EVALUATION
of the
KENTUCKY WATER SUPPLY PROGRAM
SUMMARY
DRINKING
WATER
Bureau of Water Hygiene
Environmental Protection Agency
Region IV
May 1972
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PREFACE
The information contained in this SUMMARY has been
condensed from EVALUATION OF THE KENTUCKY WATER
SUPPLY PROGRAM. The significance of the findings
is further discussed for all who have an interest
in the quality and protection of drinking water
in Kentucky.
The SUMMARY highlights the important results and
areas of major need. It is intended to conserve
the valuable time of those who do not wish to
study the numerous details of the complete report.
For more detailed information, consult the Kentucky
State Department of Health, Environmental Protection
Agency, or the complete text.
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TABLE OP CONTENTS
Page No ,
PR.EFACE ....... .•. ... ......4. . .. .•. .• . .•s i
INTRODUCTION ...S. . .S••StS•••SS•••••te••••*Ø*•••S•••••e•• 1
SCOPE •..... ...... ...ee .e• . .... •...e......... .. 3
Water Supplies in Kentucky .......................... 3
Water Supplies Studied . . . . . . . . . . . . . . . . . . . . . . . 3
figure 1. Location of Water Supplies Surveyed .. 5
Program Evaluation . . . . . . . . . . . . . . . . . * • . • . . . . . . . . . . . . . 6
SUMMARY0PflNDINGSANDCONCLUSIONS..................... 7
Water Supply Status •.....S.......................... 7
Water Supply Program .........................•...•, 14
RECo oIENDA .rIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
ACKN()WLEDGENENTS • .. .••••s••••••••••••se••*e•s•••e•st4• • 23
STATE AND FEDERAL AGENCY ADDRE SSE S . . . . . . . . . . . . . . . . . . . . . 24
REFERENCES •. . .......e••e• .e•s .e*•****e*•s••* 25
APPENDIX A . . . . . . . . . . . . . . . . . . . . . . . . . . , • • • • • • , • • • • , • • • • • 26
ii
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INTRODUCTION
Historically, water in the United States has been involved in the
transmission of much infectious disease, and many epidemics were
sustained and spread by pathogenic organisms in drinking water.
With the advent and widespread application of modern water treat-
ment techniques, especially filtration and disinfection with chlorine,
water-borne disease occurrence declined dramatically until it became
unusual for public water supplies to be implicated in disease trans-
mission. Today, however, there is evidence that growing complacency
in public drinking water regulation and surveillance has replaced the
aggressiveness which characterized earlier efforts. Even though
water pollution control programs will surely be expanded in the
future, this alone cannot assure safe drinking water. Both today and
in the future, delivery of adequate quantities of safe, wholesome
drinking water will be dependent upon properly designed, constructed,
and operated water systems and vigorous health agency regulation and
surveillance.
Recognizing the importance of drinking water and its impact on public
health, Dr. William P. McElwain, Commissioner, Kentucky State Depart-
ment of Health, requested that the Environmental Protection Agency
evaluate the Kentucky Water Supply Program. In making the request,
Dr. McElwain stated that “A potential health hazard appears to be
evident to the people of our commonwealth through lack of adequate
surveillance of public water supplies and training of water plant
operators.”
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This evaluation was conducted to determine the effectiveness of the
Kentucky Water Supply Program, and if necessary, to recommend such
improvements as may be needed to assure safe, wholesome drinking
water for the residents of Kentucky.
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SCOPE
WATER SUPPLIES IN KENTUCKY
According to the 1970 census, 3,218,706 people reside in Kentucky.
About 2 million of these people are served by 423 public water supplies.
Many of the remaining 1,2 million people live in rural areas and obtain
their drinking water from individual water systems. In addition to the
public supplies, there are an estimated 1,800 water systems generally
known as “semi-public” which may serve as many as 2.5 million residents
and traveling public annually at restaurants, service stations, recrea-
tional facilities, schools, trailer courts, and other establishments.
WATER SUPPLIES STUDIED
In discussion with Mr. Ralph C. Pickard, Deputy Commissioner for
Environment, and Mr. Nick G Johnson, Director, Division of Sanitary
Engineering, it was agreed that the study would generally follow the
procedures used in the national Community Water Supply Study and the
Evaluation of the Tennessee Water Supply Program .
