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Topic 3: Use the authority of multiple statutes to help protect drinking water.

2010 July 29

We want to take common sense steps that make the most of EPA’s broad-reaching programs and use all appropriate authorities to protect drinking water. Rather than having these programs working independently, we want to bring them together where they overlap. For example FIFRA – the Federal Insecticide, Fungicide, and Rodenticide Act – can use pesticide registration to assess drinking water risks, generate missing data and develop analytical methods for drinking water regulations. Under TSCA – the Toxic Substances Control Act – we can use EPA’s chemical action plans to identify and address drinking water issues that may be posed by widely used chemicals. This means that we can take steps to stop contaminants before they get into drinking water – a safer and cheaper alternative to getting them out of drinking water.

  • EPA is focusing on regulated contaminants and those that are on the Candidate Contaminant List 3. Are there other contaminants you believe EPA should focus on?
  • EPA has the ability to limit or restrict the use of chemicals, if warranted.  What kind of requirements or criteria should EPA consider for chemical contaminants using authorities other than SDWA?
  • How often and who should be conducting monitoring to determine occurrence?  Should it be states, public water systems, or pesticide manufacturers?
  • What other opportunities do you suggest for EPA to use authorities to protect drinking water?

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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30 Responses leave one →
  1. Planet Watcher permalink
    August 17, 2010

    Thanks for the opportunity to comment.

    The Nation and the EPA must come together and recognize the largest threat to drinking and recreational waters. I expect that those reading this may have already assumed I am referring to large farms. I am not. While large farms do contribute to the problem, they are a long, long way from being the single largest source. What is that source?? It is you and I. Many of our nations municipal sewage treatment plants are in decrepit condition, they are forced to dump raw human sewage into the nearest water body whenever there is a modest to significant rainfall. EPA has given tacit approval to these dumps. If they did not dump this raw waste into our rivers, streams lakes and oceans during large rainstorms, our sewage would back up into our houses causing a significant health problem. The agriculture community, farms large and small have many tillage and runoff practices in place and have significantly reduced runoff from farm fields. What good does it do for us if a farm manages it’s waste in a responsible manner only to have the nearby town dump millions of gallons of raw sewage downstream from the farm. Lets admit responsibility for our waste and petition government to stop municipalities from dumping. Milwaukee WI is a prime example. The city dumps 2 or 3 times a year and it is always in the Billions of gallons. I don’t advise swimming in any of the Great Lakes, they are all septic tanks for many of the municipalities on their shores

  2. Barry Tonning permalink
    August 17, 2010

    I think source water protection is key to addressing contaminants as a group. We’ve made some progress along these lines for both groundwater and surface waters, but I believe a stronger message is needed to convey the types of practices that protect drinking water sources (e.g., keeping livestock out of source waters, maintaining vegetated buffers, stabilizing eroded stream banks, better communication and focus on high-risk activities in source water protection areas, etc.). In terms of what works, I would promote to the states a program of property tax relief for landowners who maintain vegetated surface water buffers, for starters. Thanks for the opportunity to comment.

  3. Beth Marsala permalink
    August 17, 2010

    My section in the MO Dept of Natural Resources regulates the construction of private wells in MO. We estimate that there are probably hundreds of thousands of abandoned wells in the state of MO and somewhere around 5,000 new private drinking water and irrigation wells are installed each year. The abandoned wells, as well as old improperly constructed wells that are still in use constiture a constant threat to a groundwater resource that affects not only the private well owners but also public water supplies. Has EPA looked at coordinating with other laws that are not federal that protect the groundwater?

  4. Robert permalink
    August 18, 2010

    More public outreach about not flushing medicines/drugs down the toilet; and how they should be properly disposed of.

  5. Mitch permalink
    August 18, 2010

    Based on the assumption that all potable water within a particular system meets appropriate regulations, prime concern should be directed toward preventing backflow of contaminants into the system. The primary means of accomplishing this task is through education – on all levels. Our findings indicate that the lack of education about cross connection control and backflow prevention is prevalent throughout the populus – including regulatory officials, water purveyors, and consumers. What good does providing safe potable water to customers accomplish if the water is not protected? A pilot study to determine potential risks due to backflow would be in order.

