Document RaZYr8zkORzBxLmnRKg492DnB

REPORT OF PUBLIC WATER SYSTEM COMPLIANCE INSPECTION AT Republic County Rural Water District Number 2 1903 North Street, Post Office Box 501 Belleville, Kansas 66935 Public Water Supply ID#: KS2015711 November 4-5, 2025 BY U. S. ENVIRONMENTAL PROTECTION AGENCY Region 7 Enforcement and Compliance Assurance Division (ECAD) INTRODUCTION I conducted a Public Water Supply (PWS) Compliance Evaluation Inspection (CEI) at the Republic County Rural Water District Number (RWD) Number 2 on November 4 through 5, 2025. The inspection was conducted under the authority of Section 1445 of the Safe Drinking Water Act (SDWA) and as part of the EPA's National Enforcement and Compliance Initiative (NECI). The purpose of the inspection was to assess the System's compliance with the SDWA. This narrative report and attachments present the results of the inspection. PARTICIPANTS Republic Co. RWD No. 2 Brian Stindt, Board Chairman - (785) 527-0611, brian.stindt@gmail.com Charlie Vieselmeyer, District Operator (Operator In Charge) Adam Junek, District Operator Dan Moore, District Operator Becky O'Dell, Office Manager Tim Gottschalk, Board Member U.S. Environmental Protection Agency (EPA) Lantz Tipton, Physical Scientist, 913-551-7897, tipton.lantz@epa.gov SYSTEM DESCRIPTION AND COMPLIANCE HISTORY System Description The Republic Co RWD 2 (District) PWS (KS2015711) is classified as a community water system (CWS) that is owned and operated by the Boad of Directors for the District. According to the Kansas drinking water watch (DWW) website the District directly serves a population of approximately 1,293 people through 564 service connections. In addition, the District supplies water to the following consecutive connection systems: City of Agenda City, KS with a population of 44, City of Munden with a population of 99, and the City of Narka with a population of 80. The Village of Cuba formerly purchased water from the District but has since transitioned to an emergency use only connection for the District. The total population served by the District (including consecutive connections) is approximately 1,516 people. According to the Kansas DWW database, the system purchases approximately 40 percent of its finished water from the City of Belleville, KS and produces approximately 60 percent of its finished water. The District's source water consists of two groundwater wells that are owned and operated by the system. The system's average daily demand is approximately 220,000 gallons per day (gpd) with the highest demand being during the summer months with an average of approximately 300,000 gpd. The system can receive 100% of its required water usage from the City of Belleville if needed. System produced water is currently sourced by two active groundwater wells. The system's original wells, designated as Wells #1 and #2, have been appropriately decommissioned. Presently, Wells #3 (referred to as the South Well) and Well #4 (the North Well) are operational. The South Well is equipped with an electric-powered vertical turbine pump and is situated within a secure well house, which also accommodates the chlorine storage and disinfection equipment. Disinfection is conducted at the well house using gas chlorine to ensure a free chlorine residual is maintained. The North Well utilizes an electric submersible pump and is positioned outside the well house. The North Well pumps water to the South Well wellhouse to be blended with the South Well water for chlorine treatment. Both wells are designed to deliver a production capacity of approximately 500 gallons per minute (gpm). The wells are located approximately 11.5 miles north of the City of Belleville. The distribution system contains approximately 550 miles of water lines that consist of polyvinyl chloride (PVC). Water line sizes in the distribution system range from 2", 2.5", 3", 4", 5", and 8". The system has both a valve exercising and flushing program and the distribution system is designated into 4 quadrants (Northeast, Northwest, Southwest, and Southeast) and the distribution system is additionally broken into 24 zones throughout the 4 quadrants. Flush hydrants are installed on every dead-end line of the system, and portions of the system are looped. Isolation valves are located approximately every 2-3 miles. The system has five standpipes located throughout the distribution system that provide a total finished water storage capacity of approximately 215,000 gallons. The system's standpipes and their respective capacity are listed as: The 81 Tower with 84,554 gallons, Norway Tower with 31,649 gallons, Narka Tower with 45,095 gallons, Cuba Tower with 47,562 gallons and Francis Tower with 46,974 gallons. The total storage capacity compared to the average daily demand is equivalent to approximately one day of storage for the system. According to the State of Kansas operator certification requirements (Kansas Administrative Regulation 28-16-33), the District is classified as a Class I system, due to the population served (between 501 and 1,500) and the type of treatment conducted (disinfection of groundwater). The District is operated and managed by a team of three operators. Mr. Vieselmeyer is the designated responsible operator in charge of the system. Two additional operators are employed by the District who assist with the operation and maintenance of the system. 