Five concerning truths about Richmond’s public water system: 2022 EPA report

RICHMOND, Va. (WRIC) -- Richmond's public water system was found to be crumbling, broken down and filthy during a 2022 federal inspection, with debris ranging from algae to chemical leaks found throughout various parts of the system.

8News obtained the 114-page report compiled by the U.S. Environmental Protection Agency (EPA) following a July 2022 inspection of Richmond's public water system.

In those pages, the EPA outlines a variety of troubling discoveries -- including significant amounts of out-of-service equipment, standing water, leaking chemicals and faulty gauges, among others.

ALL COVERAGE: Richmond Area Water Crisis

While our 8News team continues to dig into this report, here's five of the most concerning findings we identified across its pages.

1. Staff were not prepared for emergency situations

According to the EPA, the water system -- at the time of the 2022 inspection -- did not perform emergency scenario planning exercises for crisis events like large-scale power failures, contaminations or any other issue that would impact production.

The first of those is what took out Richmond's city water system on Monday, Jan. 6, leading to a widespread water crisis.

"The superintendent stated that the local fire department performs such activities and the System occasionally participates," the EPA said.

Additionally, the water system's Emergency Response Planning (ERP) guidelines were several years old and referenced outdated information. According to the EPA, its inspectors were given an unsigned and unfinalized ERP dated for 2020, but this document also contained an outdated contact list.

Several of its action descriptions were kept in a separate document -- an Emergency Operations Manual (EOM), which was also unsigned and unfinalized, dated April 2021.

2. There was degrading, broken, unreliable infrastructure

In the 2022 report, EPA inspectors listed a variety of issues with vital parts of the water treatment process.

Dozens of pieces of equipment were out of service during their 3-day inspection, from water pumps to filtration screens -- which take debris out of water.

Additionally, several meters and other such equipment used to measure various important metrics -- like water clarity (measured as turbidity), its pH or the dosage of chemicals being put into it -- were either out of service or unreliable.

Raw water intake and screens that are out of service. (Photo: U.S. Environmental Protection Agency)

Raw water intake and screens that are out of service. (Photo: U.S. Environmental Protection Agency)

An out-of-service filter, Filter 19. (Photo: U.S. Environmental Protection Agency)

Programmable logic controller (PLC) out of service at the Columbus Pump Station main building. (Photo: U.S. Environmental Protection Agency)

Non-operational meter at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

Non-operational meter at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

This included a flow meter at Plant 2. According to the EPA, this meter and ones like it measure how quickly water is moving through any given system.

The inspectors were told that the meter had not been working properly and that "operators were testing a hypothesis of sun interference," so a piece of plywood was placed over the flow meter to protect it from light.

Plant 2 flow meter above a raw water coagulation channel. Employees placed this wood to block potential sun interference, which they think could be causing the meter to have issues. (Photo: U.S. Environmental Protection Agency)

Plant 2 flow meter above a raw water coagulation channel. Beneath a piece of plywood. (Photo: U.S. Environmental Protection Agency)

Overall, the EPA inspectors found that flow rate was not being measured appropriately throughout the entire system. This means there's a risk of water coming through at too high a speed.

Another area where EPA inspectors noticed attempts at fixes using wood was at the Warwick Road Tank. According to the report, multiple concrete structures supported a pipe that ran throughout the area.

One such concrete structure was damaged and inspectors found that it had been "augmented with several pieces of wood."

"The stacked pieces of wood did not appear to be functional to support the pipe," the EPA said.

Pieces of wood stacked to attempt to provide support to the transmission pipe at Warwick Road Tank. (Photo: U.S. Environmental Protection Agency)

Pieces of wood stacked to attempt to provide support to the transmission pipe at Warwick Road Tank. (Photo: U.S. Environmental Protection Agency)

The EPA found several areas along Plant 2 and around a filter called "Filter 16" where the concrete was cracking.

According to the report, some of these cracks were over a foot long and more than 1/8" in width.

In the case of Filter 16, during the inspection, "an abnormally loud noise" came from a valve when it opened.

"[A supervisor] confirmed the noise was atypical and directed an employee to start a work order for the issue," the EPA said.

Cracks in concrete above Plant 2 filter beds. (Photo: U.S. Environmental Protection Agency)

Cracks in concrete above and vegetation growing around Plant 2 filters. (Photo: U.S. Environmental Protection Agency)

Cracking above influent valve of Filter 16. (Photo: U.S. Environmental Protection Agency)

There were pipes and tanks throughout the water system where EPA inspectors found leaks. This included pump stations with water pouring out of many different places, with that water pooling on the floors and running down walls.

At that station -- the Korah 2 and 3 Pump Station -- a white PVC pipe was found discharging process water from about three to four inches above ground level near a pump. Some water was not being captured and was instead draining across the floor into a floor drain.