It was agreed that investigation of a representative number of water
supplies was sufficient to judge the effectiveness of the Kentucky
Water Supply Program. Although statutory authority excludes private
individual water systems from the current water supply program, it
was decided that each type of supply used by Kentucky residents should
be represented in the Study. A sample of public, “semi-public”, and
individual water supplies was selected for study. The technique used
for selection of the stUdy sample was not intended to provide a perfect
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random sample. However, the results are considered to reasonably
represent water supply practice in the State.
Twenty (20) public water supplies were selected to reflect sizes,
types of source, methods of treatment, and geographical location
within the State. In addition, 16 public water supplies from north-
central Kentucky that were investigated during the national Community
Water Supply Study of 1969, were resurveyed for inclusion in this
Study. These 36 supplies provide a cross-section of the State’s
public water supply practice and represent about one-tenth of all
public water supplies in the State. It is estimated that these 36
systems serve over 1,230,636 people or about 61 percent of all those
served by public water supplies in Kentucky. The location of water
supplies surveyed is shown in Figure I.
Eleven (11) of the 36 public water supplies selected for study adjust
the fluoride content of their water for dental health protection.
A special fluoride study was made of these and three other systems,
which were selected to provide a representative sample of fluoridation
practice in the State.
For the purpose of evaluating “semi-public” water systems, three
counties were selected for study, one in each of the geographical
areas of the State. The counties were Boyd in the east, Russell In
the central, and McCracken in the western part of the State. Fifty-
nine (59) “semi-public 1 ’ water systems wcre surveyed, and this represents
approximately three percent of the estimated 1,800 supplies in this
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FIGURE 1
LOCATION OF WATER SUPPLIES SURVEYED
11(2,5,9,25,32,3536)
27(6,18, 26)
17
34
24
12
29
.
23
8
21
.
Madison
Butler
4
I
1
I
Lawrence
7
3
I
13
.
31
I
Russell
16
10
I
22
I
S
Public water supply surveyed (See Table I, Appendix A for supply name corresponding to number)
County surveyed for rural individual supplies ® Earlington—Western Regional Office
County surveyed for semi-public supplies L I Paducah—State Branch Laboratory
Frankfort—Water Supply Program Headquarters Office
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category. It is estimated that perhaps as many as 2.5 million resi-
dents and travelers may drink water from this type of supply at some
time during the course of a year.
Rural individual water supply practice was investigated in three other
counties, again one in each of the State’s three geographical. areas.
The counties were Lawrence in the east, Madison in the central, and
Butler in the western part of the State. Five hundred forty (540)
individual water systems were surveyed. These systems serve approxi-
mately 2,700 people or about 0.2 percent of those served by individual
systems in the State.
PROGRAM EVALU TI0N
The basic water supply Statute, regulations, and program policies were
reviewed. The Water Supply Program’s activities, responsiveness to
water supply problems, and staffing were also examined. Reported water-
borne disease outbreaks were studied. Additionally, many residents,
waterworks personnel, municipal officials, health officials and others
were interviewed.
Pour bacteriological laboratories were surveyed and evaluated. These
included the patmen’s Central Laboratory, and three water treat-
isent plants previously certified by the Department of Health. The
Department’ a Water Chemistry Laboratory and the Water Supply Program’s
chemical surveillance activity were also studied.
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SUMMARY OF FINDINGS AND CONCLUSIONS
WATER SUPPLY STATUS
Water ua1 y-Bacterio1pg ca1
Bacteria of the coliforin group have been used as indicators of the
sanitary quality of waters since 1880 when these organisms were shown
to be normal Inhabitants of fecal discharges. The Drinking Water
Standards recognizes the coliform group as a reliable indicator of
the disease producing potential of drinking water. Failure to meet
bacteriological standards indicates that drinking water is a potential
carrier of infectious disease. Such a situation is a serious, potential
health hazard and calls for prompt corrective action.
Seventeen (17) percent of the public water
systems examined did not meet bacteriological
standards one or more of the past 12 months.
These systems serve approximately 12,500 people.
No data existed to determine bacteriological
quality of an additional 17 percent of the
public water systems.
Seventy (70) percent of the rural individual
supplies examined failed to meet bacteriological
standards and fecal contamination was confirmed
in two-thirds of these cases. These systems
serve approximately 1,900 people.