2 Compliance History The Water District was last inspected by the KDHE on September 9, 2024, when a sanitary survey (SNSV) was conducted (Attachment 2). The SNSV report did not identify any significant deficiencies. However, the report identified during the survey that the "Leak loss for the system exceeded 15% for the previous year" and stated that the "The department recommends that leak loss not exceed 15% annually." This issue was discussed with the system during my inspection and is also included as Finding #12 of this inspection report. A review of Kansas DWW website shows that the system has experienced ten (10) Nitrate maximum contaminant level (MCL) violations dating back to October 2021. In 2025, the City of Belleville, that supplies over half of the District's source water, upgraded its treatment plant with an ion exchange treatment system to address their elevated nitrate levels. The KDHE conducted a post construction inspection of the consecutive connection to the City of Belleville's system on August 14, 2024. No additional Nitrate MCL violations have been reported to DWW following the City of Belleville's treatment upgrades, therefore these violations have been returned to compliance (RTC). During the past 5 years, there has been one monitoring violation from the Ground Water Rule (GWR) and one Lead Consumer Notice violation. According to DWW each of these violations have been RTC'd. I asked if the system has had any boil water advisories (BWA) in the last 5 years and Mr. Junek explained that there has not been any system wide BWAs. He explained that the District does provide customer specific advisories for service connections that are required to be turned off to conduct system maintenance or repairs. He explained that these customer notices are provided verbally or with door hanger information to notify the customer of the loss of pressure. NOTICE OF INSPECTION State Notice On September 3, 2025, Kansas Department of Health and Environment staff were notified, in writing, of the EPA's intention to inspect the Republic Co. RWD 2's PWS. This notification was conducted pursuant to Section 1445(b)(2) of SDWA, 42 U.S.C. 300j-4(b)(2). Public Water System Notice On October 22, 2025, Mr. Stindt, the Board Chairman for the District was contacted by telephone and notified via email (Attachment 3), of the EPA's intention to conduct the inspection. This notification was conducted pursuant to Section 1445(b)(1) of SDWA, 42 U.S.C. 300j-4(b)(1). INSPECTION PROCEDURES Information Request On October 22. 2025, as part of the inspection notification, I emailed the system and requested the following information in order to prepare for the inspection. The information requested consisted of the following: well maintenance records, cross connection program records, valve exercise program records, flushing program records, chlorine residual logs, system maps and 3 schematics, lead service line inventory, lead and copper sampling pool, boil water advisories/orders (if applicable), 4-log certification and contact time calculation records (if applicable), chemical application records, a demonstration of technical managerial, and financial information, water loss calculations, finished water storage structure inspection reports, responses to state sanitary surveys, and available emergency plans or procedures. The requested information was either provided prior to or during the inspection as requested. The information provided as part of this inspection is maintained the Enforcement and Compliance Assurance Division Facility Site Files. Opening Conference On September 4, 2025, I arrived at the District's office building at approximately 9:00 a.m. and met with Mr. Stindt, Mr. Vieselmeyer, Mr. Junek, Mr. Moore, Mr. Gottschalk, and Ms. O'Dell from the District. During the opening conference, I introduced myself and presented my EPA inspector credentials. I explained that I was there to conduct a compliance inspection of the District's water system and to evaluate the system's compliance with the SDWA. I also explained the scope of the inspection, which would include an onsite review and discussion of the records and processes previously requested, in the inspection notification email, along with a visual inspection and observations of the PWS's facilities and components. I began the in-person inspection with a review of the system's records. Following the records review, I inspected the system's components including the source water wells, the treatment building, and the finished water storage structures. After inspecting the facilities, I conducted an exit conference with the system to discuss the preliminary findings of the inspection. FINDINGS AND OBSERVATIONS During the