Patricia J. Ritchie 23600 S. MissouriRiverView Drive Hartsburg,

MO 65039-8808 June 20.2015

CERTTFIED

MArL #70rs 0640

0004 2$7 A263 RETURN RECEIPT

REQUESTED Mr. Sean Conley US EPA Offrce of GroundWaterand Drinking Water Standards

and Risk Reduction

Branch l20l Constitution

Avenue NW Mail Code4607

M Washington

DC 20004

RE: COMMENTSIN SUPPORT OF RULEMAKING FOR DRINKING WATER DISTRIBUTIONSYSTEM STORAGE FACILITY INSPECTION AND CLEANING DearMr. Conley; Overview I did not learn

of the October15,2014

meeting on this subject

until January

2015 and received

a copy of the recorded

webinar in May. I havereviewed the webinarand urge US EPA to swiftly promulgate

a basic rule to dealwith the doubtless hundreds of contaminated

watertanks

that exist at public water systems across the country. Thereis broadconcrurence andvirtually no dissent that inspection

and cleaning

of these tanks is desperately

needed. The voluntary approach hasachieved

atl it can over the past

two decades.

The time for a federalrule is now. The main challenge

is how to assure

cleaning and inspection

is perforrned

safely by qualified personnel. The elephant-in-the-room questions that no one dealt with directly during the webinararc the following: Could US EPA rulemaking subsequent

to the Gideon,

Missouri 1993

outbreak have prevented

the 2008 Alamosa,

Colorado outbreak?

My answer

is'!es". And: Could US EPA rule promulgation

now prevent

outbreaks

in the future? My answer is likewise o'yes''. This issue

also goes far beyond

the prevention

of acute waterborne

disease outbreaks. Contaminated

water tanks at chlorinated

systems have long been

known to generate

increased levels of disinfectionbyproducts (DBPs), known carcinogens regulated astotal trihalomethanes and haloacetic

acids. Rarely does

US EPA havethe opportunitydecrease both acute

and longterm healtheffects in a single rule; please don't waste

it.Page

2 of8

Backeround A US EPA document

entitled *Finished

WaterStorage

Facilities"ldated

August 15,2002

states the following in the Background and Disclaimersection: "TheUSEPA

is revising the Total Coliform Rule (TCR) and is considering

new possible distribution

system requirements

a part of these revisions." This document

describes the 1993 Gideon. Missouri outbreak asfollows: Str)lilge tn;ilitter lt.ri'e Lteert rrttplic.ttc.l trt rei'eltri rlitetbrrnje.1t;elr:e r)utbteltki rrt tlte I--nrleil St.rte:;tirl EtuoPe Itt Decernlrer li:)-:,. rt.Srr/lrrclrt'1 lo npitunrtt?l/rl ollttrr'elk ur Cir.lerrn. \li.r.''urr teitrltetl tjtrttt trttcl collt.lltlll).ltrolIill i cclr'€lrcl rtnrnr;rl-r;rl

..',.rtet \tor.tge Iitl)k rC i.rrk at al lppli r Ptgcrtrt d11r111.r1119

olt the tlr* trrtrf r.i'ere cJrnccl urlo ihe irrnk [.r",r incl .rr]!l r..rul tlutrugir J :.ri-r111

ijlg rrrof itrttclt tlrrttte iZelch lt'lril i Prr.rt c[stri[ruli!]ll \\'>laru tlrrsirrnl prr'lctice: letl to the c.rurplete tltlrrttrtg e'rf

tlte t.trtk'; corlr.tt))uiitlecl ',r.ltet irtttr the ttitlitrrrtiort \\'\tell] .{: rrf .lltrlir:lrt'S. 1tt9l. -il C.1!€i trf ilrt'rtrt.rtr'rt1'

cr)trl'illucd srrlttrtrtrellrrsr: h.icl Lreerr

rclcntrtlecl Selen lluf\ulg herruc re:r.{enti esitr['ttlirtg .Jtlrtrherl illne;i Jie .1.tirur trt ''r htrr)r 'rIerB crrnl-u:necl ['tv cultrr|e It ',i'r: e\t:.!]rltle(l thrli ;1ls1li'riT tit.iii perrpletrt JJ':',:

rrf tire citr". re:idelrt!',\'ele lttcctecl l'1'clir,r.rherr ui tiir> trnie perrtrcl. Fast forward to March 2008 Alamosa, Colorado. The report entitled "Waterbome Salmonella Outbreak in Alamosa, Colorado March and April2008"2 states on page4: "The outbreak

