Text

Official Exhibit - ENT00320B-00-BD01 - Haverstraw Water Supply Project Water Supply Permit Application. Part B
	ML12339A447
Person / Time
Site:	Indian Point
Issue date:	12/31/2011
From:	; AKRF, CDM, United Water New York
To:	; Atomic Safety and Licensing Board Panel, State of NY, Dept of Environmental Conservation
	SECY RAS
References
	RAS 22146, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
	Download: ML12339A447 (82)
	v • d • e

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 ENT00320B Docket #: 05000247 l 05000286 Submitted: March 29, 2012 Exhibit #: ENT00320B-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations parameters monitored and the number of samples. The minimum, maximum, and average result for each parameter analyzed are also included in all tables.

Table 4-2 Summary of Prior River Water Quality Monitoring/Analysis Performed by UWNY PERIOD SAMPLE COLLECTION EVENT SITE PARAMETERS FREQUENCY SAMPLED NOTES

1. Quarterly Sampling Events Sites 1, 2, & 4 VOCs/SVOCs, Pest., PCBs, TCDD Single event Apr 2007 High & Low tide, 3 depths Radionuclides Single event Apr 2007 High & Low tide, 3 depths Site 3 VOCs/SVOCs, Pest., PCBs, TCDD Quarterly (2 qtrs) Apr & Jun 2007 High & Low tide, 3 depths Radionuclides Quarterly (2 qtrs) Apr & Jun 2007 High & Low tide, 3 depths Site 5 VOCs/SVOCs, Pest., PCBs, TCDD Quarterly (4 qtrs) Jun 2007 - May 2008 High & Low tide, 3 depths Radionuclides Quarterly (4 qtrs) Jun 2007 - May 2008 High & Low tide EDCs/PPCPs Quarterly (4 qtrs) Jun 2007 - May 2008 High & Low tide

2. Monthly Sampling Events Sites 1, 2, & 4 Metals & Nutrients Monthly (2 mths) Apr & May 2007 High & Low tide, 3 depths Crypto & Giardia Single event May 2007 High & Low tide Site 3 Metals & Nutrients Monthly (4 mths) Apr-Jul 2007 High & Low tide, 3 depths Crypto & Giardia Monthly (3 mths) May-Jun 2007 High & Low tide Site 5 Metals & Nutrients Monthly (12 mths) Jun 2007-May 2008 High & Low tide, 3 depths Crypto & Giardia Monthly (12 mths) Jun 2007-May 2008 High & Low tide

3. Weekly Sampling Events Site 1 Field Parameters Weekly Apr-Jun 2007 Depth profiling Conv. Param, Select Ions,

& Bacteria Weekly Apr-Jun 2007 3 depths Sites 2, 3, & 4 Field Parameters Weekly Apr-Aug 2007 Depth profiling Conv. Param, Select Ions,

& Bacteria Weekly Apr-Aug 2007 3 depths Site 4S Field Parameters Weekly Aug 2007-May 2008 Depth profiling Site 5 Field Parameters Weekly Aug 2007-May 2008 Depth profiling Conv. Param, Select Ions,

& Bacteria Weekly Aug 2007-May 2008 3 depths

4. Continuous Reading pH, Temp, Conductivity, Continuous hrly Installed Mar 2008 Removed during winter Water Quality Buoy (Sonde) Salinity, DO, & Turbidity readings (ongoing) icing (mid Dec-Mar, typ) 4-3 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations 4.1.1.2 Parameter Detections The results of the water quality monitoring are summarized in the following analyte groups.

Organic Compounds With the exception of four volatile and semi-volatile organic compounds, all other organic contaminants were not detected at any of Hudson River monitoring sites, as indicated in Tables 1A and 2A of Appendix B. The four organic compounds detected were Benzene, Methylene Chloride, Toluene and Dioxin (2,3,7,8-TCDD). While Dioxin and Benzene were only detected once, Methylene Chloride and Toluene were detected 8 and 11 times, respectively.

Pesticides/PCBs/EDCs and Pharmaceuticals According to Tables 1A and 2A of Appendix B, no pesticides or polychlorinated biphenyls (PCBs) monitored during the 2007-2008 Hudson River water quality monitoring program were detected at any of the five sampling locations. There were 17 endocrine-disrupting compounds (EDCs) detected in the samples.

Metals and Inorganic Ions Metals detected in the Hudson River throughout the 2007 to 2008 water quality monitoring period included aluminum, boron, iron, lead, manganese, nickel, potassium and zinc. Fluoride was detected three times.

Conventional Parameters Nitrogen species including ammonia, nitrate, nitrite and total nitrogen were all detected, as indicated in Tables 1A and 2A of Appendix B. Table 3 of Appendix B provides a summary of conventional parameters monitored and detected at the 5 sites. Conventional parameters presented in Table 3 include pH, salinity, conductivity, temperature, total dissolved solids (TDS), total organic carbon (TOC),

and turbidity.

Pathogens/Microbiological Parameters Total coliform in the 2007-2008 Hudson River sampling was detected within the range of 2 to 2,420 cfu/100 mL with an average of 759 cfu/100 mL (Table 1A of Appendix B).

4.1.2 Sonde Water Quality Buoy Data Generally from March and April 2008 to July 2011, Hudson River water quality has been monitored continuously by a water quality buoy (Sonde) located within the vicinity of the proposed intake location. The data collected yields tidal and daily variation of water quality throughout the spring, summer and fall seasons. It should be noted that the buoy is removed from the water during winter months due to the impacts of icing on the river.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations 4.1.2.1 Parameters Monitored The Sonde water quality buoy logs hourly water quality data near the proposed intake location. As indicated in Table 3 of Appendix B, the following parameters are monitored:

pH; Temperature; Conductivity; Salinity; and Turbidity.

4.1.3 Pilot Study Water Quality Data While not required by the New York State Department of Health (NYSDOH) or New York State law, UWNY has voluntarily constructed a temporary water testing and treatment facilitylocated on Carol Avenue within the West Haverstraw Business Park.

The water quality sampling and modeling conducted and the testing being performed, referred to as the Pilot Study, allows UWNY to continue the process of gathering information on Hudson River water quality, but on a continuous basis. The Pilot Study draws water from the Hudson River in the vicinity of the location proposed for the Project, and analyzes it and uses it to conduct engineering studies of treatment processes that can be employed for Hudson River water. Use of the Pilot Study will provide additional information on ambient water quality, treatment methods (such as the sequencing of treatment processes to result in the highest quality potable water while optimizing the treatment cost), and volumes of waste and reverse osmosis (RO) concentrate streams generated by the treatment processes throughout the range of water quality conditions. This information will allow refinement of the treatment processes and sequencing of treatment to provide information for the detailed design of the Proposed Project.

Water quality data has been collected from the pilot plant for raw water, throughout the water treatment process, and for the RO influent, permeate and concentrate (brine). Tables 1B and 2B of Appendix B include summaries of the raw water quality as well as RO influent and concentrate laboratory data collected from December 2010 through July 2011. Sampling frequencies varied based on analyte group and are detailed below.

4.1.3.1 Parameters Analyzed and Frequency As mentioned above, several water quality parameters were analyzed both continuously and at varying frequencies throughout the treatment process. The following summarizes the analyte groups and monitoring frequencies:

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Laboratory/Field Parameters Volatile Organic Compounds (VOCs) - monthly; Semi-volatile Organic Compounds (SVOCs) - monthly; Pesticides - monthly; PCBs - monthly; EDCs/ pharmaceutical (PPCPs) - monthly; Metals/Inorganic parameters - monthly and weekly; Conventional parameters - weekly; and Pathogens/Microbiological parameters - twice monthly.

Continuously Monitored Parameters Conductivity, pH, Temperature, and Turbidity.

4.1.3.2 Parameter Detections The results of the raw water quality monitoring for the Pilot Study are summarized in the following analyte groups.

Organic Compounds According to Tables 1B and 2B of the appendix, the only organic compound detected in the raw water was methylene chloride, which was detected twice.

Bromodichloromethane, Bromoform, Carbon Disulfate, Chloroform, Dibromochloromethane, Methylene Chloride, Styrene and Xylenes were detected between 1 and 2 times in the RO influent and concentrate.

Pesticides/PCBs As indicated in the appended table, no pesticides or PCB Aroclors monitored at the pilot were detected in the raw water on any occasion. Delta-BHC and Gamma-BHC were detected once and twice, respectively in the RO concentrate. PCB Congeners were detected in the pilot raw water, RO influent and RO concentrate. Of the 27 Congeners analyzed, 12 were detected primarily in the raw water and RO concentrate. These included PCB 101 (BZ), PCB 105 (BZ) (RO concentrate only), PCB 118 (BZ) )RO concentrate only), PCB 18 (BZ), PCB 183 (BZ), PCB 28 (BZ), PCB 44 (BZ),

PCB 49 (BZ), PCB 52 (BZ), PCB 66 (BZ), PCB 8 (BZ), and PCB 90 (BZ).

EDCs and Pharmaceuticals Tables 1B and 2B of Appendix B indicate that 20 of the 39 EDCs/Pharmaceuticals analyzed were detected in the raw water of the Pilot Study, Acetaminophen, 4-6 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Azithromycin, Benzo(a)pyrene, Caffeine, Carbamazepine, Cotinine, Diltiazem, Fluoranthene, Fluoxetine, Gemfibrozil, Ibuprofen, Lincomycin, Naphthalene, Naproxen, Phenanthrene, Pyrene, Sulfamethoxazole, Triclosan, Trimethoprim and Tylosin. The detections of the above mentioned EDCs averaged within the range of 0.7 and 160 ng/L. It should be noted that each of these parameters was previously analyzed and not detected using EPA method 625 for SVOCs.

Metals and Inorganic Ions Several metals were detected in the raw water, RO influent and RO concentrate of the HWSP pilot facility. The metals detected include Aluminum, Arsenic, Barium, Boron, Calcium, Hexavalent Chromium, Copper, Iron, Lead, Magnesium, low level Mercury, Manganese, Nickel, Potassium, Silver, Sodium, Strontium, Vanadium and Zinc.

Bromide, Chloride, Fluoride, Hexane Extractables (Oil and Grease), Perchlorate and Sulfate were also detected in the raw water, RO influent and RO concentrate.

Conventional Parameters According to Tables 1B and 2B, nitrogen species including Algae, Alkalinity, Chlorophyll, Conductivity, DOC, Ammonia, Nitrate, Nitrite, Total Phosphorous, Orthophosphate, Total Nitrogen, TKN, TDS, TOC, TSS and UV 254 were all detected either in the raw water, RO influent or RO concentrate. A comparison of the conventional parameters monitored and presented in Table 3 of the appendix include pH, salinity, conductivity, temperature, TDS, TOC, and turbidity.

Radionuclides According to Tables 1B and 2B, Gross Alpha, Gross Beta, Radium-226, Radium-228, Tritium and Uranium were all detected in the either in the raw water, RO influent and RO concentrate. Gross Beta appeared to be the most detected of all the radionuclides, having 9 detections in the raw water, 7 in the RO influent, and 11 in the RO concentrate. The majority of the other radionuclides were detected less than 5 times throughout the pilot study. Strontium-90 was detected twice in the RO concentrate.

Pathogens/Microbiological Parameters Cryptosporidium was detected once at 0.05 oocysts/l, while Giardia was detected 6 times within the range of 0.05 and 0.55 cysts/l in the raw water. Total coliform was detected within the range of 140 to 11,000 cfu/100 mL, at an average of 1,700 cfu/100 mL in the raw water. It was detected at an average of 285 and 120 in the RO influent and RO concentrate, respectively. HPC was detected in both the RO influent and RO concentrate at average quantities of 360 and 3,000 cfu/ml, respectively.

4.1.4 Water Quality Data Comparison 4.1.4.1 Appendix B Tables 1A and 2A Summary Tables 1A and 2A provide a summary of Hudson River Water Quality Data where Pilot Study data appears to be consistent with the historical Hudson River data 4-7 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations gathered in 2007 and 2008. VOCs and SVOCs were detected infrequently in either data set. Pesticides and PCB results indicated no detections historically or in the Pilot Study raw water. Metals and conventional parameters were detected both historically and currently under the Pilot Study, at comparable minimum, maximum and average values. Total coliform was detected and averaged at 759 cfu/100 mL and 1,700 cfu/mL during 2007 and 2008 sampling and under the Pilot Study, respectively.

4.1.4.2 Appendix B Table 3 Summary Table 3 provides a summary of conventional parameters monitored in the Hudson River both historically, continuously with the water quality buoy, and under the Pilot Study. The pH range appears to fall within the range of approximately 6.7 to 8.4, at an average of near 7.35-7.6 for both historical and Pilot Study raw water data. While the average data is similar for historical and the Sonde water quality buoy data, the salinity range for historical data peaks slightly higher than that of the Sonde water quality buoy data, which is likely due to the availability of data during summer months. Historical data indicates a range of 0.1 to 14.5 ppt (average of 2.8 ppt), while the Sonde water data indicates a range of 0.1 to 8.3 ppt (average of 2.2 ppt). The Pilot Study indicates a range of 0.1 to 4.5 ppt, with an average of 1.1 ppt in the raw water and RO influent. The RO concentrate has a salinity of between 0.5 and 29.5 ppt, at an average of 6.5 ppt. The raw water temperature range was consistent throughout each data set, ranging from a minimum of between 0.4 to 5.9 degrees Celsius, to a maximum of 25.4 to 30.0 degrees Celsius. Hudson River water TDS for historical and Pilot Study raw water data was within the range of 6 to 11,000 mg/L, and 74 to 4,340 mg/L, respectively. TDS in the RO influent and concentrate was within the range of 80 to 4,800 mg/L and 728 to 28,800 mg/L, respectively. TOC detected in the Hudson River water for historical and Pilot Study raw water data was between 1.0 to 4.7 mg/L and 2.6 to 3.7 mg/L, respectively. RO influent TOC was detected at between 1.4 and 2.2 mg/L, while RO concentrate TOC was detected at between 3.6 and 34.5 mg/L.

Hudson River water turbidity during the 2007 and 2008 monitoring program ranged between 0.8 and 69.0 NTU. The Sonde water quality buoy detected a range of 0.1 and 155.8 NTU for turbidity. The Pilot Study raw water detected between 2.3 and 99.8 NTU of turbidity in the raw water and 0.02 and 0.26 NTU turbidity in the RO influent.

4.1.4.3 Conclusion It appears that Pilot Study data, Water Quality Buoy (Sonde) data, and historical data attained from UWNYs 2007-2008 sampling program are generally consistent in classifying Hudson River water quality.

4.1.5 Hydrodynamic Modeling Results Potential issues for drinking water from any source can include the presence of radionuclides, PCBs, and EDCs/ PPCPs. Hydrodynamic modeling conducted by HydroQual, Inc. indicated that upstream dredging (approximately 100 miles from the proposed intake structure) conducted for the Hudson River PCBs Superfund Site would result in future PCB concentrations in the vicinity of the intake structure at 4-8 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations levels far below the maximum safe drinking water standards (i.e., maximum contaminant levels, or MCLs). The results of this modeling conclude that point and non-point discharges to the Hudson River within a 25-mile radius of the intake structure would not adversely affect the suitability of the Hudson River as a water supply source. Similarly, modeling at the intake structure indicates that discharge of the water treatment plants reverse osmosis effluent (RO concentrate) through the Haverstraw Joint Regional Sewage Treatment Plant (JRSTP) effluent outfall, and the discharge of other residual waste streams to the influent of the JRSTP, would not adversely affect the quality of the surface water at the intake structure for the Proposed Project. The standard water treatment processes proposed as part of the Haverstraw Water Supply Project would be used to meet or exceed drinking water standards established by the U.S. Environmental Protection Agency (USEPA) and the NYSDOH. Further details on the hydrodynamic modeling are included in Appendix C.

4.1.6 Municipalities Utilizing the Hudson River as a Water Supply The Hudson River is currently being used as a drinking water source by more than 20 municipalities. The public water supplies from the Hudson River that serve at least 1,000 people include the City and Town of Poughkeepsie, the Town of Lloyd, the Village of Wappingers Falls, the Town of Hyde Park, the Town of Esopus, the Village and Town of Rhinebeck, the Town of Halfmoon, the Village and Town of Waterford, and the Town of Queensbury, and the City of Glens Falls. In addition, water from the Hudson River has been used by the City of New York at Chelsea, New York during past drought emergencies.

Numerous industrial and commercial entities, which are listed below in Table 4-3, also utilize the Hudson River (south of Troy) as a source of water supply.

Table 4-3 Hudson River Water Industrial and Commercial Uses th 59 Street Steam Station Dinsmore G.C. Mirant Bowline AMRI Rensselaer Holcim (US) Inc. Athens Generating ASR, Inc. IBM Hudson Valley Research Park Roseton Generating Station Bethlehem Energy Recovery IBM Poughkeepsie Wheelabrator Westchester Clover-Leaf Nursery Indian Point 2 & 3 World Financial Center Danskammer Generating Lafarge Building Materials Station 4-9 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations 4.2 Water Quantity The proposed Haverstraw Water Supply Project would introduce a new surface water source to the Rockland County water supply system, the Hudson River. Unlike the reservoirs, smaller rivers, and groundwater sources that currently supply UWNYs system in Rockland County, the Hudson Riverby virtue of its size and connection to the Atlantic Ocean, as discussed belowis far less affected by local drought conditions. For this reason, and for most efficient plant operation, UWNY proposes to operate the Haverstraw Water Supply Project at or close to its design capacity, to provide a steady source of clean water regardless of changes in the hydrologic cycle elsewhere in Rockland County 4.2.1 Hudson River Hydrology The Hudson River originates at Lake Tear of the Clouds in the Adirondack Mountains and flows south 507 kilometers (315 miles) to its confluence with Upper New York Bay. The Hudson River drainage basin covers 33,835 square kilometers (13,064 square miles) and drains parts of New York, Vermont, New Jersey, Massachusetts, and Connecticut. It is divided into three major sub-basins: the Upper Hudson River (Upper Hudson, 11,987 square kilometers or 4,628 square miles), the Mohawk (8,972 square kilometers or 3,464 square miles), and the Lower Hudson (12,876 square kilometers or 4,971 square miles). The Proposed Project is located in the Lower Hudson. At Troy, north of Albany, the river is joined by the Mohawk River, the major tributary of the Hudson River, and the flow nearly doubles. Land cover within the Hudson River basin is approximately 62 percent forest, 25 percent agriculture, 8 percent urban and residential, 2.6 percent open water, and the remaining is miscellaneous. Land cover within the Lower Hudson is about 55 percent forest, 29 percent agriculture, and 13 percent urban (see Figure 4-2).

The Lower Hudson is a partially mixed estuary due to mixing of freshwater with water from the Atlantic Ocean. The river is tidally affected as far as the Federal Dam near Troy, which is 153 river miles upstream of the mouth of the Hudson at the Battery in New York City. The flow in the estuary can be in either direction depending on the tidal conditions and the seasons, which influence freshwater flow.

