Yes, I suppose that's a unique implementation risk for CTR and in that case Kragen's concerns about XOR are valid as well since you've got a stream cipher with a short period.
I was more thinking about how the cipher input has a predictable structure, in particular every pair of adjacent blocks differ by only a single fixed bit. This isn't an issue unless the underlying block cipher is badly broken, but it still feels unnecessarily risky.
OFB has the same problem with IV reuse, but because CTR divides the IV into a nonce and a counter, it basically begs you to make the error by giving you two opportunities to make it.