inspection, 19 photographs were taken. The photographs taken during the inspection and the photograph log are included as Attachment 1 of this report. The following findings were noted during the inspection and were discussed with the system during the exit meeting prior to the conclusion of the inspection and provided to the system in the Notice of Preliminary Findings (NOPF) included as Attachment 4. This narrative inspection report provides a summary of the observations and findings identified as a result of the compliance inspection. American Water Infrastructure Act (AWIA) Based on the population served (<3,300) people, the system is not required to meet the requirements of SDWA Section 1433. However, the system's security (including cybersecurity) and emergency measures were discussed and no issues were noted. Source Water As noted in the system description, the Republic Co. RWD #2 is served by two active ground water wells and also obtains approximately 60% of its water from the City of Belleville's treatment system. During the inspection, the District staff explained that since the City of Belleville completed the upgrade of their treatment plant, the District's Nitrate MCL Violations have ceased. The District provided a copy of the "Water Purchase Agreement" between the City of Belleville and Rural Water District No. 2, Republic County. According to the agreement, the 4 District agreed to purchase a minimum of twenty-five million gallons and up to fifty million gallons of water annually. According to District staff, this volume from the agreement in addition to the volume supplied by the District's wells provides an adequate source volume to meet the current and future source water needs of the system. In addition, the agreement provides that, "The Treated Water shall have a nitrate level as low as can be reasonably attained by the treatment plant. The expected Treated Water nitrate level will be below 1 ppm (part per million)." The agreement appears to ensure that at least 60% of the water supplied to the system is below the Nitrate MCL of 10 ppm or milligrams per liter (mg/L). During the inspection, I observed each of the active wells. Mr. Vieselmeyer explained that the wells are visually inspected each day and readings and measurements (Photograph #4) are recorded on the daily log. The South Well (Well #3) was observed first, and it was located inside a physically secure, structurally sound, and temperature controlled well house. Water was observed on the floor of the well house and corrosion was noted on the well plumbing and piping (Photograph #3). This issue was listed as Finding #1 of the NOPF provided to the system and discussed during the exit conference. Leaking water in the building and on the plumbing surfaces can lead to an environment that allows or encourages corrosion. Leaks should be repaired to prevent water loss and to ensure a dry environment in the well house. In addition, the raw water sample tap was observed to have a threaded opening and was not a smoothed nosed sample tap. This issue was noted as Finding #2 in the NOPF. According to Kansas Minimum Design Standards, "Smooth-nosed sampling taps shall be provided, for control purposes, for each raw water source", in addition the Design Standards also reference the following American Water Works Association information, "AWWA Standard C651-05 recommends the use of a specially installed sampling tap consisting of a smooth, unthreaded, 0.5-inch hose bib". Therefore, the threaded sample tap should be replaced with a smooth nosed sample tap as required by the State's design guide. The North Well (Well #4), a submersible pump, was located outside of the treatment building. I noted that the well had adequate physical protection with concrete posts, the well vent cap was securely bolted (Photograph #5) and the well screen intact. The concrete pad for the well had a large crack through the center of the pad and tall vegetation had grown up around the well pad. These issues were listed as Findings #3 and #4 on the NOPF. The well pad should be stable to prevent settling or expansion of the pad that could affect the well's operations. Vegetation should be controlled around the well to prevent rodents or other small animals from nesting near the well structure. In addition, I also observed that the pressure gauge for the well was inoperable. This Finding was listed as Finding #5 in the NOPF. Pressure gauges are important for ensuring proper pumping and operating pressures are maintained in order to supply water to the distribution system. The District does have a Water Conservation Plan that was developed in 2012; however, District staff explained that they have not had to implement any measures from the plan. In addition, the District explained that they have a contract with Sargent Drilling who performs well and pump tests annually and the wells were last inspected in January 2025. The well company provided a report to the District that both wells were operating properly. Below is an excerpt from the well company's report: "North Well: The average pump efficiency is 66%, this is excellent. The well is producing 123 gallons of water per foot of drawdown. This is down from the last test. 5 The flow meter registers 6% high. South Well: The average pump efficiency is 69%, this is good. The well is producing 126 gallons of water per foot of drawdown. This is down from the last test. The electric motor was serviced and the packing was greased." Treatment As noted in the system description, the system's only treatment includes disinfection using gas chlorine. I inspected the District's chlorine storage room and chlorine injection equipment at the South Well House (Photograph #1). The chlorine storage room, and injection components appeared well maintained and in proper operating condition. Distribution System As part of the inspection of the system's distribution system, I reviewed the District's pollutant monitoring plans, the initial service line inventory, cross connection control program, flushing program, valve exercise program, and water loss information. Monitoring Plans During my record review, I asked facility personnel for the system's Revised Total Coliform Rule (RTCR), Lead and Copper Rule (LCR) and Stage 2 Disinfection Byproducts (DBP) Rule sampling plans. All three plans were available for my review at the time of inspection. All three of the system's sampling plans appeared to be complete and adequate to the requirements. Lead and Copper I reviewed the system's service line inventory and the system's 2023 Lead & Copper Sampling Pool. Information from the inventory noted that the system had not identified any service lines, water mains, or gooseneck connections that were composed of or constructed with lead materials in the distribution system. Of the 565 service connections listed in the inventory, there were 296 customer service connections listed or categorized as "Lead Status Unknown". The District provided consumer notification to each of the service connections identified as "Unknown" within 30 days of submitting the Inventory and certified to the State that the notifications were made. I explained that the District should continue to identify the materials of the "unknown" service connections, and that annual consumer notification is required until the service line materials are identified. This issue was listed as Finding #13 in the NOPF. Mr. Junek explained that the District did not currently have a plan to evaluate and identify the unknown service connection materials. I explained that further evaluation could be conducted in multiple ways including customer surveys, visual inspection, or possibly consulting with the Kansas Rural Water Association. The system directly serves a population of approximately 1,293 and is on a reduced monitoring schedule and therefore is required to collect a minimum of 10 samples from the system. The system's last lead and copper sampling event was conducted in July 2023. The results of the LCR sampling recorded the copper 90th percentile level at 0.73 mg/l and the lead 90th percentile as 0.0033 mg/L, both of which are below the Action Levels for the respective parameter. There were no Action Level Exceedances (ALE) identified in DWW dating back to at least 2002. The 6 system's 2023 Lead & Copper Sampling Plan identified 10 tier 3 sites and 4 additional sample sites. The plan appeared to properly list the tier associated with the service connection's plumbing type. Lead and copper samples are collected by the customer from the customers tap. In addition, the District staff provided me with the customer sampling instructions, sample results, and notification to customers of sample results for review. These records appeared well organized and readily available. Cross Connection Control I reviewed the system's cross connection control program records including the District's cross connection control regulation. The District's cross connection control program's regulation had been developed and approved by the KDHE in October 1991. The regulation appeared thorough and adequate to meet the requirements of Kansas cross-connection control regulation K.A.R. 2815-18f. I requested a list of all service connections served by the District that required a backflow prevention device. According to District staff, they were not aware of any connections in the District that would be considered high hazard connections or that would require back flow prevention. District staff explained that the system serves an agrichemical facility, but the facility has its own wells that are used for mixing chemicals. I explained that according to the District's cross connection program regulation the following facilities are identified as high hazard connections that may require a backflow prevention device: 1) Agricultural chemical facilities, 2) Auxiliary water system (wells), 3) Boilers, 4) Bulk Water Loading Facilities, 5) Carwash or Truck washing facilities, 6) Chemical manufacturing, processing, compounding or treatment plants, 7) Chill water systems, 8) Cooling towers, 9) Feedlots, 