Carefree Truth
                      Issue #761, July 1, 2019


Utilities manager Jim Kaylor recommended that Cave Creek lease to own 2 water filtration units to support the Basin Road Water Treatment Plant in order to meet the Total Organic Carbon (TOC) alkalinity regulations.  This would be done in 2 phases.


Phase 1:
The work would be done between early June, 2019 and March, 2020.  The study of the existing plant and the implementation of the membrane units would eliminate the need for quarterly public notices, two of which had been sent out so far this year.  Cave Creek was required to do so by the EPA and the State of Arizona because they hadn't met the treatment techniques.  He stated that the water is safe, but the violation occurred because at least 15% of the TOC must be removed, by regulation, which Cave Creek is currently unable to do.  A solution must be found.  They don't want to send out public notices, and are looking for a rationale to get rid of public notices and meet the techniques as soon as possible.



The modifications to the current plant would be in place for at least a year, so would require a permit from the Arizona Department of Environmental Quality (ADEQ).  The membrane units would provide 75% for the daily peak summer flows and should provide 100% between October and late April.  They would decommission the existing plant during the wintertime for maintenance, and base load the membrane units which take out the required TOCs.  Arizona regulations are straightforward and go on a nationwide scale.  The goal is to have this in place by September 1st, but it could be slowed down by regulators.  Membranes would provide immediate relief from the requirement for quarterly public notices.  He repeated that there is nothing wrong with the water.  It just doesn't meet the treatment techniques percentage removal of disinfectant by-products.


Membranes remove 99.99% of everything the membrane sees, and provide a consistent quality of water for the entire filter run.  They last 10-15 years with proper care and maintenance.  Membranes also reduce the backwash requirements.  All the existing treatment plant units are approaching their usable life.  75% of them are 20-25 years old.  In 2-5 years the plant will require a major capital improvement project.  Site constraints are a big issue.  The current plant has no room left inside.  The membranes will be delivered in, and will remain in, a large container outside of the plant.  Cave Creek will have to decide whether to retire the plant and go to a full membrane plant as the current units become obsolete.


Phase 2:
An engineering study will begin in August and finish in March to study upgrading the current plant vs. new technology, including membranes.  Upgrades to the current plant would take 3-8 months.  Membranes are easy to install because they are modular.  Mr. Kaylor recommended entering into a membrane rental contract for 1 year while completing the study.  When implementing the study, they might decide to replace treatment units 1, 2, & 3, which could cost approximately $3 million, or they could purchase the membranes for $1.8 million after rebated costs for the rental.  The membrane rental would eliminate the requirement for warning letters sent to customers of the Cave Creek Water Company.  He asked if the Council had any questions.


Mayor Bunch asked if there would be a difference in the taste of Cave Creek's water in the summer and the winter, as he experienced in his office in Phoenix.  Mr. Kaylor explained that a bad taste and smell in water are a result of algae and dead algae residue.  The membranes should be more efficient in removing that.  They also require less use of chemical disinfectants.



Councilwoman Kathryn Royer noted that there has been some negative reactions to the letters the Town was required to send out to the water customer.  She asked if the water is safe to drink.  Mr. Kaylor said it is safe to drink.  The letters went out because in 1996 the EPA created the Surface Water Rule to make sure people were aware if a lot of disinfectant by-products were coming into a plant.  It is best to remove them before adding chlorine because the combination creates Trihelamethane (THM).  He said that Cave Creek water meets the THM requirements.  Ms. Royer assumed that ADEQ oversaw the effort and agreed with Mr. Kaylor's opinion, or it would have stated otherwise.  Mr. Kaylor said the letter that went out in January was approved for content.  It was just a treatment violation, nothing to do with public health.


Mayor Bunch opened the meeting to public comment.  Dr. Kerry Smith, the current Water Advisory Committee Chair, said he has served on the EPA Science Advisory Board (SAB) associated with decision making involving water quality standards.  He was on a special committee of the SAB evaluating the arsenic rule for the EPA.  He appreciated Mr. Taylor's comments but said it was not accurate with respect to THM.


