On behalf of the City of Chesapeake, I would like to submit the following comments:

1)  Definitions:  We recommend clarification of the definition of "community water system" , does this mean an actual treatment system or does it also include the potable water distribution system?

2)  Secondary Containment:  Do the secondary containment requirements for piping (within 1000 feet of a community water sytem) apply to lines which do not hold product and are not ordinarily under pressure such as emergency generators? If so, this is an overly burdensome requirement. We recommend that corrosion proof piping only be required in situations where piping does not typically hold product.

3)  Operator Training Requirements:   We strongly recommend that internet training options be made available which will satisfy the operator training requirements.

9VAC25-580-125 B.1.b. We also strongly recommend that Class A operator training will be deemed to satisfy Classes A, B, and C; and similarly, that Class B operator training will be deemed to satisfy Classes B and C. Class A training should cover all three classes without the need to take multiple training sessions and exams, similar to DPOR licensing for water and wastewater treatment system operators. We recommend that this referenced section be modified or eliminated.