July 11, 2011
Monday

It is my understanding that Ketchikan will be converting to a chloramine disinfection system in the public drinking water.  I am the director of The Chloramine Information Center in Pennsylvania. I have been corresponding with Thomas and Kristine Bellanich, customers in your water district and submit this letter together with them.  I would ask that you consider this letter and the information attached to this email in educating your readers as to whether it is prudent to proceed with Chloramine in your water system.  I sent a similar letter to the mayor, council and water company manager prior to the July 7th meeting.

Issues regarding chloramine across the country:

The rise in chloramine use in the US from 2005 to 2010 is a direct result of Stage 2 regulations by EPA requiring the reduction of TThms and haas, byproducts of chlorination. These regulations are to be implemented as of 2012. The determination of levels of these byproducts will change with the new regs to a locational running annual average rather than an average across the testing locations.  Water companies are often finding that they have one or two testing locations that exceed EPA levels when tested individually.   however water companies across the US are also finding that use of pre-chlorination filtration significantly reduces the formation of tthms and haas during the chlorination process and thereby eliminates the need for introducing chloramines.

Chloramine is not necessary, it is dangerous to humans and the environment and it will most likely be an unaccepted alternative within the next five years.  here is why highly toxic unregulated byproducts of chloramine:

The current and accepted science in peer reviewed studies acknowledges that the byproducts of chloramine (hydrazine, iodoacetic acids, NDMA and DXAA) are thousands of times more toxic than the tthms and haas it is used to control.  These byproducts are genotoxic, cytotoxic and mutagenic meaning that they can cause birth defects, cancer and cell damage.  We have over 50 peer reviewed studies that verify this point.  We have asked the water companies, state EPAs and US EPA to provide even one study that disputes our findings or that concludes that chloramines and their byproducts are safe...in 4 years, we have not received a single study.  The byproducts of chloramine are formed primarily in the distribution system and therefore cannot be remedied at the plant. According to NSF, filters will not remove the byproducts from the water, they can only reduce the compound itself at the tap or as it enters the house. Two states have already regulated NDMA to levels that will make compliance difficult if not impossible using chloramine. Others will be following.  A national effort is underway to make these levels an urgent priority of the USEPA. Chloramine is already on its way to being an obsolute aternative.

Acute adverse health effects reported in 20 states:

We have hundreds of reports from individuals and families in 20 different states reporting similar symptoms from chloramine exposure. These symptoms include:  mouth ulcers, persistent skin rashes, digestive issues including IBS and reflux, and respiratory ailments.  These individuals have removed themselves from their water temporarily and found the symptoms have abated and upon return to their chloraminated water, the symptoms return.  Doctors are unable to successfully treat these issues with salves or medicine.

The symptoms are most noticeable in older individuals and children.  Chloramine can cause an increase in nitrates in the water. Blue Baby Syndrome results when infants and toddlers ingest nitrates. The nitrates rob the blood of oxygen. In adults the deficiency in minimal however in babies and toddlers, such oxygen deficiency can cause brain damage.  Making bottles of formula with chloraminated water increases the possibility of Blue Baby Syndrome.

Lead poisoning in D.C.

The uninformed use of chloramine in washington D.C. resulted in thousands of children suffering ingestion of large amounts of lead in their drinking water.  A law suit is currently filed in D.C. by parents of children who suffered developmental delays due to lead exposure.

Environmental issues:

At least three major fish kills resulted from exposure to chloraminated water during main breaks or facility leaks or spills.  In Virginia, 9 miles of stream were rendered dead when a main break poured chloraminated water into the stream. In British Columbia, a thousand species of white fish and invertebrates were killed as a result of a leak and in California, protected steelhead trout were killed as a result of a spill.

National Security issues:

The chief of infrastructure security for home land security testified before Congress that chloramination posed a security risk to water systems and recommended that it not be used in areas that include military bases.  Chlorine will react to a foreign agent introduced into the water supply...levels will drop and flags will go up immediately at the plant warning of an invading contaminant. Chloramine, however, binds the chlorine keeping it from reacting with the intruding contaminant, maintaining its levels and allowing the contaminant to flow through the system undetected and into our homes.

Rubber and elastomer erosion:

Peer reviewed studies have indicated that rubber and elastomer plumbing fixtures that had a life expectancy of 5 to 6 years in chlorine have a life expectancy of 5 to 6 months in chloraminated water.

Why Alaska does not need to use chloramine:

A review of your water quality report indicates that your water facility  does not pre-filter your surface water prior to chlorination. Studies have shown that precursor removal is the preferred and most effective manner of reducing regulated byproducts.  In fact, since numerous studies from AWWA and renowned universities have cautioned against the wide spread use of chloramine, the industry is turning toward precursor removal as the preferred method of meeting EPA stage 2 regs.  Your levels of tthms and haas are sufficient low that precursor removal appears to be a viable and safer alternative.  I am attaching materials from Calgon who is a leader in the nation in providing education and systems in filtration and precursor removal.  Contrary to what you may have read, filtration is not cost prohibitive. If in fact, EPA reconsiders approving the use of chloramine, which we have reason to believe the will within the next 5 years, your facility to have to explore other alternatives to reduce tthms and haas.  Why not look at those alternatives now to provide water that is safe to your customers and avoid the problems and expense of re-creating the wheel when chloramine is no longer an option.

I have spoken with the leading experts in water in the US and have the studies to back what I have set forth above. I would be happy to speak directly to you regarding these issues and forward any and all materials you may request. Please give the use of chloramine more thought before you expose your residents to this very toxic, little understood and unregulated alternative.  

Susan K. Pickford, Esq.
Camp hill, PA

www.chloramineinfocenter.net
www.vce.org
www.chloramine.org