>According to the State, Graydon is not a pool, it is a man‐made pond. It is filled using well water and there are no circulation or filtration systems. Graydon is therefore subject to much different regulations and standards than other municipal swimming facilities. For many years, chlorine was used to disinfect the water at Graydon. Then, in 1992, the Village was fined for this practice because, at the time, there were no chlorination products registered for use in natural bottom swimming pools. The result was that a Special Local Need (SLN) pesticide label was created that allows the Village to treat the water for algae control only, but there are no longer any disinfecting chemicals allowed to be used at Graydon. RPP Final Report, p. 6.
Why does the State require more stringent criteria for a traditional swimming pool different than ponds? Notwithstanding the effects on animal and plant life inherent to ponds, is it because the State intends a different use and purpose in terms of scope and extent for a pond in comparison to a traditional swimming pool? If not, then why aren’t the regulations and standards for a pond sufficient for a traditional swimming pool?
Further, I have read that because there are no disinfecting chemicals allowed to be used at Graydon, the bacteria count in the water is higher than in a traditional swimming pool. The New Jersey State Department of Health has set bacterial and chemical standards for both traditional swimming pools and ponds such as Graydon. In swimming pools, an acceptable fecal coliform test result is less than one organism per 100 ml versus 200 organisms per 100 ml in ponds. See Public Recreational Bathing Water Standards, N.J.A.C. 8:26-1, et. seq. If you were to fill a half-liter drinking bottle with water from a traditional swimming pool, the State would only allow less than one bacteria organism to be present. However, if you fill that same bottle with water from a pond like Graydon, the State would allow up to 200 organisms to be present. Therefore, Graydon is permitted by law to have roughly 200 times the bacteria count of a traditional swimming pool. Again, we must understand why the State makes a distinction between ponds and traditional swimming pools.
I think many residents would find it helpful to have more information regarding the statement about the
grand-father clause referenced above.
I have read the DEP regulations and determinations. In March 2008, the DEP Assistant Commissioner of Compliance and Enforcement
“offered direction as to how to more effectively utilize the approved chemicals, but then stated, “The Department still recommends, however, that Graydon Pool be replaced with a bona fide swimming pool in the future.” RPP, pg. 6.
I would like to know what administrative opinion the DHS would issue regarding the Village’s decision to use a pond as a municipal swimming pool that does not meet State standards for recreational bathing water.
If you refute any of the information I have read above or have answers to the questions I posed, please be kind enough to provide the links and resources to such information.