resulted in 442reported

illnesses,

122 of which werelaboratory-confirmed and onedeath. Epidemiological estimates

uggest that up to 1,300

people may have

been ill." The authors describe the Colorado Safe Drinking Water Program's (SDW) failure to prevent the outbreak in the following manner: Altlttttrglt the SD\\'ptrrgl .'llu i rssrrtrtce\ jrli'e in;rerr:eil ut lecelit leJri. ihc urcre:ier hlrve gertelllll'ttecti lieil irr ullPleluerltutg r)e',\'re grrlltrtrn:. rnd the enr1.rl1;1.,1,. r.rll tletttlllelil chrririg ul\Pectiolti letu:irted l--lltbrttu)r'tleh'. lire citv irrrcl

not i'rddleise.l

lntegltt\-i.'rrei lt tire \\'el.rer Reietr-.'rit rrrtcl

tlt,.rse ii;ttei'rlile rtr-rt

cletectecl

.{rrrutg ul\pectlou\ trf tlte .{l.rrtt,,.s.r',\'r.rtel i\-stelll colxltlctcd l.rv

titc 5D\\- p1.'r91

rtttt cltutttg tlte..lecrrcle t)llt'rl trl ihe.-'rrttrrelk. rucltr.lrrrg:rlr u)rl)ect1L1l} rrt Attgtr:i lt,tliThe new regulations

the SDW program

were implementing,

however, did not include distribution watertank inspection and cleaning. The authors imply had the National Primary Drinking Water Rulesnew requirements included watertank inspection

and cleaning,

the Alamosa outbreak would likely not have

occuned. The report

concludes,

l United States Environmental

Protection

Agency, "Finished

Water Storage Facilities",

August 15,2002.

Prepared by AWWA with Assistance from Economic

and Engineering

Service, Inc. 2Falco R. and Willianr, S. I. *Waterborne Salmonella

Outbreak

in Alamosa,

Colorado

March and April 2008'. November

2009. ColoradoDeparfnentof Public Health and Environment.Page

3 of8

"The investigation

intothe Alamosa outbreak of 2008 confirmed that the physical,

regulatory and human infrastructure

had all failed in some way to protect he public's

safe drinking water supply." The State

of Colorado

has learned

from this regulatory

failure and promulgated

Regulation 11.28 Storage Tank Rulewith an effective date of April1,20t6, asper https://www.colorado.govipacilic/cdphe/drinkilg-water-r'tcr-rulernaking. EPA must

transition from its status

of collecting more information on the subject and promulgate

a federalrule. Colorado has given you a goodtemplate to startwith. Incidgnce

of Waterborne

Illness During the meeting

of October

15, 2014 commenter

Randall Mooreof Utility Services Group mentioned

an incidence

of waterborne

illness not previouslyfound in documentation: Serious illnesses resulted when seasonal

tumover of a watertank at a Missouri state park occurred; fortunately

there were no fatalities. Personal

communication

with Mr. Mooreon May 15,2015 indicated the watertank in question wasthe pedestal

watertower at Washington State Park in Washington

County, Missouri. He indicated this incident occurred

a long time ago, but subsequent

to the Gideon,Missouri outbreak. While waterborne

disease outbreaks

linked to water tank contamination appear rare as reported by the Centers

for Disease

Control, I propose

the Gideon

and Alamosa

outbreaks

represent he tip-of-the-iceberg

of these occunences.

Transient

non-community

systems, such as the state park presented

in the previous

paragraph,

would be panicularly difficult to track regarding possible waterborne

disease outbreaks. Many day-use visitors would not be registered and could not be tracked. A transient system along a highway would be evenmore diffrcult to track, with consumers

readily leavingthe state

beforesymptoms

occurred. Such

scenarios demonstrate

a federal rule is in order. On page l0 of the Alamosa report, Falco and Williams includethe following statement: "Most people do notseek

care for their symptoms.

Typically,

an estimated 3E acfual cases oc.cur for each one reported." If onewereto then factor in the increased cancer risk dueto an increase

in disinfection byproducts

at chlorinated

systems with problem

water storage

tanks, the risk to the public heatth becomes several orders of magnitude

greater than the seemingly

isolated incidences

of Gideon andAlamosa. It is the documentation of suchincidents

that is rare, not their occurrence. Voluntarl Approach

Not Working in Missouri The Federal

Register for September

4,2014 posting

includes the following athups://www.federalregister.gov/articles/20141}9/0412014-21073lnotice-of-public-meeting-andwebinar-distribution-system-storage-facility-inspection-and-cleaning: "Some commenters

suggested theneed for a Federal

regulation requiring systematic

inspection and cleaning because theexisting

practices ane not successful

in all cases.

