From my conversations with others in the industry this is what

their concerns are for storage tanks.

None of the tools that are outlined below have worked to get PWSs to

clean their tanks every 5 years.  Unfortunately, it comes down to the

personal preference of each PWS’s Manager whether the tank is cleaned on

a schedule recommended by guidance.

Some manager’s religiously clean their tanks every year, or every three years but for others, it never

occurs to them to clean their tanks.

This is unacceptable and can

sicken hundreds and cause fatalities.  Because nothing has worked, it is
vital for the protection of public health to create a regulatory (not
guidance) back stop that any system that has not cleaned and inspected
their storage tanks in the last 5 years would incur a violation.  This
is not a burden to those PWSs that have done what is right and followed
guidance but it does provide equal public health protection for those
who have not followed guidance.  We need to ask ourselves, where will
the next waterborne disease outbreak, like Alamosa occur?   In Alamosa,
one person died and 1300 others were sickened in a waterborne disease
outbreak that was caused due to neglect of their storage tanks – this
was completely preventable.  This person died needlessly.  Create a
regulatory backstop to prevent waterborne disease outbreaks from ever
occurring from such a preventable cause.

AWWA guidance and EPA whitepapers do not work to get PWSs to clean their
tanks every 5 years!

AWWA Manual M42 recommends tanks be drained, inspected and cleaned at
least every 3 years.  This same recommendation is reflected in EPA’s
Whitepaper on Finished Water Storage Tanks.  Kirmeyer, one of the
industry’s most  knowledgeable persons on storage tanks and water
quality, recommends tanks be drained, cleaned and have a comprehensive
inspection every 3  to 5 years.  These recommendations are ignored and
unknown to most PWSs.  They are recommendations, they are nice to do and
as a consequence, tanks are not cleaned and inspected and that’s why we
continue to find feet of sediment inside of tanks.  They don’t realize
the public health significance that sediment and holes large enough to
allow birds, rodents and insects into their tanks can have, it can lead
to waterborne disease outbreaks.  Salmonella can last for months in a
wet environment.  Clearly guidance does not work to get PWSs to clean
their tanks every 5 years.  We need a regulatory backstop to get PWSs to
do what is right for public health protection.  This does not need to be
delayed to study this to death, this is one of the most simple and
practical ways to protect public health.

None of the 50 states use their Significant Deficiency authority in
sanitary surveys for ground or surface water to clean their tanks every
5 years

None of the states have “not cleaning and inspecting their tank within
the last 5 years” as an item on their list of significant deficiencies.
The reason is States don’t realize the public health significance of
sediment buildup and/or the significance of breaches to a storage tank.
That is why cleaning and inspection is not on State’s significant
deficiency lists for sanitary surveys.  When you have both sediment
buildup and breaches, that is a fatal combination, and what causes
waterborne disease outbreaks like in Alamosa, Colorado.  One person died
from this Salmonella waterborne disease outbreak in Alamosa, he died,
from something that is totally and completely preventable.  There is a
class action lawsuit ongoing at this time.   You may justly ask why
aren’t we having waterborne outbreaks at more systems?  Because along
with sediment buildup and holes you need an event that would scour this
disease laden sediment into the distribution system.  Unfortunately,
that event that would awake this sleeping giant of a public health
concern is uncontrolled (e.g., fire flow, poor operation, power outages,
etc.) and that is completely unpredictable.  Gideon, Missouri had holes
that allowed salmonella contaminated bird feces into their tank but, it
was not until they underwent a flushing program that accidentally
drained their tank and flushed contaminated sediment into their
distribution system that the outbreak occurred.  This series of events
that led to hundreds of illnesses and 7 deaths stands ready to occur
again at hundreds of PWSs across the country.  EPA you have given the
drinking water industry a tremendous opportunity to prevent hundreds of
serious illnesses and fatalities from occurring from something the
industry already recognizes is vital to perform by creating a regulatory
backstop.  But, and I can not say this strongly enough, if you are
relying on significant deficiencies to achieve this goal it is not and
will not work unless there is a regulatory back stop.

State regulations that require PWSs to inspect their tanks only do not
work to get PWSs to clean their tanks every 5 years!

In the State of Texas where they have regulations that require PWSs to
have yearly inspections do not clean their tanks even when provided
overwhelming video and picture evidence of the sediment buildup.  They
don’t clean their tanks because they are not required to.  It is
impossible to inspect the floor of a tank when the sediment is not
removed.  The State of Wisconsin has recommendations for inspection
every 5 years, yet in the City of Brookfield two tanks were last cleaned
at a frequency of 7 years with 4 to 12 inches of sediment and another at
a 15 year frequency with 28 inches of sediment.     Clearly regulations
and recommendations to inspect only do not work to get PWSs to clean
their tanks every 5 years.  We need a regulatory backstop to get PWSs to
do what is right for public health protection.

State recommendations to inspect and clean their tanks do not work to
clean tanks every 5 years

Recommendations are largely ignored by PWSs.  Actually it’s much worse,
PWSs don’t even know these recommendations exist.  For example in the
State of Minnesota they had recommendations that stated ” All water
storage tanks should be inspected, cleaned and disinfected on an annual
basis.  Cleaning and disinfection should take place more frequently when
there have been identified water quality issues”.  The City of Moorhead,
one of the largest PWSs in the State, was unaware of any such
recommendation.  Recommendations to inspect and clean do not work to get
PWS to clean their tanks every 5 years.  We need a regulatory backstop
to get PWSs to do what is right for public health protection.

Protect public health over politics

Many agencies purporting to protect small systems (e.g., Rural Water,
RCAP, etc.) from the high costs of regulations are the very same systems
with the highest levels of sediment and most significant holes in their
storage tanks.  Many of these small systems can clean their tanks by
themselves with their own staff and fire hoses.  If these agencies were
truly helping these systems they should be assisting them to comply with
industry guidance of cleaning their tanks every 3 years.  If this were
the case such agencies would be able to say don’t worry about a
regulation to inspect and clean your tank it will never apply to you
because we ensure your tank in cleaned every 3 years.   The cost of a
cleaning a storage tank does not compare to the cost of a waterborne
disease outbreak and defending yourself from class action lawsuits.