The mixing of freshwater and ocean water results in brackish water in the lower reach of the estuary. The salinity and its vertical mixing or lack thereof (stratification) vary significantly with tides, season, and weather. Semi-diurnal tides (i.e., two high tides and two low tides occur each day) affect salinity and mixing, particularly in the lower stretches of the river.

The average annual flow of the Hudson River at Green Island, which is just downstream of its confluence with the Mohawk, as gauged from 1947 through 2006 by the U.S. Geological Survey (USGS) (USGS Gauge No. 1358000) is approximately 14,000 cubic feet per second (cfs). Freshwater flow in the Hudson varies seasonally 4-10 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Land Use Major Rivers and Streams

*))8 Land Use 7'%0)

Forested Agricultural Urban/Residential Water Other Figure Hudson River Watershed Showing UNITED WATER Haverstraw Water Supply Project Land Use, Major Rivers and Streams

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations with the highest rates typically in the spring when rainfall combines with snowmelt particularly in the Upper Hudson.

The average depth of the river varies from 16 feet at Haverstraw Bay to 35 feet at the Battery. The width of the river is largest at Haverstraw Bay (17,000 feet or 3.2 miles) and decreases downriver. Haverstraw Bay has extensive shallow areas (less than 15 feet deep at mean lower low water [MLLW]). The bay deepens in the navigation channel which is maintained at a depth of about 35 feet (New York State Department of State [NYSDOS] Undated, Coastal Fish and Wildlife Habitat Rating Form Haverstraw Bay). Channel depths within the study area range from 18 to about 61 feet at MLLW (National Oceanic and Atmospheric Administration [NOAA] Chart 12343, Edition 19, 10/1/2005). The mean tidal range, defined as the difference between high water and low water surface elevations, in the Hudson River at Haverstraw is 2.9 feet; spring tidal range, which coincides with the full and new moon, is 3.4 feet. Average maximum flood current is 0.4 meters per second (m/s), or 1.3 fps/0.8 knots, and the average maximum ebb current is 0.7 m/s (2.3 fps/1.4 knots). The greater ebb velocity is attributable to the freshwater flow, which yields a net flow to the Battery and beyond it through New York Bay. 2 4.2.2 Minisceongo Creek Hydrology The Minisceongo Creek flows out of the Ramapo Mountains to its confluence with the Hudson River just southeast of the proposed Intake Site. The Water Treatment Plant Site and the raw water transmission main route options are located within the Minisceongo Creek watershed. The north branch of the Minisceongo Creek originates in the Palisades Interstate Park and the south branch originates about two miles south of the Mt. Ivy Swamp, near the Village of New Hempstead. The branches meet at Letchworth Village. Except for the reach of stream in Letchworth Village, and several small impoundments on the stream, the Minisceongo has a moderate gradient and the streambed is characterized by stones (gravel to large rocks). The average stream flow for the period of October 1960 through September 1963 at USGS Gauge No. 01374480 (Minisceongo Creek at Thiells, New York), northwest of the Town of Haverstraw, where the drainage area is 15.1 square miles (39.1 square kilometers), is 23.1 cfs. 3 4.2.3 Project Effect on Water Quality The ultimate daily production capacity of the new water treatment plant would be 7.5 mgd. Initial estimates show that approximately 33 percent of the raw water flow would be consumed within the treatment process. Therefore, the phased minimum firm daily raw water capacity would range from 3.4 to 10 mgd.

The amount of water withdrawn for the Proposed Project would represent a minute fraction of the total freshwater flow of the Hudson River as it passes the Intake Site.

2 Referenced from Tides and Currents Pro software, except for spring tidal range which was obtained from Reeds Nautical Almanac.

3 USGS http://waterdata.usgs/nwis/ dv/?referred_module=sw 4-11 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations According to USGS estimates, the annual mean flow rate of freshwater in the river as it passed Poughkeepsie in the years 1995 through 2004 ranged from a low of 12,000 cfs (5,385,970 gpm) to a high of 26,700 cfs (11,983,800 gpm). This does not account for the additional effect of saline water associated with tidal activity.

4.3 Key Drinking Water Regulations Drinking water is federally regulated to minimum standards by the USEPA under the authority of the Safe Drinking Water Act (SDWA). The SDWA was established by Congress in 1974 to protect human health by regulating the nations public drinking water supply. The SDWA was extensively amended in 1986 and again in 1996. In New York, the NYSDOH enforces these regulations in general. These regulations are adopted and, in some cases, made more restrictive by the NYSDOH.

A primary focus of the SDWA is to set national contaminant-based drinking water standards, including both primary and secondary standards. Primary drinking water standards are intended to address adverse health effects and consist of maximum contaminant level goals (MCLGs), which are non-enforceable goals, and MCLs, which are enforceable limits set as close to MCLGs as practical, considering cost and feasibility of attainment. Secondary drinking water standards address general public welfare, such as the odor or appearance of drinking water, and are also non-enforceable. "Contaminant" is defined by the SDWA to include any physical, chemical, biological, or radiological substance.

Originally, the SDWA focused primarily on treatment as the means of providing safe drinking water at the tap. The 1996 amendments greatly enhanced the existing law by recognizing source water protection, operator training, funding for water system improvements, and public information as important components of safe drinking water. This approach helps to ensure the quality of drinking water from the source to the customers tap.

Under the SDWA, all public water systems are subject to the drinking water standards, enforced as MCLs for particular contaminants. A "public water system" as defined by USEPA is one that provides piped water for human consumption and has at least 15 service connections or regularly serves at least 25 persons. Regulations require these systems to meet MCLs and/or to use certain treatment techniques to protect against adverse health effects. Regulations include prescribed testing, recordkeeping, reporting, and timely notification of failure to meet applicable drinking water standards.

The current primary and secondary drinking water regulations are listed in Table 4-4.

Each category of contaminant in Table 2-6 is discussed below with respect to occurrence and relevance to this project.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 National Primary Drinking Water Regulations Microorganisms MCLG1 MCL or Potential Health Effects Sources of (mg/L)2 TT1 from Ingestion of Water Contaminant in (mg/L)2 Drinking Water Cryptosporidium as of as of Gastrointestinal illness (e.g., Human and animal fecal 01/01/02: 01/01/02: diarrhea, vomiting, cramps). waste.

zero TT 3 Giardia lamblia zero TT3 Gastrointestinal illness (e.g., Human and animal fecal diarrhea, vomiting, cramps) waste Heterotrophic plate n/a TT3 HPC has no health effects, HPC measures a range count (HPC) but can indicate how of bacteria that are effective treatment is at naturally present in the controlling microorganisms. environment.

Legionella zero TT3 Legionnaire's Disease, Found naturally in water; commonly known as multiplies in heating pneumonia. systems.

Total Coliforms zero 5.0%4 Used as an indicator that Coliforms are naturally (including fecal other potentially harmful present in the coliform and E. Coli) bacteria may be present5. environment; fecal coliforms and E. coli come from human and animal fecal waste.

Turbidity n/a TT3 Turbidity is a measure of the Soil runoff cloudiness of water. It is used to indicate water quality and filtration effectiveness (i.e., whether disease-causing organisms are present). Higher turbidity levels are often associated with higher levels of disease-causing microorganisms such as viruses, parasites, and some bacteria. These organisms can cause symptoms such as nausea, cramps, diarrhea, and associated headaches.

Viruses (enteric) zero TT3 Gastrointestinal illness (e.g., Human and animal fecal diarrhea, vomiting, cramps). waste.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Disinfectants & MCLG1 MCL or Potential Health Sources of Disinfection (mg/L)2 TT1 Effects from Ingestion Contaminant in Byproducts (mg/L)2 of Water Drinking Water Bromate as of as of Increased risk of cancer. Byproduct of drinking 01/01/02: 01/01/02: water disinfection.

zero 0.010 Chloramines (as as of as of Eye/nose irritation; Water additive used to Cl2) 01/01/02: 01/01/02: stomach discomfort, control microbes.

MRDLG=41 MRDL=4.01 anemia.

Chlorine (as Cl2) as of as of Eye/nose irritation; Water additive used to 01/01/02: 01/01/02: stomach discomfort. control microbes.

MRDLG=41 MRDL=4.01 Chlorine dioxide (as as of as of Anemia; infants and Water additive used to ClO2) 01/01/02: 01/01/02: young children: nervous control microbes.

MRDLG=0.8 1 MRDL=0.81 system effects.

Chlorite as of as of Anemia; infants and Byproduct of drinking 01/01/02: 01/01/02: young children: nervous water disinfection.

0.8 1.0 system effects.

Haloacetic acids as of as of Increased risk of cancer. Byproduct of drinking (HAA5) 01/01/02: 01/01/02: water disinfection.

n/a6 0.060 Total none7 0.10 Liver, kidney, or central Byproduct of drinking Trihalomethanes ---------- ---------- nervous system problems; water disinfection.

(TTHMs) as of as of increased risk of cancer.

01/01/02: 01/01/02:

n/a6 0.080 Inorganic MCLG1 MCL or TT1 Potential Health Sources of Chemicals (mg/L)2 (mg/L)2 Effects from Ingestion Contaminant in of Water Drinking Water Antimony 0.006 0.006 Increase in blood Discharge from cholesterol; decrease in petroleum refineries; blood glucose. fire retardants; ceramics; electronics; solder.

Arsenic none7 0.01 Skin damage; circulatory Erosion of natural as of 1/23/06 system problems; deposits; runoff from increased risk of cancer. glass and electronics production wastes.

Asbestos 7 million fibers 7 MFL Increased risk of Decay of asbestos (fiber >10 per liter developing benign cement in water mains; micrometers) intestinal polyps. erosion of natural deposits.

Barium 2 2 Increase in blood Discharge of drilling pressure. wastes; discharge from metal refineries; erosion of natural deposits.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Inorganic MCLG1 MCL or TT1 Potential Health Sources of Chemicals (mg/L)2 (mg/L)2 Effects from Ingestion Contaminant in of Water Drinking Water Beryllium 0.004 0.004 Intestinal lesions. Discharge from metal refineries and coal-burning factories; discharge from electrical, aerospace, and defense industries.

Cadmium 0.005 0.005 Kidney damage. Corrosion of galvanized pipes; erosion of natural deposits; discharge from metal refineries; runoff from waste batteries and paints.

Chromium (total) 0.1 0.1 Some people who use Discharge from steel water containing and pulp mills; erosion chromium well in excess of natural deposits.

of the MCL over many years could experience allergic dermatitis.

Copper 1.3 TT8; Short term exposure: Corrosion of household Action Gastrointestinal distress. plumbing systems; Level=1.3 Long term exposure: Liver erosion of natural or kidney damage. People deposits.

with Wilson's Disease should consult their personal doctor if their water systems exceed the copper action level.

Cyanide (as free 0.2 0.2 Nerve damage or thyroid Discharge from cyanide) problems. steel/metal factories; discharge from plastic and fertilizer factories.

Fluoride 4.0 4.0 Bone disease (pain and Water additive which tenderness of the bones); promotes strong teeth; Children may get mottled erosion of natural teeth. deposits; discharge from fertilizer and aluminum factories.

Lead zero TT8; Infants and children: Corrosion of household Action Delays in physical or plumbing systems; Level=0.015 mental development. erosion of natural Adults: Kidney problems; deposits.

high blood pressure.

Mercury (inorganic) 0.002 0.002 Kidney damage. Erosion of natural deposits; discharge from refineries and factories; runoff from landfills and cropland.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Inorganic MCLG1 MCL or TT1 Potential Health Sources of Chemicals (mg/L)2 (mg/L)2 Effects from Ingestion Contaminant in of Water Drinking Water Nitrate (measured 10 10 "Blue baby syndrome" in Runoff from fertilizer as Nitrogen) infants under six months - use; leaching from life threatening without septic tanks, sewage; immediate medical erosion of natural attention. Symptoms: deposits.

Infant looks blue and has shortness of breath.

Nitrite (measured 1 1 "Blue baby syndrome" in Runoff from fertilizer as Nitrogen) infants under six months - use; leaching from life threatening without septic tanks, sewage; immediate medical erosion of natural attention. Symptoms: deposits.

Infant looks blue and has shortness of breath.

Selenium 0.05 0.05 Hair or fingernail loss; Discharge from numbness in fingers or petroleum refineries; toes; circulatory erosion of natural problems. deposits; discharge from mines.

Thallium 0.0005 0.002 Hair loss; changes in Leaching from ore-blood; kidney, intestine, or processing sites; liver problems. discharge from electronics, glass, and pharmaceutical companies.

Organic MCLG1 MCL or Potential Health Sources of Chemicals (mg/L)2 TT1 Effects from Ingestion Contaminant in (mg/L)2 of Water Drinking Water Acrylamide zero TT9 Nervous system or blood Added to water during problems; increased risk sewage/wastewater of cancer. treatment.

Alachlor zero 0.002 Eye, liver, kidney or Runoff from herbicide spleen problems; anemia; used on row crops.

risk of cancer.

Atrazine 0.003 0.003 Cardiovascular system Runoff from herbicide problems; reproductive used on row crops.

difficulties.

Benzene zero 0.005 Anemia; decrease in Discharge from blood platelets; increased factories; leaching from risk of cancer. gas storage tanks and landfills.

Benzo(a)pyrene zero 0.0002 Reproductive difficulties; Leaching from linings of (PAHs) increased risk of cancer. water storage tanks and distribution lines.

Carbofuran 0.04 0.04 Problems with blood or Leaching of soil nervous system; fumigant used on rice reproductive difficulties. and alfalfa.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Organic MCLG1 MCL or Potential Health Sources of Chemicals (mg/L)2 TT1 Effects from Ingestion Contaminant in (mg/L)2 of Water Drinking Water Carbon zero 0.005 Liver problems; increased Discharge from tetrachloride risk of cancer. chemical plants and other industrial activities.

Chlordane zero 0.002 Liver or nervous system Residue of banned problems; increased risk termiticide.

of cancer.

Chlorobenzene 0.1 0.1 Liver or kidney problems. Discharge from chemical and agricultural chemical factories.

2,4-D 0.07 0.07 Kidney, liver, or adrenal Runoff from herbicide gland problems. used on row crops.

Dalapon 0.2 0.2 Minor kidney changes. Runoff from herbicide used on rights of way.

1,2-Dibromo zero 0.0002 Reproductive difficulties; Runoff/leaching from chloropropane increased risk of cancer. soil fumigant used on (DBCP) soybeans, cotton, pineapples, and orchards.

o-Dichlorobenzene 0.6 0.6 Liver, kidney, or Discharge from circulatory system industrial chemical problems. factories.

p-Dichlorobenzene 0.075 0.075 Anemia; liver, kidney or Discharge from spleen damage. industrial chemical factories.

1,2-Dichloroethane zero 0.005 Increased risk of cancer. Discharge from industrial chemical factories.

1,1- 0.007 0.007 Liver problems. Discharge from Dichloroethylene industrial chemical factories.

cis-1,2- 0.07 0.07 Liver problems. Discharge from Dichloroethylene industrial chemical factories.

trans-1,2- 0.1 0.1 Liver problems. Discharge from Dichloroethylene industrial chemical factories.

Dichloromethane zero 0.005 Liver problems; risk of Discharge from cancer. pharmaceutical and chemical factories.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Organic MCLG1 MCL or Potential Health Sources of Chemicals (mg/L)2 TT1 Effects from Ingestion Contaminant in (mg/L)2 of Water Drinking Water 1,2- zero 0.005 Increased risk of cancer. Discharge from Dichloropropane industrial chemical factories.

Di(2-ethylhexyl) 0.4 0.4 General toxic effects or Leaching from PVC adipate reproductive difficulties. plumbing systems; discharge from chemical factories.

Di(2-ethylhexyl) zero 0.006 Reproductive difficulties; Discharge from rubber phthalate liver problems; increased and chemical factories.

risk of cancer.

Dinoseb 0.007 0.007 Reproductive difficulties. Runoff from herbicide used on soybeans and vegetables.

Dioxin (2,3,7,8- zero 0.00000003 Reproductive difficulties; Emissions from waste TCDD) increased risk of cancer. incineration and other combustion; discharge from chemical factories.

Diquat 0.02 0.02 Cataracts. Runoff from herbicide use.

Endothall 0.1 0.1 Stomach and intestinal Runoff from herbicide problems. use.

Endrin 0.002 0.002 Nervous system effects. Residue of banned insecticide.

Epichlorohydrin zero TT9 Stomach problems; Discharge from reproductive difficulties; industrial chemical risk of cancer. factories; added to water during treatment process.

Ethylbenzene 0.7 0.7 Liver/kidney problems. Discharge from petroleum refineries.

Ethylene dibromide zero 0.00005 Stomach problems; Discharge from reproductive difficulties; petroleum refineries.

increased risk of cancer.

Glyphosate 0.7 0.7 Kidney problems; Runoff from herbicide reproductive difficulties. use.

Heptachlor zero 0.0004 Liver damage; increased Residue of banned risk of cancer. termiticide.

Heptachlor epoxide zero 0.0002 Liver damage; increased Breakdown of risk of cancer. heptachlor.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Organic MCLG1 MCL or TT1 Potential Health Sources of Chemicals (mg/L)2 (mg/L)2 Effects from Ingestion Contaminant in of Water Drinking Water Hexachlorobenzene zero 0.001 Liver or kidney problems; Discharge from reproductive difficulties; metal refineries and increased risk of cancer. agricultural chemical factories.

Hexachlorocyclopentadiene 0.05 0.05 Kidney or stomach Discharge from problems. chemical factories.

Lindane 0.0002 0.0002 Liver or kidney problems. Runoff/leaching from insecticide used on cattle, lumber, gardens.

Methoxychlor 0.04 0.04 Reproductive difficulties. Runoff/leaching from insecticide used on fruits, vegetables.

Oxamyl (Vydate) 0.2 0.2 Slight nervous system Runoff/leaching effects. from insecticide used on apples, potatoes/ tomatoes.

Polychlorinated zero 0.0005 Skin changes; thymus Runoff from biphenyls (PCBs) gland problems; immune landfills; discharge deficiencies; reproductive of waste chemicals.

or nervous system difficulties; increased risk of cancer Pentachlorophenol zero 0.001 Liver or kidney problems; Discharge from increased risk of cancer. wood preserving factories.

Picloram 0.5 0.5 Liver problems. Herbicide runoff.

Simazine 0.004 0.004 Problems with blood. Herbicide runoff.

Styrene 0.1 0.1 Liver, kidney, and Discharge from circulatory problems. rubber and plastic factories; leaching from landfills.

Tetrachloroethylene zero 0.005 Liver problems; increased Discharge from risk of cancer. factories and dry cleaners.

Toluene 1 1 Nervous system, kidney, Discharge from or liver problems. petroleum factories.

Toxaphene zero 0.003 Kidney, liver, or thyroid Runoff/leaching problems; increased risk from insecticide of cancer. used on cotton and cattle.

2,4,5-TP (Silvex) 0.05 0.05 Liver problems. Residue of banned herbicide.