Others suggested thatPage

4 ofE regular sanitary surveys conducted

by States and theadherence

to existing

industry guidance could resolve such issues." Working with Public Employees for Environmental

Responsibility

(PEER) we conducted multiple Missouri Sunshine Law Requests

that show a troubling lack of adherence to existing guidance for water storage

tanksownedand operated by the Missouri Deparhnent of NaturalResources

(MDNR) in its Division of State Parks (DSP). This department

also houses

the state primacy agency

for administration

and enforcement

of the SafeDrinking Water Act in Missouri: the Public Drinking Water Branch (Water Protection Program, Division of Environmental Quality). This agency

hasposted

its guidance

for tank inspection

at http ://dnr.mo. gov/rrirbs/pub2

I I ?_pdi At last count, MDNR was responsible for 49 public water systems at the 87 state

parks and historic sites it administers

through its Division of State

Parks. In 2013

and 20014 PEER reviewed 11 state

park water systems.

At only threeparks had any comprehensive inspection and cleaning

of water storage

tanks been

conducted

within the previous

five years. At these threestate

parks that conducted

the comprehensive

inspections,

threedifferent professional tank inspection

firms were hired to inspect and clean

four water storage

tanks. Results

of PEER's MissouriSunshine

Law requests

aresummanzed

in thetable

below:

Reports for those four professional

inspections

contained

cause for major concem. Only one watertank, at Onondaga CaveState

Park,was fenced

for security;

the otherthree

tankswere cited for the lack thereof. The Onondaga Cave tank had an inadequate

vent which was replaced by the inspector;

the tank overflow screen was nearly clogged

by lady bugs,demonstrating the tank had been

contaminated,

The pedestal

watertower at Washinglon State Park,attributed cause of unreported

waterbome

illness discussed

above, was cited \n a2012 inspection report not only for a lack of security fencing, but also for failure to lock the roof hatch. Missowi State

Parla: Sunshine

Review of Water Storage Taerks 2013 and 2014 PWS ID# PWS Name County lnspection and Cleaning within 5 vears? MOI120159 Knob Noster StatePark Camoeround Johnson No MOrr22U9 Harry S Truman State Park Camppround Benton No MO4l2016l Lake Wappapello State Park Wayne No MOsl20l48 Bennett Springs State Park Well I Laclede No MO5l20166 Roarins River State Park Barry I yes. I no MOsl2266l Lake of the OzarksState Park-Homestead Miller No MO6120055 Cuiwe River StatePark CamD Derricotte Lincoln No MO6r20t47 Babler State Park St. Lnuis No MO6l20l73 Washineton State Park Washinston Yes (2) MO6t22t99 Onondaga Cave State Park Crawford Yes MO6122659 Cuivre River StatePark Camp Sherwood Lincoln NoPage5 of8

The Roaring River State Park Sunshine

Request yielded a20ll comprehensive inspection/cleaning

report by a professional

firm for their standpipe,

but not for their in-ground storage tank. A 2010inspection by MDNR's Southwest

Regional Office contained

the following in regard to that facility: 7. Thepublic

water syslem does not have adequate sccurity around the storage tanks. In particular,

the valve house door to the concrete in-ground stor&ge tank serving Well #3 h8d been forsed open. basically thesame condition as found during theprcvious

ycar's inspection when vandals had destroyed

lhe concrete

blocks anchoring

the valve house doorlock.-
Lack of security

fencing around

watertankswas also cited by multiple regional offices of MDNR's Division of Environmental Quality (DEO in their routine inspection

reporrs.For Lake Wappapello

State Park,the Southeast

Regional Office stated

the following in 2009: "It is recommended

that planning begin now to arrange for the next inspection which should be performed within the next one to twoyears.

It is also recommended

that security fencing be installed around the storage facility." Lack of security

fencing is alsomentioned

in this office's inspection reports of 2008 and 2013 for this water system.

Notesfrom the 2008 Compliance and Operational

Inspection

form indicate security fencingwas "In budget,"but by Z0l3 ithad still not beeninstalled. One can find this old water toweron Google

Earth, about a mile from the endof Highway 172 onAllison Peninsula.

Thereis no evidence

of fencing and it appears very isolated

and vulnerable

to any carload of partying teenagers

with a can of spray

paint. The history

of the water

towerat Cuivre River State Park's Camp Derricotte,

PWS ID # MO6120055,

merits a case study. Camp

Derricotte

had oneof the worst records

of the 2,800 public water systems

in Missouri for compliance with the Total Coliform Rule in fiscal year 2012(July 2011

through June 2012) when it incurred

six health-based

violations.