Dr. Smith said the current federal standard for THMs is 80 parts per billion.  The standard was set as a compromise, evaluating the health risks associated with THM and the costs associated with small systems managing the reduction in THMs required to attempt to make it safe.  The bi-partisan non-profit Environmental Working Group, which provides information on safe drinking water levels, encourages home filtration for these types of disinfectants which are by-products of the cleaning process.


One reason for the letters is to inform people about these contaminants and ideally to provide additional information about home filters and other actions households can take.  The Arizona Department of Water Quality (ADWQ) produces and requires consumer confidence reports for all water companies in the state.  Dr. Smith reviewed the reports from 2009-2018.  Cave Creek's THM problem is not new.  In 2018, 2017, 2011, 2010, and 2009, the readings were at the upper end of the range.  Readings from Cave Creek exceeded federal standards.  Cave Creek was one of the highest reported towns in Arizona for THMs.  Granted, the reports available are from communities much larger than Cave Creek.  Nonetheless, the national average is 13.6, compared with Cave Creek's, which ran from 26.2-142, based on the 2018 record.



Dr. Smith was not opposed to the membrane system but asked why it didn't come before the WAC.  That night was the first he'd heard of it.  His second question was why this was being faced as an emergency, when the records of this problem go back as far as 2009.  ADEQ sent Cave Creek notices in 2017 associated with THMs and other by-products of the water treatment process.



Third, he took issue with the fact that this will not have any affect on the rate study.  He is also on the rate study committee.  They had been told by staff that every capital expenditure being made for the Cave Creek water system is absolutely essential.  At a minimum, this expenditure will require over $1 million.  They can reallocate the $4.5 million proposed for 2020, but what of the absolutely essential things in there will be taken out to replace with this, given that $100,000 of that $4.5 million was for work on the water treatment plant?  Cave Creek could advance some of the capital expenditures, but that was not what was before them that night.  The budget has the full expenditures, not financing, so is Cave Creek going to finance this somehow?  Dr. Smith asked where the money will come from?  If it comes from the expenditures, he could tell them for sure that the rate study committee didn't assume $4.something million in the rate study.  They assumed about $1.2 million in capital expenditures.  At that point, Dr. Smith was told his 3 minutes were up.


Mr. Kaylor said the expenditures didn't show up in the most recent budget was because they were negotiating with ADEQ.  The first public notice letter went out at the end of January.  Because the water treatment plant was reclassified in 2014, there was the risk they would have to send out letters.  They began negotiations with ADEQ at the end of April.  They did testing at the plant.  Cave Creek corresponded with the County at the beginning of April, requesting to have the treatment plant returned to its original classification as a direct filtration unit.  County didn't respond until the end of April.



When told the plant would not be reclassified, work began to find a solution to get Cave Creek out from underneath the requirement to send out the required public notices.  That is why it is not reflected in the budget.  They were lucky to have found 2 units that could be delivered by the end of June, and they didn't know what the rental cost would be until May 17th, by which time the budget was "pretty much in the can".



The letter saying there were no health risks was reviewed and approved by regulators, and is standard language.  Why didn't Cave Creek address home filtration systems?  Mr. Kaylor said he would never recommend that a public water provider suggest to residents to install their own home water treatment units.  Maintenance schedules should be performed on them or bacteria can occur.


Just because THM is too high one quarter doesn't mean there is a violation for the year.  The EPA made this a year long rolling average because summertime is when the highest incidents of organics in the water occur, due to the rise in water temperature.  THMs are formed by organics in the water.  Organics and chlorine form THMs.  The more chlorine in the water, the more THMs.  The longer water sits in the reservoir, the more THMs.  Cave Creek practices reservoir management techniques.  2 tank mixers have been placed in the past 12 months, with water moving between the tanks, and the age of the water is being reduced with periodic flushing.  Cities and towns with lower THMs blend CAP water with groundwater.  The only way to get THMs is through surface water.  Cave Creek is 100% CAP water.  If THMs are out of compliance, it becomes a public health concern.  He said Cave Creek is not out of compliance on a rolling average.  Customers must be notified of THM violations within 24 hours, and TOC violations within 30 days.   



Another speaker said his budget concern was relative to the rate study.  In the Cave Creek water system budget, there are different projects identified for financing.  The entire Capital Improvement Plan (CIP) amount was identified to be financed.  Relative to the capital improvement plan, this is an emerging issue and there are capital projects that could be delayed until another fiscal year so as not to exceed the anticipated total expenditure amount in the rate study.


