October 6, 2014

Mr. Sean Conley Standards and Risk Management Division Office of Ground Water and Drinking Water (MC 4607M) US Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington DC 20460



## RE: Distribution System Storage Facility Inspection and Cleaning

PUBLIC COMMENT

Dear Mr. Conley :

This letter is in response to ongoing conversations with Mr. Bob Clement , EPA Region 8

, and the Notice of Public Comment respect ing the above referenced matter. B ased on my

firm , Liquid Engineering Corporation ’s (‘LEC’)

, experience and expertise in this arena , this is a compelling matter that we believe all stakeholders would agree has remained

unaddressed for far too long

. I will be providing representative photographic documentation under separate cover.



## Introduction

In our experience there are three driving elements of potable water tank inspections ; t hey

are: The interval between inspections (i.e. frequency)

, t he scope (i.e. level of detail) of the inspection , and method (i.e. wet/dry) of inspection. This comment will attempt to provide hard quantifiable data

, in such a manner that the uninitiated reader will be able to extract

this information, to assist them in formulating a proactive set of possible solutions to th is

very significan t issue of public policy and public safety in the drinking water industry.



## Background

Liquid Engineering Corporation (“LEC”) has been exclusively involved in potable water storage reservoir (tank) inspection, cleaning and maintenance for 2 5 years. Specifics of that experience include:

1. LEC has conducted inspect ions o f approximately 50,000 potable water tanks throughout the United States during that quarter century of business

.

2. LEC’s Customer Data Base includes approximately 30,000 water utilities in all 50

states.

3. LEC’s Customer Data Base incorporates both detailed historical (going back a quarter of a century) and current information on an estimated 75% of the total potable water production capacity in the U.S.Page 2

Mr. C onley

Octobe r 6, 2014

4. LEC is the largest provider in the country of these highly specialized services

.

5. LEC is both a Licensed Engineering Firm and Licensed Marine Engineering & Construction company, with licensed professional engineers and project man a gers on staff

.

6. LEC was a member of the AWWA Committee tasked with drafting the updated potable water tank disinfection standards (AWWA C652

- 02)

.

Based on that experience and national exposure, I will describe in broad terms LEC’s experience and observations in the a rea of potable water tank inspections and maintenance, as it exists in the U.S. today.



## Findings, Observations & Experience

Representative examples of findings:

 Inside a potable water tank located in one of the largest urban areas in the US was discovered the remains of three decomposed human bodies. It was estimated the murder victims had been in the tank, undiscovered, for 1

- 3 year s

. Subsequen t investigation determined that local drug dealers, knowing that the tanks were seldom inspected o r for that matter, even visited, used it as a risk

- free place to hide their ‘competitors’; on three separate occasions.

 A Liquid Engineering potable water tank inspection and cleaning found a fully decomposed adult horse skeleton lying in the bottom of the tank. [ Y ears earlier when

the tank had been open

- topped , the horse had apparently entered the tank (which

wa s shouldered into a hillside) for water, and unable to get out

, had drowned. The water utility subsequently installed a roof on the tank (some time prior to LEC’s inspection) without seeing the skeleton

— for the simple reason that the tank had never been inspected internally

, prior to LEC’s inspection.]

 LEC inspected and cleaned a potable water tank that had been sealed since 1941 and never agai n entered

, until our inspection in 1994. During that inspection we found approximately 18 feet of debris and accumulated organic material. The tank was in danger of imminent collapse and was ultimately decommissioned, based on our inspection findings.

 L iquid Engineering often inspect s and clean s potable water tanks that contain as

much as 6

- 25 feet of various materials, including accumulated sand, organic

material and/or mixed debris

— that in most cases the utility i s unaware i s present.Page 3

Mr. C o nley October 6, 2014

 As recently as this past spring, LEC identified several tanks that were constructed in the 1940’s and have NEVER been opened for interior inspection. When we queried the owner , the y stated that “ if they inspected the tanks, they wou ld have no choice but to do something to resolve the problems ”

.

 LEC regularly inspects and cleans potable water tanks (on a routine and continuing nationwide basis) that contain 1

- 3 feet of accumulated organic and non

- organic

debris and sediment

.

 On very rare occasions, LEC inspects a tank that contain s accumulated debris

, with embedded resident biological colonies and their associated byproducts

, on the floor of the tank. These colonies can be anywhere from a few inches to 12 inches deep.

 LEC frequently finds floating debris and organics (dead birds, insects, snakes,

rodents , mammals, and most commonly, pump lubricants) to a depth of 6

– 12 inches floating on top of the water

, or lying on the bottom of the tank in various stages of decomposit ion

. In t his past four

- week period, LEC’s six field crews identified decomposing snakes, frogs, birds, and a 1 4 foot long 8 in ch diameter tree root that had penetrated a joint in a concrete potable water tank

.