1,2,4-Trichlorobenzene 0.07 0.07 Changes in adrenal Discharge from glands. textile finishing factories.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-4 (continued)

Organic MCLG1 MCL or Potential Health Sources of Chemicals (mg/L)2 TT1 Effects from Ingestion Contaminant in (mg/L)2 of Water Drinking Water 1,1,1- 0.20 0.2 Liver, nervous system or Discharge from metal Trichloroethane circulatory problems. degreasing sites and other factories.

1,1,2- 0.003 0.005 Liver, kidney, or immune Discharge from Trichloroethane system problems. industrial chemical factories.

Trichloroethylene zero 0.005 Liver problems; increased Discharge from risk of cancer. petroleum refineries.

Vinyl chloride zero 0.002 Increased risk of cancer. Leaching from PVC pipes; discharge from plastic factories.

Xylenes (total) 10 10 Nervous system damage. Discharge from petroleum factories; discharge from chemical factories.

Radionuclides MCLG1 MCL or Potential Health Sources of (mg/L)2 TT1 Effects from Ingestion Contaminant in (mg/L)2 of Water Drinking Water Alpha particles none7 15 Increased risk of cancer. Erosion of natural

picocuries deposits.

as of per Liter 12/08/03: (pCi/L) zero Beta particles and none7 4 millirems Increased risk of cancer. Decay of natural and photon emitters ---------- per year man-made deposits.

as of 12/08/03:

zero Radium 226 and none7 5 pCi/L Increased risk of cancer. Erosion of natural Radium 228 --------- deposits.

(combined) as of 12/08/03:

zero Uranium as of as of Increased risk of cancer, Erosion of natural 12/08/03: 12/08/03: kidney toxicity. deposits.

zero 30 ug/L Notes 1

Definitions:

Maximum Contaminant Level (MCL) - The highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. MCLs are enforceable standards.

Maximum Contaminant Level Goal (MCLG) - The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Maximum Residual Disinfectant Level (MRDL) - The highest level of a disinfectant allowed in drinking water. There is convincing evidence that addition of a disinfectant is necessary for control of microbial contaminants.

Maximum Residual Disinfectant Level Goal (MRDLG) - The level of a drinking water disinfectant below which there is no known or expected risk to health. MRDLGs do not reflect the benefits of the use of disinfectants to control microbial contaminants.

Treatment Technique - A required process intended to reduce the level of a contaminant in drinking water.

2 Units are in milligrams per liter (mg/L) unless otherwise noted. Milligrams per liter are equivalent to parts per million.

3 USEPA's surface water treatment rules require systems using surface water or groundwater under the direct influence of surface water to (1) disinfect their water, and (2) filter their water or meet criteria for avoiding filtration so that the following contaminants are controlled at the following levels:

Cryptosporidium: 99% removal/inactivation Giardia lamblia: 99.9 percent removal/inactivation Viruses: 99.99 percent removal/inactivation Legionella: No limit, but USEPA believes that if Giardia and viruses are removed/ inactivated, Legionella will also be controlled.

Turbidity: Filtration systems must achieve a filtered water turbidity level of less than or equal to 0.3 NTU for 95 percent of measurements taken each month, and less than or equal to 1.0 NTU at all times. Water utilities are required to record the effluent turbidity of individual filters every 15 minutes. For any individual filter that has a measured turbidity level greater than 1.0 NTU in two consecutive measurements taken 15 minutes apart, a report of the filter number, the turbidity measurement, and the date(s) on which the filter exceeded this limit must be included. In addition, a profile on the individual filter must be maintained and reported to the State, depending on the measurement of NTU that exceeded the limit.

HPC: No more than 500 bacterial colonies per milliliter.

4 No more than 5.0 percent samples total coliform-positive in a month. (For water systems that collect fewer than 40 routine samples per month, no more than one sample can be total coliform-positive). Every sample that has total coliforms must be analyzed for fecal coliforms. There may not be any fecal coliforms or E. coli.

5 Fecal coliform and E. coli are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Disease-causing microbes (pathogens) in these wastes can cause diarrhea, cramps, nausea, headaches, or other symptoms. These pathogens may pose a special health risk for infants, young children, and people with severely compromised immune systems.

6 Although there is no collective MCLG for this contaminant group, there are individual MCLGs for some of the individual contaminants:

Trihalomethanes: bromodichloromethane (zero); bromoform (zero); dibromochloromethane (0.06 mg/L). Chloroform is regulated with this group but has no MCLG.

Haloacetic acids: dichloroacetic acid (zero); trichloroacetic acid (0.3 mg/L). Monochloroacetic acid, bromoacetic acid, and dibromoacetic acid are regulated with this group but have no MCLGs.

7 MCLGs were not established before the 1986 Amendments to the Safe Drinking Water Act. Therefore, there is no MCLG for this contaminant.

8 Lead and copper are regulated by a Treatment Technique that requires systems to control the corrosiveness of their water. If more than 10% of tap water samples exceed the action level, water systems must take additional steps. For copper, the action level is 1.3 mg/L, and for lead is 0.015 mg/L.

9 Each water system must certify, in writing, to the state (using third-party or manufacturer's certification) that when acrylamide and epichlorohydrin are used in drinking water systems, the combination (or product) of dose and monomer level does not exceed the levels specified, as follows:

Acrylamide = 0.05% dosed at 1 mg/L (or equivalent).

Epichlorohydrin = 0.01% dosed at 20 mg/L (or equivalent).

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations National Secondary Drinking Water Regulations National Secondary Drinking Water Regulations (NSDWRs or secondary standards) are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. USEPA recommends secondary standards to water systems but does not require systems to comply as summarized in Table 4-5. However, states may choose to adopt them as enforceable standards.

Table 4-5 National Secondary Drinking Water Standards Contaminant Secondary Standard Aluminum 0.05 to 0.2 mg/L Chloride 250 mg/L Color 15 (color units)

Copper 1.0 mg/L Corrosivity Noncorrosive Fluoride 2.0 mg/L Foaming Agents 0.5 mg/L Iron 0.3 mg/L Manganese 0.05 mg/L Odor 3 threshold odor number pH 6.5-8.5 Silver 0.10 mg/L Sulfate 250 mg/L Total Dissolved Solids 500 mg/L Zinc 5 mg/L Microorganisms Conventional coagulation/clarification/filtration and chlorine disinfection meets all current federal requirements for control of microorganisms. However, recent regulations are more restrictive with respect to Cryptosporidium.

Disinfectants and Disinfection By-products (D/DBPs)

The RO and granular activated carbon (GAC) processes will remove the majority of the DBP pre-cursors, thereby minimizing DBP formation. The DBP formation potential of RO and GAC treated water will be evaluated as part of the Pilot Study.

Inorganic Chemicals Compliance should be achievable with membrane filtration and reverse osmosis.

Organic Chemicals The selected process (microfiltration/ultrafiltration, RO, and GAC) provides a multi-barrier approach for removal of organic chemicals. Contaminant removal will be demonstrated in the Pilot Study.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Radionuclides Except for one sample, all radionuclides in the water quality sampling were below MCLs. The one exception, was a gross beta level of 62 pCi/L in one sample from Site

5. The treatment process will remove most radionuclides, except for tritium.

4.3.1 Current Regulations Under the 1996 SDWA Amendments, the USEPA developed several regulations that became effective in late 1990s and early 2006 and will affect the HWSP. These regulations are the Interim Enhanced Surface Water Treatment Rule (IESWTR), Stage 1 D/DBPR, Stage 2 D/DBPR, the Long Term Stage 1 Enhanced Surface Water Treatment Rule (LT1ESWTR), the Long Term Stage 2 Enhanced Surface Water Treatment Rule (LT2ESWTR), Filter Backwash Recycling Rule (FBRR), Ground Water Rule, and the Lead and Copper Rule (LCR) revisions.

4.3.1.1 IESWTR and LT1ESWTR Turbidity Requirements As part of the IESWTR, promulgated in 1998, turbidity can be measured in two ways:

combined filter effluent (CFE) and individual filter effluent (IFE). As of January 1, 2002, where population served is equal or greater than 10,000 people, the CFE value recorded at least every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must not exceed 0.3 NTU in at least 95 percent of the measurements taken each month. The LT1ESWTR subsequently applied this limit to smaller surface water systems. Additionally, the CFE level of representative samples must not exceed 1.0 NTU at any time. The most significant change in the monitoring requirements is that the utility is required to record the IFE every 15 minutes. In addition to the past reporting and record keeping requirements, the utility is required to report turbidity measurements within 10 days after the end of each month.

Information in this report must include the following:

The total number of CFE measurements taken during the month.

The number and percentage of CFE measurements taken during the month, which are less than or equal to the 95 percent limit.

The date and value of any CFE measurements taken during the month, which exceed 1.0 NTU for systems using conventional filtration treatment or direct filtration, or which exceed the maximum level set by the state.

The IFE monitoring conducted and any follow-up actions taken for exceedances during the month.

Utilities must maintain their record keeping for the above requirements for a minimum of three years. The additional IFE follow-up and reporting requirements include:

For any IFE recordings greater than 1.0 NTU in two consecutive measurements taken 15 minutes apart, a report of the filter number, the turbidity value, the date(s) on which the filter exceeded the limit and the cause (if known) must be reported to 4-23 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations NYSDOH. In cases where cause for an exceedance is unknown, a profile on the individual filter must be produced within 7 days and reported to NYSDOH.

For any IFE recordings greater than 1.0 NTU in two consecutive measurements taken 15 minutes apart at the same filter for 3 months in a row, filter self-assessment should be conducted within 14 days and a report of the filter number, the turbidity value, the date(s) on which the filter exceeded the limit, and the produced filter self-assessment must be reported to NYSDOH.

If two consecutive IFE recordings exceed 2.0 NTU and were taken 15 minutes apart at the same filter for 2 months in a row, a comprehensive performance evaluation (CPE) must be performed within 30 days and the CPE report must be submitted to NYSDOH within 90 days. In addition, a report including the filter number, turbidity value and the date(s) on which the filter exceeded the limit shall be submitted to NYSDOH by the 10th of the following month.

4.3.1.2 Stage 1 D/DBPR MCLs for Disinfection By-Products The Stage 1 D/DBPR, which intended to reduce the levels of disinfectants and disinfection by-products (DBPs) in drinking water supplies, became effective in February 1999. Under the D/DBPR, two groups of chlorinated DBPs - total trihalomethanes (TTHMs) and five haloacetic acids (HAA5) - are regulated in two stages. In Stage 1, USEPA set MCLs of 80 g/L and 60 g/L, as annual averages, for TTHMs and HAA5, respectively. Compliance is defined on the basis of a running annual average (RAA) of quarterly averages of all samples. Monitoring requirements for systems serving 10,000 people or more include collection of four water samples from the distribution system per quarter per treatment plant. The sampling locations should be representative of the average residence time in the distribution system with at least 25 percent of the samples to be taken at locations that represent the maximum residence time of water. For systems monitoring quarterly, if the RAA of quarterly averages covering any consecutive four-quarter period exceeds the MCL, the system is in violation of the MCL and must notify the public, in addition to reporting to the State.

In addition, MRDLs in the distribution system were established for chlorine (4 mg/L),

chloramines (4 mg/L), and chlorine dioxide (0.8 mg/L). Table 4-6 provides the final MRDLGs and MRDLs. Table 4-7 includes the MCLs and MCLGs for the disinfection byproducts.

4.3.1.3 Total Organic Carbon (TOC) Removal The Stage 1 D/DBPR also requires that utilities achieve specific TOC removals to control DBP precursors. The amount of TOC that must be removed is dependent upon the alkalinity and TOC concentration of the raw water. Table 2-10 shows the percent removal of TOC that is required under this Rule. Percent removal is measured upstream of the point of primary disinfection. Thus, if chlorine is not added until after the filters for chlorine contact time, then the TOC of the filtered water may be compared to the TOC of the raw water to calculate TOC removal.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Table 4-6 Stage 1 MRDLGs and MRDLs for Disinfectants Parameter MRDLG MRDL Compliance Routine (mg/L) (mg/L) Based On Monitoring Chlorine 4.0 4 RAA TCR sampling (as free Cl2)

Chloramines 4.0 4 RAA TCR sampling (as combined Cl2)

Chlorine Dioxide 0.8 0.8 (as ClO2) Sample Daily at entry point results collected on two consecutive days Table 4-7 Stage 1 MCLGs and MCLs for Disinfection By-Products Parameter MCLG MCDL Compliance Routine (mg/L) (mg/L) Based On Monitoring Chlorite 0.8 1.0 Average of Daily at entry point, each 3-sample monthly in set* distribution system Bromate 0 0.010 RAA Monthly at entry point TTHMs n/a 0.080 RAA 4/plant/qtr HAAs(5) n/a 0.060 RAA 4/plant/qtr Chloroform 0 n/a - -

Bromodichloromethane 0 n/a - -

Dibromochloromethane 0.06 n/a - -

Bromoform 0 n/a - -

Dichloroacetic acid 0 n/a - -

Trichloroacetic acid 0.3 n/a - -

Notes:

A set of samples collected for chlorite on the same day in the distribution system at the following sites: one at the first customer served, one at a representative site and one at the waters maximum residence time.

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Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations The TOC removal requirements would most likely be met with a combination of pretreatment, RO, and GAC.

Table 4-8 TOC Percent Removal Source-Water Alkalinity (mg/L as CaCO 3)

Source-Water TOC (mg/L)

<60 60-120 >120

> 2.0-4.0 35 25 15

> 4.0-8.0 45 35 25

> 8.0 50 40 30 The Stage 1 D/DBPR provides exemptions for enhanced coagulation. The key exemptions are:

1. Source or treated water TOC running average is below 2.0 mg/L

2. TTHM < 40 ppb, HAAs < 30 ppb, and use only free chlorine

3. Source water specific ultraviolet absorbance (SUVA) 2.0 L/mg m running annual average

4. Finished water SUVA 2.0 L/mg m 4.3.1.4 Disinfection Profiling/Benchmarking Under the IESWTR, a utility must monitor daily for a period of 12 consecutive calendar months to determine the total logs of Giardia lamblia inactivation for each day of operation based on the published CT99.9 values throughout the entire treatment plant. Additionally, any utility that uses either chloramines or ozone for primary disinfection must also calculate the logs inactivation for viruses using a method approved by NYSDOH.

If a system is modifying its disinfection practices to comply with the new regulations, it must calculate their disinfection benchmark by determining the lowest average monthly Giardia lamblia inactivation in each year of profiling data. They must also determine the average Giardia lamblia inactivation for each calendar month for each year of profiling data.

4.3.1.5 Stage 2 D/DBPR MCLs and MCLGs for Disinfection Byproducts The final Stage 2 D/DBPR, as promulgated in January 2006, is designed to reduce DBP occurrence peaks in the distribution system based on changes to compliance monitoring provisions. Compliance monitoring is preceded by an Initial Distribution System Evaluation (IDSE) to find the worst-case distribution system sample points.

These locations will then be used by the systems as the sampling sites for Stage 2 DBP rule compliance monitoring. The number of compliance monitoring sites is determined by the population served and the source water type. Compliance is defined on the basis of a locational running annual average (LRAA) of TTHMs and 4-26 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations HAA5. Compliance must be met at each monitoring location, instead of system-wide using the RAA under the Stage 1 D/DBPR. The Stage 2 D/DBPR will limit all sample points in the distribution system to RAA of 80 g/L TTHMs and 60 g/L of HAA5.

4.3.1.6 LT2ESWTR Cryptosporidium Treatment Details The LT2ESWTR was released simultaneously with Stage 2 DBPR on January 4, 2006 to address concerns about risk tradeoffs between pathogens and DBPs.

In order to have an extra barrier to Cryptosporidium, additional removal/inactivation capabilities like UV are recommended as soon as affordable in the future. Level of treatment required based on LT2ESWTR is listed as follows:

If the average Cryptosporidium concentration is between 0.075/L and 1.0/L, then 1 log treatment is required.

If the average Cryptosporidium concentration is between 1/L and 3/L, then 2 log treatment is required with at least 1 log being by ozone, chlorine dioxide, UV, membranes, bag/cartridge filters, or in-bank filtration.

If the average Cryptosporidium concentration is over 3.0/L, then 2.5 log treatment is required with at least 1 log being by ozone, chlorine dioxide, UV, membranes, bag/cartridge filters, or in-bank filtration.

Cryptosporidium removal/inactivation requirements listed in final Rule are as follow:

Watershed Control Program: 0.5 log credit and reductions in cysts as measured.

Alternative sources such as intake relocation: credit based on measured drop in cysts.

Pretreatment: Days of raw water storage and pre-settling with coagulant get 0.5 log credit. Weeks of raw water storage and in-bank filtration get 1 log credit.

Improved treatment: Monthly CFE turbidity of 0.15 NTU or less 95 percent of the time gets extra 0.5 log credit. Monthly IFE turbidity of 0.15 NTU or less 95 percent of the time with no individual filters greater than 0.3 NTU in two consecutive days get an extra 0.5 log credit. Slow sand filters and membranes get greater than 2.5 log credit.

Improved disinfection with chlorine dioxide, ozone, and UV.

4.3.1.7 Filter Backwash Recycling Rule (FBRR)

FBRR published on June 8, 2001 applies to all systems that use surface water or groundwater under the influence of surface water, employ conventional or direct filtration, and recycle one or more of the following:

Spent filter backwash water.

Thickener supernatant.

4-27 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations Liquids from dewatering processes.

Per FBRR, the utility has to report the following to NYSDOH:

Intent to recycle in writing.

A plant schematic showing the origin of all recycle flows, hydraulic conveyance used to transport the recycle flows, and location where they are recycled back into the plant.

Details of typical recycle flow, design flow for the WTP, and State-approved operating capacity.

In addition, the systems must collect and retain on file the following:

A copy of the recycle notification form.

A list of all recyle flows and the frequency at which they are returned.

Average and maximum backwash flow rates through the filters and the average and maximum duration of the filter backwash process, in minutes.

Typical filter run length and a written summary of how filter run length is determined.

If applicable, the type of treatment provided for the recycle stream before it enters the conventional process.

If applicable, data about the physical dimensions of the recycle treatment units, typical and maximum hydraulic loading rates, etc.

4.3.1.8 Ground Water Rule (GWR)

USEPA promulgated the final GWR in October 2006 that applies to all public water supply (PWS) systems that use groundwater. The rule also applies to systems that mix surface and groundwater and if the groundwater is added directly to the distribution system and provided to consumers without equivalent surface water treatment.

Major components of the final GWR include:

Periodic sanitary surveys to identify the significant deficiencies. The initial survey is to be completed by December 31, 2012 for all community water systems.

Source water monitoring to test for E. coli, enterococci, or coliphage in the sample.

Corrective actions to rectify significant deficiency or source water fecal contamination.

Compliance monitoring to ensure that the treatment technology installed is able to meet 99.99 percent inactivation or removal of viruses.

4-28 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations 4.3.1.9 Lead and Copper Rule Revisions On January 12, 2000, the USEPA published minor revisions to the 1991 Lead and Copper Rule (LCR). The purpose of the Lead and Copper Rule Minor Revisions (LCRMR) is to eliminate unnecessary requirements, streamline and reduce reporting burden, and promote consistent national implementation. In some cases, USEPA has added language, which clarifies requirements and corrects oversights in the original rule. These revisions do not affect the lead or copper MCLGs, the action levels (ALs),

or the basic regulatory requirements of the rule.