The EPA noted that none of the instrumentation at this pump station appeared to have been calibrated recently, as there were no calibration stickers on them.

Process water pipe discharging to floor on lower level of Korah 2 and 3 Pump Station. (Photo: U.S. Environmental Protection Agency)

Water flowing across floor near K3-2 pump, and algal growth on floor near pump motor in Korah 2 and 3 Pump Station. (Photo: U.S. Environmental Protection Agency)

K2-2 pump motor discharging water onto Korah 2 and 3 Pump Station floor. (Photo: U.S. Environmental Protection Agency)

K2-2 pump motor discharging water onto Korah 2 and 3 Pump Station floor. (Photo: U.S. Environmental Protection Agency)

Leaking fitting from corroded pipe in Korah 2 and 3 Pump Station. (Photo: U.S. Environmental Protection Agency)

Fitting leaking from corroded pipe onto floor in Korah 2 and 3 Pump Station. (Photo: U.S. Environmental Protection Agency)

Leaking seals on gate valves at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

Leaking seals on gate valves at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

Leaking lubrication at pump at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

The inspectors found more than just water leaks -- they found multiple chemical leaks, including a caustic soda leak at the Korah 1 Pump Station. Caustic soda is used to increase the pH of water during the water treatment process.

According to the report, a caustic soda line at that pump station was coated in said chemical. It also had some caution tape draped around it.

When the EPA inspectors checked the pH meter used to control caustic soda dosing, they "observed dust and dirt built up on the analyzers and the screen."

Caustic soda line leak and caution tape in Korah 1 Pump Station. (Photo: U.S. Environmental Protection Agency)

Caustic soda line leak in Korah 1 Pump Station. (Photo: U.S. Environmental Protection Agency)

More chemical leaks were observed at the West Chemical Building, this time involving sodium hypochlorite -- commonly known as bleach -- and aluminum sulfate, another water-purifying chemical.

In the case of the sodium hypochlorite, the EPA inspectors found a leaking tank with a pile of the crystalized chemical on the floor below it. They also saw a line in the elevated plumbing system leaking it and dropping it into the room from above.

The aluminum sulfate collected on a tank supply line, crystallized along its length.

Floor below active sodium hypochlorite leak at Tank T-SH-1-3 at the West Chemical Building. (Photo: U.S. Environmental Protection Agency)

Leak around gasket of sodium hypochlorite tank T-SH-1-3 at the West Chemical Building. (Photo: U.S. Environmental Protection Agency)

Crystalized sodium hypochlorite around gasket at tank T-SH-1-3 at the West Chemical Building. (Photo: U.S. Environmental Protection Agency)

Crystalized aluminum sulfate on the day tank supply line. (Photo: U.S. Environmental Protection Agency)

While at the West Chemical Building, the EPA inspectors were told by a supervisor that there are "often failures" with the system that feeds potassium permanganate -- a chemical that helps debris clump together so it's caught by water filters during the treatment process -- because "not enough potassium permanganate is used for the machinery to operate properly."

There were a few cases of exposed wires or other unsafe electrical practices, such as an electric box along a walkway left open at Byrd Park Reservoir.

Exposed wiring at flocculator 4-2A. (Photo: U.S. Environmental Protection Agency)

Exposed wiring on K1-2 pump at Korah 1 Pump Station. (Photo: U.S. Environmental Protection Agency)

Opened electric box at end of southern access walkway at Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Hose connected to threaded tap without vacuum breaker at Westhampton Pump Station. (Photo: U.S. Environmental Protection Agency)

Regarding Byrd Park Reservoir, the EPA was told that, as of the inspection dates, work was being done to replace the reservoir's roof. The current concrete roof would be replaced with one made out of aluminum.

They also learned that the reservoir had not been inspected since "2017 or 2018" due to "safety concerns."

Roof of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Roof of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

There was leaking along the side and roof of the reservoir, which had caused water damage. Caulking along multiple plates on the walkway was also not fully intact.

The inspectors also learned that -- like several other sites in Richmond's water system -- the reservoir did not have an overflow, which is required.

Water leaking from siding on Byrd Park Reservoir roof. (Photo: U.S. Environmental Protection Agency)

Water leaking from siding on Byrd Park Reservoir roof. (Photo: U.S. Environmental Protection Agency)

Damage and water leaking from roof and siding on Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Richmond leaders have regularly called attention to the aging infrastructure across the city as it weathers the current water crisis. The water treatment plants themselves were built in 1924 and 1950, respectively.

3. Inspectors found debris, rust, corrosion and standing water

Rust and corrosion were found across the system, including the Jahnke Road Tank, which was covered in rust and stains.

The corrosion was often paired with the various leaks.