  6. Dean Wilson permalink
    August 18, 2010

    I live in a rural area of Michigan. Our local school tested as one of the worst in the state on the state wide educational tests. So , let’s make the school more interesting for the students be introducing real world problems as a method of learning science and what scientists do. First the students could survey the area’s evidence of health problems which might be related to drinking water(mostly wells). As we are in the corn belt with numerous CAFOS, one might suspect nitrites and nitrates from nitrogen fertilizer and also antibiotics from the manure of pigs and cows(which leads to MRSA which is reported byCDC and JAMA to have increased by nearly 75% over the past few years and now results in more deaths per year than from the HIV virus.)

    Next the students might set up a data collection system from the wells in the area and send the samples to a laboratory or two for testing.

    Next the students could publish their results in the local paper or in a special section of the EPA blog.

    Another benefit might prove to be that more students might choose science and /or science related diciplines for future study and career.

  7. Jane permalink
    August 18, 2010

    Where I live in upstate NY, very close to the Canadian Border and Vt., there are many natural springs and artesian wells. Does the EPA regulate who can take water from the ground and sell it on the open market? I presume around the world. Much of the ground water being taken from my area and across the border by the truckload comes from sources that straddle the border. Should the EPA be looking at ways to regulate this kind of activity, unless it already does? You can’t protect water if you don’t have any.

  8. Anna Nowack permalink
    August 18, 2010

    A designation of drinking water use in Water Quality Standards requires the body of water to meet Safe Drinking Water Act criteria. Those criteria are more stringent, providing better protection for the public, but are sometimes evaluated and tested in a different manor than WQS criteria. dissolved versus total recoverable, Total Chromium versus Chromium III or VI, etc. Is EPA considering a better correlation between SDWA and WQS criteria? Example, human health criteria for water only, such as organism only criteria developed in 2000.

  9. Daniel Cote permalink
    August 19, 2010

    In regards to getting people to participate in there communities water supplys’needs one has to inform the public about what they are facing and it’s conceqences for not doing anything about it. There is a true lack of public comunication regarding water issues.As an example I recently gave a talk to a group real estate agents regarding rules for radon testing in rental apartments and it’s importance. To my surprise none of the agents new anything about it though this law had been passed in 2009

  10. Marian permalink
    August 19, 2010

    Drilling for gas using fracking methods requires drilling through aquifers and pumping hundreds of thousands of pounds of toxic materials through those aquifers. DRILLING FOR GAS HAS BEGUN IN PENNSYLVANIA. Drilling activities and regulating this activity is “evolving” in the state, which means that companies don’t know what to expect from the various layers of regulatory agencies and that regulatory agencies are “reacting” to company activities. At the federal level, the Safe Water Drinking Act still exempts oil and gas industry from its standards. “Adaptive Management” may be effective for continuous improvement when managing natural resources, however, drinking water is too important of a resource to risk contamination by “evolving” or “adapting” or “learning as we go”, or “letting the process happen naturally”, or “having campfire or Bar-b-que sessions” to solve problems.

  11. Craig permalink
    August 20, 2010

    Quality of drinking water requires the coordination and cooperation of multiple authorities. Water sources are hydrological systems, fed by precipition, conveyed by rivers and streams, held by snowpack and reservoirs and urban piped systems. Contrary to conventional beliefs about protecting sources from intervention, allowing people to interact with water – recreate, enjoy the beauty of clean water and healthy landscape and perhaps even recognize water for its role in life on earth – will bring the greatest benefit for public health. In Colorado and the arid west people recognize the fiscal value of water. Let’s use multi-jurisdictional statues on water use and quality to achieve multiple benefits that include clean drinking water, prevention of flood disasters, quality of environment and quality of life.