Additional changes to the LCR were prepared on July 18, 2006 (USEPA, 2006).

Relevant changes include requiring water systems to:

Provide advanced notification to the primacy agency or intended changes in treatment or source water that could increase corrosion of lead.

Provide a notification of tap water monitoring results for lead to owners and/or occupants of homes and buildings that are part of the utilitys sampling program.

The USEPA is also proposing to change the content of the message to be provided to consumers, how the materials are delivered to consumers, and the timeframe in which materials must be delivered after a lead AL exceedance.

In the proposed revisions in June 2006, the USEPA requires PWSs to provide advanced notification to the state primacy agency of intended changes in treatment or source water that could increase corrosion of lead. The primacy agency must approve the planned changes using a process that will allow them and the PWSs to take as much time as needed to consult about potential problems.

4.3.1.10 Total Coliform Rule Revisions On July 14, 2010, the EPA published proposed revisions to the Total Coliform Rule (TCR). Last updated in 1989, the TCR establishes requirements for monitoring and treatment of pathogens, including distribution system monitoring. Key elements of the proposed rule changes include the following:

Eliminates the MCL and MCLG for total coliform and replaces it with an MCL and MCLG of zero for E. coli.

Establishes a treatment technique requirement for total coliform and E. coli as an indicator of a potential pathway of contamination into the distribution system.

Exceedances trigger the need to perform an assessment for sanitary defects.

Ties monitoring requirements to contamination risk and system performance.

Modifies violations and public notification requirements based on the new MCL and treatment technique requirements.

4-29 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Section 4 Water Quality, Quantity and Compliance with Drinking Water Regulations 4.3.2 Compliance with Current Regulations The water treatment plant will provide treatment that meets or exceeds the applicable rules and regulations outlined above and in accordance with NYSDOH requirements, including the Recommended Standards for Water Works (also known as the Ten State Standards).

4-30 W:\Projects\40306 - UWNY HUDSON RIVER DESALINATION\Permitting\PERMIT FOR FULL SCALE\2011_Water Supply Application\Water Supply Permit Components\Sept 29 2011 submission\Engineer's Report\04 Section 4_9-29-11_CLEAN.docx

Appendix A

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Appendix B

Table 1A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Clean Water Act Methods (40 CFR 136)

Haverstraw Water Supply Project United Water New York HISTORICAl. HUDSON RIVEIt WATER QUAlITY DATA 12OCI7-oa..11 sItft)!

FRACT10N/

.......... ......YI1CAI. REPORT UNITS

.ROUP METHOD NO. UMIT' s.:, I0.:.1 Mn Concentrltion Detected

....,

9S"*i" Aluminum, Total E200.7 200 "s/l 40 3S 2,. 3,100 .90 2,'"

Aluminum, Tota~ lDw Level NA Antimony E2oo.7 60/10 "s/l 40 0 NO NO NO NA NO NO NO Arsenic Barium E2oo.7 E2oo.7 10/5 200 "all "s/l '"'" 0 0 NO NO NO NA NA Beryllium E2oo.7 5/2 "s/l 40 0 NO NO NO NA 80~

Boron, Low level E2oo.7 NA 50 "s/l 216

'" 52 1,300 590 1,100 Cadmium E2oo.7 5 "s/l 40 0 NO NO NO NA Call:ium Chromium E2oo.7 E2oo.7 5000 10 "s/l "s/l 40 41 "0 15,000 NO 100,000 NO 61.000 NO 140,000 NA Coblillt NA Copper E2oo.7 25 "s/l 40 0 NO NO NO NA Cyanide* Total SM 4S00CN*E 0.01 mall 41 0 NO NO NO NA Cyanide, Amenable NA Iron, Total Iron, Total, Low Level E2oo.7 NA 100/150 "s/l 40

" 120 3,600 1.100 2,975 5,1 Lead MaSnI!slum E2oo.7 E2oo.7 5

5000 "s/l "s/l '"'" 2 33 6,200 6

300,000 5.6 120,000 5.96 290,000 Manganese, Total Manganese, Total, Low Level E2oo.7 NA 15 "s/l 41

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Radlum*226 E903.0 O.14to 0.18 pl:VL 1. 0 NO NO NO NA Cryptosporldlum E1623 0.1 _l 34 0 NO NO NO NA Fecal Coliform SM9221E 10/1 rolf/l00ml 216 179 10 900 110 401 Giardia E1623 0.1 Cym/l 34 2 0.1 0.1 0.1 0.1 Total Coliform SM9222B 2/1 rolf/lOOml 216 m 2 2,420 75. 2,419.2 Es<:herll:hla Coil 9223 1 dujl00mL 216 m 1 2400 110 .72 10F23

_ ._ _ _..-..rn>_...'.. _ _ , ............................._.............,;...

Table 1A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Clean Water Act Methods (40 CFR 136)

Haverstraw Water Supply Project United Water New York HISTORICAl. HUDSON RIVEIt WATER QUAlITY DATA 12OCI7-oa..11 sItft)!

FRACT10N/

.......... ......YI1CAI. REPORT UNITS

.ROUP METHOD NO. UMIT' s.:, I0.:.1 Mn Concentrltion Detected

....,

95"*i" Nates.

Genenl- Blanks in the bible indicate no ilnlllysis performed/no datil lIvailible.

-All results are based an laboratory analyses performed byTest Amertca, Inc.

1 The Laboratory Reporting Umtt Is the lawest concentration that can be reliably measured within specified limits afpreclslon and accuracy.

lHlstorkal Hudson River water quality data WIS collected by United Water between 2007 and 2008.

3 Water Quality models used for comparison are referenced In appended memo, SW-l.

{l} NO denotes not lietl!ctl!d.

12} NA dl!notes not appllcabll!.

13} BRL denotes below reporUng limit.

~ previously analyzed using EPA method 625 for Semi-Volatile Orpnic Compounds 5 Please nate that the Human Consumption of Fish classification H{FC} has mare sbingent guidelines than the Water Supply classification H{WS}.

I Based an 5/26/11 meetlnl with NYSOEC. Acute ratio - 46:1. Chronic ratio -131:1 7 Based an assumption of4108 removal of pathogens/mlcroblolagicals during pretreatment 20F23

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H8U~- ** ~

j~ " " t" t" E EE E '" E .. ~H ,

~ **

z i.

~ ~]

.\:l'" "'~-i*i!

. . II .;p.!"'" ",i!E"j

!S~ ~

H ii' a 88 ::E::E::E::I;::Ez :lii'iJlOlt::!:R ~~ ~

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I'

=* " i !

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si Iii L

iiM Ji " ~ I U i II

" N I r:-l f------7

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a ~

~

L J* a iii

~Q ~

.~ i i a iii! .! "

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~i " *

~ **

i :gl!ll~~

d~c;;,.;'

C

~

I~ '< ~~~5

~i "i 1I .~.§

~ il u d..;'d;::f

§ -

"! I ~ .. ~~

I-

.i r----::;-

":;1"':::1

'1 :!i:::l:!i:::l

tid 0, ,

n ;;; .. ;;; ....

. II 1i!i1i! I~

~~!\l

~

liU

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-8 oH h ~H .~

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o::\!;§ Ii

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT 12007...... sItn)~

. ~I~*I ANAlYTE ..oIlS GIIOUP M~NO. UMrr' Concentnltion o.tected

..... Mu A gs,...ile

'IX>

1,1,1-Trichloroethane SW8260B 5 "IiL 35 D ND ND ND NA 1,1.2.2-Tetrachloroethane NA 1,1,2-Trichloroethane SW8260B 5 "IiL 35 D ND ND ND NA 1,1-Dlchloroethane NA 1,1-DlchloroetliE!ne SW8260B 5 "IiL 35 D ND ND ND NA 1,2-Dibromo-3-Chloropropane SW8260B 5 "IiL 49 0 ND ND ND NA l,2-Dlbromoethane SW8260B 5 "IiL 36 D ND ND ND NA 1,2-Dlchloroethane SW8260B 5 "IiL 35 D ND ND ND NA 1,2-Dlchloropl'Qpanf! SW8260B 5 "IiL 35 D ND ND ND NA 2-Butanone NA 2-Hexanone NA 4-Methyl2-Pentanone NA Aortani! NA Benzene SW8260B 5 "IiL 35 1 0.23 0.23 0.23 0.23 Bromodlchloromethane NA Bromoform NA Bromomethiime NA Carbon Disulfide NA Carbon Tetrachlortde SW8260B 5 "IiL 35 D ND ND ND NA Chlornbenzene SW8260B 5 "IiL 35 D ND ND ND NA Chloroethane NA Chloroform NA Chloromethane NA cls-l,2-0Ichh::lrQE!thene SW8260B 5 "IiL 35 D ND ND ND NA cis-l,3-Dichloropropene NA Olbromochloromethane NA Olchlorodmuoromethane (Freon 12) NA Ethyl Ben;tene SW8260B 5 "IiL 35 D ND ND ND NA Methylene Chloride SW8260B 5 "IiL 35 8 0.28 1.1 OAl 0.845 Styrene SW8260B 5 "IiL 35 D ND ND ND NA Tetrabromobl!phenol A L200 0.1 "IiL 11 D ND ND ND NA Tfltrachlgroethene SW8260B 5 "IiL 35 D ND ND ND NA Toluflne SW8260B 5 "IiL 35 11 0.11 0.43 0.23 0.385 trans-l,2-Dlchlgroethene SW8260B 5 "IiL 35 D ND ND ND NA trans-l,3-Dlchlgropropehl! SW8260B 1 "IiL Trlchlol'Olrthene SW8260B 5 "IiL 35 D ND ND ND NA Vinyl Chlgrlde SW8260B 5 "IiL 35 D ND ND ND NA Xylene! - Total SW8260B 5 "IiL 35 D ND ND ND NA 1,2,4-Trlchlgrobenzene SW8270C 5 "IiL 35 D ND ND ND NA 1,2-Dlchlorobenzene SW8270C 5 "IiL 35 D ND ND ND NA 1,3-Dlchlorobenzene NA l,4-Dichlorobenzene NA 2,4,S-Trlchlgrophenol NA 2,4,6-Trlchlgrophenol SW8270C 10 "IiL 11 0 ND ND ND NA 2,4-Dlchlorophenol NA 2,4-Dimethylphenol NA 2,4-0lnltrophenol NA 2,4-Dlnltrotoluene NA 2,6-DlnltrotollJf!ne NA 2-Ollgronaphthalene NA 2-Ollgrophengl NA 2-Methyl-4,6-Dlnltrophengl NA 2-Methylnaphthalene NA 2-Nitroanilihl! NA 2-Nltrophenol NA 3,3'-Dlchlgrobenzldlne NA 3-Nitroanilihl! NA 4,6-Dlnltro-2-Methylphenol NA 4-Bromgphenyl Phenyl Ether NA 4-Ollgro-3-Methylphengl NA 4-Ollgroaniline NA 4-Ollgrophenyl Phenyl Ether NA 4-Methylphenol NA iOF23 \~--'-~'---"""-"-'"-~

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT 12007...... sItn)~

. ~I~*I ANAlYTE ..oIlS GIIOUP M~NO. UMrr' Concentnltion o.tected

..... Mu A gs,...ile 4 Nltraanlllne NA 4-Nitrophencl NA Acenaphthene NA Acenaphthylene NA Anthracene SW8270C 10 ...." 16 0 ND ND ND NA Atra~lrtI! SW8270C 1lI 22 0 ND ND NO NA Benzo(a)Anthracene Benzo(a)Pyrene NA NA BenzolblFluorantnene NA Bl!n~18hI)Peryiene NA Benzo(k)Fluoranthene NA blsl2-Chloroethoxy) Methane NA bls(2-0dol'Oethyl) Ether NA bls(2-0dorolsopropylJ Ether NA bis(2-Ethylhexyl) Phthalate bls(20Ehtylhexyl) Adlpate SW8270C E525 10 1

16 11 0

0 ND ND ND ND NO ND NA NA DIoxin 12,3,7,8-TIDD} SW8270C 1lI PIll 14 1 14 14 14 14 Butyl Benzyl Phthalate NA Carbazole NA Chrysene NA Dlbenzo(a,h)Anthracene NA Dibenzofur.m NA orethyl Phthalate NA Dimethyl Phthalate NA Ol-N-Butyl Phthalate NA Di-N-octyl Phthalate NA Ruoranthene NA Fluorene NA Hl!!lCaChlQl'tlbenzell!! SW8270C 10/1 16 0 NO ND NO NA Hexachlorobutadiene Hexachlorocyclopentadlene NA SW8270C 10

"'...."" 16 0 ND ND ND NA Hexachloroethane NA Indeno(l,2.,3-cdjPyn!ne NA lsophorone NA Naphthalene NA Nitrobenzene NA n-Nltroso-dl-n-Propylamlne NA n-Nltrosodfphenylamlne NA Pentachlorophenol SW8270C '0 ...." 27 0 ND ND ND NA Phenanthrene NA Phenol SW8270C 1lI 16 0 NO ND NO NA Phenol5, Total Pyre" NA NA 2,4,S-T swa151 0.5 "", , 0 ND ND ND NA 4,4'-000 swa081 0.05 16 0 ND ND ND NA 4,4'-00E 4,4'-001 swa081 swa081 0.05 0.05

"", 16 16 0

0 NO NO NO ND NO NO NA NA Alachlor Aldlcarb E525 ES31.1 1

1

"'"'"" 11 1

0 0

ND ND ND ND ND ND NA NA Aldlcarb Sulfone E531.1 1 "'"

"", 1 0 ND ND NO NA Aldlcarb Sulfoxide Aldrin ES31.1 SW8081 1

0.05

"", 1 16 0

0 NO ND NO ND NO ND NA NA alpha-BHC SW8081 0.05 "'...."" 16 0 ND ND ND NA alpha-Chlordane beta-BHC swa081 swa081 0.05 0.05

"", 22 16 0

0 ND ND ND ND NO NO NA NA CarlHlryl Carbofuran ES31.1 ES31.1 1

1

"'"'....""" 1 10 0

0 ND ND ND ND ND ND NA NA ChlordOine NA delta-BHC swa081 0.05 16 0 ND ND NO NA Dfeldrin Dlnoseb 5W8D81 5W81S1 0.05 0.5

"'"'....""" 16 10 0

0 ND ND ND ND ND ND NA NA Oiquat Endothall E549.1 E548.1 1

50 11 11 0

0 NO ND ND ND NO ND NA NA Endosulfliln I SW8081 0.05 16 0 ND ND NO NA 90F23 \~--'-~'---"""-"-'"-~

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT 12007...... sItn)~

. ~I~*I ANAlYTE ..oIlS GIIOUP M~NO. UMrr' Concentnltion o.tected

..... Mu A gs,...ile Endosutfan II SWB081 0.05 ....,l 16 0 NO NO NO NA Endosulfan Sulfate SWB081 0.05 ....,l 16 0 NO NO NO NA Endrin SWB081 0.05 "Ill 16 0 NO NO NO NA Endrln aldehyde SWB081 0.05 "Ill 16 0 NO NO NO NA Endrln Ketone SWB081 0.05 ....,l 16 0 NO NO NO NA gamma-BHe SWB081 0.05 "Ill 16 0 NO NO NO NA pmma-Chlordane SWB081 0.05 "Ill 22 3 0.007 0.014 OD1 0.014 Glyphosate '547 10 "Ill 11 0 NO NO NO NA Heptachlor SWB081 0.05 ....,l 16 0 NO NO NO NA Hllptachlof epoxlde SWB081 0.05 "Ill 7 0 NO NO NO NA Methomyl ES31.1 1 "Ill 1 0 NO NO NO NA Methoxychlor SWB081 0.05 ....,l 16 0 NO NO NO NA DxlImyl ES31.1 1 ....,l 11 0 NO NO NO NA Simazlnll E525 O.S "Ill 11 0 NO NO NO NA Toxaphene SWB081 1 "Ill 16 0 NO NO NO NA Azlnphosmethyl NA Basudin, Neoadol NA Chlorpyrtfos NA Coumaphos NA CVBon NA Dasanit NA DDVP (Olchlorvos) NA Dememn NA Dllrnetcln-o NA Demeton-5 NA Olsulfoton NA EPN NA Ethoproph05 NA Ethyl Parathion NA Famphur NA Fenthion NA Midathion NA Methyl Parathion NA Mevlnphos NA O,O,D-Triethyl Ph05phorothioa1:e NA o,o-Diethylo-Pyrazlnyl NA Phosphorothloate Phorate NA Ronnel NA Stirophos NA Sulfotep NA Sulprofos NA Tokuthion (Prothiofos) NA Trichloronate NA Aroclor 1016 Aroclor 1221 SWB082 SWB082 O.S 1

....,l

....,l 18 0

0 NO NO NO NO NO NO NA NA Aroclor 1232 SWB082 O.S "Ill 18 0 NO NO NO NA Aroclor 1242 SWB082 O.S "Ill 18 0 NO NO NO NA Aroclor 1248 SWB082 O.S ....,l 18 0 NO NO NO NA Aroclor 1254 SWB082 O.S "Ill 18 0 NO NO NO NA Aroclor 1260 SWB082 O.S "Ill 18 0 NO NO NO NA Decachlorobiphenyl-209 (Sur) NA PCB 1011BZ) NA PCB 1051BZ) NA PCB 118(BZ) NA PCB 1261BZ) NA PCB 1281BZ) NA PCB 1381BZ) NA PCB 153(BZ) NA PCB 1561BZ) NA PCB 1691BZ) NA PCB 170IBZ) NA 100F23 \~--'-~'---"""-"-'"-~

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT ANAlYTE ..oIlS I I GIIOUP M~NO. UMrr' Concentnltion o.tected

..... Mu A gs,...ile PCB 18 (Bl} NA PCB 180(BZ) NA PCB 183 (82) NA PCB 184IBl) NA PCB 187 (BZ) NA PCB 195 (BZ) NA PCB 206 (BZ) NA pea2S (HZ) NA PCB 44 (BZJ NA PCB 49 (Bl} NA PCB 52 (HZ) NA peB66 (Bl} NA PCB 77 (BZ) NA PCBB(BZ) NA PCBS7 (82) NA peB9D (BZ) NA 1,4-Dlchlorobenzene NA l-M£!thylnapthall!ne NA 2-Methylnaphthalene NA 17alpha-£stradlol 1211 o.s "1/' 11 0 NO NO NO NA 17alpha-Ethynyl estradiol 1211 o.s "1/' 11 0 NO NO NO NA 17b1rta-Estradlol 1211 o.s "1/' 11 0 NO NO NO NA 3-Hydroxylcarbofuran ES31.1 1 "1/' 1 0 NO NO NO NA 4-n-octylphenol 1200 o.s "1/' 11 0 NO NO NO NA Acetaminophen Acetophenone E169(