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Thirty-six (36) percent of the “semi-public”
systems examined failed to meet bacteriological
standards. It is estimated that as many as
17,971 people (State residents and the traveling
public) may be exposed to this water during one
year’s time.
Water Quality-Chemical
Drinking water must not contain any impurities which may be toxic or
otherwise hazardous to the health of man. The Drinking Water Standards
list such substances in a special group of mandatory chemical. standards
which if exceeded, constitute grounds for rejection of the water supply.
Ninety-seven (97) percent of the public water
systems examined met mandatory chemical drinking
water standards.
Ninety-eight (98) percent of the rural individual
water supplies examined met mandatory chemical
drinking water standards.
All but one of the tesemi_publicit water systems
met mandatory chemical drinking water standards.
Good quality drinking water should contain no impurities which would
cause offense to the sense of sight, taste or smell. The Drinking
Water Standards include a group of recommended chemical standards
which are intended to assure that drinking water contain no substance
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in quantities which would render it undesirable or aesthetically
inferior. Experience has shown that when a water supply contains
such aesthetic impurities, many people turn to alternate supplies
which may be less safe.
Twenty-two (22) percent of the public water
systems examined did not meet one or more of
the recommended chemical drinking water
standards. These systems serve approximately
69,250 people with less than desirable or
aesthetically inferior drinking water.
Forty-one (41) percent of the rural individual
water systems failed to meet one or more of
the recommended chemical standards. These
systems serve approximately 1,110 people.
Thirty-four (34) percent of the “semi-public”
systems failed to meet one or more recommended
chemical standards. As many as 13,326 people
(State residents and the traveling public)
may be exposed to this water during one year’s
time.
Facilities
Water supply facilities include all works and auxiliaries for collection,
treatmen4 storage and distribution of drinking water from the source
of supply to free flowing outlet of the ultimate consumer. Health
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protection is adequate only when the source of supply is of acceptable
quality, of sufficient quantity and under continuous surveillance;
treatment processes are appropriate to the quality of the source; the
facilities are of adequate capacity to meet maximum demands and are
located, designed, and constructed to eliminate or prevent contatnina-
tion; and all facilities are operated in such a manner to deliver a
high quality product. Any condition, device or practice in the water
supply system and its operation which allows - or may allow - impure,
contaminated, or questionable water to be provided the consumer con-
stitutes a health hazard,
Fifty-eight (58) percent of the public water
systems needed additional treatment facilities
and 73 percent needed important changes in the
operation of present facilities. Without these
additions and changes, continuous production of
safe drinking water may not be maintained.
None of the 14 public water supply fluoridation
programs evaluated were fully acceptable. Sixty-
four (64) percent of the systems were fluoridating
at less than the proper level, significantly re-
ducing the dental health benefits of this treat-
ment.
Twenty-eight (28) percent of the public supplies
and 68 percent of the 41 semi-pi.ibli&.’ supplies
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examined which chlorinate did not provide a
detectable chlorine residual in all parts of
the distribution system. Unsatisfactory
chlorination practice reduces the margin of
safety against disease transmission through
drinking water.
Nineteen (19) percent of the public water
systems examined had inadequate distribution
system storage and 8 percent had inadequate
water pressures in some or all areas of the
distribution system. Ninety-two (92) percent
of the public supplies examined had inadequate
cross-connection control programs. Flawless
treatment avails nothing if’ the distribution
system does not deliver adequate water for
essential health needs or permits entrance of
hazardous substances through cross-connections
or other system deficiencies.
Eighty-three (83) percent of the ‘ t semi-public t ’
systems rated overall less than ?tsatisfactorytf
and 56 percent needed additional treatment.
Thirty-four (34) percent had visible sanitary
defects, which clearly present the potential
for dangerous contamination.
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Twenty (20) percent of the rural, individual
water systems examined had sources with in-
sufficient quantity. Nearly every one of the
individual systems had one or more facility
deficiencies. Very few of these systems were
constructed to prevent entrance of contamination.
Ninety-one (91) percent of the systems had never
been tested for bacteriological quality.
