October 6, 2014

Office of Ground Water and Drinking Water (MC 4607M ) Standards and Risk Management Division U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW. Washington, DC 20460;

RE: Distribution System Storage Facility Inspectio n and Cleaning

All,

Although I would like to have participated in the p ublic meeting and webinar that will be held on October 15, 2014 from 12:00 p.m. to 5:00 p.m., East ern time, I will be traveling that entire day and I am unable to change my travel plans.

However, I would like to hereby request that the it ems presented in this correspondence, as well as the documents and photos included with this corr espondence, be reviewed, discussed, and considered by EPA during their decision process of this issue.

As a brief introduction, I started to inspect potab le water storage tanks in 1976 with engineering firms, then performed sanitary surveys on hundreds of tanks as a health official charged with The Enforcement Of The Safe Drinking Water Act. In 198 2 I started my own inspection firm whereby I have personally inspected more than 4,000 tanks since 1982 and I personally inspect about 150 tanks each and every year.

Attached with this correspondence is additional inf ormation about me and my company.

Also attached are a few representative inspection p hotos from 20 tanks chosen completely randomly from the hundred plus tanks we inspected t his year already, which very clearly demonstrate that, even after 8 to 31 years being in service after the tank was either installed or last cleaned, there are only traces to maybe 1⁄2” of dirt on the bottom. Also note that there is virtually no dirt on the sidewalls, even in the tan ks that are corroded and require a recoat. There are only traces, to less than 1⁄2”, of dirt on the bo ttom of at least 95%, and more likely, 99% of all the tanks we inspect each year.

Please note that the inspection photos are from var ious types of tank construction such as welded steel, epoxy coated bolted steel, glass lined bolte d steel, prestressed concrete, hypalon lined reservoir with floating cover, etc. I can provide you with inspection photos from hundreds of additional tanks that show you the same thing, ther e is no need to clean the tanks every 5 years.

ROV And Drained Potable Water Storage Tank, NFPA Fi re Water Tank, & Pipeline InspectionsConrady Consultant Services

Office of Ground Water and Drinking Water (MC 4607M ) U.S. Environmental Protection Agency October 6, 2014 Page 2 of 2

Please consider the following:

1. I fully agree that potable water tanks should be required to be completely inspected internally and externally every 5 years but not cle aned. The 5 year inspection would determine if there is enough dirt or any biofilm th at the tank should be cleaned. The only way to adequately clean a tank is to drain and pressure wash it. ROV or diver cleaning only removes the bottom silt and does not remove the sidewall dirt or any biofilm if existing.

2. Draining any water tank to be cleaned is a consi derable expense and inconvenience to the utility, especially if they only have one tank. Ev en with multiple tanks on the system, draining one of their tanks involves adjusting the entire system to operate without the flows and pressure provided by this tank during nor mal operation of the system for the

time that this tank is out of service. There norma lly is a loss of available fire protection

water when this tank is out of service. Then there are the hundreds of thousands of utility water systems with only 1 tank. Taking their one a nd only tank out of service, especially just to have it cleaned, is an absolute nightmare. DO NOT TAKE MY WORD ON THIS. SURVEY YOUR UTILITIES. No utility water system any where, at any time, wants to take a tank out of service. Even worse, just to be required to take a tank out of service every 5 years for an unnecessary cleaning is unjust ifiable.

3. Potable water tanks should be required to be ins pected by a professional firm specializing in tank inspections, and not by unqualified firms o r persons with no experience and education whatsoever about tank construction, recoa ting, inspection, or repair. There are currently no minimum requirements whatsoever by any federal regulatory agency for tank inspection companies, and only a few states place a ny kind of requirements for the individuals or firms that inspect tanks in their ju risdiction. No joking, at this point in time, a high school child, postman, plumber, car me chanic, real estate agent, etc., can purchase an ROV for $3,000.00 and start inspecting tanks tomorrow. Although they are completely clueless about what to look for, and wha t they are looking at, they are hired if their inspection price is the lowest bid, and then utility and water consumers and their engineer have to deal with an inaccurate inspection . Not recoating/repairing a tank when it needs it results in the eventual repair/recoat o r even replacement being much more expensive than it would have been. Even worse, an inspection that results in the utility recoating/repairing a tank now when there was no ne ed to this to occur until another 10 to 20 years is a complete waste of the utility funds.

4. The dirt on the tank bottom comes from the water lines supplying the tank. Requiring annual or semiannual flushing of the water lines ma kes much more sense than requiring the cleaning of the tank. Utilities with effective line flushing programs have very little, if any, dirt on their tank bottoms. Flushing the wate r lines prevents the dirt from reaching the tank as well as reducing or eliminating dirty w ater complaints.Conrady Consultant Services

Office of Ground Water and Drinking Water (MC 4607M ) U.S. Environmental Protection Agency October 6, 2014 Page 3 of 3

Please consider the following:

5. Interior protective coatings on steel tanks, and the interior caulking on glass lined bolted steel tanks, deteriorates and fails to the extent t hat repair/replacement becomes necessary in time periods of as little as 10 years or as long as 25 years. Five year inspections determine when these are necessary. Whenever a rep air/recoat is required, the tank is drained, and the contractor cleans the tank as part of the repair/recoat. Please refer to the representative photos.

6. In tanks that previously had water stratificatio n, the installation of either passive or active water mixing systems in tanks has virtually elimina ted the formation of biofilm on the tank walls due to the mixing of the fresh chlorinat ed water with the older non-circulated water. On tanks with adequate circulation and no w ater stratification, we have not

observed formation of biofilm. In either of these cases, there is no need to clean the tank.

7. What our inspections have determined is that the re is considerable risk of tank water

contamination of birds and animals/varmints/snakes being able to enter the tank and that this occurs much more frequently than previously th ought. Water system personnel do not routinely, if ever, climb their tanks to observ e if the overflow pipe screens or vent screens are still effective and not damaged. Healt h officials doing yearly sanitary surveys are not adequately trained, and do not have the app ropriate climbing safety equipment, to climb to the top of a taller, or elevated water tan k to determine the condition of these

screens or if the roof hatches are closed and seale d. This is a major problem and requires regulatory action to prevent this. We have inspected tanks then traveled to a neighboring utility to have lunch because we would not drink their water.

In conclusion, we believe that the EPA should requi re tank inspections to occur at intervals that should not exceed 5 years but not that the tank be cleaned every 5 years. Do not require utilities undergo unnecessary, expensive, and very inconvenie nt and time consuming tank cleaning unless the 5 year inspection determines that cleani ng should be done. EPA should require semiannual or annual water line flushing which prevents any buildup of silt in the tanks and virtually eliminates the need for cleaning.

Instead of being so concerned about cleaning the in significant dirt from the very rare tanks that actually need to be cleaned, EPA should focus on pr eventing water contamination by eliminating access to the tank interior by birds, animals, etc. Want some photos?

Sincerely,

John R. Conrady, P.E.