10) Fire protection systems, 11) Hazardous waste storage and disposal sites, 12) Hospitals, mortuaries. clinics or others, 13) Irrigation and sprinkler systems, 14) Laundries and dry cleaning, 15) Meat processing facilities, 16) Metal manufacturing, cleaning, processing and fabricating plants, 17) Oil and gas production, refining, storage or transmission properties, 18) Plating plants, 19) Power plants, 20) Research and analytical laboratories, 21) Sewage and storm drainage facilities -- pumping stations and treatment plants, and/or 22) Veterinary clinics. I explained that the system should evaluate the connections served by the District and if the District serves any of these types of facilities, they should be included in an inventory of highhazard connections and evaluated for the need for backflow prevention. This issue was cited as Finding #11 of the NOPF, which states: "Develop a list of high hazard connections (if any) served by the District to include types of hazards listed in `Section IV. Survey and Investigations of the District's Cross Connection Ordinance. Track installation, testing, and inspections of connections with backflow prevention devices." Valve Exercising and Flushing Programs During the inspection, the District's valve exercise program and processes were discussed. The District explained that they do have a program, and the system is broken into 4 quadrants and staff plan to exercise one quadrant per year. Mr. Junek explained that valves are regularly exercised when staff are searching for or repairing leaks. In addition, he explained that the distribution system is broken into 24 zones and their plan calls for the system to exercise two zones worth of valves each month, cycling through all of the valves every two years. He explained that the District has an adequate number of valves to isolate all areas of the system necessary to conduct maintenance and repairs and that the system primarily has valves located 7 every 2 miles with a few remote areas having valves every 3 miles. Records of valve exercising activities are documented on operator log sheets (Attachment 5). We also discussed the system's flushing program. The District staff explained that the system does not have fire hydrants, but flush hydrants located throughout the system. System personnel explained that they try to flush all hydrants in the system every spring and every fall. The system notifies the public with a notification flyer and flushes from the center of the distribution system out to the edges. In addition, District staff also explained that the system is moving to a digital mapping system of the valves, meters, water lines, etc. of the system a global positioning system (GPS) and that the Kansas Rural Water Association is assisting with that project. Water Loss For water loss information, I reviewed the system's water use report from 2025. The system conducts annual water loss evaluations that are included in the annual water use reports that are reported to Kansas Division of Water Resources. The system's overall unaccounted for water loss in 2025 (through September) was calculated at 48% of the total water produced. In 2024, the total water loss % was calculated at 37%. This finding was listed as Finding #12 on the NOPF provided to the system at the close of the inspection. I asked if there were other areas in the system where water could be utilized that is unaccounted for and the District staff were unaware of any. Waterloss is calculated by comparing gallons pumped and purchased against gallons of water sold. District staff explained that other areas of water loss could be associated with leaks in the distribution system and unpaid customer water bills. They explained that the system has been in place for approximately 50 years and that PVC water lines sit on rocks and this can cause leaks in the system. District staff explained that they have an active leak detection program that involves listening to valves, receiving and responding to low pressure calls from customers, and receiving and responding to tips, concerns, or leak calls from customers. The District explained that they actively work with customers with unpaid water bills to have them paid. Water loss greater than 15% is considered significant by the KDHE and was previously cited in the State's 2024 sanitary survey. Finished Water As noted in the system description, the District has five standpipes that are used for finished water storage. The standpipes are located throughout the distribution system and the system's pressure is gravity fed throughout the distribution system from these structures. The District has an inspection and maintenance schedule with Viking Industrial Painting (Attachment 6) from 2025 through 2033 to inspect the structures and clean and complete repairs of identified issues. The contractor performed an inspection of each of the standpipes in March of 2025. I visually inspected each of the District's finished water storage structures from the ground level. The standpipes are not located inside areas