Operator Coznpe tence
The water supply operator’s actions or inactions influence the health
of every person who drinks from the water supply. The water supply
operator must be conscientious, well-trained and capable of handling
all responsibilities of the water system. Even the most efficient and
sophisticated water supply facility is inadequate without proper opera-
tion and maintenance.
Eighty-one (81) percent of the public water
supplies examined were maintaining inadequate
operational records and/or conducting inadequate
water quality testing.
Thirty-nine (39) percent of the public water
systems evaluated had only part-time operators
and 56 percent of public water supply operators
were not certified by the Kentucky State Depart-
ment of Health. Most of these systems also had
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water quality problems and/or facilities
deficiencies.
Surveillance
The surveillance of water systems involves constant vigilance by health
and waterworks officials over water quality, water system facilities,
and operational practices. Bacteriological quality of drinking water
can only be gauged by frequent examination of samples collected from
representative points throughout the distribution system. Chemical
characteristics must also be routinely examined. To prevent health
hazards from developing in a water supply system, someone trained in
proper water supply practice and not associated with the supply should
regularly review operational procedures and physical facilities. The
frequency and detail of these sanitary surveys are dependent on the
complexity of the system and extent of the problems.
Sixty-four (64) percent of the public water
systems studied did not meet bacteriologicaP
surveillance standards. Although ninety-
four (94) percent of the public water supplies
received a chemical evaluation during the past
three years, most evaluations did not include
all 26 constituents listed in the Drinking
Water Standards . Sixty-seven (67) percent
of the public supplies had not been rated
by a representative of the Kentucky State
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Department of Eealth during the previous
twelve months. Without health agency sur-
veillance, hazardous conditions will persist
undetected and uncorrected.
Thirty-seven (37) percent of the “semi-public”
water systems studied had not had a health
agency visit in the previous two years. Even
when made, these visits often do not include a
full inspection of facilities and operational
practices.
WATER SUPPLY PROGRAM
The funds expended for drinking water protection in Kentucky are totally
inadequate to support a comprehensive program. The Division of Sanitary
Engineering operates on a budget of only $103,075 with approximately
$82,500 available for the administration of the Water Supply Program.
Even taking into consideration laboratory support provided by other
programs, less than 2.6 cents per capita per year is spent to protect
drinking water.
Staff limitations have prevented the Water Supply Program from ful-
filling its responsibilities. Evaluation of Kentucky water supply
practice indicates many supplies are deficient and present a high
risk to the public. Because the Division employs only five sanitary
engineers, with approTIm tely four man-years being devoted to the
Water Supply Program, important activities are not being performed,
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or are being performed in a superficial manner, seriously reducing
the effectiveness of the program. A Water Supply Program conducted
in this manner creates a false sense of security.
In spite of increases in the number of water supplies and the popu-
lation served by these supplies, the staff of the Division of Sani-
tary Engineering has dwindled from nine in 1963-66 to five at the
present time. Ten experienced men have left the program in the
past seven years. Unfortunately, the water supply experience of
those who left was generally greater than their replacements.
Compliance with Departmental directives has generally been obtained
through persuasion and cooperation with County Health officers, who
have issued “boil water” orders. However, failure to initiate legal
proceedings against the City of Covington, which has ignored a written
Departmental Compliance Order on fluoridation, has weakened the Depart-
ment’s credibility and compromised its effectiveness. In addition, the
penalty for violating the Water Supply Rules and Regulations is in-
sufficient.
Current Public Water Supplies Regulations were adopted July 20, 1967,
and provide useful guidance for certain water supply matters. Bacterio-
logical and chemical finished water quality standards are included.
A crucial omission, however, is the lack of a specified sampling fre-
quency for either bacteriological or chemical quality. The Regulations
do not specifically require disinfection of all public water supplies,
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although disinfection equipment is discussed in detail. No provision
is made for the planned and orderly development of new public water
supplies.
The Division of Sanitary Engineering’s water supply policies are con-
tained in a number of letters, publications and documents which provide
the bases for sound water supply practice. However, the absence of a
single water supply policy document has hampered Water Supply Program
staff, waterworks officials, and consulting engineers.
Consistent engineering review of bacteriological laboratory results
has not been provided. by the Division of Sanitary Engineering, and
at present no systematic procedure to examine and record bacterio-
logical data is in use. In addition, follow-up and resampling pro-
cedures, if pursued at all, are not adequate. A bacteriological
surveillance program conducted in this manner negates the conscientious
efforts of those collecting and analyzing samples. Such. a program
creates a false sense of security for water supply operators and the
public.