  12. Barnett Frankel permalink
    August 20, 2010

    Enforce existing regulations and penalties. Known pollution-producing industriies need to contribute to superfund. Educate the public on point soure and non-point source pollution.

  13. John M. Ackerman, M.D. permalink
    August 20, 2010

    Potable Water Forum-Applies to parts 2,3 and 4

    EPA has historically researched and Regulated the chemical aspects of water Emergent Contaminants of Concern (ECC) but not the biological water Contaminants of Concern. Now, the most potentially dangerous and, therefore, urgent areas of concern are the multi-antibiotic resistant organisms. This must be priority No. 1. re: preservation of Public Health.

    The international medical, water and biological literature includes pertinent research by various authors including EPA scientist, Meckes (1982) documenting that:
    -potable water at the end of wastewater treatment processes and later at the points of use (POU) cultures out multi-antibiotic organisms that are potentially dangerous to Public Health. The use of single indicator testing is antiquated because it does not accurately reflect the universe of pathogens, especially those existing in water requiring high level disinfection.
    -contamination of potable water is, in large part, due to insufficient high level disinfection by wastewater treatment facilities of a.) recycled water (which leaves multi-antibiotic resistant organisms and their genetic fragments in agricultural ground) and b.) biosolids with the same contamination both washed off by stormwater from agricultural and/or pasture lands into river tributaries and aqueducts carrying wastewater treatment plant processed water to disinfection facilities which produce potable water.
    -there is no Regulated testing or culturing of chlorinated water at the points of use even though the literature documents that chlorine can:
    -increase resistance and virulence of some organisms and
    -shock ( kill or arrest) multi-antibiotic resistant organisms which often revive after a period of time.
    -organisms need not be killed by chlorine because it is their genetic fragments that transfer the resistance to our normal intestinal tract organisms (see Griffith, 1928)
    -it only takes a tiny genetic fragment to transfer the resistance and/or virulence to the normal organisms in our intestinal tracts. Once transferred, the medical use of antibiotics may not be able to kill or arrest organisms already in our systems that have initiated serious infectious disease both in immune compromised people or even people with normal functioning immune systems. This genetic fragment phenomenon is not characterized as a dose-response issue.
    – filtering the disinfected water with pores small enough to remove the tiny genetic fragments exactly at the points of use is essential.
    – culturing the multi-antibiotic resistant organisms must take place at the points of use after the above filtering and before the distribution to points of use.
    -it is essential that Federal and State Regulations for both wastewater treatment plants and disinfection facilities (just prior to points of use) be upgraded to deal effectively with the above sanitization of potable water.
    -Federal and State Regulations must convert to new cutting edge technologies that upgrade the processes of wastewater treatment plants by incinerating and therebye removing the contaminated biosolids suspended in wastewater prior to entering wastewater facilities. The incineration produces a methane type gas that can be used to power other equipment or be sold. Strategic metals can be recovered from the ash. Such new technology will usually create a profitable bottom line. The footprint of the plant will be substantially smaller.
    -the above type filters must be manufactured and utilized prior to the distribution of potable water.
    – the understanding of the culturing for multi-antibiotic organisms and the need both for a.)the above types of cutting edge wastewater treatment plants and b.) the creation and utilization for the above filters will definitely help the public and private sectors to invest in advanced drinking water technologies (for example,MicroMediaFiltration: 949-380-9800;
    – CDC and Public Health must be part of the initiation of upgraded Regulatory requirements.
    The monitoring should be done daily by the public water systems.

  14. L. Lawrence permalink
    August 20, 2010

    Stop exempting the biggest polluters from the clean water and clean air act. These are minimum standards at best and this would be a good place to start.

  15. Audrey permalink
    August 21, 2010

    I didn’t think so.

  16. Derek permalink
    August 23, 2010

    The Halliburton Loophole in the 2005 Energy Act exempts Hydraulic Fracturing from the Clean Water Act, Clean Air Act and a host of other protections. Now Drillers are bringing their poisons to Pennsylvania, New York, Virginia, West Virginia, Kentucky, Tennessee, and other states.

