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.

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.

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.

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: http://www.charitablewealthinfo.com/pics/drugsinthewater.pdf)

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: http://www.time.com/time/specials/packages/article/0,28804,1976909_1976907_1976871-2,00.html). There are currently some organizations promoting this type of education and community outreach: http://www.iisgcp.org/unwantedmeds/. 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.

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.

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.