Operator training activities have reached a majority of the public
water supply operators. Nevertheless, facility and operational
deficiencies indicate that recoiauended waterworks practices and
public health protection are not being universally applied.
An immense quantity of data must be assembled, analyzed, and stored
for successful management of a water supply program. This important
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activity, now being done entirely by “hand”, is considered too time
consuming for professional personnel, and is seldom given proper
attention.
* * * * * * *
The Kentucky Water Supply Program is not providing the health evaluation
and engineering services necessary to fulfill its responsibilities to
protect the health of the citizens of Kentucky. Well established stan-
dards of good practice are not being universally applied in Kentucky.
This Study documents that many water systems deliver water of marginal
or poor quality and substantiates Dr. McElwain ’s assertion that the
people of Kentucky are faced with a potential health hazard because
of their drinking water.
Water supply technology was devised decades ago to treat raw water of
generally high quality for protection against transmission of infec-
tious disease. Today’s industrial and agricultural practices can
result in increasing quantities of toxic chemicals being found in
natural waters. Conventional water treatment practices do not always
remove these chemicals, and some were found in drinking water during
this Study. Without complete water quality surveillance, no assurance
can be given that toxic impurities will be absent from Kentucky’s
drinking water.
These findings are not reassuring with regard to the future. It is
evident that Kentucky must vigorously pursue an expanded drinking
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water program, giving increased attention to the broad problems of
water supply in order to assure an adequate supply of safe drinking
water on a continuing basis.
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RECOMMENDATIONS
It is recommended that:
1. The Water Supply Program be restored to a stature
commensurate with its importance to the health of
Kentucky residents with a minimum annual budget of
$514,000. These funds should be used as follows:
a. Water Supply Activities $359,000
b. Laboratory Services $155,000
Total $514,000
2. The Water Supply Program be initially staffed with
a minimum of 18 professionals and 6 secretaries.
3. Water Supply activities be further decentralized by
assignment of two additional staff to assist the
Sanitary Engineer stationed at the Earlington
Regional Office and establishment of two new
Regional Offices, one in the southeast and one in
the northeast, as soon as competent staff can be
recruited and trained.
4. One bacteriologist, and one secretary be hired by the
Division of Sanitary Engineering and assigned to the
Division of Laboratory Services for additional water
bacteriology work. Similarly, two chemists and one
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secretary should be hired and assigned to the Divi-
sion of Laboratory Services for drinking water
chemical analyses.
5. The Water Supply Regulations be revised and expanded
to more comprehensively reflect current recommended
water supply practice. Specific features should be
included to:
a. Establish a minimum sampling frequency
for acceptable bacteriological sur-
veillance.
b. Clarify and reword the quality standards
for finished drinking water.
c. Require mandatory disinfection of all water
systems serving the public, and specify
minimum distribution system residual for
systems disinfecting with chlorine.
d. Redefine a cross-connection.
e. Provide for orderly development of new
supplies.
f. Require that water system plans and specif i-
cations be prepared by registered professional
engineers.
g. Require that an individual or group be desig-
nated legally responsible for each public
water supply.
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6. Cooperative compliance with Water Supply Rules
and Regulations continue to be emphasized.
However, if cooperation and persuasion fail to
achieve prompt compliance to protect drinking
water and public health, enforcement measures as
provided by statute should be initiated.
7. A single document be prepared and distributed which
presents all current Kentucky Water Supply Program
Policy. Provision should be made for updating this
document as policy revisions occur.
8. The Division of Sanitary Engineering increase and
improve its surveillance of drinking water supplies
to at least the minimum levels set forth in the
Public Health Service Drinking Water Standards and
Manual for Evaluating Public Drinking Water Supplies .
These activities should include, but not necessarily
be limited to:
a. Thorough periodic sanitary surveys of
each system, setting priorities and time
schedules for improving those systems with
deficiencies.
b. Bacteriological surveillance sufficient to
check laboratory analyses provided by the
larger public water supplies, and in the
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case of small systems without laboratories,
bacteriological surveillance sufficient to
meet reco mnended Standards.
c. Complete routine chemical analyses of all
drinking water.