Rust on exterior of Jahnke Road Tank. (Photo: U.S. Environmental Protection Agency)

Rust on exterior of Jahnke Road Tank. Photograph (Photo: U.S. Environmental Protection Agency)

Corrosion and degraded seal at base of Jahnke Road Tank. (Photo: U.S. Environmental Protection Agency)

Corrosion on the control valve on the transmission pipe of the Warwick Road Tank. (Photo: U.S. Environmental Protection Agency)

Corrosion on pump 1 that takes water from the Plant 1 clearwell to the finished water basin. (Photo: U.S. Environmental Protection Agency)

Corrosion on pump 2 that takes water from the Plant 1 clearwell to the finished water basin. (Photo: U.S. Environmental Protection Agency)

Corrosion on pump 3 that takes water from the clearwell to the finished water basin in Plant 1 pipe gallery. (Photo: U.S. Environmental Protection Agency)

This included significant corrosion on air scour pipes -- or pipes that direct high-speed air through water mains to help keep them clean.

Corrosion on air scour pipes located inside the enclosed Plant 1 filter room. (Photo: U.S. Environmental Protection Agency)

Corrosion on air scour pipes located inside the enclosed Plant 1 filter room. (Photo: U.S. Environmental Protection Agency)

Vegetation was also observed in a variety of places, from algae growth in and around water to entire trees springing up at the base of water tanks.

EPA inspectors found this throughout the water system, with fences and pipes surrounded by weeds and crawling vines.

Some overflow and/or discharge pipes were even tucked away beneath abundant overgrowth.

Vegetation growing in a concrete raw water channel at the water line. (Photo: U.S. Environmental Protection Agency)

Vegetation growing around concrete structures above Plant 2 filters. (Photo: U.S. Environmental Protection Agency)

Fencing and vegetation growth at the Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Vegetation growth on the roof of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Vegetation growth on the roof of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Plant growth at base of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Plant growth at base of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Plant growth at base of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

Fencing at Jahnke Road Tank. (Photo: U.S. Environmental Protection Agency)

Vegetation and algal growth at base of Jahnke Road Tank (Photo: U.S. Environmental Protection Agency)

Vegetation growing up and overhanging the Huguenot Road Tank. (Photo: U.S. Environmental Protection Agency)

Vegetation growing up and overhanging the Huguenot Road Tank. (Photo: U.S. Environmental Protection Agency)

Overflow and/or discharge pipes from the Huguenot Road Tank. (Photo: U.S. Environmental Protection Agency)

Overflow and/or discharge pipes from the Huguenot Road Tank. (Photo: U.S. Environmental Protection Agency)

Leaf litter, dirt and debris were observed in many locations, including near water that was close to the end of the treatment process.

A piece of debris that measured about 18" long and 2 to 4 inches wide was found near a valve in Filter 16.

"The debris remained in place throughout the backwash cycle but was at risk of falling into the filter media," the EPA said.

Debris near influent/effluent channel of Filter 16. (Photo: U.S. Environmental Protection Agency)

Debris near influent/effluent channel of Filter 16. (Photo: U.S. Environmental Protection Agency)

At Plant 2, the "finished water basin" -- or the basin that holds water that is ready for consumption -- does not have walls around its entryway.

Debris was found all over that entryway. According to the EPA, without walls or any structures to prevent it, that debris could fall directly into the finished water.

Landing area at entry of Plant 2 finished water basin; no baseboards to prevent debris from falling into water. (Photo: U.S. Environmental Protection Agency)

Dirt and debris on landing area above Plant 2 finished water basin. (Photo: U.S. Environmental Protection Agency)

With the many leaks found in the water system, in places where that water could not drain, it collected. Standing water was found in at least two pump stations -- the Korah 2 and 3 and the Byrd Park Main pump stations.

This led to algae growth in some cases, according to the EPA.

Water and algal growth on floor of Korah 2 and 3 Pump Station. (Photo: U.S. Environmental Protection Agency)

Standing water on floor at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

EPA inspectors peeled back a metal plate between vents at the Byrd Park Reservoir and found about a foot of standing water underneath.

"System [employees] were not sure if the water could be a combination of finished and stormwater, only stormwater, or finished water, indicating a lack of regular inspection," the EPA said.

Access vault filled with water in northern walkway of Byrd ParkReservoir. (Photo: U.S. Environmental Protection Agency)

Metal plates in between vents in access area on northern walkway of Byrd Park Reservoir. (Photo: U.S. Environmental Protection Agency)

This was in addition to leaf litter and vegetation having collected in these places.

The Byrd Park Main Pump Station -- which has been in service since 1928, according to the report -- was in the process of being updated at the time of the 2022 inspection dates.

It was littered with debris, with the report describing it as "poor housekeeping conditions." Some of this was due to the installation of an overhead crane, which was being used in rennovating the station's ceiling.

