1999  2001), a water system must collect one sample every three months (that is, every quarter) for four 60 consecutive quarters. The samples must be taken from each well or from where the water enters the distribution system. This sampling must be repeated every three years.

In the second threeyear compliance period (20022004), however, DEQ may be able to reduce or completely waive sampling requirements for some chemicals. DEQ can do this if information, including previous monitoring results, indicates contamination does not threaten a water system’s source of water. This is why it is so important to collect the initial four quarters of samples; this baseline data will allow DEQ to make informed decisions that may provide significant cost savings in the future.

There has been much misinformation printed recently that needs to be corrected. First, none of the expenses that water systems must pay for this organic chemical sampling goes to DEQ. The fee for shipping and analysis is sent directly by the water system to a drinking water laboratory on the U.S. mainland. Although there is only one DEQ-certified laboratory that can currently perform these analyses (Montgomery Watson Laboratories in Pasadena, California), any laboratory can apply to DEQ for certification. The price that the Montgomery Watson Lab charges for analysis is very competitive with prices charged by other laboratories on the mainland.

Second, it is not DEQ’s responsibility to collect the samples nor pay for the analysis of the samples. This is the responsibility of the public water system. Third, all water wells do not need to be sampled. Sampling is required only of wells used by certain types of public water systems, and only then if the water is used for human consumption. Finally, these are not proposed regulations. They have been CNMI regulation since 1997. They have been federal requirements since 1991.

In fact, all CNMI water systems have been out of compliance with these regulations since the early 1990’s. From that time until now, those water systems have saved tens of thousands of dollars by not performing the required sampling. The down side, of course, is that the people of the CNMI have potentially been exposed to chemical contamination during all that time.

All water systems seem to agree that this type of sampling is necessary to help protect the public’s health. The water systems are justly concerned about the high cost for shipping and analysis of these samples. This cost is approximately $2,700 per sample (that is, per well) for the first quarter. The cost of the next three quarters will be several hundred dollars less. For a water system with one well, they can expect to pay approximately $10,000 total for the four quarters of sampling. For systems with multiple wells, the requirement that the 3rd and 4th quarter samples be taken at the location where the water enters the distribution system (as opposed to the wellhead) may significantly reduce the cost of compliance.

Considering the savings that water systems have experienced in the past by not performing the required monitoring, and DEQ’s commitment to allow reduced sampling (where appropriate) in future sampling periods, the price of these analyses seems a good investment. There is no better way to protect public health, or to assure tourists and potential businesses that their drinking water is safe, than by being in full compliance with all CNMI and federal drinking water requirements.