This is a seasonal system listed as routinely openApril throughOctober. For five of the seven monthsit was open in FY20l2, it exceeded

the manimum

contaminant

level for total coliform bacteria.In September

2011 this system

exceeded the standard

for bothtotal coliform and E. coli bacteri4 resulting in a boil water order. Drinking WaterWatch on the MDNR website documented

that from June

2011 through May 2012,36samples

tested positive for total coliform bacteria with one E coli positive. All these positive samples

were collected

in the distribution system. All source water samples

tested negative. The Missouri Departrnent of Nattual Resources

responded

by budgeting

$100,000 to install chlorination,

but failed to inspect

the watertower. After new construction of permanent disinfection,major problems with the stnrctural

integrity of the existingwatertower (circa 1938) were evident.

As stated

in a May 18,2012 e-mail between DEQ staff, "Their tower still has a leak and drains down partially overnight, so they are fighting with that also."Page

6 of8

PEER's Sunshine

request netted a shing of e-mailsshowingDivision of State parks staff considered

hiring a professional

tank inspection

firm, but faitea to follow through. AMay 22, 2012 e-mul states, ".. 'I recommend

starting the repair process of theCamp

Derricotte water tankby having

a thorough cleaning & inspection.

DEQsuggests

havingtanks

inspected every five yr*tl I do not know when thistank was lastinspected." In a June 13,2012

e-mail, howevero DSPstaffindicate

a reliance

on chlorination

to postpone

the obvious need

for a comprehensive,

professional

watertank inspection

and cleaning: * If thechlorine

system, after everything

is up and running the way it should,

works and our bacteriological

samples consistently

come back good, then I have no problem

waiting for the inspection..." And wait they did. In e-mails dated September

ll,2}Il,two years

after the Carnp

Derricotte acute maximum contaminant

level violation and boil order, DSP staffe-mails DEQ staff; "Do youknow

thelast time that our water towers were inspected (inside and out)?' DEQ staff replies, "I have nothing except DNRexternal

comments during water system inspections." Any chlorinatormalfunctioncould cause any problemwith the sanitary integrity of this water tower to pose

an imminent threat

to consumers.

A flock of birds roosting in or on this tank could overwhelm

the routine operation

of this disinfectionsystem. At Camp Derricote they could be bleaching

the bones

of a dozen

dead birds with others

entering and leavingthe tank at will; all out of sight,

out of mind. As a group camp,long

periods between use couldcause

a significant build-up of disinfection byproducts; these would also go undetected, astesting is not required at a transient

non-community

system. PEER has

written both EPA Region VII and MDNR concerning

the lack of a comprehensive inspection

of the Carnp

Derricotte

watertower. Region VII thought

their status

quo was adequate.

MDNR did not respond

at all. PEER has issued

two news releases

concerning

the lack of water storage tank inspection

at Missouri State Parks: http://www.peer.org/nervs/news-rele'ases/201 3/1 0/29lmissouri-park-water-systems-courtcontamination/ and http:i/www.peer.org/news/ncws-re le ases/2014/07/

l4imore-salt-drinking-water-violations-atmi ssouri -state:parks/ Missouri is the only state for which PEERhasconducted Sunshine Law or Freedom

of InformationAct Requests concerning

water storage

tanks. We speculate

that Missouri is probablybetter

than average,

given their experience

with Gideon. For other states, Gideon and Alamosa may se€m

like flukes that happen

oncea decade

somervhere

lse. When MDNR fails to heedits own primacy agency's guidance in the state

with the greatest

documented

loss of lifePage

7 of8

dueto a contaminated

water storage

tank, it is time for federal rulemaking to mandate

a minimum standard

nationwide.

In EPA Publication'Controlling Disinfection

By-Products

and Microbial Contaminants in Drinking water"3, the authors eloquently

describe a serious dilemma: "Drinking water disinfection,

therefore, poses the dilemma of a risk tradeoff. Chemical disinfection

reduces riskof infectious

disease, but the interaction

between chemical disinfectants and precursor materials in source water results in the formation of DBps." This scenario

becomes extreme whenthe precmsor

material is introduced

in the distribution system rather than the source

water. Thereis no endto the documentation of whole animals being introduced

to storage

tanks in the distribution system. Influx of natural organicmaterial

of this magnitude

precludes

rational chlorine dosage

and causes

DBP levels to skyrocket. The Groundwater

Rule has required

hundreds of public water systems

across the countryto install permanent

disinfection

whenthey had not been

required to do so before. When a problem with a watertank then arises, disinfectant

residual masks ih. d.t "tion of microbial pathogens in the distribution. Disinfection by product generation would then result at a type of water slstem not previouslyat risk for DBPs. These small groundwater

systems af,e most at risk for faiiure to maintain their chlorinator. The end result could also be worsemicrobiologically than had this system never installed disinfection

to begin with. Chlorination

is no cure-all

aliowinga pWS to neglect maintenance

of its distribution system. It is important

to remember

that not all forms of disinfectionare effective against all microbial pathogens,

the 1993 Milwaukee

outbreak,

a case-in-point.