with security fencing, but Mr. Vieselmeyer explained that the standpipes are in remote areas and are visually inspected at least weekly. There were several issues noted with the District's standpipes that were included as Findings #6 through #10 of the NOPF. These findings included: 8 Finding #6 - The exterior paint of the 81 Tower was flaking and peeling (Photograph #8). District staff explained that this standpipe was painted less than 1 year prior and is working with the contractor to explore warranty coverage to correct the issue. Finding #7 - There was no splash pad located under the overflow of the 81 Tower (Photograph #7). Splashpads are important to prevent erosion near the base of the standpipe and to ensure stability of the base. Finding #8 - The overflow of the Francis Tower (Photograph #11) and Norway Towers were not extended down to 12 to 24 inches above ground level as required by the KS Minimum Design Standards. Overflows shall be located 12 to 24" above ground level to allow for inspection to ensure insects or animals are not allowed to enter overflow or the standpipe. Finding #9 - While observing the standpipes' concrete bases, there were various levels of cracking or pitting noted of concrete bases of the Francis Tower (Photograph #10), Norway Tower (Photograph #13), and Narka Tower (Photograph #16). Finding #10 - In addition, there was a leak noted in the altitude valve pit of the Cuba Tower. These findings were discussed with District staff during the exit meeting at the close of the inspection. Mr. Vieselmeyer explained that the leaking valve would be repaired immediately, and the other issues would be discussed with the Board and the inspection company to determine which repairs would be the priority. I reviewed the 2025 inspection reports for the Norway and Narka Towers, reports for the remaining standpipes were not available for review. The primary issues noted in the 2025 inspection reports included the hatch of the Narka Tower not closing properly and being wired shut and not securely locked and the overflow of the Norway Tower not being extended to 12-24 inches above the ground surface. District staff explained that the issues identified in 2025 were being evaluated and repair priorities established. The Narka Tower hatch was identified in the NOPF and is being added to this inspection as Finding #14. The access hatches of the standpipes must be locked to prevent unauthorized access. Operations and Management The Water District is owned and operated by the Republic County RWD No. 2 Board of Directors. The District creates an annual budget and Mr. Gottschalk explained that the system has a necessary budget to cover parts and that large purchases (no set amount) do require a `Board Approval', but operators can call the Board and get quick approval with a majority vote. The system has an emergency water supply plan that it can initiate if necessary. The District also has a Capital Improvement Plan with current and future priorities established. With current priorities being upgrading the District's finished water storage structures and improving their water loss. As noted previously the high water loss is believed to be primarily from leaks and unpaid customer billing. According to Mr. Vieselmeyer, the system has adequate staffing and equipment to operate and maintain the system. In addition, the District's financial statements demonstrate that system appears to be financially stable with adequate rates to cover operation and maintenance of the system. 9 SUMMARY AND CONCLUSION The following findings were discussed with facility personnel during the exit briefing at the end of the inspection. The NOPF was emailed to the District on November 5, 2025. The District signed the NOPF and returned it to me on November 18, 2025 without any additional information or responses to the Findings discussed during the inspection or in the NOPF. Findings 1) Corrosion of piping of the South Well (Well #3). Ensure painting of pipe surfaces is conducted and consider dehumidification in the well house to prevent corrosion of piping. 2) Threaded sample points on South Well. 3) Tall vegetation surrounding the North Well (Well #4). 4) Large crack in the concrete well pad of North Well. 5) Pressure gauge inoperable on North Well. 6) Exterior paint peeling off the 81 Tower. 7) No splash pad under the overflow of 81 Tower. 8) Overflow not extended to 12-24" above ground at the Francis Tower and Norway Tower. 9) Cracking of concrete based of the Francis Tower, Norway Tower, and Narka Tower. 10) Leak noted in the altitude valve pit of the Cuba Tower. 11) Develop a list of high hazard connections (if any) served by the District to include types of hazards listed in "Section IV. Survey and Investigations" of the District's Cross Connection Ordinance. Track installation, testing, and inspections of connections with backflow prevention devices. 12) Water loss calculation greater than 15% (53% in August 2025) - The District should account for and track all unsold water usage (pump to waste, unmetered water usage, plant usage, etc.) and incorporate into water loss calculations. 