Public comments and response

Attachment B1
Public Comments and Agency Responses

We received 5 public comments about this ICR Clearance. The Docket Number in
regulations.gov is CDC-2019-0080. The comments and responses, where appropriate, are listed
below.

Page 1 of 1

PUBLIC SUBMISSION

As of: 3/16/20 9:43 AM
Received: September 18, 2019
Status: Posted
Posted: September 19, 2019
Tracking No. 1k3-9c99-nyzw
Comments Due: November 18, 2019
Submission Type: Web

Docket: CDC-2019-0080
Assessment of Potential Exposure from Private Wells for Drinking Water
Comment On: CDC-2019-0080-0001
Assessment of Potential Exposure from Private Wells for Drinking Water
Document: CDC-2019-0080-0002
Comment from (jean publicee)

Submitter Information
Name: jean publicee

General Comment
more fakery from teh cdc on whether water is contaminated or not. i am not in favor of
taxpayers paying for this stupid collection of information. first of all teh standards for pure
clean water were made abouit l00 years ago and they do nothing about the hundreds of
thousands of chemicals that ar ein water today. nobody tests for that. nobody tests for lead
routinely.
our men in aemrica are becoming emasculated and turning into women. that is fact. our fish are
turning into females. they live in water and drink it. that is fact. clearly our water is very
polluted alredy. wells too are polluted. so to do this collection based on information from the
safe drinking water act shows that is all made up political crap that mean nothing.this is fake
healthcollection with no real meaning for health. first of all we need testing for all the pollutants
that are out there today. that is the first necessity. this collection is pure fakery. we need to take
more budget money from teh cdc. they work only for bit pharma, big medicine and big
chemicals. they donj work for health of the us public at all. they are in fact hurting the us public.
look at how our lifespans are going down each year.

https://www.fdms.gov/fdms/getcontent?objectId=0900006483f99991&format=xml&show... 3/16/2020

Page 1 of 1

PUBLIC SUBMISSION

As of: 3/16/20 9:45 AM
Received: October 22, 2019
Status: Posted
Posted: October 23, 2019
Tracking No. 1k3-9cvp-pend
Comments Due: November 18, 2019
Submission Type: API

Docket: CDC-2019-0080
Assessment of Potential Exposure from Private Wells for Drinking Water
Comment On: CDC-2019-0080-0001
Assessment of Potential Exposure from Private Wells for Drinking Water
Document: CDC-2019-0080-0003
Comment from (redner enterprises)

Submitter Information
Name: joe redner
Address: 33607
Email: [email protected]
Organization: redner enterprises

General Comment
The agriculture industry must be made to clean their water before it goes into Lake
Okeechobee. This is all a ruse to shift the cost of cleaning the water to tax payers.

https://www.fdms.gov/fdms/getcontent?objectId=09000064840e88b7&format=xml&show... 3/16/2020

Page 1 of 1

PUBLIC SUBMISSION

As of: 3/16/20 9:46 AM
Received: November 13, 2019
Status: Posted
Posted: November 14, 2019
Tracking No. 1k3-9daq-3jhh
Comments Due: November 18, 2019
Submission Type: Web

Docket: CDC-2019-0080
Assessment of Potential Exposure from Private Wells for Drinking Water
Comment On: CDC-2019-0080-0001
Assessment of Potential Exposure from Private Wells for Drinking Water
Document: CDC-2019-0080-0004
Comment from (Maleeha Darab)

Submitter Information
Name: Maleeha Darab

General Comment
I agree with this proposed rule because of its timely importance in the United States currently.
The Center of Disease Control must do its due diligence in assuring that all Americans are
drinking from clean water. As part of the Safe Drinking Water Act of 1974, the legislation
makes it incumbent to assure many Americans receive clean drinking water, however the
number of people who do not have this access is staggering and must be addressed. If clean
drinking water is not secured nationwide, it could lead to greater public health issues in the long
run. If the water from private wells turns out to be contaminated in some way, this could lead to
a larger epidemic and effect more people than those who drink from the wells. If we begin to
research and understand more about the private wells in the United States, we may come across
more information that we may not have known for sure beforehand, such as the shared
demographics or socioeconomic status patterns that may exist, or the patterns of poverty and
health issues that are rampant in certain communities. Once research is conducted and potential
health risks are drawn from the drinking water, requesting agencies will be better able to serve
their communities and work to provide them with clean and safe drinking water. Social
determinants of health are a big aspect of what the Center of Disease Control work to address
and change. The environments we live in, the communities we live in, the schools we go to, the
water that we drink, the access to safe and clean drinking water are all integral parts that, when
combined, determine a persons longevity and health life span. I agree and advocate for this rule
because it will help to address long term issues, and will work to increase access to safe and
clean drinking water to all Americans no matter what type of water well they are drinking from.
The tax money collected to conduct this research will be in respect towards finding the greater
good.