Treatment

at the mostsophisticated plant in the world will do nothingto prevent a mammal

carrying Cryptosporidium into an inground water storage

tank with serious

sanitary defects. Disinfectant

byproducts

would still be generated,

but the Cryptosporidiun oocysts would not be inactivated. While it was

deficiencies in a tank at the Pitsford, United Kingdom watertreatment planta that allowed a rabbit to carry Cryptosporidium

into the system,

a defective

water storage

tank in the distribution could have the same result. Inspection

and cleaning

of water storage

tanksdecrease

both microbial disease

risk andthe generation

of carcinogens.

It is important

to factor-in the benefit of reduced of cancer risk of this regulation. This is a rare opportunity to decrease

risk on both sides

of the microbiallDBP equation.

3 Clarh RobertM. and Boutin, Brenda K. *Controlling Disinfection By-Products and Microbial Contaminants in DrinkingWater." U.S. Environmental Protection

Agency. Publication

Number EPA/600/R-01/110,

December 2001. a Drinking Water Inspectorate. "Drinking water 2008 Eastern region of England."

July 2009. A report by the Chief Inspector of Drinking Water. ISBN: 978-l-905852-31-4.Page

I ofE Vandalismgmd

the Need for Security Tank inspections

frequently

cite one of the top concems for the sanitary

integrity of a watertank: security. The watertower has long been the most recognized

and celebrated

water storage

tank and long shown

to be irresistible

to adolescent

males. In the movie "What's Eating Gilbert Grape" Leonardo

DiCaprio climbs the fictional village of Endora's water tower. Comedian

Jeff Foxworthy's

routine "You might be a redneck i{" includeso

"you've ever climbed a water tower with a bucketof paint to defend your sister's

honor". But when Country singer Montgomery

Genry's lyrics inspired

a young man to climb the Paul, Idahowatertower and spray paint*I LUV STACI" in 2007 the $1,970

bill was no

joke:http://www.deseretnews.com/articlel69523855lilvlans-graffiti-plight-is-playing-out-like-acountry- song.html?p

g=al . What may seem

as harmless

pranks to some escalates to serious

public healthconcern

when hapless youth open

tank hatches,

urinate andthrow garbage inside. The Missowi Department of Natural Resources

documented

suchan incident in Lanagan, Missouri in about 1995,

but this could occuranytimeanywhere there is inadequate

security at a water storage

facility. While fencingwill not deter

an individual with a bolt cutter,fencing goes a long way to deter

the casual vandal. Water system

securityrules apparently do not apply to systems

servingless

than a population

of 3,300. While these

small systems

are less likely to be targets

of international terrorisrn,

a remote location makes

them much more inviting to a carload of partying teenagers. Watertank inspections

help close

this gap. Satelliteimageryreveals thereare far too many unfenced water storage

facilities. Conclusion It is significantthat the Association of State Drinking Water

Administrators

(ASDWA) stated 45% of states

responding

favored federalregulation

of distribution system

storage facility inspection

and cleaning. While numbers opposed were not given, that 45o/o is not bad given the heavy load of new regulations states are charged

with implementing. Also no one disputed the necessity of water tank inspection

andcleaning. The question

remains, if EPA does

not regulate

tank inspection

and cleaning,

how will it proceed given ttre incontrovertible evidence concerning

water storage

tank contamination?

EPA iegulation has neglected

the distribution system

at public water systems

far too long. As the doundwater Ruli requires 4-log inactivationof viruses, will the Revised

Total Coliform Rule then require gg.gg%inactivation of bugs,birds, squirrels

andteenagers?

Crankingup the chlorinator is not a valid answer. The obvious solution is to require every public water system to provide proof positive of the sanitary integnty of their water storage tanks' Sincerely,
;

Irl i ,r l{.ar rr \ ,' !

-- Patricia J. Ritchie Hartsburg,

Missouri .. I

g' ;" i t-a!