NA SO "1/' 11 4 1

6 NA Amoxlclllon 1221 0.05 "1/' 9 0 NO NO NO NA Anthracene NA Antipyrine 12'0 0.001 "SI' 11 0 NO NO NO NA Aspirin 1221 0.05 "SI' 11 S 0.06 0.34 0.22 NA Azlthromydn E1694 10 "1/' 11 0 NO NO NO NA Bat::ltracln 1220 o.s "SI' 9 0 NO NO NO NA BenzolaJpyrene BNASIM/SW8270CSIM 52/50 "Si' 16 0 NO NO NO NA Bezafibrate 1221 O.S "1/' 11 0 NO NO NO NA Bisphenol A Bromoform caffl!lne Carbadox L200/MS-SIM NA L220/E1694 12'0 0.1/1 5/50 SO "1/'

"Si' "1/'

11 11 11 0

11 0

NO 60 NO NO NO NO 131 NO NA NA NA Carbamazeplne Ll20/E1694 0.1/10 "1/' 11 11 12 5 NA Carbazole NA ChlllramphenlCQI 1221 S "Si' 11 0 NO NO NO NA Chillrotetracycline 1221 SO "1/' 11 0 NO NO NO NA ClproflllXadne 12'0 SO "1/' 11 0 NO NO NO NA cis-TestllSterone 1211 0.1 "Si' 11 0 NO NO NO NA Cloffbrlc Acid CIltinine 1221 L220/E1694 o.s 1/10 "Si' "1/'

11 11 0

11 ,

NO NO 12 NO 9

NA 12 OEEr DlchlDfenec 12'0 1221 1/8 O.S "1/'

"Si' 11 11 11 0

NO 179 NO 51 NO 116 NA Diethylstilbestrlll (DES)

Dlltlazem 1211 L220/E1694 O.S 1/5 "Si' "1/'

11 11 ,0 NO 1

NO 1

NA 1

Doxyc.ycIlne 1221 0.05 "1/' 11 0 NO NO NO NA EnroflllXilcin 12'0 0.05 "SI' 11 0 NO NO NO NA Erythromycin 12'0 0.001 "SI' 11 0 NO NO NO NA estriol 1211 O.S "1/' 11 0 NO NO NO NA Estrone 1211 O.S "Si' 11 0 NO NO NO NA Fluoranthene Fluoxetine (ProitilcJ BNASIM/SW8270C 51 M L220/E1694 52/50 1/25 "Si' "Si' 16 11 0

1 ,

NO NO NO NA Galaxallde Gemflbrozll 5170 L221/E1694 10 0.5/25 "1/'

"Si' 11 11 10 11 ,.*

12 65 13 28 6

NA 11 Ibuprofen L221/E1594 SO/2S "Si' 11 0 NO NO NO NA lsophorone NA I~SOpropy1 Benzene NA Lasalocld 12'0 1 "Si' 11 0 NO NO NO NA I..evothyroxine (Synthroid) NO NO NO NA 12'0 SO "1/' " 0 110F23 \~--'-~'---"""-"-'"-~

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT ANAlYTE ..oIlS I~*I GIIOUP M~NO. UMrr' Concentnltion o.tected

..... Mu A gs,...ile Lincomycin L220/E1694 0.1/10 ogIL 11 4 0.1 0.1 0.1 0.1 Monensin U20 0.1 ogIL 11 0 NO NO NO NA Naphthalene 827OC/BNASIM/5W827OC SIM 0.01/52/50 ogIL 16 0 NO NO NO NA Naproxen L220/E1694 2/50 ogIL 11 11 0.002 0.007 0.003 0.006 Nara5in U20 0.1 ogIL 11 0 NO NO NO NA Nicotine U20 O.OOS ogIL 11 10 0.01 0.199 0.0881 0.1954 Nonylphenol Dlethoxylate (Tech.) NA Norfloxatin U'O 500 ogIL 4 0 NO NO NO NA OleiilndomY'=in U20 1 ogIL 11 0 NO NO NO NA Oxytetracydlne U21 500 ogIL 11 0 NO NO NO NA p-Nonylphenol (Tech.) NA p-tert-Odylphenol L200jMS-SIM 0.0005/1 "SIL 11 0 NO NO NO NA Pentachlorophenol NA Paraxanthlne Penicillin G U20 U21 ,,5 ogIL ogIL 11 11 11 0

NO 75 NO 41 NO 74.5 NA Penicillin V U21 ogIL 11 0 NO NO NO NA Phenanthrene NA Phenol E625/SW8270C 10 ogIL 16 0 NO NO NO NA Phenyl phenol PMi:lnlsOhe UOO 1.220/1..221 ,

100 ogIL ogIL 11 "11 0

0 NO NO NO NO NO NO NA NA Progesterone U11 100 ogIL 0 NO NO NO NA P'ln", 872OCjBNASIM/5W827OC SIM 10000/52/50 ogIL 16 0 NO NO NO NA RDXlthromyc:ln U'O 1 ogIL 11 0 NO NO NO NA Sallnomyc:ln 0.1 0 NO NO NO NA Simvastatin U20/L2Z1 U20 1 ogIL ogIL "11 0 NO NO NO NA 5 0 NO NO NO NA Sulfachloropyrldazlne L220/l.221 5

ogIL

" 0 NO NO NO NO Sulfadiazine L220/l.221 0.1 ogIL

" 1 0.1 0.1 0.1 0.1 Sulfadimethoxine L220/l.221 5

ogIL

" 0 NO NO NO NO Sulfamerazine L220/L221 1

ogIL

" 0 NO NO NO NA Sulfamethazine L220/l.221 5

ogIL

" 0 NO NO NO NA Sulfanethlzole L220/l.221 ogIL

" 11

NA Sulfilmethoxawle L220/L221/E1694 S/2S 5

ogIL

" 0 NO 13 NO 8

NO NA Sulfathiazole Theobromine L220/L221 U20 50 ogIL ogIL "11 0 NO NO NO NA Theophylline Tonalid U21 5170 10 5 ogIL ogIL 11 11 1

0 NO NO NO NA trans-Testosterone U11 0.1 ogIL 11 0 NO NO NO NA Trlclosan Trlmethoprlm NA L220/E1694 1/10 ogIL 11 4 1 , 1 1.5 0 NO NO NO NA Tylosin Virginiamycin Ml L220/l.221/E1694 L22D/L221 1/10 0.5 ogIL ogIL "11 0 NO NO NO NA Chromium (Hexavalent Compounds) SW7196A 10 ogIL Asbe5tos ELAP 198.2 -10 M 0.02 mfi Chloride NA Petroleum Hydrocarbons C1D-OS NA Perchlorate NA SiliCil 200.7/A4500C/SM4S0D-SI-C 1/0.1/1 mg/l. 73 73 1.' 15 4.' 5.'

A... NA TobIl Alpe (includinB Diiiltom) NA Alkiilllnlty, Total As CaC03 A2320B 5 mg/l. 194 192 8.7 110 59 80.9 Alkiilllnlty, Bicarbonate NA Alkiilllnlty, Hydroxide (caCO) NA Alkiillinity, Total As CilC03 NA BOD20 NA BOO5 NA Chlorophyll A NA Conductivity NA OOC SM5310B 1 mgJI. 324 '79 1 4.4 2.485 3.91 N,Total Ortho P, Total CALC SM4500P-E-ORTHO 0.03 mg/l.

mgJI.

67 74

0 1.'

NO 4.'

NO 2.844 NO 4.54 NA 120F23 \~--'-~'---"""-"-'"-~

Table 2A - Summary of Historical Hudson River Water Quality Laboratory Analytical Data, Non-Clean Water Ad Methods Haverstraw Water Supply Project United Water New York HISTOIUCAL HUDSON RIVER WATER QUAUT FRACTION/ ANALYTlCAL REPORT ANAlYTE ..oIlS I I .....,

GIIOUP M~NO. UMrr' Mu A gs,...ile TOS TOC TSS UV254 SM2S4OC SMS31OC/SMS310B SM2540D SMS910B 100/10 10 0.009 mg/l mgJl mg/l 110m 324 325 324 112 300 278 112

. 08 11,000 4.7

'00 0.26 2,9S7 2.536 25.475 0.12 8,200 U

67.95 0.19 Color, ApPirent Field 15 mgJl Cesium-137 NA Radium-228 Strontlum-89 70D-SR/SR-D3-RC-MOD 0.33 to 0.39 0.57 to 0.84 pcf/L perIL 19 10 NO ORl NO 0.75 NO NA NA NA Strontlum-90 70O-SR/E905.0/SR-03-RC MOD 0.15 tClO.51 perIL 11 11 ORl 0.98 N' NA 11 11 ORl OR1 NA Tritium Uranium E906.0 SW6020 120 0.1400 0.7 ....,.

pcVL 21 10 ORl 0.98 N'

N' NA M

Diawm NA HPC tfu/mL .79 321 SM92158 '/1

'" '10 2 738 Notes.

General- Blanks in the table indicate no analysis perfonned/no data available.

- All results are based on laboratory analyses performed byTest America, Inc.

t The Laboratory Reportln! Limit Is the lowl!!St contl!!ntratlon that can IH! ~lIablv measul"l!!d within sPl!!!dfled limits of precision and accuracy.

2 Historical Hudson Riverwater quality data was collected by United Water between 2007 and 2008.

3 Watf!r Quality models used feJr comparison art! l"Idl!rt!nced In append!!d m!!mo, SW-1.

(1) NO denotes not detected.

(2) NA denob!s not applicable.

(3) BRL denotes below rt!porting limit*

previously analyzed using EPA method 625 feJr Semi-Volatile Orsanlc Compounds 5 Plea5e note that the Human Consumption of Fish clclssification H(FC} hilS more stringent guidelines thiln the Wiilter Supply cliIS5ification H{WS}.

6 Based on 5/26/11 meeting with NYSDEC, Acute ratio -46:1, Chronic ratio -131:1 7 Based on assumption of 4 log removal of pathosens/microbiologicals during pretrt!atment 130F23 \~--'-~'---"""-"-'"-~

TlIb.. 2& - Summlllry of Pilot WatH Quality Labomory Analytkal Data.

NDn-tlean water Act Methods (Raw Water. RO Influent. and RO Concentrate)

Haverstraw Water Supply Project United Watler N_ York

-...... .....m .....""""

METtIJONQ, ...,.

HWSP I'ILOT MWWATn DATA

..!. I..:.. I ....

(11K. 201D -.1liiy 2011J ConcantrIIiDn ~

....

95%-;1.

..!.I..:..I HWSP I'IlOTIIO NLlJENTDATA (DK. 2010 -.1liiy 21111 ConcantrlliDn ~

Mo.

".... ..!. I..:..* I HWSP I'ILOT ItO IXIJiIaN1'MTI! DATA IIJK. 201D -.1liiy 2011J ConcantrlliDn ~

"'.H 4,4'-DDD

~

4,4'-DDE ~

4,4'-DDT ~

A1achlar A1dialrb '"

~

A1dk:irb SuIfaM A1dk:irb SlMtwJde

~Iphll-DHC

~Iph&-Chlordan!

~

bm-BHC '"

~

C;1I11iryl CIIl'bofuran '"

~

Chlardanle ~

deltll-BHC ~

Dlleldrin ~

DlnDll!!b ~

Dlquit ~

EndDlha11 ~

Endosu/f;on I ~

Endasulhm II Endos..r.n Sulfab! '"

~

Endrtn ~

Endrtn Iidehyde Endrin Ketane '"

~

pmmHlHC ~

I8mm&-chlardlne GlyphaSlb! '"

~

H.,.ntir;hior ~

Hepar;hior epmclde ~

Mettoamyl ~

Methrlxychllll" ~

On"",

51",..lne '"

~

Toxaphene AzinphaslMlhyl SW8141 B;..ud." Neocldal SWIIlA.2

,, *oIl ChlarpyrJfas SW8lA3

oIl CDumlpt,as SWII144 SWI!I145 DilSilnlt SW8lA6 DDVP IDlchlorvasl

,~"

SW8147 5WII148 ",,'

,~""

SW8149

,~""

SWI!I150 DI.ulfDlon SWlI151

'" SW8152

" " " " " 1

___ ~ _ _ """ __ "'h'--::'=

140f2!

TlIb.. 2& - Summlllry of Pilot WatH Quality Labomory Analytkal Data.

NDn-tlean water Act Methods (Raw Water. RO Influent. and RO Concentrate)

Haverstraw Water Supply Project United Watler N_ York

-...... Ethoprophas Ethyl Parathion

.....m .....""""

METtIJONQ.

SW8153 SWI154 ooJL ooJL ,, 0 0

HWSP I'ILOT MWWATn DATA

..!., I..:.. I ....

(11K. 201D -.1liiy 2011J ConcantrIIiDn ~

95%-;1.

..!.I..:..I 0

0 HWSP I'IlOTIIO NLlJENTDATA (DK. 2010 -.1liiy 21111 ConcantraliDn ~

Mo.

..!. I..:..* I 0

0 HWSP I'ILOT ItO IXIJiIaN1'MTI! DATA IIJK. 201D -.1liiy 2011J ConcantraliDn ~

Fimpl!ur SWIIIS5 ooJL ooJL ,, 0 0 " " '" " ,,

0 0 "" "" "" "" ,,

0 0 " " " "

Fanthlon SW8156 Mallthion SWIJ1S7 ooJL

,, 0 0

0 Methyl P~mhlon MevlnphDl SWIIIS8 0

0

"" "'" "" 0 0

0 0 "" " "" "

SWIJ159 o,.llp-Tril!lhyl Phasphorathicm. SWII160 0 0 0 o,D-lllethylo-l'yrImyI , , '" " , , " "

0 0 0 SW8161 "oil PhOlpharothlaile PhOr;1! ooJL Ronnel SWIJ162 0

0 "" "" "" "" ,,

0 0 " " " " 0 0 "" "" "" ""

SW8163 S1lrophos SW8164 ""'- 0

" " '" " 0 0 ooJL 0

,, 0 0 Sulfoll!p 5WII165 Suiprofoli

, ""'- 0 "" "" "" "" 0 " " " ,, 0 "" "" "" ""

Tolwtllian (Prothiafosj SW8166 SWIJ1&7

, 0

"" "" "" "" , 0 "" "" "" 0 Trkhloronile ooJL 0 0 0 SWII168 Arodor 1016 Arodor 1221 Aroda. 1232 "'"'"

Arodor 1242 Aroda. 1248 Arodor 1254 Aroda. 1260 Oe<:i<hloroblphMYI.2M (Sur)

PCB 101 (Bl) """'"

0 0.36 " 0."" " ,,

0

"" "" "" " U 0

0 0 PCB IDS (Bl)

PCB 1111 (Bl)

"""'" ,, 0 "" "" "" "" ,, 0 "" "" "" "'" 0.31 0.59 0.31 0.59 0.31 0.59 0.31 PCB 126 (Bl) 0

"" "" "'" "" 0

"" "" " "" 0 PCB 128 (BlI PCB 1311 (BZ)

....., ,, 0 0 ,, 0 0 '" 0 0

PCB 153 (Bl) 0 0 0 PCB 156 (Bl) 0 0 0 PCB 169 (Bl)

....., ,, 0 " " " 0 " " 0 " " "

PC8170 (Bl) 0 0 0 PCB18(Bl) 0.75 U U 0.58 U U PCB 180 (Bl)

....., ,, ,, , 0 0

,, 0 PCB 183 (Bl) 0.55 0.55 0.55 0." 0 PC8114 (BlI

....., ,, ,, 0 0

"" "" ,, 0 PCB 187 (Bl) 0 0 0 PCB 195 (Bl) 0 0 0 PCB 206 (Bl)

PCB 28(Bl)

PCB 44(Bl)

PCB 49(Bl)

SW8082 0

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Appendix C

Memorandum DEIS Support Technical Memorandum (TM # SW-1) July 2, 2010 Source Water and Receiving Water Analysis Introduction The purpose of this technical memorandum is to provide additional information requested by New York State Department of Environmental Conservation *(NYSDEC) as part of the Final Scoping Document for a DEIS for the United Water New Yorks (United Water) proposed Haverstraw Water Supply Project. This memo addresses NYSDECs request for the following additional information:

The discussion of existing water quality of the Hudson River, and the effects on that water quality from relevant industrial or municipal wastewater discharges and other relevant activities, will be expanded. Specific information to be provided will include:

Assess potential contaminants reaching the intake site as a result of upstream dredging of PCBs, including data from the proposed pilot operation as well as any water quality sampling data available from the PCB dredging operations; Evaluate possible contamination at the proposed intake site by groundwater flow from the former Haverstraw landfill, based on sampling data from landfill monitoring wells as well as sampling data from proposed intake or pilot operation; modeling may be used to augment or support conclusions, but may not be substituted for sampling; Identify and assess potential contaminant loads at the proposed intake site from discharges to the river by other industrial operations, including waste water treatment plants and power generation facilities; location maps and discharge profiles will be provided for all such discharges within 25 miles of the proposed water intake site, and pilot plant sampling will specifically test for constituents of these identified discharges; Identify and assess impacts on water quality at the proposed intake site of existing significant non-point water pollution sources within 25 miles of the proposed intake site, including but not limited to agricultural or landscaping operations adjoining the shoreline, and storm drain discharges; and Based on available water quality data and information gathered during operation of the pilot plant, provide a full chemical and contaminate profile of Hudson River

July 2, 2010 Page 2 water at the intake; analysis of data should reflect changes over time, including but not limited to tidal and seasonal variations as well as any effects of large precipitation or storm water flow event (such as spring runoff).

United Water requested an assessment of potential contaminants reaching the Haverstraw Water Supply Project intake and a profile of water quality constituents at the intake location. In response, this technical memorandum has been developed and addresses several key potential sources of contamination identified by NYSDEC. These are:

Upstream dredging of PCBs Haverstraw Landfill groundwater Indian Point Nuclear Power Plant Other loadings within a 25-mile radius Each of these potential sources is discussed below in the context of a water quality profile at the intake location.

1.0 Assessment of Potential Impacts at the Intake from Upstream Dredging of PCBs The assessment of potential impacts at the intake from upstream dredging of PCBs includes a consideration of both measured data and model results for pre-dredging, during-dredging, and post-dredging conditions.

Pre-Dredging Conditions - The New York State Department of Health (DOH) began monitoring nine public drinking water supplies on the Hudson River for PCBs in May 2008 to establish a baseline before now on-going General Electric dredging of con-taminated sediments in the Upper Hudson River commenced in 2009 from. The dredging will occur along a 40 mile stretch of the Hudson River from river mile 153.9 to river mile 193.7. The southern-most of the drinking water supplies monitored is at Poughkeepsie. Poughkeepsie (about river mile 80) is significantly upstream and closer to the General Electric dredging than the proposed Haverstraw intake (about river mile 38). The measured baseline PCB concentration for Poughkeepsie raw water was less than 68.7 ng/L. The measured baseline PCB concentration for Poughkeepsie treated water was less than 31.1 ng/L. These data were web available from DOH in February 2010 at http://www.nyhealth.gov/press/releases/2008/2008 21_pcb_testing_pre_dredging.htm and http://www.nyhealth.gov/environmental/water/drinking/hudson_river_baseline_mo nitoring_program_summary_2008.htm. In New York State, the drinking water maximum concentration for PCBs is 500 ng/L. Thus, prior to General Electric dredging, raw water PCB levels at Poughkeepsie were at least seven times smaller than the final maximum drinking water standard. These DOH measurements at Poughkeepsie set a reasonable expectation for even lower pre-dredging PCB levels at the proposed Haverstraw intake.

