Tag Archive: Clean

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.

You would think if an inspection of a water storage tank or tower shows a lot of nasty looking sediment in the floor, the tank would be cleaned.  But that is often not the case.  Our company performs water tank inspections with a custom made underwater video camera that enters the tank records the interior roof conditions and then makes its way to the floor of the tank.  The camera sends its video signal to the topside operator who records it on an HD recorder.

When our camera comes back with several inches of soft ugly sediment in the floor of a water storage tank or tower most people would assume that the utility manager would make sure that tank gets cleaned out ASAP.  The fact is most try, if it is a water tower the choice of doing it “In House” may not exist for many small utilities.  Water utility workers are just not trained or equipped to work 150 feet off the ground.  So the operator or utility manager request funds to get the tank cleaned.

Here is where the problem comes in, the city manager, city council or board of directors decide that spending money to clean the inside of a water storage tank or tower may not be a good use of the funds, often they  refuse to look at the inspection video.

While some utilities have good management, more and more are ignoring needed maintenance procedures because of shrinking budgets and bad priorities.  After all what is the most important priority for a water utility anyway?  We have several customers who hire us every year to inspect their water storage tanks & towers and every year we tell them their facilities need to be cleaned.

They tell us that they ask for the funds but are turned down for various reasons year after year.  In Texas, a rule in the Texas Administrative code 290.46 requires water utility operators to inspect their tanks & towers each year.  Many of our customers tell us because of that rule they can get funds to preform the tank inspection, but no requirements to clean the tank means its just not important.  I approach administrators as a contractor and they see me as a guy looking for work and somehow trying to trick them into looking at the inspection video.  This should not be a sales job.  Sediment Builds up in water storage tanks & towers over time,  it has already gone through the water treatment plant, its as clean as it is going to get.  The water goes from that water storage tank to your tap.  If the tank or tower is full of sediment bacteria, protazoa and even viruses can find a safe harbor where they get a foothold in the water system and grow.  Removing the sediment from the floor of the tank removes the habitat that contaminates can hide and thrive it.  Florida has one of the best rules in the country requiring that water storage tanks & towers be cleaned at least once every five years.  The American Water Works Association recommends that water tanks be cleaned every three to five years or as needed.  How long would you use a water glass in your house without washing it?  The City of Arlington Texas was recently ranked the # 1 water in the country.  I happen to know they clean their water storage tanks every year.

Nationally, there are approximately 170,000 public water systems (PWS). These public water systems range in size from large metropolitan areas to rest stops and campgrounds, provided that they meet the public water system definition. The definition of a public water system is a system for the provision to the public of water for human consumption through pipes or other constructed conveyances, if such system has at least 15 service connections or regularly serves at least 25 individuals. Nationally, 22% of the public water systems (approximately 37,000 pws) had violations of the National Primary Drinking Water Regulations in calendar year 1999.  I recently read an estimate that there were more than 400,000 water storage tanks and towers in the U.S.  The majority of them probable need to be inspected, cleaned or both right now.

Isn’t it time we demand clean water for everyone?  Isn’t it reasonable to demand that all water storage tanks & towers be cleaned at least once every five years?  What good is a multi million dollar water treatment plant if the clean pure water is pumped into a forty year old water tower that has never been cleaned?  It is just basic housekeeping, floors need to be cleaned from time to time water storage facilities are no different.  The difference is without a law, a rule a code too many of us are drinking from water tanks that rarely if ever get cleaned.  I think water tank inspections and cleanings should be part of the the National Primary Drinking Water Regulations.  If we had some basic housekeeping in the rules, it may well be that the overall water quality violations greatly decrease because contaminates will routinely be removed from water systems before they become a threat.

For More information on EPA enforcement of the Safe Water Drinking Act Click here  EPA compliance and enforcement of the Safe Water Drinking Act.

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