    Oil, Gas and Chemical companies complain that not allowing them to Poison Local Communities and their Water Supplies will force them to curtail hiring; Sounds a lot like the Offshore Drilling argument.

    “CANONSBURG, Pa. – Federal researchers studying a natural gas drilling technique that involves blasting chemical-laced water into the ground got an earful from residents who say it’s poisoning them and killing their animals” “In fracking, drilling crews pump millions of gallons of sand- and chemical-laced water deep into the earth to break up dense rock to free the natural gas. …water returns as a briny, chemical- and metal-laden brew”

    Frack Fluid Spill in Dimock Contaminates Stream, Killing Fish
    “drinking water in several area homes was found to contain metals and methane gas that state officials determined leaked underground from Cabot wells”

    Officials in Three States Pin Water Woes on Gas Drilling

    The fracing industry doesn’t care about doing it right and safe. They care about doing it cheap and dirty. The chemicals are poisons that are pumped directly and indirectly into ground water. The industry creates poisonous pools adjacent to wells that are lined with plastic as best, and not lined at all in most cases. Polluted water is sprayed into the air to help it dissipate and evaporate. Billions of gallons of fresh water supplies are poisoned as well as the people and livestock near fracing sites.

    Profiting on killing people and wildlife because the industry is too cheap cannot be allowed to continue. Just like the deep water oil drilling industry had fraudulent plans for dealing with an environmental disaster, the fracing industry has fraudulent plans for mitigating their pollution. The Halliburton Loophole (which needs to be closed ASAP) currently frees the industry from the Clean Water and Clear Air acts and other public protections. This is the first “Get out of Jail free” card that must be eliminated.

  17. Joseph Groen permalink
    August 23, 2010

    Stop Farm runoff.

  18. Joseph Groen permalink
    August 23, 2010

    We need to stop dairy runoff.

  19. Larry Menkes, cSBA permalink
    August 23, 2010

    I suggest a “both-and” approach that is case appropriate.

    To me, the most important issue is to address cumulative impacts both of similar insults from different sources, and the synergistic effects of the effects of multiple toxins in a single source.

    A good example of that would be the flowback and internal losses of frack fluids in wells near or in aquifers. This is emerging as a national crisis, and is beginning to cause great concern in the Delaware River basin; source of drinking and ag water for over 20 million people (if you count visitors and tourists).

  20. Edward Martinez permalink
    August 25, 2010

    We can talk about mainstreaming green automotive sectors all day long but until we adress the braking systems on these “eco-cars” we are missing a huge point source pollution problem.

  21. kelly zimmerman permalink
    August 30, 2010

    I live in Pennsylvania. It is a nice idea to instill some new rules and impose some fines for violators of our Clean Water Act, however what is the point if the EPA and our government allow the Gas and Oil drilling companies to be exempt from all of the rules!!! Apparently this has been a law since 1984. Until this is changed we will never have clean water in pa!!!

  22. Christy Perrin permalink
    September 1, 2010

    Source water protection provides a huge return on the investment. While engaging communities in watershed planning across NC, we often hear that the economics of keeping land in forest and farmland is not enough for most landowners to choose this option. Rather than pay property taxes on land where the “best use” is for development, they sell it for subdivisions and commercial uses. We need better and easier to understand economic incentives for land conservation, including riparian buffer protection. Funding mechanisms to help local governments acquire property and development easements for the express purpose of protecting headwaters and recharge areas would be very helpful. In the rapidly growing southeast, we’re in a race to protect water quality and supplies. We need incentives, and we need them fast. Tighter state regulations will likely get opposed by the more powerful interest groups if they are not required by EPA.