 A n LEC potable water tank inspection at a US Government f acility identified dozens

of 6

- 12 in . long fish swimming around inside two of their potable water tanks. The fish were surviving by eating the 2

- 3 feet of live snails living on the bottom of the two

tanks. We removed the snails ; a nd assume th e government ’s employees caught the fish upon LEC’s departure

, enjoy ing a great fish fry

.

 In the recent past

, LEC inspected and cleaned two potable water storage tanks that had never been previously inspected since the day they were placed in service

, in 1938 and 1947 respectively

.

 On a nation

- wide daily basis, a routine, typical

, and expected finding is 1

- 3 inches

of accumulated bottom sediment and debris. In fact this finding is so customary that LEC does not charge extra to clean ‘up to’ that amou nt of accumulated material in its standard contract language. Typically this debris is composed of sand, dirt, inert organic material, iron compounds and various precipitating and flocculating agents used in the water treatment process.

 So far in 2014, L EC has identified more than 100 potable water storage tanks that

have not been opened (i.e., inspected) for over 10 years.Page 4

Mr. C onley October 6, 2014



## Relevant Statistics

Some statistics gleaned from LEC’s two + decades of potable water storage tank inspections:

• In LEC’s customer base, approximately 70% of potable water providers

, nationally, inspect and clean their potable water storage tanks at least every 3

- 5 years, with approximately half of these inspect ing their tanks a maximum of every three years. This time interval is not only an industry

- wide ‘standard /best practice s ’ but is

reflected in the American Water Works Association ( AWWA’s ) Standard M42, which specifies normal interior tank inspections no less than every 3 years, unless there are unusual levels of sediment accumulation, in which case it is recommended annually

.

• In addition, AWWA’s Standard D101

- 53 (R1986) calls for interior inspection of all “potable water storage tanks at intervals not more than every 5 years”. It is important

to note that it is not more than every 5 years , implying that more frequently than every 5 years is the desired inspection interval.

• Of the remaining 30 % of potable water providers, the time between inspections and

cl eaning can be anywhere from 7

- 20 years but is

, with LEC’s customers

, on average around every 7

- 10 years.

• In LEC’s experience, virtually all potable water utility operators in the country would ideally like to inspect and clean their water storage tanks no less frequently than every three (3) years. Over the past two decades, n either my staff nor I can recall a single operator or utility manager who would oppose such an inspection interval. For those utilities that do not meet that frequency standard

, it a lways seems to be for one of two reasons: Either a lack of money (i.e. it’s not the city’s “squeaky wheel”), or it’s the utility’s inability to lose the use of their single water storage tank during a ‘dry’ (empty tank) inspection or cleaning

, thus preven ting adequate capacity for fire protection or drinking water. (By utilizing a properly qualified

, trained and experienced potable water diving contractor, the latter reason is rendered moot).

• Of those estimated 30% of potable water providers that do not inspect and clean their water storage tanks on a regular basis (defined here as every 3

- 5 years), the

most common reason LEC has heard

— literally thousands and thousands of times over the past quarter century

— is: “ The city council /mayor /Board told me t hat as long as nobody is getting sick or no one is making us do it, we don’t need to spend the money ”.

• One of the key reasons that the 70% of potable water providers who do undertake routine inspections (in addition to the obvious public health and safe ty issues) is that it allows them to identify and quantify a variety of needed maintenance discrepancies.Page 5

Mr. C onley October 6, 2014

These include paint failure and associated corrosion in steel tanks, cracking in concrete tanks, developing stru ctural issues

- up to and including possible structural failure, potential tank contamination issues, and long

- term maintenance budgeting and planning.



## General Comments

Various AWWA Standards (as described above) recommend all potable water storage

tanks be inspected at least every three (3) years. In our quarter

- century of experience nationally, fewer than 4 0% of potable water tank owners (private and public) follow th i s 3

- year standard, generally as a result of funding limitations. I n LEC’s experience i n some
50 ,000 water tanks nationwide, 99% of significant health and maintenance problems can be identified within any given 3

- year inspection window, thus allowing adequate time for correction/mitigation before public health or safely is placed at risk.

[As a sidebar comment, since our earlier conversations with Mr. Clement, we have polled a number of utility operators and managers who have been unsuccessful in getting the money for more frequent inspections and tank cleaning (typically done every 7

- 10 ye ars with the group we polled).