13) Continue activities to identify "Lead Status Unknown" service connections identified in the Initial Service Line Inventory. 14) *As noted in the 2025 inspection report, the access hatch of the hatch of the Narka Tower was not closing properly, was "wired" shut, and not securely locked. 10 * This Finding was not noted on the NOPF and identified after the onsite inspection was completed. * LANTZ LANTZ TIPTON Digitally signed by _T__IP___T_O___N___0_7_:2_0_:1_6_-_0_6'_00_' Date: 2026.01.13 Lantz Tipton Physical Scientist, WB JODI Digitally signed by JODI BRUNO B__R__U__N___O___0_8_:2_9_:_4_0_-06'00' Date: 2026.01.13 Nicole Moran Supervisor, WB/DWIS ATTACHMENTS: 1. Photolog and Digital Photographs (20 Pages) 2. KDHE 2024 Sanitary Survey (3 Pages) 3. Inspection Notification Email (3 Pages) 4. Signed NOPF (2 Pages) 5. Operator Valve Exercise Log Sheets (4 Pages) 6. Finished Water Storage Inspection and Maintenance Agreement (1 Page) 11 United States Environmental Protection Agency - Region 7 1. Facility Name: Republic County Rural Water District 2 2. PWS ID #: KS2015711 4. Photographer (if Different): N/A 6. Street Address of Digital Images: Multiple Locations 10. Image Numbers: 1 - 19 Digital Image Log 3. Inspector Name: Lantz Tipton 5. Date of Inspection: 11/4-5/2025 7. City: Belleville 8. State: KS 9. Zip: 66935 11. File Name: IR.WB.FY26.KS.Republic Co RWD 2 Digital Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 File Name IMG_0931.JPG IMG_0932.JPG IMG_0933.JPG IMG_0934.JPG IMG_0935.JPG IMG_0936.JPG IMG_0937.JPG IMG_0938.JPG IMG_0939.JPG IMG_0940.JPG IMG_0941.JPG IMG_0942.JPG IMG_0943.JPG IMG_0944.JPG IMG_0945.JPG IMG_0946.JPG IMG_0947.JPG IMG_0948.JPG IMG_0949.JPG Description Storage room for gas chlorine cylinders and chlorine feed system with scale and ventilation system South Well with pump motor, casing vent, concrete well base, and pressure relief valve screened discharge line. Note corrosion on piping View of South Well piping Operator's daily log for October 2025 North Well - submersible pump with cracked concrete pad and tall vegetation surrounding View of the exterior of the South Well house 81 Tower -overflow discharge outlet with screen and without splash pad 81 Tower exterior paint peeling after being recently painted View of the Francis Tower adjacent to communication tower Mildew accumulation on exterior paint and cracks in the concrete base of the Francis Tower Francis Tower exterior - note the overflow is screeded but not extended to ground level Additional view of Francis Tower exterior Norway Tower concrete base with cracks and pitting around the foundation bolts Norway Tower altitude valve pit Cuba Tower overflow extended to 12-24" above the ground with screen Narka Tower drain valve and concrete base with cracking Narka Tower overflow with screen note calcium accumulation on the overflow screen Narka Tower concrete base with minor cracking Narka Tower altitude valve vault with leak observed Date and Time Digital Image Taken 2025:11:04 11:07:05 2025:11:04 11:09:41 2025:11:04 11:09:44 2025:11:04 11:14:15 2025:11:04 11:24:05 2025:11:04 11:26:43 2025:11:04 11:34:58 2025:11:04 11:35:35 2025:11:04 11:53:34 2025:11:04 11:53:58 2025:11:04 11:58:16 2025:11:04 11:58:18 2025:11:04 12:20:20 2025:11:04 12:20:31 2025:11:04 12:55:18 2025:11:04 13:14:44 2025:11:04 13:15:04 2025:11:04 13:15:10 2025:11:04 13:17:41 Number Photo 1 Storage room for gas chlorine cylinders and chlorine feed system with scale and ventilation system IMG_0931.JPG 2 South Well with pump motor, casing vent, concrete well base, and pressure relief valve screened discharge line. Note corrosion on piping IMG_0932.JPG 3 View of South Well piping IMG_0933.JPG 4 Operator's daily log for October 2025 IMG_0934.JPG 5 North Well - submersible pump with cracked concrete pad and tall vegetation surrounding IMG_0935.JPG 6 View of the exterior of the South Well house IMG_0936.JPG 7 81 Tower -overflow discharge outlet with screen and without splash pad IMG_0937.JPG 8 81 Tower exterior paint peeling after being recently painted IMG_0938.JPG 9 View of the Francis Tower adjacent to communication tower IMG_0939.JPG 10 Mildew accumulation on exterior paint and cracks in the concrete base of the Francis Tower IMG_0940.JPG 11 Francis Tower exterior - note the overflow is screeded but not extended to ground level IMG_0941.JPG 12 Additional view of Francis Tower exterior IMG_0942.JPG 13 Norway Tower concrete base with cracks and pitting around the foundation bolts IMG_0943.JPG 14 Norway Tower altitude valve pit IMG_0944.JPG 15 Cuba Tower overflow extended to 12-24" above the ground with screen IMG_0945.JPG 16 Narka Tower drain valve and concrete base with cracking IMG_0946.JPG 17 Narka Tower overflow with screen note calcium accumulation on the overflow screen IMG_0947.JPG 18 Narka Tower concrete base with minor cracking IMG_0948.JPG 19 No changes were made to the original image files Narka Tower altitude valve vault with leak observed IMG_0949.JPG