https://www.fdms.gov/fdms/getcontent?objectId=0900006484151f84&format=xml&show... 3/16/2020

Page 1 of 1

PUBLIC SUBMISSION

As of: 3/16/20 9:48 AM
Received: November 14, 2019
Status: Posted
Posted: November 15, 2019
Tracking No. 1k3-9dbc-mohw
Comments Due: November 18, 2019
Submission Type: Web

Docket: CDC-2019-0080
Assessment of Potential Exposure from Private Wells for Drinking Water
Comment On: CDC-2019-0080-0001
Assessment of Potential Exposure from Private Wells for Drinking Water
Document: CDC-2019-0080-0005
Comment from (Anonymous Anonymous)

Submitter Information
Name: Anonymous Anonymous

General Comment
I recommend the government stay out of the citizens private wells. If the citizen is worried they
can figure it out themselves.
This sounds like another Republican water grab where they test your water and say its no good
shut down your well, make you buy "their " water which used to be yours

https://www.fdms.gov/fdms/getcontent?objectId=090000648415c88b&format=xml&show... 3/16/2020

Page 1 of 1

PUBLIC SUBMISSION

As of: 3/16/20 9:50 AM
Received: November 18, 2019
Status: Posted
Posted: November 18, 2019
Tracking No. 1k3-9ddo-qqpc
Comments Due: November 18, 2019
Submission Type: Web

Docket: CDC-2019-0080
Assessment of Potential Exposure from Private Wells for Drinking Water
Comment On: CDC-2019-0080-0001
Assessment of Potential Exposure from Private Wells for Drinking Water
Document: CDC-2019-0080-0006
Comment from (Anonymous Anonymous)

Submitter Information
Name: Anonymous Anonymous

General Comment
The comments of the National Ground Water Association on Assessment of Potential Exposure
from Private Wells for Drinking Water, Docket No. CDC-2019-0080, are in the attached file.
Thank you for the opportunity to comment on this information collection request.

Attachments
NGWA Comments on CDC Assessment of Potential Exposure from Private Wells for Drinking
Water Final PDF 2019 11 15

https://www.fdms.gov/fdms/getcontent?objectId=09000064841715c5&format=xml&show... 3/16/2020

National Ground Water Association
Comments on
Centers for Disease Control and Prevention (CDC), Department of Health and
Human Services
Proposed Data Collection Submitted for Public Comment and Recommendations
titled “Assessment of Potential Exposure from Private Wells for Drinking Water”
Published in the Federal Register: September 17, 2019
Document Citation: 84 FR 48931
Agency Number: 60Day-19-1173
Docket No. CDC-2019-0080
Electronic Link: https://www.federalregister.gov/documents/2019/09/17/2019-20086/proposed-datacollection-submitted-for-public-comment-andrecommendations?utm_medium=email&utm_campaign=subscription+mailing+list&utm_source=federal
register.gov
Date Submitted: November 18, 2019

Summary
The Centers for Disease Control and Prevention (CDC) invited public comment on a proposed
information collection project titled “Assessment of Potential Exposure from Private Wells for Drinking
Water.” The purpose of this generic information collection request is to assess the health risks
associated with exposure to contaminants (i.e., arsenic and uranium) in drinking water from private
wells across varied geographic areas of the United States in partnership with the requesting agency. The
information obtained from these investigations will be used to describe health risks from exposure to
the contaminants in drinking water from private wells within a defined time period and geographic
distribution. This information will be used to inform public health protection activities conducted by the
requesting agencies.
Comments of the National Ground Water Association
The National Ground Water Association reviewed the protocol and proposed questionnaire for the
project to assess the potential exposure from private wells for drinking water. The NGWA appreciates
the opportunity to provide input to this survey. The three NGWA reviewers have a combined
experience of over 90 years in hydrogeology, environmental microbiology, drinking water supply
protection and infrastructure surveys, with two reviewers having state licenses as professional
geologists. The comments are presented first on the protocol (titled: Exposure to arsenic and uranium
from private wells in Connecticut, New Hampshire and New Mexico) and then on the survey
questionnaire (titled: Att1 Example Questionaire 3-17-17 CLEAN) provided on October 15, 2019, by Dr.
Page 1 of 6