  23. Eric Madsen permalink
    September 3, 2010

    What is important, and in turn regulated, wrt water use will be determined by the perceptions of the harm of withdrawing water and impact of pollution from the discharge of water. The International Organization for Standardization (ISO) is writing a water footprint standard that will probably be referenced to quantify the harm of withdrawing water and discharging polluted water. Everyone who has concerns over this international evaluation of the impact of water withdrawal and pollutants discharged to water should voice their opinion. To participate in the writing of ISO 14046 Water footprint – Requirements and Guidelines, please contact the US administrator of the activity:

  24. Jenny Hoffner, American Rivers permalink
    September 13, 2010

    American Rivers appreciates this opportunity to submit comments on EPA’s new Drinking Water Strategy. This is an important step towards developing more effective federal protections for communities and the ecosystems on which they depend.

    American Rivers is a national non-profit conservation organization dedicated to protecting and restoring healthy natural rivers for the benefit of people, fish and wildlife. Our work is driven by a core conviction that a healthy river can be a community’s most valuable asset. By protecting and restoring rivers, streams and wetlands, we work to make communities and ecosystems more resilient to the impacts of climate change. American Rivers has over 65,000 supporters nationwide and has offices around the country. We are pleased to submit the following comments for your consideration.

    Water quantity is critical to any drinking water strategy especially as it relates to contaminants. Reduced flows in rivers (such as when flows are at or below 7Q10 or other low flow parameter used for setting permit limits) whether they are caused by drought, dam operations or development have the effect of concentrating pollutants and presenting increased risks to aquatic life, primary and secondary recreation, drinking water, and industrial and agricultural water use. Flow is fundamental to achieving the goals of the Clean Water Act to protect and restore the chemical, physical and biological integrity of our nation’s waters. American Rivers encourages EPA to examine and, where needed, implement new water quantity requirements or criteria as part of EPA’s drinking water strategy.

    In addition, climate change will have a significant impact on the sustainability of drinking water supplies in the coming decades. In order to ensure sufficient clean drinking water supplies in the context of climate change, utilities must adapt their operations to take into account the impacts of a changing climate. We encourage EPA to adopt the recommendations in the upcoming report from the National Drinking Water Advisory Council’s Climate Ready Water Utilities Working Group. The report includes a wide range of recommendations that will support utilities as the adapt to a changing and uncertain climate. Specifically, we encourage EPA to support climate change planning, education and adaptation at the utility level and incorporate climate change considerations into standard setting, permitting and modeling efforts in order to protect clean and safe drinking water supplies in the face of climate change.

    Finally, we urge EPA to maximize the use of source water protection as a robust strategy to protect clean and reliable drinking water supplies while also providing additional benefits to communities, rivers and wildlife. The Clean Water State Revolving Fund and the Drinking Water State Revolving Funds provide important funding streams for source water protection projects, and we ask that the EPA prioritizes source water protection in its guidelines and criteria for the use of these funds.

    We appreciate this opportunity to comment and look forward to working with EPA to move towards more sustainable infrastructure and cleaner and safer water.

  25. Janet Andersen permalink
    September 15, 2010

    Multiple regulations and integrated approaches to protect drinking water and the waters of the United States are essential to address the multi-faceted aspects of drinking water. I don’t know of any other way to end up with a system approach to the issue. Using FIFRA for pesticides permits, for example, will address some of the concerns with pesticides, but not others. The need is to embrace and address multiple areas of concerns without making the permit process complicated and expensive for both the applicant and the regulators. And I applaud a focus on preventing contaminants from entering our source waters.

    A systems perspective should really help. One of my pet peeves is that orthophosphate is one of the few corrosion control options for water supply small systems to control lead and copper in household plumbing. And phosphates are one of the leading contaminants of fresh water ecosystems. While some wastewater treatment plants have the capability to treat phosphorus, aging on site septic systems can be inadequate. And from a systems perspective, why must we add something to drinking water that we then must remove from our waste water? It would be helpful to have regulations address the components of faucets. And, in our small community system, the level of orthophosphates that we add is dictated by our copper results – not our lead results.

    As we think about source water protection, we need to apply sustainability concepts to both the quantity and quality of our source water. In land use decisions, we have to consider the implications on our water supply. Before water intensive industries or housing are installed, the sustainable supply of water should be considered. Who regulates bulk water exports, including drinking water sales like Alaska Resource LLC’s plans to export 2.9 billions of gallons annually, water bottlers, or major industrial or agricultural uses?