To a man (all happened to be men) they opined that they would love to see a Federal regulation that would mandate frequent tank inspections and cleaning (every 3 years was proposed to them

, without one person demurring ), bec ause it would provide ‘top cover’ (i.e.

“ protection ” ) for the operators from the board/manager/ city council

— who would be left with no choice but to comply with the regulation , because it would now be a “squeaky wheel”. ]

In the event a particula r potable water storage tank is found to have significant physical condition or potential public

- health issues, this requirement should mandate annual inspections and monitoring (in emergency situations) until the identified discrepancies are

rectified.



## Continuing State Regulatory Challenge s

One of the specific issues facing thousands of single

- tank community water systems is the

occasional state

- mandated requirement that tanks must be drained in order to be inspected. The hardship for these single

- tank or intrinsic system design

- limited communities is that during the 5, 6 or even 7 days required to drain, clean, inspect, refill, disinfect and test a tank before it can be placed in service, it can leave many of these communities without adequate drinking water or fire protection. This als o ignores the extremely high cost of dumping the hundreds of thousands, or even millions of gallons of finished (i.e. expensively treated) water, prior to the inspection.

The fall

- out from this regulation is that many utilities simply don’t inspect th eir tanks. Mandatory tank draining is an onerous and ill

- advised regulation, which while undoubtedly created with the best of intentions, is neither supported by any scientific evidence nor current best practices.Page 6

Mr. C onley October 6, 2014

On the contrary, the AWWA, as well as other nationally recognized organizations have developed and implemented standards, policies, procedures and best practices to ensure that the public health and safety are protected when undertaking ‘wet’ potable water tank

maintenance activities.

These mandatory draining regulations should be specifically limited to the most exigent circumstances, and should require a written notice from the state regulatory authority to the utility as why this is requirement has been manda ted in this specific instance. In short, mandatory tank draining is a vexing, even impossible compliance issue for thousands of water utilities across the country. [ This regulatory issue is well known by the respective state regulatory authorities, and as a result is often ignored by them

— turning a blind eye and tacitly allowing ‘wet’ (i.e. diver inspections/cleaning)

— in order to facilitate critically needed

tank inspections , cleaning or maintenance. ]

In the course of litigating with two state regulatory a uthorities to allow ‘wet’ (i.e. diver) tank inspections, LEC has actually been told by state regulators that they would rather see tanks go uninspected

, than allow properly certified, trained and experienced potable water commercial divers to inspect their state’s water tanks. Under rigorous questioning, no t one

person could offer a science

- based reason for their position. The result of this attitude is that hundreds and hundreds of potable water storage tanks in this country go uninspected year after year, after year, after year

— often for decades.

As to the issue of the level of inspection detail described at the beginning of this statement, there is one state that currently has a regulation in place that mandates an annual inspection of every potable water tank located within that state. On its face, this would appear to be a very proactive approach to maintaining water quality and storage tank condition monitoring.

Unfortunately this is not the case

, for the simple reason that the state

- mandated “inspection”

criteria can be met by simply opening the hatch on the top of the tank and looking inside

the dark

, water

- filled reservoir. They are referred to

, tongue

- in

- cheek

, as “hatch peek” inspections.



## Summary

Those well

- run and properly administered potable water utilities ( the 70% nationwide) in the United States today almost universally inspect their water storage tanks on a frequent

basis

— typically every three years.

Only the most poorly administered water utilities ( estimate d 30% nationwide)

— for financial

or other reasons

— do not meet even a minimum 5

- year inspection period.

This lack of even minimal inspections appears indefensible on its face, when one considers that every water utility in the country undertakes the disinfe ction expense and effort of daily monitoring of both its water production and storage (water tank) facilities ; yet on the other hand nearly one

- third of these same utilities refuse to inspect their water storage system at least once every 3 years

.Page 7
Mr. C onley October 6, 2014

And this is doubly troubling when one considers the fact that a water utility’s potable water storage tank s are the final step in the process before the water is distributed to the families

who drink it , including children, th e elderly and those who may have compromised immune
systems

.

A three

- year potable water storage tank inspection mandate would meet current recognized

, science

- based, published (AWWA and others ) standards and best practices, improve water quality, and identify potential problems before they become serious problems, thus ensuring both the public ’s health and safety . All of these benefits could be

had at nominal cost to the utility

, and can be accomplished eithe r with the tank empty or filled with water, thus offering no disruption in service or loss of expensive water to the utility.

Hopefully this information will be use ful to USEPA in developing a responsive and well

crafted final regulation. I appreciate the opportunity to provide input on this most important

matter.

Sincerely,
LIQUID ENGINEERING CORPORATION 

# Wayne Dykstra

Wayne Dykstra

President

CC: File