Johnni H. Daniel of the Health Studies Section, Division of Environmental Health Science and Practice,
National Center for Environmental Health, Centers for Disease Control and Prevention.
As an overall comment, NGWA is concerned about the sufficiency of attention to water well and
chemical substance characteristics and information processes used to develop the survey. These
characteristics information and processes significantly affect the questions asked, the responses, and
the results of the survey. Insufficient knowledge of wells and their interaction with the surrounding
environment on and under the ground and the associated data processes that were used to design the
protocol and the questionnaire is very obvious to experts in the field of hydrogeology. This insufficient
knowledge raises questions about the validity of the results that the Centers for Disease Control and
Prevention would obtain from administering the survey questionnaire as proposed.
Protocol
(1) More references supporting the survey are available than are listed and should have included
citations for data collection at wells. For example, see Advisory Committee on Water Information,
Subcommittee on Ground Water. 2013. A National Framework for Ground-Water Monitoring in the
United States. https://acwi.gov/sogw/ngwmn_framework_report_july2013.pdf. Other data
standards are also cited in this document for further reference.
(2) Well logs, documents containing vital information on the history and stratigraphy of the well and the
ground surrounding it, are not mentioned in the protocol but are vital to understanding the
hydrogeology affecting the quality of the groundwater being drawn on by the wells being
considered in the survey and assessment.
(3) Prior to survey administration and in its development, an assessment of activities near the wells
should be conducted to determine whether actions that could result in the presence of the
contaminants of concern – arsenic and uranium – or the presence of bio-physico-chemical
substances that could contribute to the occurrence of contaminants of concern may have taken
place in the surveyed areas. A database search may be useful in conducting this assessment.
Activities to search for may include:
a. Mining and mineral processing
b. Road salt application (CT, NH)
c. Chemical spills
d. Oilfield brine application to roadways for dust control (NM)
e. Other actions
As an example of our concern about other substances applied that could cause the release of
uranium, monitoring in Delaware identified eleven groundwater-supplied water systems with wells
between 75 and 450 feet deep receiving stormwater in their groundwater capture area to have
statistically significant trends of increasing chloride. Four systems have radionuclide problems due
to the high chloride concentrations. At current rates of increase, groundwater serving two systems
will reach the 250 mg/L SMCL for chloride in about 10 years. With no suitable alternative sources of
supply, these systems will need expensive treatment to remain viable. (Communication from
Delaware Geological Survey, October 21, 2019)
(4) While the USGS laboratories will analyze samples for arsenic and uranium and the CDC laboratory to
analyze urine samples, the protocol does not cite the analytical methods to be used.
(5) The protocol does not address sample collection procedures, particularly for well samples.
Standard environmental sampling protocol should be followed.
Page 2 of 6

(6) Sample tests should run standard environmental sample tests, including general ion and chemical
interactions.
(7) The protocol should also state the level of data Quality Assurance and Quality Control (QA/QC) to be
applied to the laboratory results and the statistical method to be used.
(8) Regarding training the survey staff, it is not clear what “just-in-time” training is and how it
contributes to a credible survey. We would expect survey staff to be trained in and have expertise
in health surveys and analysis.
(9) “Refused” should not be an accepted answer to any survey question. If the responder refuses to
answer any question, the survey should be stopped or discarded and a new responder selected who
will answer the questions.
Questionnaire
NGWA recommends inserting additional questions that will be provided below. Also, NGWA
recommends that “pick lists” of potential responses to questions be used rather than open-ended
questions. This latter approach facilitates both compiling and analyzing the results.
Recommendations for additional questions or their modifications will be presented by the question
number.
Question/Recommended change or addition
10a – Do you have a well log describing the well, geology and site?
[A well log will provide the depth, age and stratigraphy of the borehole. It should also state what
material the well casing is as the material could influence the presence of heavy metals.]
10b – How far from the well is the on-site wastewater system?
[Chemicals in the wastewater may become concentrated in the on-site wastewater system
release area and if too close to the well may affect groundwater quality of the well.]
13a – Do you check for possible sources of potential contamination of your well around the area of the
well? [ ] Yes [ ] No
13b – What sources of potential contamination did you find?
[ ] Fertilizer
[ ] Pesticide
[ ] Waste
[ ] List other contamination sources that may have arsenic or uranium exposure
[ ] Other (please describe)
13c – What did you do with the potential contamination source(s) (check all that apply)?
[ ] Applied to lawn
[ ] Put in trash
Page 3 of 6

