Improve the safety of WV American Water's system

I am writing to provide comments in the general investigation of WV American Water's response to the Freedom Industries spill (Case No. 14-0872-W-GI). The Freedom Industries chemical spill has revealed a number of weaknesses at WV American Water raising questions about what “reasonable utility practice” means for the Kanawha Valley and surrounding counties. The water utility must be able to supply safe and wholesome water in the face of chemical challenges like that of January 9. I believe you need to address the following issues in your general investigation. I believe that WV American Water:

• Had no effective source water protection plan in place that identified threats to its only water supply intake;
• Had no system for monitoring for potential contaminants upstream of its water intake;
• Had little or no reserves and leaky infrastructure that prevented the company from closing its intake;
• Failed to quickly remove contaminated charcoal filters that continued to leak MCHM and PPH into drinking water for months;
• Had no emergency response protocols for sampling for contamination throughout its systems, standards for chemicals stored upstream from the intake, or procedures for clearing their system and its customers’ homes and businesses of contaminated water;
• As public water systems and groundwater have been contaminated by pollution from the coal industry and other sources, and as smaller PSD’s have struggled to maintain their infrastructure, the Public Service Commission has approved the takeover of these systems by WV American Water, resulting in an overextended system with many operating problems.

WV American Water customers have filed complaints at the PSC protesting being charged for contaminated water. The PSC sets and manages rates for water, and determines whether water company practices are “just and reasonable,” including whether these practices produce water that is pure and wholesome. The WV Bureau for Public Health sets specific chemical content standards for safe drinking water. The WV Department of Environmental Protection also protects source water in WV by inspection and enforcement of water quality pollution standards. This spill has shown that there is poor coordination between these agencies in protecting drinking water for which customers are charged. Please use this general investigation to improve coordination among agencies, set clear standards, and develop protocols for managing emergencies like the Freedom spill.

Thank you for accepting these comments in this case.