GREG



### J . DAVIES 

### Dir ec t o r 

## Sean Conley Standards and Risk Management Division Office of Ground Water and Drinking Water (MC 4607M) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, D.C

. 20460 conley.sean@epa.gov

THE
C IT Y 

### O F



## * 

# COLUMB US MICHAEL

B . COLEMAN

, **~AYOR** 

### DEPAIHMEN

f 

### Or PUBLIC UTIL

I 

### liES 

## December 15, 2014 Re: Stakeholder Outreach-Rulemaking

on Inspection and Cleaning
of Finished Water Storage Tanks Dear Mr. Conley: I am writing on behalf of the City of Columbus, Ohio, Department

of Public Utilities

, Division of Water, to provide requested information and comments
on U.S

. EPA's stakeholder outreach regarding the inspection and cleaning
of finished water storage tanks. The Columbus Division of Water treats and distributes drinking water to approximately
1.2 million people

in Central Ohio. Columbus operates three drinking water treatment plants and operates and maintains
36 steel finished water storage tanks
in the water distribution system

. The 36 water tanks are on two-year inspection and cleaning schedules that require the tanks to be emptied

, inspected, cleaned

, repaired

if necessary, and chlorinated, sampled and brought back into service.

I have attached for your review the Storage Tank Washout and Inspection Report that details the water tank inspection checklist that Columbus uses in inspecting and cleaning the tanks. The vents on 34 Columbus' water tanks have been replaced with frost-free vents that are designed without screens and that are designed
to prevent birds or other animals from entering the vent. The vents on the remaining two tanks are to be replaced with frost-free vents within the next year. The water tanks are on a 15 to 20-year painting schedule. Equipment associated with the water towers are on a weekly inspection schedule. This equipment includes computer telemetry connected

to the SCADA system, water alarms, sensors, lighting, and heating at the base of the tanks. Director's Office

I 910 Dublin Road

I Columbus OH 432

1 5
I T (614) 645.6141

I F (614) 645.8019 Sewerage and Drainage

1 1250 Fairwood Avenue

I Columbus OH 432061

T (614) 645

. 7175

I F (614) 645

. 3801 Power and Water Administrat

i on 1910 Dub

l i n Road Columbus OH

I 43215

1 T (614) 645

. 7020

I F (614) 645

. 3993 Customer Service

I Power and Water

I T (614) 64S.8276

I F (614) 645.0222

I TOO (614) 645.7188 columbus.govColumbusbelievesthataone-size-fits-allregulatoryschemeforinspectingandcleaningfinishedwaterstoragetanksisnotappropriate.Aregulatoryschemethatpermitspublicwatersystemstosubmitinspectionandmaintenanceplanstailoredtotheirspecificneedsforregulatoryagencyapprovalpursuanttoflexibleandgeneralguidanceandrecommendedbestpracticesisamoreappropriateregulatoryschemethatwilladequatelyprotectpublichealth.Ifyouhaveanycommentsorquestio'ns,orifIcanbeofanyfurtherassistanceinthismatter,pleasecontactme.Sincerely,RichardC.Westerfiled,P.E.,Ph.D.AdministratorCityofColumbusDivisionofWater910DublinRoadColumbus,Ohio43215614-645-3710rcwesterfield@columbus.gov2

### If addilional Revision Date. 9.12.12 

# Storage Tank Washout and Inspection Report Operations Control Center Please enter comments and ·nate 

### isolated: 0Took Tech: Page

1 of 2

TliE CITY OF

, 

# COLUMBUS r;.r:-;pi\;,_. rMl:o_NT

1 ':1F PUE':<L!G \JTHJT!E5 Water Tank Inspection FormsStorage Tank Washout and Inspection Report Operations Control Center Overall condition
of tank and site: Overall condition
of INTERIOR WET coatings: Overall condition
of INTERIOR DRY **coatin~s:** Overall condition
of EXTERIOR coatings:

. 1.)

. Issues needing added to washout procedures: Issues needing immediate attention: Date/Time dilution began:

Feet of water added: 3rd Sample collected by: **Chlori~e** reading before sample taken: Date/Time
of collection: Date/Time delivered
to Lab: Chlorination Notes: Revision Date. 9.12.12

Page
2 of2 Tl-jECITY OF

, COLUMBUS 1-\qVo,[l **O.«Jt.t::~AH.HAY¢R tJSPAF~l'Mf;NT** 
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. Water Tank Inspection Forms