Eileen Wright said she had heard much from people like Dr. Smith and Mr. Kaylor that night, but she wished to address a different point of view.  Test results for the last 12 months from ADEQ provided compelling evidence that, beginning December 31st, 2018, Cave Creek did not meet the required standards.  The notice sent out did talk about health concerns on the bottom of page 3.  "Drinking water containing these by-products in excess of MCL may lead to adverse health defects, liver, and kidney problems, or nervous system effects, and may lead to the increased risk of getting cancer."  Mrs. Wright said if she read that on a label, she guaranteed it would concern her health, and stated that, as a Council, this information is not getting out to the public.  The Cave Creek Council has held multiple executive sessions on this topic.  They are not being transparent to the public on this subject.



Mr. Kaylor replied that the language in the public notice is language that is required by the EPA.  It states in the letter that there are no health effects.  It states that disinfectant
by-products do have long range effects, but Cave Creek has no problem with these by-products because they are meeting the total THM regulations on the annual rolling average.  Customers should only be worried if they get a letter saying, "Don't drink the water".


Ron Silva said that while the proposal was not contained within the CIP or the budget, he still supported the plan which eliminates organic material in the water system.  He believed the water was safe and will continue to be safe, as per comments made by Mr. Kaylor, for a system that will allow a water plant that does not have a sedimentation process to eliminate organic material from the CAP water supply.  The membrane system will keep the water above the State and EPA standards, and eliminate the need for quarterly public notices.


Recent posts on social media said the water was unsafe.  The letter did not say the water was unfit to drink.  Mr. Silva felt these posts might be meant to discredit the water company, perhaps to strike a lower purchase price for the water infrastructure serving the neighboring community.  Labeling on many common products such as sugar substitutes, meats, tobacco products, and beer say the product can cause cancer.  Mr. Silva continues to drink beer, smoke cigars, and eat meat, but he does use real sugar.  He supports the staff and the filtration system, and hopes the Council will as well.



Councilwoman Susan Clancy thought Cave Creek was taking the right steps, based on ADEQ changing the original standing that put Cave Creek in this position.  They are doing the best they can.



Councilman David Smith said he was in favor because it will not only address TOC issues but also several other issues that have been problematic at the water plant for a long time.  It is a substantial amount of money, but it is not always easy to understand how municipal budgets work.  This is workable and he supports it.



Councilwoman Royer asked Town attorney Bill Sims if the subject was allowed as a topic for executive session.  Mr. Sims replied that many issue relate in part to the ongoing dispute with Carefree.  The initial discussions were about the health ramifications.  Since then, they have been discussing the next steps.  It was appropriate to get legal advice concerning compliance with federal law and concerning its integration with Carefree.  Councilwoman Royer said they will always be as open and transparent with residents as they can be.  Mr. Sims said he needed to advise the Council about the law and the regulatory framework.  He also advised the Council on updates concerning the Carefree dispute.


Councilman Bob Morris said many think that penicillin was the greatest public health thing in the last 150 years, but it was actually chlorinated water, which saved more people than everything else combined.  It has this unfortunate
by-product, but he drinks it every morning and makes his coffee with it.  The project has savings too; it's not just all negative.  It's newer technology.  The current plant technology is a little dated.  This will give it a good start in getting where it needs to be, and will provide citizens with top quality water.  He will propose cutting back other places so they can afford it.


Councilman Tom McGuire said he supports it, but wishes they had more time to prepare a response to Dr. Smith. 



Councilman Paul Deifendorfer said the current system is ancient at best.  This is great new technology that would need to be done soon anyway.  Keeping the old system was not an option. 



Mayor Bunch commented that there have been 5 utility directors and 4 town managers since 2009.  The water plant has always been a direct filtration system.  The County and ADEQ decided it was a conventional treatment plant.  If not for that reclassification, Cave Creek would have no problem.  No public notices to anyone would have been required.


The Council unanimously approved the lease of the 2 membranes.

https://vimeo.com/343782194


Lyn Hitchon


Prepared by Carefree Truth
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