Patricia J. Ritchie

23600 S. Missouri River View 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 Ground Water and Drinking Water

Standards and Risk Reduction Branch

l20l Constitution Avenue NW

Mail Code 4607 M

Washington DC 20004

RE: COMMENTS IN SUPPORT OF RULEMAKING FOR DRINKING WATER

DISTRIBUTION SYSTEM STORAGE FACILITY INSPECTION AND CLEANING

Dear Mr. Conley;

Overview

I did not learn of the October 15,2014 meeting on this subject until January 2015 and received a

copy of the recorded webinar in May. I have reviewed the webinar and urge US EPA to swiftly

promulgate a basic rule to deal with the doubtless hundreds of contaminated water tanks that

exist at public water systems across the country. There is broad concrurence and virtually no

dissent that inspection and cleaning of these tanks is desperately needed. The voluntary

approach has achieved atl it can over the past two decades. The time for a federal rule 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 webinar arc 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 disinfection byproducts (DBPs), known carcinogens regulated as total trihalomethanes

and haloacetic acids. Rarely does US EPA have the opportunity decrease both acute and longterm health effects in a single rule; please don't waste it.
Page 2 of8

Backeround

A US EPA document entitled *Finished Water Storage Facilities"l dated August 15,2002 states

the following in the Background and Disclaimer section:

"The USEPA is revising the Total Coliform Rule (TCR) and is considering new possible

distribution system requirements apart of these revisions."

This document describes the 1993 Gideon. Missouri outbreak as follows:

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).ltrolI ill 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-r 111 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 perrple trt 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 page 4:

"The outbreak resulted in 442 reported illnesses, 122 of which were laboratory-confirmed and

one death. Epidemiological estimatesuggest 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.rlltletttlllelil 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 water tank inspection and cleaning. The authors imply had the National Primary

Drinking Water Rules new requirements included water tank 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. Colorado Deparfnent of Public Health and Environment.
Page 3of8

"The investigation into the Alamosa outbreak of 2008 confirmed that the physical, regulatory and

human infrastructure had all failed in some way to protecthe public's safe drinking water

supply."

The State of Colorado has learned from this regulatory failure and promulgated Regulation 11.28

Storage Tank Rule with an effective date of April1,20t6, as per

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 federal rule.

Colorado has given you a good template to start with.

Incidgnce of Waterborne Illness

During the meeting of October 15, 2014 commenter Randall Moore of Utility Services Group

mentioned an incidence of waterborne illness not previously found in documentation: Serious

illnesses resulted when seasonal tumover of a water tank at a Missouri state park occurred;

fortunately there were no fatalities. Personal communication with Mr. Moore on May 15,2015

indicated the water tank in question was the pedestal water tower 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 representhe

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 even more diffrcult to track, with

consumers readily leaving the state before symptoms occurred. Such scenarios demonstrate a

federal rule is in order.

On page l0 of the Alamosa report, Falco and Williams include the following statement:

"Most people do not seek care for their symptoms. Typically, an estimated 3E acfual cases oc.cur

for each one reported."

If one were to then factor in the increased cancer risk due to 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

and Alamosa. It is the documentation of such incidents that is rare, not their occurrence.

Voluntarl Approach Not Working in Missouri

The Federal Register for September 4,2014 posting includes the following at

hups://www.federalregister.gov/articles/20141}9/0412014-21073lnotice-of-public-meeting-andwebinar-distribution-system-storage-facility-inspection-and-cleaning:

"Some commenters suggested the need for a Federal regulation requiring systematic inspection

and cleaning because the existing practices ane not successful in all cases. Others suggested that
Page 4 ofE

regular sanitary surveys conducted by States and the adherence toexisting 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 tanks owned and 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 Safe Drinking Water Act in Missouri:

the Public Drinking Water Branch (Water Protection Program, Division of Environmental

Quality). This agency has posted 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 three parks had any comprehensive inspection

and cleaning of water storage tanks been conducted within the previous five years. At these

three state parks that conducted the comprehensive inspections, three different professional tank

inspection firms were hired to inspect and clean four water storage tanks. Results of PEER's

Missouri Sunshine Law requests are summanzed in the table below:

Reports for those four professional inspections contained cause for major concem. Only one

water tank, at Onondaga Cave State Park, was fenced for security; the other three tanks were

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 water tower 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 State Park

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 Ozarks State

Park-Homestead

Miller No

MO6120055 Cuiwe River State Park

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 State Park

Camp Sherwood

Lincoln No
Page 5 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 2010 inspection by MDNR's Southwest Regional Office contained the following

in regard to that facility:

7. The public 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 the same condition as found during the prcvious ycar's inspection

when vandals had destroyed lhe concrete blocks anchoring the valve house door lock. 