"EPA observed ceiling debris on the ground and equipment throughout the pump station," the EPA said.

They also saw a "nearly full and uncovered five-gallon bucket of oil/water mix."

Byrd Park Main Pump Station floor with debris. (Photo: U.S. Environmental Protection Agency)

Byrd Park Main Pump Station floor with debris and bucket of water/oil. (Photo: U.S. Environmental Protection Agency)

Five-gallon bucket of oil/water mixture at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

4. Parts of the system were poorly monitored -- if at all

EPA inspectors found multiple instances wherein machinery and processes were poorly monitored or maintained -- if they were at all.

Many parts of the water system were not being regularly inspected. For example, EPA inspectors were told that the water distribution storage tanks were inspected most recently in 2017. Records, however, reflected that it had last happened in 2015.

In other cases, inspectors were told that certain equipment could not be inspected without draining the tanks they served, as they were within them.

The EPA also learned that the pre-sedimentation basin cannot be maintained, as it is "not equipped with any means to remove sludge."

At the West Chemical Building, EPA inspectors saw a device with a failed inspection tag on it dated Oct. 20, 2021 -- just under a year prior to their inspection dates.

"It was unclear if any remedial action was taken to address the failed inspection," the EPA said.

Staff could not find parts of their own systems -- like overflow pipes -- at a few sites, according to the EPA.

In the case of water clarity, the EPA inspectors were told that filters would be pulled for service when a certain turbidity level was reached. They would be returned only when they performed at optimal levels -- below a certain NTU.

"EPA observed Filter 16 [have a] turbidity increase above 0.1 NTU in the minutes following its return to service," the EPA said.

5. Threats to public health were identified

Several hoses were found attached to finished water lines and laid out on the ground, posing a high risk of cross-contamination, according to the EPA.

Hose on ground in standing water attached to finished water line without vacuum breaker at Byrd Park Main Pump Station. (Photo: U.S. Environmental Protection Agency)

Threaded tap on finished water line without backflow prevention at the Columbus Pump Station. (Photo: U.S. Environmental Protection Agency)

Threaded tap on finished water line without backflow prevention at the Columbus Pump Station. (Photo: U.S. Environmental Protection Agency)

Hose on ground attached to finished water line without vacuum breaker. (Photo: U.S. Environmental Protection Agency)

While they were at the plants, EPA inspectors noted that potassium permanganate was not being dispensed as it should.

The water shown in the picture below should be purple while being treated with that chemical. It is instead clear. This could create issues with water quality.

Potassium permanganate chemical application area. Not operating properly, as the water is clear instead of purple. (Photo: U.S. Environmental Protection Agency)

While chemicals were not being dosed at all in that case, the EPA inspectors were informed that other chemicals were dispensed without much regularity.

This includes copper sulfate, used to prevent algae growth. According to the EPA, it was just poured into the water by 50-pound bags during the summer without prior testing or proper measurements. This could be hazardous.

Another chemical, poly aluminum chloride (PAC) -- which helps with clumping of debris -- is also dispensed without formal procedure.

As the flow rate meters were unreliable throughout the system, the EPA said this could result in improper chemical doses, as "flow is critical to determining chemical dosing."

EPA inspectors were told that no updated reference material on chemical treatment processes for employees to access.

"System Representatives explained there may be [reference material] in the operator control room, although it is dated from the 1990s," the EPA said.

The inspectors also found that chemical testing of the water is not performed on a regular schedule -- only as needed.

According to the EPA, as of the time of the inspection dates, the system had turned up five positive tests for coliform, a bacteria found in plants, soil and feces -- though there was no E. coli present. The system did not investigate these unexplained positive results, with the EPA adding that "there is no plan or procedure in place to respond to or investigate the cause of these events."

Additionally, the EPA found that the water system was not performing enough bacterial testing overall. Tests are meant to be performed in a manner proportional to population. Its sampling plan as of the 2022 inspection dates was 6,000 shy of Richmond's Census data at the time.

Many pump stations and tanks also did not have dedicated sampling locations.

What's happening with the city's water system now?

It's important to note that it has been over two years since this inspection took place. Changes and improvements could have been made in that time -- and it is not yet known what caused Monday's failure. 8News will provide updates as we learn more about the current condition of Richmond's public water system.

April Bingham, the director of the city's Department of Public Utilities (DPU), told the media on Wednesday, Jan. 8 that the DPU has filed its response for this inspection. She said the DPU is awaiting the EPA's feedback, but that she did not know when that would be because "everyone is returning from the holidays and getting agendas back up and running."

This would imply that the DPU did not reply to the EPA until recently. The report was finalized on Oct. 19, 2022.

You can read the full 114-page report below.