Investigation into Orange County odor event reveals cause and RSA code violations

ORANGE COUNTY, Va. (WRIC) -- After a multi-agency investigation, the Virginia Department of Health (VDH) has released a full investigative report detailing the believed code violations of Rapidan Service Authority (RSA) and the causes of odor during the Orange County water advisories that happened in August of this year.

What caused the odor?

According to VDH, it was determined on Sept. 13 that the cause of the odor was a "catastrophic failure" of a raw water pump intake at Rapidan River that occurred on Aug. 20 -- the day before customers noticed the odor and began sending complaints to RSA.

Around two to three gallons of food-grade mineral oil was released at the Wilderness water treatment plant (WTP) as a result of the pump failure, and according to VDH and RSA, the oil was "thermally altered, burned and scorched" creating the odor that some residents described as similar to "WD-40" and "diesel."

According to the results of the investigation, the pump failure and subsequent contamination posed no threat to public health based on "toxicology reviews, epidemiological monitoring and sampling results."

Certain chemicals that were found in the water are associated with disinfection by-products (DBPs) -- which are the result of chemical treatments raw water undergoes to be safe for human consumption. The Environmental Protection Agency (EPA) sets limits for DBPs by "balancing health benefits of water disinfection with risk of exposure to DBPs."

There were several other chemicals found in the water that are not associated with DBPs -- isovanillin, bis(2-chloroethyl)ether (BCEE) and benzaldehyde. BCEE and benzaldehyde were not found in concentration levels that could significantly impact human health given the short time period people were exposed to them, according to the VDH.

Isovanillin, which is a chemical used in the food industry, was also found in multiple sampling events and is believed to be a cause of the odor in the water.

Why did the investigation take so long?

One of the primary reasons for the length of the investigation is that the first raw water intake pump failed on Aug. 20, and RSA did not share information with VDH about the severity of the failure or how it could contribute to the cause of the odor until Sept. 3 and 4.

RSA was aware that the intake pump had failed on Aug. 20 and that there were two other pump failures that happened on Aug. 24. According to VDH, the severity of the failure was communicated to RSA by Atlantic Pump "on or about Aug. 27" when they serviced the failed pumps.

On Aug. 22, RSA issued a "do not use water" advisory as the odor complaints came in and the investigation began.

From Aug. 21 -- the day WTP began receiving water odor complaints -- to Aug. 23, the Virginia Department of Environmental Quality (DEQ) asked RSA and its contractor about equipment function at WTP and neither party communicated any concern with equipment at the plant.

On Aug. 24, RSA had planned to change the "do not use" advisory that they issued on Aug. 22 to a "do not drink" advisory, but they reported to VDH that due to pump failures, any advisory changes would need to be delayed to make sure water demand could be met.

Although RSA did eventually report pump failures to VDH, they did not report the severity level, and one of the main motivations behind reporting it was the predicted inability to meet customer water demand, not the impact it may have had on the odor investigation.

Later in the evening on Aug. 24, a temporary pump solution was put in place for the raw water intake pumps and the advisory was changed.

On Aug. 27, although the cause and source of the odor was not known, all advisories were lifted. Tests conducted by VDH had found that the water fully complied with federal and state drinking water standards.

There were two other reasons VDH gave to explain lifting the advisory, including the fact that daily inspections confirmed that the odor was no longer present at WTP and had "sufficiently dissipated in the distribution system" and an epidemiological investigation had found no evidence of negative impact from exposure to the water.

On Sept. 3, the General Manager for RSA -- Tim Clemons -- said "he did not have sufficient information to show that any pump failure would be the cause of the objectionable odor event," according to VDH.

Also, on Sept. 3, the ODW began to focus on the raw water intake pumps as a potential source of the odor, and RSA responded with "vehement denial and pushback" as they accused the ODW of "looking for the 'easy' solution," according to VDH.

On Sept. 4, Clemons reported the catastrophic pump failure that had happened on Aug. 20 to VDH in an email.

According to VDH, staff members of the VDH Office of Drinking Water (ODW) talked on Sept. 6 with the pump mechanic who repaired all three of the pumps, and the mechanic said "he has worked as a pump mechanic for 40 years and has never witnessed such a catastrophic failure before."

The investigation completed by VDH revealed that RSA participated in several incident command calls and did not mention any issues with the pumps on Aug. 22 or Aug. 23.

A taste and odor expert determined on Sept. 13 that they had a "high level of confidence" that the mineral oil release on Aug. 20 was directly related to the odor event in Orange County.

The VDH has provided RSA with several recommendations regarding how to prevent a problem like this from happening again, served in a notice of alleged violation (NOAV) -- which includes recommended changes to raw water monitoring and additional water treatment processes.

Alleged code violations of RSA

There were several areas of Virginia Waterworks Regulations that were allegedly violated by RSA according to VDH and the timeline of events, including compliance standards, responsibilities of the owner, pumps and control and operational control testing and monitoring.

The VDH listed several main observations towards the end of the final investigation document, including:

• Multiple pump failures and electrical issues
• Temporary wiring and installation issues
• Delayed reporting and lack of timely communication
• Response and mitigation measures being reactive and not proactive
• Switching pumps without seeking underlying cause, causing other pump breakdowns and system contamination
• Contractor management and oversight issues
• Poor raw water monitoring and delayed identification of the contaminant

There were several recommendations given by the VDH to RSA about how to address the outlined concerns as well as attempt to gain the trust back of the customers they supply water to in Orange County.

These recommendations included proposed changes to how raw water is monitored and treated, as well as different approaches to communication strategies as they relate to addressing public concerns about water safety and RSA's internal management structure.

Terms and Agencies Key

• Rapidan Service Authority (RSA) -- provides water and sewer services to homes and businesses in the Orange County area
• Wilderness water treatment plant (WTP) -- owned by RSA
• Virginia Department of Health (VDH)
  • Office of Drinking Water (ODW) headed the investigation
• Virginia Department of Environmental Quality (DEQ)
• Environmental Protection Agency (EPA)

The areas of Orange Count that were affected by the odor event include:

• Lake of the Woods subdivision
• Wilderness Shores
• Somerset
• Edgewood
• Germanna Heights
• Twin Lakes
• Germanna Community College, Locust Grove Campus

For more information about VDH's recommendations to RSA, the cost of the investigation, detailed water sampling results and other further details, visit the odor event incident page. The full investigative summary report can be found at this link. To view the notice of alleged violation, click here.