1 

### Laura Landes

From: Madhulika Nataraja

Sent: Thursday, November 06, 2014 3:06 PM

To: Laura Landes
Subject: FW: Comments on Storage Tank Webinar

Follow Up Flag: Flag for follow up
Flag Status: Flagged

Hi Laura,

We received an additional comment (answers to questions posed during the SFI webinar). Could you please PDF David’s

e

‐ mail and upload it to SharePoint by the end of tomorrow?

Thanks, Madhulika.

From: David Money [mailto:David.Money@tn.gov]

Sent: Thursday, November 06, 2014 2:58 PM

To: SFI Stakeholder Meeting Subject: Comments on Storage Tank Webinar

I hope it is not too late to provide comments on the questions posed during the webinar.



# 1. What additional information are you aware of regarding the potential public health risks from failure to maintain finished drinking water storage facilities? Generally, the lack of use and maintenance of a disinfectant residual throughout distribution systems presents the biggest public health risk. Additionally, a lack of national standard for inspection or criteria for storage tank construction results in tanks that are constructed without separate inlet/outlets allowing elevated residence time( water age) which, in conjunction with lack of disinfection residual, structural breech and biological contamination can result in disaster.

2. How often should storage facilities be inspected? Cleaned? Annual external/visual inspection. 5 year comprehensive internal/external inspection with clean-out.2 

# 3. Are there types of storage facilities that do not meritinspection, or should not be inspected as frequently? Nonatmospheric ( pressure tanks) used by small non-community water systems. Some states indicate source water should dictate need or frequency of inspections. This is irrelevant when thinking in terms of structural breeches and impact from distribution lines( repairs, alum overfeed etc.). Sediment could provide medium to support pathogenic microorganisms.

4. What are the most critical elements of a storage facility that should be inspected? Structural integrity, Internal conditions, coating, screens and vents, security, safety.

5. What types of deficiencies in storage facilities require prompt action to protect public health? Evidence of security breech, discovery of animals, chemicals or other potential

contaminants.

6. Are guidance and recommended best practices sufficient or is regulation needed to assure public health protection? Regulation is needed. Historically, it seems that States/Tribes are reactionary and will not address issues or implement regulations until an incident brings the issue to public attention. EPA shoul d consider development of a regulation that requires States/Tribes to develop an inspection/ cleanout requirement and program for

each PWS. Each state could then determine its own3 

# prescribed frequency and criteria, which seems to be an

issue of debate.

David Money

Division of Water Resources

Columbia Environmental Field Office

Office: 931-840-4172

Cell: 931-436-8857

Email: David.Money@TN.gov

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