The United States Environmental Protection Agency sent a letter to the management of an east valley mobile home park with contaminated water. The letter addresses the park’s violations and the agency’s concerns regarding the endangerment of the health of the park’s residents.
On Aug. 27, the EPA issued an emergency order at the Oasis Mobile Home Park on the Torres Martinez Tribe’s lands near Thermal after high arsenic levels were found in the park’s public water system. According to the EPA, the groundwater that is used in the park’s water system has naturally occurring arsenic. The system serves approximately 1,900 residents.
The EPA revealed that arsenic monitoring results from April through July were above the maximum contaminant level as set in the Safe Drinking Water Act. By July, the arsenic levels in the water were nine times above the MCL.
The arsenic MCL at the park (Results from the EPA):
April 16 – 16ppb
June 6 – 89ppb
July 15 -97ppb
The SDWA sets the MCL for arsenic at 10ppb, this level “protects consumers from the effects of long-term, chronic exposure to arsenic.”
According to the EPA, Arsenic has been linked to numerous kinds of cancers, including of the bladder, lungs, skin, kidney, nasal passages, liver, and prostate. Non-cancer effects can include thickening and discoloration of the skin, stomach pain, nausea, vomiting, diarrhea, numbness in hands and feet, partial paralysis, and blindness.
On Aug 29, Oasis residents told News Channel 3 about the concern that children in the community showing symptoms matching those of arsenic poisoning.
“Sometimes their stomach hurts and sometimes they have to vomit,” Zacarias said. “A lot of times they feel sick and I’ll take them to the doctor, but they never know what’s really wrong.”
In its letter, the EPA says management at Oasis “failed to timely comply with the following requirements of the Order.”
Failure to provide alternate sources of water for residents
One of the EPA’s requirements was for park management to provide an alternative source of water to residents at no direct cost to customers until the water system reaches safe levels, or they receive word from EPA to stop. The EPA reveals, however, that based on a recent inspection and interviews with Oasis’ residents, park management has failed to meet this requirement because “it restricts the time and manner that alternative water is provided.”
This means that Oasis management failed to provide alternate water sources to residents because of its limited hours of operation on weekends. Only residents named on the lease were able to go pick up bottled water, according to the EPA.
Possibly charging residents for providing alternate sources of water
The EPA also found that shortly after the emergency order was issued, Oasis raised rent by $100. Park management claimed this was issued before the EPA’s order, “the timing of it gives the appearance that Oasis is attempting to recoup its costs from its customers for providing water,” writes Amy C. Miller, the Director of the EPA’ Enforcement and Compliance Assurance Division.
Residents told News Channel 3 about the rent increase in Sept. Residents said they were given different answers when they asked for a reason for the rent increase. Some were told it was for the clean gallons of water they were given last week. Other tenants were told it was to fix the streets, increase security, or just a rent increase.
This would be a violation of the EPA’s emergency order.
Failure to notify residents
Another violation by Oasis management that the EPA found was the park’s failure to notify residents of the issues with the water system. The law states that public notices must go out no later than 30 days after learning of any violations. The EPA says that Oasis was in violation of this requirement prior to the emergency order.
Oasis continues to be in violation of this by posing untrue notices informing residents that the water is safe to drink. EPA inspectors posted their own public notices in English and Spanish that can’t be removed or altered.
Technical Review of Arsenic Treatment System
One of the many requirements Oasis was supposed to comply with included engaging with a qualified technical provider “regarding the particular treatment system used by Respondents to assess and
identify deficiencies related to the System’s arsenic treatment.”
Miller writes that it is unclear whether Oasis complied with the requirement. Park management provided the agency with the names of four different technical providers, however, it was not clarified which one was picked or whether any of the technical providers are experienced enough with the treatment system.
The EPA ordered Oasis to identity the technical provider and show their experience and background with regard to the park’s treatment system.
Disapproval of Work Plan
Oasis was supposed to develop a number of plans and documents for the EPA to review and approve. This includes the findings of its technical provider’s review, a written work plan, a proposed schedule for the fast implementation of any identified measures or work to make the water system function compliant with SDWA regulations.
Miller writes that while Oasis did submit a work plan on Oct. 11, the plan lacked enough details to meet the requirements of the emergency order, and that Oasis will need to revise its plan, adding more details before resubmitting for EPA approval.
The EPA also found that Oasis’ submitted plan was based on the RCAC’s technical review and recommendations done back on Aug. 23, a few days before the EPA issued the emergency order. Oasis was supposed to have its technical provider give a new technical review which could reference RCAC’s findings and attach it to the work plan.
Additionally, the EPA says that Oasis’ plan must “better identify and describe each work project in accordance with what was discovered during the technical review and described in the report, and establish realistic project completion dates with due dates for each project.”
The EPA says that Oasis should set up a call with the agency and the park’s chosen technical provider before Oct. 25 to further discuss a revised work plan. The plan would then be submitted by Nov. 1.
Entry Point to Distribution
The SDWA requires that there must be arsenic monitoring at community water systems to determine that the MCL is compliant with regulations. This monitoring includes taking “one sample at every entry point to the distribution during each compliance period which is representative of each well after treatment”
The park’s arsenic analytical reports submitted to the EPA from Babcock Laboratories reveal that arsenic sampling is not being consistently taken at the water system’s EPTD.
This has led to the EPA making a determination, based on relevant information and visual confirmation, that the system’s EPTD for Well 1 will be located at the nearest sampling tap directly after arsenic treatment.
The EPA has determined that no other sampling location (e.g., Storage Tank) will be an acceptable location pursuant to the sampling and analytical requirements under SDWA, 40 C.F.R. § 141.23, unless otherwise noted in writing by EPA.
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