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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. 
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3. Are there types of storage facilities that do not merit 

inspection, 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 should 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 own 
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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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