[ ] Burned source
[ ] Recycled through local recycling process
[ ] List other contamination source disposal or recycle method(s)
[ ] Other (please describe)

20 – The question should have check boxes listing the professions that may be associated with handling
or use of arsenic and/or uranium. Alternatively, the question could be re-formulated as:
Do you use radiation, pesticides, oil field brines or [other substances or practices associated with
arsenic or uranium] in your work? [ ] Yes [ ] No
21 – e. Essential Oils [these oils may include arsenic as an ingredient]
22 – Do you engage in any of the following activities? Check all that apply.
[ ] Ceramics
[ ] Jewelry making
[ ] Painting
[ ] Stained glass assembly
[ ] Smoking
[ ] Application of pesticides
[ ] List other activities that may have arsenic or uranium exposure
26 – During the past year, have you been concerned/worried about the quantity of water your well
provided for household uses for any of the following reasons (check all that apply)?
[ ] Drought/dry season
[ ] Low water pressure at tap
[ ] Variable water flow at tap
[ ] List other reasons associated with arsenic or uranium or the survey objectives.
[ ] Other (please describe)
27 – During the past year, have you ever been concerned/worried about the quality of your well water
for any of the following reasons (check all that apply)?
[ ] Strange Taste
[ ] Odd Color
[ ] Plants died
Page 4 of 6

[ ] Slimy feel
[ ] Illness
[ ] Indigestion
[ ] List other reasons associated with arsenic or uranium or the survey objectives.
[ ] Other (please describe)
29a – Do you have the laboratory report for the last test results of your well water? [ ] Yes [ ] No
31a – Can you provide us with a copy of the last test results of your well water? [ ] Yes [ ] No
35 – What did you do in response to receiving the test results for your well water quality (check all that
apply)?
[ ] Contacted health department
[ ] Stopped drinking or cooking with well water
[ ] Stopped bathing with well water
[ ] Used bottled water for drinking or cooking
[ ] Installed water filter or treatment system
[ ] List other possible actions.
[ ] Other (please describe)

Basis for the Interest of the National Ground Water Association (NGWA) in Exposure to Household
Drinking Well Water
NGWA, the largest trade association and professional society of groundwater professionals in the world,
represents over 10,000 groundwater professionals within the United States and internationally. NGWA
represents four key sectors: scientists and engineers, employed by private industry, by the consulting
community, by academic institutions, and by local, state, and federal governments, to assess
groundwater quality, availability, and sustainability; water-well contractors responsible for developing
and constructing water-well infrastructure for residential, commercial, and agricultural use; and the
manufacturers and the suppliers responsible for manufacturing and providing the equipment needed to
make groundwater development possible. NGWA’s mission is to advocate for and support the
responsible development, management, and use of groundwater.
Over 34 million people in the United States rely on private wells and 87 million are served by
groundwater from community water systems. Seventy-one percent of groundwater withdrawn is for
irrigated agriculture. Additionally, forty percent of baseflow of streams is contributed from groundwater
discharge through streambeds.
NGWA views groundwater and the subsurface as significant natural resource that should be sustainably
managed for current and future use. The subsurface environment should be considered from an
Page 5 of 6

integrated resource perspective. The natural resources extant in the subsurface environment with
proper management can provide fresh groundwater for drinking, industrial and manufacturing
applications, food production, and ecosystem support.
Thank you for the opportunity to review this proposed survey and questionnaire. The National Ground
Water Association is available for consultation on this proposed survey and/or its analysis.
For further information and followup, please contact:
Charles Job, Regulatory Affairs Manager
National Ground Water Association
601 Dempsey Road
Westerville, OH 43081
[email protected]
202-660-0060

Page 6 of 6

Type of
Comment

Submitter Information

Comment

Response

Public
submission

Anonymous Anonymous
Status: Posted
Posted: Nov 18, 2019
Tracking No. 1k3-9ddo-qqpc
Anonymous Anonymous
Status: Posted
Posted: Nov 15, 2019
Tracking No. 1k3-9dbc-mohw

The comments of the National Ground Water Association on
Assessment of Potential Exposure from Private Wells for Drinking
Water, Docket No. CDC-2019-0080, are in the attached file. Thank you
for the opportunity to comment on this information collection request.
I recommend the government stay out of the citizens private wells. If
the citizen is worried they can figure it out themselves.