July 2, 2010 Page 3 A lower pre-dredging baseline PCB concentration for the proposed Haverstraw intake would be approximately 12 - 34 ng/L (average 25 ng/L), based on data collected by NYSDEC in 1998-2000 in the Hudson River between the Bear Mountain Bridge and the Tappan Zee Bridge on four occasions. These data have been included in an August 2003 report web available on February 1, 2010 at http://www.dec.ny.gov/docs/water_pdf/carp.pdf. Thus, prior to General Electric dredging, raw water PCB levels near the proposed Haverstraw intake were at least fourteen times smaller than the final maximum drinking water standard over a range of tidal and seasonal conditions.

In addition, 2007 and 2008 Hudson River water quality monitoring conducted by United Water, reported non-detects for a number of PCB Aroclors near the proposed intake over a range of tidal and seasonal conditions.

During-Dredging Conditions - Dredging of the Upper Hudson River began in 2009 and was suspended after a few months. Phase 1 dredging occurred between May 15 and October 26, 2009 and 10% of a six year project was completed. Phase 2 dredging is anticipated to start in May 2011. Phase 1 dredging is described at www.hudsondredgingdata.com. During Phase 1 dredging activities, in-river PCB samples were collected and analyzed. Samples were collected far upstream of the proposed Haverstraw intake site, in the vicinity of the dredging with the southernmost samples collected at Poughkeepsie, NY.

During Phase 1 dredging, the 500 ng/L drinking water standard was exceeded near the dredging site; however that was not the case near Poughkeepsie and, by inference, further downstream in the vicinity of United Waters proposed intake. Per Figures I-3-4 and I-3-5 of the March 2010 Hudson River PCBs Site EPA Phase I Evaluation Report available at www.hudsondredgingdata.com, tri+PCB homolog concentrations in the Hudson River near Poughkeepsie ranged from 10 to 21 ng/L and total PCBs measured via the Green Bay analytical laboratory method ranged from 17 to 26 ng/L. Both of these ranges are based on seven samples collected between May and November 2009 during and immediately following Phase I Upper Hudson River dredging for a variety of seasonal and tidal conditions. Thus, PCB levels in the Hudson River during Phase 1 Upper Hudson River dredging operations were not problematic from a drinking water perspective near Poughkeepsie, the southernmost extent of regulatory monitoring for the Upper Hudson River dredging project.

The Green Bay and tri+PCB methods have been accepted by EPA, NYSDEC, and NYSDOH for measuring PCB concentrations. The tri+PCB method captures the mass of all of the PCB congeners with three to ten chlorine substitutions, but misses those congeners with one and two chlorine substitutions. The Green Bay method records peaks from an analytical instrument which can then be converted to congeners and homologs.

July 2, 2010 Page 4 Expected PCB concentrations near the proposed United Water Intake when dredging operations resume are below 26 ng/L. Below 26 ng/L is not dissimilar to and is statistically the same as what might be expected absent dredging activities (e.g.,

measurements made by NYSDEC from 1998 to 2000 in Haverstraw Bay, less than 34 ng/L). One plausible explanation for why dredging activities on the Upper Hudson River do not elevate downstream water concentrations of PCBs (as demonstrated by measured data) is that sediments contaminated with PCBs that are suspended during dredging operations on the Upper Hudson River settle back to the sediment bed in upstream reaches of the River.

Further, as explained by Mr. Walter Mugdan, Director of the Emergency and Remedial Response Division at the Region 2 office of the EPA, during a March 15, 2010 seminar at the Smithsonians National Museum of the American Indian in New York City, a resuspension standard used for the Upper Hudson River PCB remedial dredging was specifically designed to protect drinking water intakes downriver of the dredging operations. Mr. Mugdan also indicated that it is likely that the resuspension standard would be modified for Phase 2 dredging expected to commence in 2011. The 500 ng/L drinking water standard for PCBs was achieved during the dredging operations even 20 to 30 miles upstream of the nearest Hudson River drinking water intake. Mr. Mugdan indicated that there were no measurable impacts to the Lower Hudson River as a result of the Phase 1 dredging. Visual aids from Mr. Mugdans presentation, titled Hudson River Dredging - Overview and Update, are web-available at http://www.hudsonriver.org. Final decisions regarding the next phase of Upper Hudson River PCB dredging will be made by EPA sometime after June 2010.

It is anticipated that when Upper Hudson River remedial dredging resumes in 2011, United Water will be collecting Hudson River water quality data at its proposed intake location for the Haverstraw Water Supply Project and the EPA will again be monitoring Hudson River water quality at Poughkeepsie, NY.

Post-Dredging Conditions - At some point in the future, the dredging of the Upper Hudson River will be completed and a large source of PCBs to the lower Hudson River will be removed. Based on previous HydroQual modeling work for the Contaminant Assessment and Reduction Project (CARP), the Upper Hudson River is responsible for up to 93% of the PCB concentration resulting near the proposed United Water intake in Haverstraw Bay (see CARP matrix downloadable from http://www.carpweb.org ).

The EPA has projected changes to the PCB loading to the lower Hudson River at Albany in the future as a result of the completion of the Upper Hudson River dredging. These projected changes include a 98% drop over sixty-nine years in annual PCBs delivered from the Upper Hudson River at Albany according to the column labeled R20RS (REM 3/10/Select - w/0.13%resuspension) - 6 yr dredge in Table 363150-7, Tri+ PCB Load Over Federal Dam, on page 70 of Responsiveness Summary Hudson River PCBs Site Record

July 2, 2010 Page 5 of Decision, web available at http://www.epa.gov/hudson/Resp_Summ_Files/rsbk3-02.pdf.

Concentrations in the lower Hudson River resulting from the expected post-dredging PCB loading change have been modeled by HydroQual for the Contaminant Assessment and Reduction Project (CARP). The CARP model results, accessed by HydroQual specifically for United Water Haverstraw Water Supply Project New York State Environmental Quality Review Act (SEQR) purposes, suggest that near the proposed United Water Intake, future (i.e., 37 years from now) PCB water column concentrations from the Upper Hudson River and all other expected sources (e.g., in-place legacy sediments, STPs, CSO, runoff, atmospheric deposition, etc.) will be 2 - 10 ng/L, at least a 10 ng/L decrease from NYSDEC 1998-2000 CARP measurements in Haverstraw Bay.

During a March 15, 2010 seminar at the Smithsonians National Museum of the American Indian in New York City, Mr. Walter Mugdan, Director of the Emergency and Remedial Response Division at the Region 2 office of the EPA, indicated that the EPAs Record of Decision (ROD) projection for the drop in PCB loadings to the Hudson River resulting from future completion of Upper Hudson River dredging was likely an overestimate by a factor of two or three times. The projection included assumptions about natural attenuation and burial of PCBs which the agency now considers to be overestimated.

The CARP modeled estimate of less than 10 ng/L of PCBs in Haverstraw Bay after completion of the Upper Hudson River dredging is probably a factor of three higher, less than 30 ng/L rather than 10 ng/L, based on EPAs recently reported concern that loadings reductions it reported in the ROD are overestimated. Even 30 ng/L near the proposed Haverstraw Water Supply Project Intake would not pose a drinking water threat to human health as described below. Given the uncertainty regarding the PCB loading to the lower Hudson River at Albany in the future after the completion of the Upper Hudson River dredging, a modeling analysis which considers a worst-case future with current PCB loadings is relevant.

Concentrations in the lower Hudson River resulting from a no action case on the Upper Hudson River have been modeled by HydroQual for the Contaminant Assessment and Reduction Project (CARP). The CARP model results, accessed by HydroQual specifically for United Water Haverstraw Water Supply Project SEQR purposes, suggest that near the proposed United Water Intake, future (i.e., 37 years from now) PCB water column concentrations from the Upper Hudson River and all other expected sources (e.g., in-place legacy sediments, Sewage Treatment Plants, Combined Sewage Overflows, runoff, atmospheric deposition, etc.) will be 13.6 - 55.2 ng/L (average 31.6 ng/L) in Haverstraw Bay without any Upper Hudson River remedial action. This result suggests that even without Upper Hudson River remediation, there will be almost a factor of ten between the safe drinking waters standard and PCB levels near the proposed water intake.

July 2, 2010 Page 6 On the basis of measurements and numerical modeling, future PCB concentrations in the Hudson River near the proposed United Water intake will be far below the safe drinking water standard of 500ng/L both during continued Upper Hudson River dredging activities and after Upper Hudson River dredging is completed. The raw water at the proposed intake will be compliant with the PCB drinking water standard, even without the further PCB removal that United Waters proposed treatment system will achieve.

2.0 Assessment of Potential Impacts at the Intake from Groundwater Flow from Former Haverstraw Landfill To date, a release from the Haverstraw Landfill via groundwater to the Hudson River has not been identified by the CDM team.

3.0 Identification and Assessment of Contaminant Loadings within a 25-Mile Radius A wide range of contaminants and contaminant sources have been considered and are described below. At the request of NYSDEC, sources and contaminants were identified within a 25-mile radius. As part of this process, although not requested directly by NYSDEC, added attention has been given to the topic of discharge of radionuclides from the Indian Point Nuclear Power Plant due to the location of the Indian Point Nuclear Power Plant relative to the proposed United Water Haverstraw Water Supply Intake.

3.1 Identification of Contaminant Loadings within a 25-Mile Radius Contaminant sources were identified by considering the Toxics Release Inventory (TRI),

the National Priorities List (NPL), and the State Pollutant Discharge Elimination System (SPDES) facilities/sites databases. Data were obtained within a 26-mile radius of the proposed United Water Haverstraw Water Supply Intake to be fully inclusive of a 25-mile radius.

Two criteria were used to determine which facilities/sites to include. The first criterion was distance from the facility/site to the proposed intake location. The second criterion was whether or not the facility/site location would ultimately drain to the Hudson River within the search radius. The watersheds draining to the Hudson River within the 26 mile radius were identified. Figure 1 displays both the search radius and those watersheds that drain to the Hudson River within the search radius. As shown on Figure 1, there are 18 relevant watersheds in total. The 18 watersheds are named on Figure 1. Twelve of the watersheds each include drainage areas not immediately adjacent to the Hudson River and each ultimately discharges to discrete locations along the Hudson River. Six of the watersheds are immediately adjacent to the Hudson River and drain directly to the Hudson River, dispersed along a length of the shoreline.

When identifying facilities/sites to be included in the analysis, all facilities/sites falling outside of the search radius, facilities/sites that discharge to watersheds that do not

July 2, 2010 Page 7 drain to the Hudson River and those draining to the Hudson River outside of the search radius were eliminated. Those facilities discharging within one of the 12 non-adjacent watersheds were assigned a discharge location to the Hudson River corresponding to the watershed drainage point. The remaining facilities falling within the six watersheds adjacent to the Hudson River were assigned individual discharge locations along the River. All facilities within the search area were included regardless of whether they have discharge data. For instances where no discharge data are available, either estimates can later be made for the loads of individual chemicals or the loads can be left as zero where an estimate is not possible or appropriate. Figure 2 displays the locations of the contaminant sources identified from NPL, SPDES, and TRI. Figure 3 displays these locations along with the Hudson River discharge locations used in numerical modeling simulations.

3.1.1 Identification of SPDES Facilities The SPDES permitted facilities to be considered were determined using data supplied by AKRF as well as data available through the EPA Permit Compliance System (PCS)

(http://www.epa.gov/enviro/html/pcs/pcs_query_java.html) and the Enforcement &

Compliance History Online (ECHO) (http://www.epa-echo.gov/echo/

compliance_report_water_icp.html) websites. All facilities were queried for the region.

The list resulting from the regional query was shortened to only those falling within watersheds draining to the Hudson River within 26 miles of the intake location. The query list included both major and minor discharges. The majority of the minor discharges did not have any monitoring data available. All discharges to tributaries of the Hudson River were assigned the tributarys discharge location on the Hudson River for numerical modeling purposes. All of the major discharges that discharge directly to the Hudson River were assigned individual discharge locations. The minor dischargers discharging directly to the Hudson River were assigned either the nearest tributary or major discharge point for numerical modeling purposes. In total, there were 19 major discharges and 366 minor discharges included. The major facilities are listed in Table 1.

A complete list of major and minor facilities is included in Appendix A.

Table 1. Major SPDES Discharges Included in the Model Permit Name Discharge Watershed NY0006262 DANSKAMMER GENERATING Breakneck Brook-Hudson River STATION NY0008231 ROSETON GENERATING STATION Breakneck Brook-Hudson River NY0025976 BEACON (C) WPCP Breakneck Brook-Hudson River

July 2, 2010 Page 8 NY0026310 NEWBURGH (C) WWTP Breakneck Brook-Hudson River NY0005096 IBM - EAST FISHKILL FACILITY Wiccopee Creek-Fishkill Creek NY0022144 CORNWALL (T) WWTP Silver Stream-Moodna Creek NY0022446 NEW WINDSOR (T) STP Silver Stream-Moodna Creek NY0023761 WEST POINT-TARGET HILL STP Foundry Brook-Hudson River NY0100803 PEEKSKILL SANITARY SD WWTP Annsville Creek NY0004472 INDIAN POINT NUCLEAR POWER Furnace Brook-Hudson River PLANT NY0005711 LOVETT GENERATING STATION Furnace Brook-Hudson River NY0028851 STONY POINT (T) STP Furnace Brook-Hudson River NY0028533 HAVERSTRAW JOINT REGIONAL Furnace Brook-Hudson River STP NY0008010 BOWLINE POINT GENERATING Furnace Brook-Hudson River STATION NY0026743 YORKTOWN HEIGHTS SD WWTP Bailey Brook-Croton River NY0108324 OSSINING SANITARY SD WWTP Sparta Brook-Hudson River NY0026051 ORANGETOWN (T) SD#2 STP Sparkill Creek-Hudson River NY0031895 ROCKLAND CO SD#1 STP Sparkill Creek-Hudson River NY0026689 YONKERS JOINT WWTP Sparkill Creek-Hudson River 3.1.2 Identification of TRI Facilities The TRI facilities were identified using data supplied by AKRF as well as data available through the National Institute of Health (NIH) and National Library of Medicine (NLM)

TRI/NPL website (http://toxmap.nlm.nih.gov/toxmap/main/index.jsp) and the EPA TRI website (http://www.epa.gov/enviro/html/tris/index.html). Similar to the approach used for the SPDES data, all facilities/sites for the region were queried and then narrowed down to those discharging to watersheds draining to the Hudson River within the search radius. In addition, all sites with no releases to the water were identified and eliminated from the list of sites. All sites with reported releases to water between the years 1988 and 2008 were included. Sites were assigned discharge points if discharging directly to the Hudson River or the appropriate tributary discharge point if discharging to a tributary. A total of eighteen TRI facilities discharging to water within the search radius were identified. Of the 18 sites, 4 have major SPDES permits associated with them and 6 have minor SPDES permits associated with them. In this sense, only eight new sources were identified. The TRI facilities are listed in Table 2, with a complete list of all facilities/sites included in Appendix A.

Table 2. Toxic Release Inventory Discharges to Water Included in the Model TRI ID Name Discharge Watershed 10702GRPHT1050N GRAPHITE METALLIZING CORP Saw Mill River 10598NTLBSRTE13 IBM T. J. WATSON RESEARCH Bailey Brook-Croton River CENTER

July 2, 2010 Page 9 10548VHDSN138AL U.S. VA HUDSON VALLEY Furnace Brook-Hudson HEALTHCARE SYSTEM River 10566THMRL1057L BASF PEEKSKILL PIGMENT Furnace Brook-Hudson FACILITY River 10980KYFRSKAYFR KAY-FRIES INC. Furnace Brook-Hudson River 10993LVTTGSAMSO MIRANT LOVETT GENERATING Furnace Brook-Hudson STATION River 10562MTLLZ19SOU METALLIZED CARBON CORP Sparta Brook-Hudson River 10701CBLCRFOOTO BICC UTILITY CABLE CO. Sparkill Creek-Hudson River 10962MNGRPROUTE MINIGRIP INC. Sparkill Creek-Hudson River 12553MBLLN1281R GLOBAL COS LLC NEWBURGH Quassaic Creek TERMINAL 10918CHSTR15OAK NEXANS ENERGY USA INC Silver Stream-Moodna Creek 12543STRNLHENRY EASTERN ALLOYS INC Silver Stream-Moodna Creek 12508THRSTONEEA THREE STAR ANODIZING Wiccopee Creek-Fishkill CORP. Creek 12533BM EASTF IBM CORP Wiccopee Creek-Fishkill Creek 12533MCRS HUDSO NXP SEMICONDUCTORS Wiccopee Creek-Fishkill Creek 12550DNSKM594RI DANSKAMMER GENERATING Breakneck Brook-Hudson FACILITY River 12550RSTNG992RA ROSETON GENERATING Breakneck Brook-Hudson FACILITY River 12553WRXTRRIVER WAREX TERMINALS CORP Breakneck Brook-Hudson NORTH TERMINAL River 3.1.3 Identification of NPL Sites NPL sites were identified in the same manner as the TRI sites using information obtained by AKRF along with information HydroQual obtained from the NIH/NLM website to get all sites for the region. Those sites that fall within the Hudson River watershed and the 26 mile search radius were selected. NPL sites were included regardless of status. Discharge points were assigned for each of the sites within the immediate Hudson River watershed and those in tributaries were assigned the tributary

July 2, 2010 Page 10 discharge location. The six NPL facilities are listed in Table 3, with a complete list included in Appendix A.

Table 3. National Priorities List Sites Included in the Model NPL ID Name Discharge Watershed NYD980780795 KATONAH MUNICIPAL WELL Bailey Brook-Croton River NYD980652275 BREWSTER WELL FIELD Bailey Brook-Croton River NYD010959757 MARATHON BATTERY CORP. Foundry Brook-Hudson River NYD000511451 NEPERA CHEMICAL CO., INC. Silver Stream-Moodna Creek NYSFN0204269 SHENANDOAH ROAD Wiccopee Creek-Fishkill GROUNDWATER Creek CONTAMINATION NY0002455756 CONSOLIDATED IRON AND Breakneck Brook-Hudson METAL River 3.1.4 Identification of Non-Point Source Inputs Non-point sources were identified in two ways. First, HydroQuals previous modeling of the NY/NJ Harbor Estuary includes models which estimate CSO and storm water (SW) discharge volumes from precipitation records, drainage areas, land-use types, and sewer system characteristics. Second, 67 of the minor SPDES permits identified in the 25-mile radius analysis for United Water are storm water permits.

3.1.5 Identification of Contaminants 133 different contaminants were identified from the SPDES, TRI, and NPL 25-mile radius searches. Based on the SPDES permitted facilities with available Discharge Monitoring Report (DMR) data, there were 82 different contaminants discharged by at least one discharger within the search area. There were TRI releases of 44 different contaminants reported within the search area by at least one facility. There were 55 contaminants of concern listed across all of the NPL sites. There was some overlap in the contaminants identified across the different source types, and some that were unique to each source type.