    Currently, the cost of water is based on the cost of installing and operating pipes and pumps, not on figuring out how to get clean water back into the supply. Even attempts to build future asset replacement into rates may not be approved by the current rate approval authorities.

    Thanks for the opportunity to comment. I recognize I wandered a bit in my response, but the indication that the forum would last “about a month” has me rushing so I don’t miss my opportunity to comment.

  26. Barbara Salvini permalink
    September 23, 2010

    Government Planning
    By not having a general plan for our nation and each state, population centers have grown to such densities that the environment can’t keep up with our pollution. Concentrating population centers to the point where people are spending large parts of the day commuting in cars that pollute the air and water, and create an unnecessary demand for fuels, which production creates its own pollution footprint, is irrational. Mother Nature can do a lot to clean up our byproducts if not overwhelmed. New satellite cities could be created with their own economy by building bullet trains to nowhere. Developers will build the rest of the improvements through the development process, and can even contribute to the initial cost through Facility Benefit Assessment Districts. Imagine what it could do for the productivity of our nation and our quality of life if each person had an additional two productive hours a day? What would it do for families if there was cheep property available for building homes a reasonable commute time from jobs? What would it do for government spending and health care costs if workers had lower mortgages so they could work for less?
    Government Regulation
    Regulate food and water containers to eliminate toxic compounds such as BPAs so that they do not end up in food stuffs and beverage (water) products. Recent reports claim that one is six men will get prostate cancer and one in eight women will get breast cancer. These are known to be estrogenic induced cancers, and we know many compounds created by industry (plastic byproducts, pesticides, etc.) are estrogenic. These hormone mimicking endocrine disruptors impact fetal development. It’s nice to have “the cure”, but we need to find out the cause of disease and prevent it. If everyone in the country paid for health insurance, each seven people would have to fund one person’s cancer treatment for just the two cancers listed above. The medical cost to society is nothing compared to the financial cost of losing a family breadwinner, and that cost is nothing compared to the emotional devastation. If we don’t do something radical, medical costs from created illness will bankrupt our country. We eat it, it does harm to us, we urinate, some of it gets past sewage treatment and it ends up in the next downstream city’s water supply to repeat the cycle. If we don’t want it in our bodies, and in the environment then we need to eliminate these products at the source.
    Public Education
    Nationally we need to educate the public for example to eliminate trash, clean up pet waste before rains, know what items are toxic waste and how to dispose of them (what are better product options), what things are OK to let go down the drain, what things cause sewer spills (again what are good alternatives for “bad” products), how to dispose of items such as unused drugs and how to eliminate or reduce chemical use for landscaping. If it’s in the environment, it will get into our water. Americans are known to be problem solvers and it they know what to do, they will usually do it.
    Thank you for this opportunity,

  27. Hailey Mulconrey permalink
    November 14, 2010

    In 2008, the Associated Press ran an article about an investigation they had launched into America’s drinking waters. During a five month inquiry, they found that pharmaceuticals had been detected in the drinking water of 41 million Americans in 24 major metropolitan areas. The study found low levels (measured in parts per billion) of numerous different pharmaceuticals in the drinking water of Americans: sex hormones, antibiotics, epilepsy medications, heart medications, anti-anxiety medications, mood stabilizing medications, etc.

    While minute amounts of these drugs may not harm us in the short-term, there is concern about the long-term effects of drinking small amounts of these drugs in our water. Many of these pharmaceutical drugs have side effects or interact negatively with other drugs. These studies that have determined that these low levels of pharmaceuticals in our drinking water are “safe” for humans have been conducted over the course of a few months. There are no studies to show how low levels of these drugs could effect us over a lifetime. (See AP Study in ABC News article:

    Last March, EPA administrator Lisa Jackson announced that the EPA would be taking steps to regulate all drinking water contaminants, including drugs. There needs to be more scientific studies conducted in order to research and determine the long-term effects of these drugs in our drinking water. There also need to be efforts directed at developing and implementing technologies that can cost effectively treat our drinking water in order to remove these drugs. Furthermore, there should be more community outreach directed at educating people about the damaging effects of flushing cosmetics, pharmaceuticals, or other chemicals. Many communities have developed “take-back centers” where people can go to drop off their leftover meds, so that these drugs can be disposed of properly. (See “Flushed Away” article in TIME:,28804,1976909_1976907_1976871-2,00.html). There are currently some organizations promoting this type of education and community outreach: These efforts need to be expanded, and more aggressive research needs to be conducted in order to help ensure the safety of our drinking water.

  28. Tali Cordero Gorriti permalink
    November 15, 2010

    In revising this topic on the Forum, it strikes me as odd not to have found any mention to the guidelines established by the World Health Organization for drinking water (Guidelines for drinking-water quality, third edition, incorporating first and second addenda), which do seem quite comprehensive (they can be found at:

    If the U.S. is a member of the UN-WHO, why not use the information and resources available from it? I’m sure there can be useful things to adopt or adapt from their body of knowledge.

  29. MK Randall permalink
    November 19, 2010

    I recently read a news article from May 2008 “Water system at drug abuse center near Castle Rock hit by vandalism.” This was in Washington State. It cost over $150,000 to recover this well. As, the president of a rural water district in NW Montana, I was faced with a wellhead security problem in that our two wellheads were near a road in full view. Fencing was not an option as the wellheads were too close to the road. And besides fencing does not really offer much security and my well invite vandals.

    We had a steel wellhead security cover designed that kept the wellhead from being easily accessed. Yet, it is easy to install by one person and access is easy via a sheltered lock, while still protecting the wellhead. And the padlock cannot be reached with a bolt cutter. Further, the cover prevents cutting of the electrical supply conduit, which is as vulnerable as the well cap, including its vent. And no cement base is needed to hold the security cover in place.

    I, for one, feel that the EPA should do more than “recommend” wellhead security measures; they should require them. I have encouraged our Montana DEQ to move in that direction, especially for public water systems. I recommend that the EPA update the current rules to state something along the line: “All Public Water System wellheads, Community, Municipal or Transient must be securely enclosed to prevent unauthorized access and to ensure protection of the entire wellhead, including the well cap, vent and electrical connections.”

    Compared to the cost of repairing and recovering an intentionally polluted well, whether by vandals or bioterrorists, a wellhead security cover is a cheap investment. Most public water systems can obtain a cover, like the one we developed, for between $600 – $1500, depending on well casing diameter and height. History shows that most Municipal Water Systems, especially small districts and home-owners-associations, do not consider the wellhead to be a security issue, believing that the standard well cap is sufficient. Unfortunately, I doubt if anything much will be done to protect vulnerable wellheads, of both active and inactive wells, without a requirement by the EPA.

  30. MK Randall permalink
    November 20, 2010

    AWWA recommended to the EPA in June 1010 that a Gross Alpha in excess of the 15 pCi/L MCL no longer trigger 4 quarterly tests. Instead it should indicate that more and perhaps different testing be performed. As the president of our Communiity Water Systems, I agree with that recommendation. We had a GAA in excess of 15 and kept running the same tests all year, only to find out that there are multiple EPA approved test methods available, some with more accuracy than others. Using EPA 900.0 for GAA and EPA 200.8 for Uranium Mass our water tested at a range of 16 to 24 on our 2 wells. Using EPA 900.0 for GAA, EPA 200.8 for Uranium Mass and SM 7500_U_C for Uranium Activity the two wells tested at 7.5 and 0.0. Using SM 7110C for GAA and SM 7500_U_C for Uranium Activity the two wells tested at 2.5 and 1.19. Thus the wells were in full compliance.

    I recommend that the various testing methods be documented in such a way to help the operator determine what test methods to use. I am working with the Wisconsin State Lab of Hygiene on a project to do just this, but the information should be made available at the EPA level and not at the State or Lab level.

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