-

Lack of security fencing around water tanks was 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 two years. It is also recommended that security fencing be

installed around the storage facility."

Lack of security fencing is also mentioned in this office's inspection reports of 2008 and 2013

for this water system. Notes from the 2008 Compliance and Operational Inspection form indicate

security fencing was "In budget," but by Z0l3 ithad still not been installed. One can find this

old water tower on Google Earth, about a mile from the end of Highway 172 onAllison

Peninsula. There is 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 tower at Cuivre River State Park's Camp Derricotte, PWS ID #

MO6120055, merits a case study. Camp Derricotte had one of 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 open April through October. For five of the seven months it

was open in FY20l2, it exceeded the manimum contaminant level for total coliform bacteria. In

September 2011 this system exceeded the standard for both total coliform and E. coli bacteri4

resulting in a boil water order. Drinking Water Watch on the MDNR website documented that

from June 2011 through May 2012,36 samples 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 water tower. After new construction of permanent

disinfection, major problems with the stnrctural integrity of the existing water tower (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-mails showing Division 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 the Camp Derricotte water tank by having a

thorough cleaning & inspection. DEQ suggests havingtanks inspected every five yr*tl I do not

know when this tank was last inspected."

In a June 13,2012 e-mail, howevero DSP staffindicate a reliance on chlorination to postpone the

obvious need for a comprehensive, professional water tank inspection and cleaning:

* If the chlorine 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 you know the last time that our water towers were inspected (inside and out)?'

DEQ staff replies,

"I have nothing except DNR external comments during water system inspections."

Any chlorinator malfunction could cause any problem with 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 disinfection system. At Camp Derricote they could be

bleaching the bones of a dozen dead birds with others entering and leaving the tank at will; all

out of sight, out of mind. As a group camp,long periods between use could cause a significant

build-up of disinfection byproducts; these would also go undetected, as testing 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 water tower. 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-syste ms-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 PEER has conducted Sunshine Law or Freedom of

Information Act Requests concerning water storage tanks. We speculate that Missouri is

probably better than average, given their experience with Gideon. For other states, Gideon and

Alamosa may se€m like flukes that happen once a decade somervherelse. When MDNR fails

to heed its own primacy agency's guidance in the state with the greatest documented loss of life
Page 7 of8

due to 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 risk of infectious disease, but the interaction between chemical disinfectants

and precursor materials in source water results in the formation of DBps."

This scenario becomes extreme when the precmsor material is introduced in the distribution

system rather than the source water. There is no end to the documentation of whole animals

being introduced to storage tanks in the distribution system. Influx of natural organic material 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 country to

install permanent disinfection when they had not been required to do so before. When a problem

with a water tank 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 previously at risk for DBPs. These small groundwater systems af,e most at risk for faiiure to

maintain their chlorinator. The end result could also be worse microbiologically than had this

system never installed disinfection to begin with. Chlorination is no cure-all aliowing a pWS to

neglect maintenance of its distribution system.

It is important to remember that not all forms of disinfection are effective against all microbial

pathogens, the 1993 Milwaukee outbreak, a case-in-point. Treatment at the most sophisticated

plant in the world will do nothing to 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 water treatment 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 tanks decrease both microbial disease risk and the

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 Robert M. and Boutin, Brenda K. *Controlling Disinfection By-Products and Microbial Contaminants in

Drinking Water." 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 water tank:

security. The water tower 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 bucket of paint to defend your sister's honor". But when Country singer

Montgomery Genry's lyrics inspired a young man to climb the Paul, Idaho water tower 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 health concern when

hapless youth open tank hatches, urinate and throw garbage inside. The Missowi Department of

Natural Resources documented such an incident in Lanagan, Missouri in about 1995, but this

could occur anytime anywhere there is inadequate security at a water storage facility. While

fencing will not deter an individual with a bolt cutter, fencing goes a long way to deter the casual

vandal. Water system security rules apparently do not apply to systems serving less 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.

Water tank inspections help close this gap. Satellite imagery reveals there are far too many

unfenced water storage facilities.

Conclusion

It is significant that the Association of State Drinking Water Administrators (ASDWA) stated

45% of states responding favored federal regulation 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 and cleaning.

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 inactivation of viruses, will the Revised Total Coliform Rule

then require gg.gg%inactivation of bugs, birds, squirrels and teenagers? Cranking up 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!