In addition to the SPDES, TRI, and NPL data, data collected by NYSDEC CARP were considered. The Yonkers and Rockland County wastewater treatment facility effluents were sampled and analyzed by NYSDEC CARP for 288 different contaminants. These contaminants include: dioxin/furan congeners, PCB congeners, PAHs, organochlorine pesticides, and metals. Of the 288 contaminants measured by NYSDEC CARP in the STP effluents, 270 were detected at least once. Of these 270 contaminants detected in the STP effluents at least once, 263 did not appear in any of the SPDES, TRI or NPL databases. Including the contaminants measured by NYSDEC CARP, there are 396

July 2, 2010 Page 11 unique contaminants within a 25-mile radius of the proposed intake. 193 of the contaminants are PCB congeners. The contaminants are listed in Appendix B.

In addition, CARP also monitored contaminant concentrations throughout the region at CSO and stormwater discharge points and in small runoff-dominated tributaries.

Together with volumetric discharge estimates from HydroQual watershed/sewershed models, CSO and stormwater loading estimates could be made for 270 contaminants measured by CARP.

3.2 Estimation of Contaminant Loadings The contaminant specific loadings developed for each discharge identified from SPDES and TRI are included in Appendix C. The development of these loading estimates was a large effort and involved decision making on a case by case basis based on varied types of information available. Information may have been aggregated for multiple outfalls associated with a given source, flow and concentration information may have been combined to develop a loading, or seasonal information may have been annualized, etc.

The loading estimates were a critical input requirement for completing the numerical modeling evaluation within the 25-mile radius. Specifically, the steps in the modeling evaluation were to: identify discharge locations, identify contaminants released, calculate loadings for each contaminant/discharge location, perform generic loading model simulations for each discharge location, and to scale generic model simulation results for specific contaminant loadings estimates. The loading estimates developed represent a great deal of information and are probably useful for purposes beyond Haverstraw Water Supply Project SEQR requirements.

Appendix C is a table ordered alphabetically by contaminant name. For each contaminant, the multiple sources of that contaminant are identified in adjacent rows.

The last row per contaminant looks at the multiple sources as a sum. The columns in Appendix C include: the facilities/sites and the model calculated mean and maximum response factors as presented in Appendix A, the contaminant name, the available loading data from SPDES and TRI, and finally the expected mean and maximum contaminant concentrations near the proposed intake location. The concentrations near the proposed intake location were calculated based on multiplying the model calculated response factors by the contaminant loadings.

3.2.1 Assessment of Contaminant Loadings within a 25-Mile Radius Specifically for the 25-mile radius evaluation, numerical model calculations were performed using the high resolution computational grid, hydrodynamic model, and contaminant transport model developed for the United Water project. The computational grid underlying the project modeling is shown on Figure 4.

July 2, 2010 Page 12 A generic continuous discharge release was simulated for each discharge location using the high resolution computational grid, hydrodynamic model, and contaminant transport models. The simulations produced the contaminant concentration resulting near the United Water intake location per unit loading from each identified facility/site contaminant source. The last two columns in the Appendix A table present the high resolution numerical model calculations of mean and maximum concentration resulting near the Haverstraw Water Supply Project proposed intake per unit loading release from the various facilities and sites identified.

The simulations were conservative in nature in that no decay or transformation processes were considered. In total, 72 model simulations were performed representing direct releases to the Hudson River from individual sources within immediately adjacent watersheds and aggregated source releases from non-adjacent watersheds. The conservative assumption of no attenuation of loadings from non-adjacent watersheds was used for these calculations in an attempt to maximize the loadings potentially reaching the proposed United Water intake. Each simulation included the fifteen water years from October 1994 to September 2009. The fifteen water years included in the simulations capture a wide range of seasonal variations and weather conditions.

The 72 model simulations were used to predict resulting concentrations in the Hudson River at the proposed United Water intake location due to specific contaminant releases.

Specifically, the generic model results for unit loadings were scaled based on the actual reported magnitudes of individual contaminant loadings. The individual discharge results for a given contaminant were then summed to determine the total estimated contaminant concentration at the proposed United Water intake site. This approach allows additional contaminants to be considered in the future without much additional effort other than developing loading estimates. If necessary, results for any additional sources could be estimated based on the results of nearby facilities/sites.

A limitation of the 72 simulation modeling approach is that it ignores partitioning of the contaminants onto particles. While it is true that the settling of particles out of the water column to the sediment bed is a loss term not considered in the 72 model simulations, which would tend to result in model over-prediction of contaminant concentrations, there is also a particle effect not considered in the model that could cause model under-prediction of contaminant concentrations. Since estuaries are known to be efficient trappers of particles, specific contaminants which exhibit strong particulate phase partitioning would be transported toward the ocean over longer time scales (i.e., more slowly) than contaminants which do not associate with particles. Further, the location of the boundary of the high resolution model developed for the project within the estuary rather than at the ocean is less than ideal because of the bi-directional estuarine transport dynamics and the proximity of some of the contaminant sources evaluated to the model boundary.

July 2, 2010 Page 13 In addition to the 72 generic continuous release model simulations performed on the high resolution computational grid, additional simulations were completed using the CARP modeling framework to quantify the effect phase partitioning of contaminants to particulate organic carbon and other suspended particles could have on the predicted concentrations at the intake site. The CARP modeling framework includes linked sediment transport, organic carbon production, and contaminant fate and transport models. Sediment transport model outputs and associated organic carbon transport model outputs required to simulate partitioning of contaminants to solids or organic carbon were readily available from CARP and were used for the 25-mile radius analysis.

The computational grid associated with the CARP modeling framework includes less spatial resolution than the computational grid developed specifically for Haverstraw Water Supply Project purposes. Although providing less spatial resolution, the CARP modeling framework advantageously provided the ability for the Haverstraw Water Supply Project to readily consider sediment transport and contaminant phase partitioning effects on contaminant concentrations near the proposed intake.

To quantify the impacts of sediment/organic carbon transport and contaminant phase partitioning processes, CARP model simulations for a number of 25-mile radius discharges were specifically completed on the CARP model grid. Both entirely dissolved phase and highly sorbed (i.e., bound to particulate organic carbon) substances were simulated to demonstrate the maximum potential impacts of sediment transport on the estimated concentrations at the intake site. In total, 12 CARP model simulations were performed by HydroQual for the Haverstraw Water Supply Project 25-mile radius analysis of facilities/sites. An additional CARP model simulation was necessary for non-point source evaluation purposes.

The CARP model testing results indicate that the significance of not including sediment transport effects in the high resolution modeling analysis varies by distance from the intake location and reach of the River. Of the locations tested with the CARP model, calculations of factors for concentration at the intake per mass release were most similar for a dissolved vs. a fully particle bound contaminant for the Haverstraw Joint Regional Sewage Treatment Plant (JRSTP), Newburgh/Beacon, and north boundary discharge locations. It is noted that the test simulations using a fully particle bound contaminant are somewhat unrealistic in that all contaminants to some degree have a dissolved phase. The intention was to make the test as drastic as possible to maximize the impact of potential sediment transport effects. Average factors for concentration near the Haverstraw Water Supply Project Intake per mass release were within less than 25%

difference whether calculated as dissolved tracers or fully particle bound substances for each of the JRSTP, Newburgh/Beacon, and upstream model boundary discharge locations. Maximum factors for intake concentration per mass release were within less than 7% difference whether calculated as dissolved tracers or fully particle bound substances for each of these three release locations. These results indicate that for contaminant releases from these locations, sediment transport would not be expected to

July 2, 2010 Page 14 have an appreciable impact on the factors, even for 100% particulate phase contaminants. Actual contaminants would have much smaller differences.

Somewhat greater differences in calculated factors for concentration at the intake per mass release would be expected for fully particulate vs. fully dissolved contaminant releases from Indian Point, less than 25% difference either on an average factor or maximum factor basis. It is noted that actual radionuclides or contaminants would have much smaller differences than the fully particulate substance simulated for testing purposes. Radionuclides such as tritium are fully in the dissolved phase and the potential differences due to particle phenomena are completely irrelevant.

The worst comparability between factors for concentration at the intake per mass release calculated for fully dissolved and fully particulate contaminant releases obtained with CARP model testing were for the Saw Mill River and South boundary discharge release locations. These differences were up to 47% for average factors and up to 69% for maximum factors. These results are attributable to greatest spatial distance/time of travel to the intake from the discharge locations over which increased particle-related phenomena (i.e., settling, resuspension, etc.) potentially occur and greater energy in near bottom waters of downstream vs. upstream reaches. Stated more simply, differences in transport of fully dissolved phase and fully particulate phase contaminants become most apparent with increasing distance away from the intake location and in the downstream vs. the upstream direction. It is noted that actual contaminants would have much smaller differences than the fully particulate substance simulated for testing purposes.

Model simulations with the high resolution model were completed for each of the discharge locations determined above in Section 3.1 using a continuous load from each of the discharge points in the dissolved phase. Both the average and maximum concentrations at the proposed intake site resulting from each of the loads are tabulated in Appendix C for use in the analysis of individual chemical responses at the intake location. Appendix D expands upon Appendix C information, with the addition of CARP loading measurements for CSO, stormwater, and two major STPs to the analysis.

Results tabulated in Appendices C and D have the intended use of providing a quantitative screening tool for contaminant releases that could potentially pose a threat to the Haverstraw Water Supply Project intake location. In particular, the results in Appendices C and D are useful for contaminants for which concentrations have not been measured near the intake location. Any threats identified on the basis of Appendices C and D modeling results should be further evaluated with a more targeted analysis which considers:

Uncertainty of the contaminant loading information. Are loadings inferred from SPDES, TRI, NPL, and CARP information representative for the specific contaminant on an ongoing basis?

July 2, 2010 Page 15 Attenuation in the watershed before reaching the Hudson River. Was zero attenuation in the watershed before reaching the Hudson River too conservative an assumption for the specific contaminant?

Contaminant specific decay and transformation processes. Was zero decay or transformation too conservative of an assumption for the specific contaminant?

Contaminant specific phase partitioning. Is the specific contaminant strongly particle associated and is 100% dissolved an inappropriate screening calculation assumption for the specific contaminant?

Contaminant specific sediment transport and estuarine particle trapping effects.

Is the specific contaminant entering the Hudson River far away from the intake location and is it strongly particle associated?

Location/proximity of contaminant source location relative to model boundary location. Are the major discharge points for the specific contaminant very distant from the intake location and in the downstream direction?

Measurements being made at the raw water intake location during pilot testing.

Are new measurements consistent with model screening results?

Removal performance of the drinking water treatment system for the specific contaminant. Does the raw water need to fully meet the drinking water standard for the specific contaminant?

An example of the application of this approach, using Appendix C or D results for tetrachloroethylene, is described here. Tetrachloroethylene discharge information is available from all three sources: SPDES, TRI and NPL. DMR data are available from four SPDES permitted facilities: Yonkers, Newburgh, and Orangetown WWTPs and IBM East Fishkill facility. TRI data are available for the IBM East Fishkill facility. 2 NPL sites list tetrachloroethylene as a contaminant of concern: the Brewster well field site and the Shenandoah Road groundwater contamination site. The concentration impact of each of these facilities/sites at the intake location is estimated by multiplying the load or release from each site by the concentration dilution factor per unit load estimated by the Haverstraw Water Supply Project numerical model for each facility/site. The concentration dilution factor per unit load estimated by the Haverstraw Water Supply Project numerical model results are found in Appendix A and C. The estimated loading estimates are found in Appendix C. The total concentration near the intake location can be estimated by summing the individual facility/site concentration impact estimates.

The concentration totals are presented in Appendix D. Appendix C includes results for SPDES and TRI identified facilities only. Appendix D adds in additional results for CSO and stormwater and major STP releases for those contaminants for which loading estimates could be made. It is worth noting that the NPL site information does not include sufficient data to estimate loads but can be used to indicate the potential for a given chemical to occur within the 26 mile search area.

The maximum tetrachloroethylene concentration estimated through modeling based on the known loads is a maximum of 2.25 x 10-2 ug/L. The drinking water standard for tetrachloroethylene, 5 ug/L, is more than 200 times higher than the estimated

July 2, 2010 Page 16 concentrations. On this basis, tetrachloroethylene from these sources does not appear to be a problem at the intake location. Tetrachlorethylene is further discussed below in Section 3.3.5.1.

3.3 Profile of Hudson River Water Near the Proposed Intake The profile of contaminants in Hudson River water near the proposed intake will continue to be assessed on an on-going basis as the pilot plant is operated and intake water quality is monitored. In advance of considering raw water measurements expected to be collected during pilot plant operations, previous United Water monitoring during the conceptual design phase of the proposed Haverstraw Water Supply Project and recent modeling of contaminant loadings within a 26-mile radius do much to complete a profile of contaminants in Hudson River water near the proposed intake.

Data collected by United Water between May 2007 and April 2008 include numerous samples taken at five Hudson River locations within the vicinity of the proposed location for the Haverstraw Water Supply project intake. The samples were analyzed for basic water quality parameters, trace elements, microbiological parameters, radionuclides, polychlorinated biphenyls, endocrine disrupting compounds, pharmaceuticals, and personal care products. It was demonstrated that Hudson River water near the proposed intake is largely of similar quality as other local and national water supplies.

3.3.1 Basic Water Quality Parameters, Trace Elements, and Microbiological Parameters As mentioned previously, UWNY conducted water quality sampling of the Hudson River in 2007 and 2008. Measurements were taken at five locations in the Hudson River surrounding the proposed intake location during the sampling period from May 2007 through April 2008 under a variety of tidal and seasonal conditions. For several of the parameters, more than 200 independent measurements were made. These data demonstrate that Hudson River water near the proposed intake is largely of superior or similar quality as other local and national water supplies. It is anticipated that United Water will continue monitoring these parameters in the raw water intake during pilot operations of the proposed facility through a wide range of tidal and seasonal conditions.

In addition, the Riverkeeper has been collecting basic water quality data in Haverstraw Bay midchannel. Sampling results from September 2006 to October 2009 are available at http://www.riverkeeper.org/special/swimmableriver/data.php?id=35.5. These measurements include Enterococci count, temperature, salinity, chlorophyll, turbidity, and dissolved oxygen as a percentage of saturation. These data are generally confirmatory of the data collected by United Water. For example, the Riverkeepers turbidity data range from 4 to 52 NTU and United Waters measurements range from 0.75 to 69 NTU.

July 2, 2010 Page 17 Of particular interest are the Riverkeepers measurements of Enterococci bacteria.

Enterococci are considered to be sewage indicating bacteria. The Riverkeepers presentation of Enterococci measurements are presented in concert with antecedent precipitation events at http://www.riverkeeper.org/special/swimmableriver/site.php?id=35.3. The majority of the Enterococci data (i.e., < 35 per 100 ml) suggest that the Hudson River water in Haverstraw Bay is fully safe for swimming per federal guidelines outlined in the 2000 Beaches Environmental Assessment and Coastal Health Act (BEACH Act). Elevated Enterococci counts, greater than 35 per 100 ml, were observed on only four occasions with no correlation to antecedent precipitation. Only one of the elevated counts, 164 Enterococci per 100 ml on April 25, 2007, indicates that the water in Haverstaw Bay is unsafe for swimming. In New York State, total coliform, fecal coliform, and E. coli, not Enterococci, are measured/regulated in drinking water.

Although Enterococci are not measured or regulated for drinking water in New York, the fact that the Enterococci levels measured by the Riverkeeper in Haverstraw Bay meet federal guidelines for swimming is indicative of good water quality near the proposed intake for the Haverstraw Water Supply Project.

Basic water quality parameters identified in the 25-mile radius search listed in Appendix B include: ammonia, five day biological oxygen demand (BOD5), total organic carbon (TOC), nitrate, nitrite, oil and grease, orthophosphate, chemical oxygen demand (COD),

ultimate oxygen demand (ODU), dissolved oxygen (DO), pH, phosphate, phosphorus, solids, total Kjeldahl nitrogen (TKN), and turbidity.

Trace elements identified in the 25-mile radius search listed in Appendix B include:

aluminum, antimony, arsenic, barium, boron, cadmium, cobalt, copper, cyanide, germanium, hafnium, hexavalent chromium, iron, lead, lithium, manganese, mercury, molybdenum, nickel, palladium, potassium, rhenium, ruthenium, selenium, silver, tantalum, tin, titanium, tungsten, vanadium, and zinc.

Microbiological parameters identified in the 25-mile radius search listed in Appendix B include: coliform and Salmonella.

Example 25-mile radius search results and numerical modeling results for selected basic water quality parameters, trace elements, and microbiological parameters are described, including cadmium, lead, and mercury.

3.3.1.1 Cadmium Profile Results The federal enforceable standard for safe drinking water is 5 ug/L (5000 ng/L).

Cadmium releases within a 25-mile radius of the proposed drinking water intake were identified in the four data sources examined: SPDES, TRI, NPL, and CARP. CARP measured cadmium concentrations in Haverstraw Bay a few miles downstream of the

July 2, 2010 Page 18 proposed intake on two occasions between 1998 and 2002. These measurements had a mean cadmium concentration of 46 ng/L (http://www.dec.ny.gov/docs/water_pdf/carp.pdf , see page 142 Table 105). On the basis of these measurements, even raw Hudson River water near the intake location would be expected to meet the safe drinking water standard for cadmium. High resolution numerical modeling results further indicate that cadmium should not be a problem. As indicated in Appendix D, numerical model results suggest that cadmium concentrations at the proposed intake location will average 15.2 ng/L and could be as high as 706 ng/L.

3.3.1.2 Lead Profile Results The federal drinking water action level for lead is 0.015 mg/L (15,000 ng/L). Lead releases within a 25-mile radius of the proposed drinking water intake were identified in the four data sources examined: SPDES, TRI, NPL, and CARP. CARP measured dissolved phase lead concentrations in Haverstraw Bay a few miles downstream of the proposed intake on two occasions between 1998 and 2002. These measurements had a mean dissolved phase lead concentration of 99 ng/L (http://www.dec.ny.gov/docs/water_pdf/carp.pdf , see page 142 Table 105). United Water measurements of lead in the Hudson River in 2007 ranged from 5100 to 6000 ng/L. On the basis of these measurements, all below the drinking water action level of 15,000 ng/L, even raw Hudson River water near the intake location would be expected to meet the safe drinking water standard for lead. High resolution numerical modeling results further indicate that lead should not be a problem. As indicated in Appendix D, numerical model results suggest that lead concentrations at the proposed intake location will average 40 ng/L and could be as high as 2,890 ng/L.

3.3.1.3 Mercury Profile Results The federal enforceable drinking water standard for mercury is 0.002 mg/L (2,000 ng/L). Mercury releases within a 25-mile radius of the proposed drinking water intake were identified in two of the four data sources examined: SPDES and CARP. CARP measured mercury concentrations in Haverstraw Bay a few miles downstream of the proposed intake on two occasions between 1998 and 2002. These measurements had a mean mercury concentration of 6.7 ng/L (http://www.dec.ny.gov/docs/water_pdf/carp.pdf , see page 142 Table 105). On the basis of these measurements, far below the drinking water standard of 2,000 ng/L, even raw Hudson River water near the intake location would be expected to meet the safe drinking water standard for mercury. High resolution numerical modeling results further indicate that lead should not be a problem. As indicated in Appendix D, numerical model results suggest that mercury concentrations at the proposed intake location will average 1.67 ng/L and could be as high as 109 ng/L.

