National Primary Drinking Water Regulations: Finished Water Storage Facility Inspection Requirements Addendum to the Revised Total Coliform Rule.

EPA is planning to propose an addendum to the Revised Total Coliform Rule (RTCR) to strenghten public health protection by including finished water storage facility inspection (SFI) requirements. In the preamble to the July 2010 proposed RTCR (75 FR 40926), EPA requested comment on the value and cost of storage facility inspection and cleaning. (Hide)

EPA received comments regarding unsanitary conditions and contamination that can be found in finished water storage facilities that are not routinely inspected and cleaned, including breaches and accumulation of sediment, animals, insects, and other contaminants. The Agency is developing an SFI proposal in order to allow interested parties to again comment and provide any additional relevant information. EPA is planning to propose and request comment on requirements for public water systems to periodically inspect the interior and exterior of their finished water storage facilities at least and to correct any sanitary defects found. Any potential requirements would apply to all public water systems that have one or more finished water storage facilities. Like the 2013 final RTCR, the proposed storage tank inspection requirements would maintain or improve public health protection by reducing cases of illnesses, and possibly deaths, due to exposure to waterborne pathogens.
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8/15/14 UPDATE:  At a Water Quality Conference in Austin, Texas earlier this month, I spoke to an EPA official who advised me the inspection requirement of the RTCR will stop short of requiring storage tanks to be inspected.  The rule will be implemented by the States and in full effect by 2015.  We may see a wide range of different interpretations as we compare State to State.
Another EPA spokesperson confirmed to me that a water storage tank inspection would be an important part of assessing the system if there would be a violation under RTCR.  In addition, if sediment was found in the storage tank, cleaning the tank and removing the sediment would be considered a corrective action.  The official refused to go on camera and asked not to be named due to EPA rules against speaking for privately owned companies.
This blog will post new developments on the RTCR as news becomes available.

Click here for more information including the proposed time line: Regulatory Development and Retrospective Review Tracker

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Sediment being removed from potable water storage tank 2014. (c) Ron Perrin Water Technologies.

For more information on potable water storage inspection or cleaning see: http://www.ronperrin.com