9. All water plant laboratories continue to be certified by
the Kentucky State Department of Health as to their
capability of performing “official” bacteriological
analyses.
10. Automatic data processing techniques be employed for
storage, analysis, and retrieval of water supply data.
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ACKNOWLEDGEMENTS
The assistance and cooperation of Mr. Nick C. Johnson, Director,
Division of Sanitary Engineering, Kentucky State Department of
Health, is gratefully acknowledged. The Division of Sanitary
Engineering Staff gave freely of their time and accompanied survey
officers on many field evaluations. The county sanitarians of Boyd,
Lawrence, Russell, Madison, Butler and McCracken County Health Depart-
ments also made substantial contributions. The Division of Laboratories,
Frankfort, provided important bacteriological analyses. And finally,
a special thanks is given to all the residents, waterworks personnel
and utility officials who provided information and otherwise cooperated
in the Study.
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STATE ANI) FEDERAL AGENCY ADDRESSES
A. State:
Kentucky State Department of Health
Division of Sanitary Engineering
275 East Main Street
Fran.kfort, Kentucky 40601
Telephone: 502-564-3772
B. Federal:
Environmental Protection Agency, Region IV
Mr and Water Division
Water Programs Branch
Water Supply Section
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Telephone: 404-526-3781
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REFERENCES
Community Water Supply Study - Analysis of National Survey
Finding , Bureau of Water Hygiene, July 1970, 111 pp.
Evaluation of the Tennessee Water Supply Program , Bureau of
Water Hygiene, Enviromnental Protection Agency, Region IV,
January 1971, 208 pp.
Manual for Evaluating Public Drinking Water Supplies , Public
Health Service Publication No. 1820, Superintendent of
Documents, Government Printing Office, Washington, B. C.
20402, 1969, 62 pp.
1962 Public Health Service Drinking Water Standards , Public
Health Service Publication No. 956, Superintendent of
Documents, Government Printing Office, Washington, D. C.
20402, 61 pp.
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APPENDIX A
TABLE I
PUBLIC WATER SYSTEMS STUDIED
Population
No. Name of System Served Source
1 Benton 3,074 2 Wells
2 Boone County W. D. 4,800 Covington
3 Bowling Green 39,000 Barren River
4 Bradfordsville 560 N. Rolling Fork River
5 Bromley W D. 1,130 Covington (Ludlow W. D.)
6 Campbell County W. D. #1 44,000 Newport
7 Cainpton 720 2 Wells
8 Catlettsburg 10,000 Big Sandy River
9 Cold Springs W. 0. 1,900 Covington.
10 Corbin 12,500 Laurel River
11 Covington 60,000 Ohio River
12 Dixon 540 Dixon Lake
13 E lkton 2,800 Stinson Lake
14 Florence W. D. 11,000 Kenton County W. 0. #1
15 Fulton 3,500 3 Wells
16 Gamaliel 720 Line Creek
17 Henry County W. D. #1 1,200 Henry Co. W. 0. Lake
18 Highland Heights W. 0. 4,000 Newport (C.C.W.D.)
19 Jenkins 4,500 Jenkins Lake, Well
20 Kenton County W. D. #1 52,700 Licking River
21 Kingswood 200 2 Springs
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TABLE I (Cont’d)
PUBLIC WATER SYSTEMS STUDIED
Population
No. Name of System Served Source
22 Leatherwood (Blue Diamond 690 Mine Impoundment
Coal Company)
23 Lexington 172,507 Kentucky River
24 Louisville 672,585 Ohio River
25 Ludlow W. D. 6,200 Covington
26 Mentor W. D. 700 Newport
27 Newport 31,300 Ohio River
28 Oweusboro 58,800 25 Wells
29 Sharpsburg W. D. 1,000 Sharpsburg Lake
30 Silver Grove 1,500 2 Wells
31 Somerset 16,700 Lake Cumberland
32 Taylor Mill W. D. 5,000 Covington
33 Walton 1,800 2 Lakes
34 Western Mason County W. D. 1,560 Well
35 Wilder W. D. 650 Covington
36 Winston Park W. D. 800 Covington
1,230,636
4 U.S. GOVERNMENT PRINTING OFFICE: 1972.741-661/REG QN NO.4
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