3.3.2 Radionuclides The May 2007 to April 2008 United Water sampling for radionuclides demonstrated that Maximum Contaminant Levels (MCLs) set by the EPA for drinking water were

July 2, 2010 Page 19 comfortably met by raw Hudson River water for radium 226/228, total uranium, strontium 90 (90Sr), and tritium (3H). While there were a few outlier measurements for gross alpha and gross beta, average results were below drinking water MCLs. This is an important finding because of the proximity of the Indian Point Nuclear Power Plant to the proposed intake, on the eastern shore of the Hudson River in Buchanan, NY.

Cesium (137Cs) is another radionuclide which may be released from Indian Point and has an MCL of less than 200 pCi/L (note that 200 pCi/L of 137Cs corresponds to the entire 4 millirem per year allowance for all gross beta radionuclides in safe drinking water).

137Cs was widespread in the United States in the 1950s and 1960s from fallout after atmospheric nuclear weapons testing. Maximum accidental releases of 137Cs from the Indian Point Nuclear Power Plant occurred in 1971 (> 20 Ci) with more than 40 Ci of 137Cs (uncorrected for decay) being released between 1960 and 1993. The fate of the Indian Point Nuclear Power Plant 137Cs release has been well studied and documented by numerous researchers such as Chillrud, Jinks and Wrenn, Hairr, and Olsen. The numerical modeling report produced for the CARP, available at www.carpweb.org, summarizes much of the study and measurement of 137Cs in the lower Hudson River as part of the CARP model hindcast verification exercise. The report also provides complete citations for the underlying research source documents.

The maximum accidental 1971 release as well as remaining weapons testing fallout at that time and contributions from any other historical sources produced a measured 137Cs maximum dissolved phase concentration in the Hudson River near mile 30 of 1500 fCi/L (i.e., 1.5 pCi/L). Note that 1.5 pCi/L is well below the allowed 200 pCi/L drinking water standard. There was also a coincident maximum of 7,000 pCi/kg of 137Cs in the particulate phase occurring slightly upstream, near River mile 40. Particulate phase 137Cs would be completely filtered out for drinking water purposes and is not likely a threat.

Nonetheless, the observed particulate phase 137Cs can be expressed on a mass per volume basis, added to the observed dissolved phase, and compared to the drinking water standard.

The conversion of the measured particulate phase 137Cs to mass per volume units involves a consideration of the total suspended solids concentrations in the Hudson River. Based on United Waters sampling of the Hudson River in Haverstraw Bay from May 2007 to April 2008, 215 total suspended solids measurements ranged from 4.4 to 100 mg/L with an average of 26.1. Assuming the highest measured total suspended solids concentration of 100 mg/L, the historical observation of 7,000 pCi/kg of 137Cs in the particulate phase would be equivalent to 0.7 pCi/L. Summing the observations of dissolved and particulate phase maximum concentrations after the accidental release, 1.5 pCi/L dissolved and 0.7 pCi/L particulate, yields 2.2 pCi/L of total 137Cs, well below the drinking water standard of 200 pCi/L. Present day measurements of 137Cs made in the Hudson River in 2008 by IPNPP at its inlet location were even lower than the historical measured maximum of 2.2 pCi/L. In 2008, twelve monthly samples analyzed by IPNPP were all below method detections ranging from 1 to 1.5 pCi/L.

July 2, 2010 Page 20 Based on the historical 137Cs worst-case release of large magnitude and Hudson River measurements made at that time, it does not appear that potential future large-scale accidental releases of 137Cs from Indian Point would pose a threat to the proposed Haverstraw Water Supply Project. Based on 2008 records from the IPNPP, the current release of 137Cs from IPNPP is 0.014 Ci, four orders of magnitude smaller than the >20 Ci 1971 release considered in the historical worst-case analysis.

Specific questions addressed through the use of numerical water quality modeling of current loadings within a 25-mile radius of the proposed Haverstraw Water Supply Project, related to current Indian Point releases of radionuclides, include:

Where do the compounds released from Indian Point go?

What is the concentration of these compounds at the HWSP intake?

Numerical model results show that compounds released from Indian Point are rapidly mixed by the estuary, spreading upstream and downstream and uniformly across the Hudson. Compounds released from Indian Point would reach the proposed Haverstraw Water Supply Project intake; however, the concentrations of the compounds at the proposed Haverstraw Water Supply Project intake will be expected to be greatly reduced or diluted. Numerical modeling suggests a range of dilution factors depending upon hydrodynamic conditions in the Hudson River and the duration of the Indian Point release. Model outputs have been summarized in terms of the maximum concentration that would result at the proposed Haverstraw Water Supply Project intake per Ci/day of dissolved-phase compound (i.e., compounds such as tritium which exhibit no or little phase partitioning to solids) released by Indian Point Nuclear Power Plant. Examples of the numerical model outputs showing the dilution of Indian Point Nuclear Power Plant loads by the Hudson River are included in Table 4.

Table 4. Compounds Released from Indian Point Nuclear Power plantand Resulting Concentrations near Proposed Haverstraw Water Supply Project Intake 1 Release Duration Maximum Concentrations near the Proposed Haverstraw Water Supply Project Intake per Ci/day discharge from Indian Point pCi/L Hour 1.78 Day 7.73 Week 30.13 Month 41.24 Continuous 114.6 1Calculated using water year 1994-95 Hudson River flows. 1994-95 is a relatively dry period and represents a condition under which the dilution effect of the Hudson River would be minimized. Portions of 1994-95 qualify as Hudson River drought conditions

July 2, 2010 Page 21 based on two methods of defining droughts considered by researchers at Columbia University: departure from average precipitation method (March 1995 to March 1996) and the Palmer Drought Severity Index (August/September 1995 was a severe drought).

See http://superfund.ciesin.columbia.edu/Rocklandwater/supply_droughts.html.

To put a perspective on the potential Hudson River concentrations reported in Table 4, the EPA drinking water standard for tritium is 20,000 pCi/L. Measured tritium in drinking water ranges from not detectable to 392 pCi/L per the 2005 EPA Environmental Radiation Data Report No. 122. A Ci/day release from Indian Point would produce tritium concentrations in the Hudson River well below the drinking water standard and within the range of drinking water measurements.

Per the Indian Point Annual Radiological Environmental Operating Reports for quarterly composites from the cooling water intake and in the discharge canal of the Indian Point Nuclear Power Plant, measured tritium concentrations, inferred to represent Hudson River water, have ranged between not detectable (i.e., less than 450 pCi/L) to 618 pCi/L over the time period 1997 to 2008. This is suggestive that if Indian Point Nuclear Power Plant were the singular source of tritium to the Hudson River, Indian Point Nuclear Power Plant releases could have likely ranged, at most, from 5.4 Ci/day (continuous release) to 347 Ci/day (one hour release).

Tritium releases from the Indian Point Nuclear Power Plant cooling water discharge were available for 2006 and 2007 from mass and dilution flow measurements reported as quarterly composites. There is somewhat of a pattern common to the two years in that releases are slightly elevated in the first quarter of each year as compared to the remaining quarters of the year. 2006 had a slightly higher release of tritium than 2007 overall. The information suggests that in 2006, 1557 Ci of tritium in total were discharged. This corresponds to a 4.3 Ci/day average discharge of tritium for 2006 released continuously and would be expected to produce a Hudson River tritium concentration near the intake location of 493 pCi/L based on HydroQuals modeling results presented in Table 1.

To summarize, several independent data and numerical modeling lines of evidence, spanning multiple seasons and years suggest that tritium concentrations in the Hudson River near the proposed intake are consistently below 700 pCi/L (IPNPP annual reporting 1997 to 2008, <450 to 618 pCi/L; HydroQual modeling of 2006 IPNPP loadings, 493 pCi/L; and United Water 2007 and 2008 monitoring, 39 to 391 pCi/L, all below typical detection levels). These multiple sources of information evidence that existing tritium releases will not be a problem for safe drinking water.

In addition to tritium and 137Cs described already, other radionuclides discharged from Indian Point in 2008 per IPNPP records include: Ag-110m, Co-58, Co-60, Cr-51, Cs-134, Fe-55, Mn-54, Ni-63, Sb-124, Sb-125, Sr-90, Te-123m, and Te-125m. In total, these releases for 2008 were less than 0.07 Ci for the entire year. These radionuclides can be compared

July 2, 2010 Page 22 and contrasted to both tritium and 137Cs in terms of phase partitioning behavior and half-life.

A majority of the radionuclides discharged (Ag-110m, Co-58, Co-60, Cr-51, Mn-54, Sb-124, Sb-125, Sr-90) are strongly dissolved phase, like tritium and unlike 137Cs, based on known phase partitioning behavior. Further, although Fe-55, Ni-63, Te-123m, and Te-125m partition to particles more than the other radionuclides discharged by IPNPP in 2008, they are still more similar to tritium than to 137Cs in terms or partitioning behavior.

It is noted that 134Cs would behave similarly to 137Cs, but comprises only 1% of the IPNPP discharge. To the extent that these radionuclides are largely dissolved phase, the 2008 release of less than 0.07 Ci per year can be translated to a Hudson River concentration near the proposed Haverstraw Water Supply intake location of 0.022 pCi/L using modeling results presented in Table 1 for a continuous release. The lowest drinking water standard identified for any of these contaminants individually is 8 pCi/L for Sr-90, well above the 0.022 pCi/L Hudson River water concentration near the proposed intake expected for the summation of all these discharged radionuclides.

Tritium (3H) and 137Cs each have a relatively long half-life, 12.3 and 30.2 years, respectively, making management of their releases important over a long-term horizon.

Similarly, Co-60, Sb-125, Sr-90, Fe-55, Ni-63, and Cs-134 each have a multi-year half-life.

Other radionuclides discharged by IPNPP each have a half-life less than a year (e.g., Ag-110m, Co-58, Cr-51, Mn-54, Sb-124, Te-125m).

In addition to the example modeling results presented in Table 1 based on a single year of modeling and multiple release conditions for Indian Point, modeling was performed over a period of fourteen water years for a continuous release from Indian Point.

Factors for converting lb/yr releases from Indian Point to ug/L concentrations resulting near the proposed Haverstraw Water Supply Project Hudson River intake were developed and are summarized in Appendix A. These factors are 2.844 x 10 -05 mean and 1.36 x 10-04 maximum ug/L at the proposed Haverstraw Water Supply Project intake location per lb/yr discharge from Indian Point. These factors correspond to 0.063 pCi/L mean and 0.30 pCi/L maximum near the proposed intake per Ci/yr discharge from Indian Point.

Per the April 3, 2010 Wall Street Journal, operating licenses for Indian Point units 2 and 3, which came on line in the 1970s, are due to expire in September 2013 and December 2015, respectively. Certification is required under Section 401 of the Clean Water Act before the United States Nuclear Regulatory Commission can approve an extension of the Indian Point operating licenses. It is unclear if or how Indian Points current operation would be changed in the future to obtain Clean Water Act Section 401 certification. An Environmental Impact Statement from Indian Point is expected after May 2010, too late to be considered in this technical memorandum for Haverstraw Water Supply Project purposes. It is a reasonable expectation that any future changes to

July 2, 2010 Page 23 Indian Points operation would only improve, not worsen, the already good water quality in Haverstraw Bay.

3.3.3 Polychlorinated Biphenyls (PCBs)

A discussion of PCB concentrations near the proposed Haverstraw Water Supply Project intake location was provided above in this technical memorandum under the evaluation of upstream dredging impacts in a description of the pre-dredging condition of the Hudson River. Based on measurements, a pre-dredging condition of the Hudson River is 25 ng/L PCBs near the proposed intake. The pre-dredging condition meets the drinking water standard of 500 ng/L. This data result is further confirmed by numerical modeling results presented in Appendix D which indicate mean and maximum PCB concentrations of 0.4 ng/L to 27.5 ng/L due to local sources (i.e., within a 25 mile radius) only (i.e., ignoring the Upper Hudson River Superfund Site impact).

3.3.4 Endocrine Disrupting Compounds, Pharmaceuticals, and Personal Care Products (often called emerging contaminants)

In 2007 and 2008, measurements made in the Hudson River in the Haverstraw-Stony Point area, near the proposed intake location occured over a 40-week period during high and low tides. 89 different contaminants, including phenolic endocrine disrupting chemicals, pharmaceutically active compounds, fragrances, estrogens, and other hormones, were each sampled/analyzed for 11 times. Only 19 of the 89 contaminants analyzed for were actually detected. The key findings are:

In general, the number of compounds detected in the Hudson River was found to be slightly less than reported by the American Water Works Association (AWWA) Research Foundations survey of concentrations for microconstituents in 17 drinking water systems around the country.

In general, the magnitude of the concentrations of the microconstituents found in the Hudson River were comparable to those AWWA reported for its national survey of both raw and finished drinking water.

In general, the magnitudes of the concentrations of the microconstituents found in the Hudson River were comparable to concentrations reported in the peer-reviewed literature for local and international waterways.

The nine contaminants consistently (frequency of 10 or 11 out of 11 samples) detected in the Hudson River include: caffeine, DEET, nicotine, paraxanthene, galaxolide, carbamazepine, cotinine, sulfamethoxazole, and gemifibrozil. The five contaminants occasionally (frequency of 3, 4 or 5 out of 11 samples) detected in the Hudson River include: acetaminophen, diltiazem, lincomycin, trimethoprim, and aspirin. The five contaminants infrequently (frequency of 1 or 2 out of 11 samples) detected in the Hudson River include: fluoxetine, sulfadimethoxine, naproxyn, theophylline, and nonylphenol and its isomers.

July 2, 2010 Page 24 The mere presence of these contaminants does not necessarily pose a threat to drinking water safety. Attempting to rank these contaminants by magnitude of concentration may be of little or no relevance. It has yet to be determined what the environmentally relevant concentrations for the majority of these contaminants are in terms of either ecological or human health risk. Further, the potency/toxicity of each of the contaminants may very widely so that equal amounts of any of the individual contaminants may not pose equal risks.

State and/or federal water quality standards and/or criteria were not found for caffeine, DEET, nicotine, paraxanthine, galaxolide, carbamazepine, cotinine, sulfamethoxazole, gemifibrozil, acetaminophen, diltiazem, lincomycin, trimethoprim, aspirin, fluoxetine, sulfadimethoxine, naproxyn.

For theophylline, NYSDEC promulgates a surface water quality standard of 40 ug/L for the protection of non-oncogenic human health in fresh surface waters used for source water (see http://www.dec.ny.gov/regs/4590.html). The single theophylline concentration detected (detection frequency of 1 in 11) in the Hudson River near the proposed Haverstraw Water Supply Project intake location, 0.006 ug/L, is well below the NYSDEC standard. It is recognized that the Hudson River near the proposed Haverstraw Water Supply Project is salt water and the NYSDEC standard for fresh surface waters, while a basis of comparison, is not necessarily directly applicable.

For nonylphenol, the EPA has established numeric criteria to guide the states in the protection of aquatic life (see http://www.epa.gov/waterscience/criteria/nonylphenol/index ). There are both acute (1 hr average, allowed to exceed once in three years) and chronic (4 day average, allowed to exceed once in three years) criteria for each of freshwater and saltwater. The saltwater criteria are 7.0 ug/L acute and 1.7 ug/L chronic. The single nonylphenol concentration detected (detection frequency of 1 in 11 or 2391 hours0.0277 days 0.664 hours 0.00395 weeks 9.097755e-4 months in 3 years) in the Hudson River near the proposed Haverstraw Water Supply Project intake location was 0.5 ug/L, well below the federal acute and chronic criteria.

It is noted that the 25-mile radius source search did not identify any inputs for the 19 contaminants detected in the Hudson River by previous United Water monitoring.

The Hudson River Environmental Society (HRES) sponsored a conference on April 23, 2010 at Vassar College which explored pharmaceuticals, personal care products, and sewage from storm overflows entering the Hudson River (see www.hres.org ). A goal of the conference was to identify future actions needed to deal with the anticipated continued presence of these substances in the Hudson River. Findings of the conference include that although it is known that hormones, drugs, and personal care products enter the Hudson River and other surface waters through sewage treatment plants or CSOs, the ecological impacts and human health consequences are just beginning to be understood. Accordingly, federal and local regulatory authorities are not yet in a position to fully manage the problem, but are taking steps to do so. Emerging

July 2, 2010 Page 25 contaminants findings reported at the conference, relevant for the Haverstraw Water Supply Project, include:

A possible regulatory approach that might be taken locally or nationally in the future to deal with emerging contaminants is to regulate whole effluents with numeric toxicity limits rather than numeric discharge limits for specific substances.

NYSDEC continues to move forward with regulation of CSOs, requiring best management practices (BMPs) and long term control plans (LTCPs). Once completed, these strategies should reduce any releases of emerging contaminants via CSOs to the Hudson River and other New York waterways.

The medical therapeutic dose of pharmaceuticals humans consume is multiple orders of magnitude greater that what is being measured nationally in receiving water or in drinking water. In this senses, pharmaceuticals are of potentially the least concern for human health as compared to other emerging contaminants.

Since 2009, the New York State Legislature has introduced legislation to provide for the disposal of pharmaceutical drugs. The most recent bill (S. 513) was introduced on January 5, 2011, but it, as its predecessor bills, has not been enacted into law. (www.dontflushyourdrugs.net )

3.3.5 Other Contaminants In addition to basic water quality parameters, trace elements, microbiological parameters, radionuclides, PCBs, and emerging contaminants, a number of other contaminants entering the Hudson River within a 26-mile radius of the proposed Haverstraw Water Supply Project intake were evaluated and are listed in Appendix B.

An example, tetrachloroethylene, is considered here.

3.3.6. Tetrachloroethylene An example of another contaminant is tetrachloroethylene (PERC). Through the 26-mile radius search, loadings of PERC were identified. Through numerical modeling, the loadings were translated into PERC concentrations near the proposed Haverstraw water Supply Project intake. The PERC concentration calculations and underlying numerical modeling results and loading estimates are presented in Appendices C and D. The maximum PERC concentration estimated based on the known loads is a maximum of 2.25 x 10-2 ug/L. The drinking water standard for PERC, 5 ug/L, is more than 200 times higher than the estimated concentrations.To some degree, the concentration calculated may under-predict PERC levels. It is noted that it was not possible to estimate PERC loads from two NPL sites listing PERC as a contaminant of concern. These NPL sites are the Brewster Well Field Site and the Shenandoah Road Groundwater Contamination site. In addition, given the widespread use of PERC, it is likely that stormwater runoff and/or CSOs would carry some level of PERC to the Hudson River. Modeling results available suggest that raw Hudson River water would likely meet the drinking water standard of 5 ug/L even with large loadings of PERC from the two NPL sites and

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