See response following
list of comments.

Public
submission

Public
submission

Maleeha Darab
Status: Posted
Posted: Nov 14, 2019
Tracking No. 1k3-9daq-3jhh

This sounds like another Republican water grab where they test your
water and say its no good shut down your well, make you buy "their "
water which used to be yours
I agree with this proposed rule because of its timely importance in the
United States currently. The Center of Disease Control must do its due
diligence in assuring that all Americans are drinking from clean water.
As part of the Safe Drinking Water Act of 1974, the legislation makes it
incumbent to assure many Americans receive clean drinking water,
however the number of people who do not have this access is
staggering and must be addressed. If clean drinking water is not
secured nationwide, it could lead to greater public health issues in the
long run. If the water from private wells turns out to be contaminated
in some way, this could lead to a larger epidemic and effect more
people than those who drink from the wells. If we begin to research
and understand more about the private wells in the United States, we
may come across more information that we may not have known for
sure beforehand, such as the shared demographics or socioeconomic
status patterns that may exist, or the patterns of poverty and health
issues that are rampant in certain communities. Once research is
conducted and potential health risks are drawn from the drinking
water, requesting agencies will be better able to serve their
communities and work to provide them with clean and safe drinking
water. Social determinants of health are a big aspect of what the
Center of Disease Control work to address and change. The
environments we live in, the communities we live in, the schools we go
to, the water that we drink, the access to safe and clean drinking water
are all integral parts that, when combined, determine a persons
longevity and health life span. I agree and advocate for this rule

No reply needed.

No reply needed.

Public
submission

Public
submission

Joe Redner
Status: Posted
Posted: October 23, 2019
Tracking No. 1k3-9cvp-pend
Jean Publicee
Status: Posted
Posted: Sept 19, 2019
Tracking No. 1k3-9c99-nyzw

because it will help to address long term issues, and will work to
increase access to safe and clean drinking water to all Americans no
matter what type of water well they are drinking from. The tax money
collected to conduct this research will be in respect towards finding
the greater good.
The agriculture industry must be made to clean their water before it
goes into Lake Okeechobee. This is all a ruse to shift the cost of
cleaning the water to tax payers.

No reply needed.

more fakery from teh cdc on whether water is contaminated or not. i
No reply needed.
am not in favor of taxpayers paying for this stupid collection of
information. first of all teh standards for pure clean water were made
abouit l00 years ago and they do nothing about the hundreds of
thousands of chemicals that ar ein water today. nobody tests for that.
nobody tests for lead routinely.
our men in aemrica are becoming emasculated and turning into
women. that is fact. our fish are turning into females. they live in water
and drink it. that is fact. clearly our water is very polluted alredy. wells
too are polluted. so to do this collection based on information from the
safe drinking water act shows that is all made up political crap that
mean nothing.this is fake healthcollection with no real meaning for
health. first of all we need testing for all the pollutants that are out
there today. that is the first necessity. this collection is pure fakery. we
need to take more budget money from teh cdc. they work only for bit
pharma, big medicine and big chemicals. they donj work for health of
the us public at all. they are in fact hurting the us public. look at how
our lifespans are going down each year.

Response to National Ground Water Association
To: National Ground Water Association
Thank you for your response to the Federal Register Notice Docket No. CDC-2019-0080.
This proposed information collection project is a generic clearance information collection request (Gen ICR). This Gen ICR allows the CDC to expedite
investigations to assess private well water for drinking in response to specific requests. A Gen ICR can be thought of as an umbrella that covers a
collection of specific investigations related to the topics covered in the Gen ICR. That is, CDC writes a general protocol to do a series of specific studies
regarding the subject matter (as requested by agencies such as state and local health departments). The general premise of the Gen ICR is kept when
designing specific studies; however, some aspects (e.g., the contaminants under study, region of interest, analytic methods, and exposure questions) will
be determined in response to specific investigation requests. Because no specific study is identified for the Gen ICR, such specifics cannot be addressed
in the general protocol. The arsenic and uranium study in three states mentioned in your comments is an example of a specific investigation that would
be covered by this Gen ICR. We will take your comments and suggestions for this study example into consideration. Other investigations of interest
under this umbrella may examine different contaminants or take place in different states, for example.
We appreciate your suggested questionnaire items. They are very helpful and we will consider them when we develop questionnaires for studies that
fall under this umbrella of studies.