The EPA is considering requiring ALL POTABLE WATER STORAGE TANKS in the U.S.A. TO BE INSPECTED AND CLEANED.

The EPA is considering requiring ALL POTABLE WATER STORAGE TANKS in the U.S.A. TO BE INSPECTED AND CLEANED.

Ron Perrin in Washington D.C. on 10-14-14 to attend EPA meeting

Washington D.C. 10-14-14

 

On October 15th 2014, the EPA held a public meeting in regards to Distribution System Storage Facility Inspection and Cleaning. I attended that meeting in person to express my opinion on this issue. During the meeting a couple of surprising things were revealed. Many were under the impression that water tanks and towers were already being inspected during Sanitary Surveys performed by state regulators, when in fact most, if not all, state agencies do not allow their employees to climb to the top of water tanks and towers.  The few states that climbed the towers in the past did not do an internal inspection of the facility.

A survey had been sent to state regulators to get their opinion on this issue. About half thought a regulation would be a good idea, the other half thought a paper on guidance would be sufficient. I went away from the meeting more convinced than ever that there should be a national regulation requiring all potable water storage tanks to be inspected and cleaned on a regular schedule.

The webinar is over but the EPA is still taking comments until the end of 2014. If you would like to make a comment on this issue, please send an e-mail to:  SFIWebinar@cadmusgroup.com.  Or take the poll below and I will send in the results at the end of the year. This is a chance to let your opinion be known!

My customers tell me they need less chlorine to meet water quality standards after I remove the sediment from their water storage tanks and towers. Sediment enters the tank one particle at a time and eventually accumulates enough for bacteria, protozoa and even viruses to use it as a habitat to grow and become a serious health problem. If proper inspections are not done to determine sediment levels, corrective action is seldom, if ever, taken. My opinion is that potable water storage facilities should be inspected inside and out every year, and a cleaning program to ensure tanks and towers are cleaned every 3 to 5 years should be in place on all tanks. What do you think? Take THE POLL BELOW and also visit http://www.tankdiver.us.

10-14-14 Washington D.C. Mall

 

 

 

 

 

 

 

This is important!  Please SHARE OUR POLL!

 

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Topic: Distribution System Storage Facility Inspection and Cleaning

Background: The United States Environmental Protection Agency (EPA) Office of Ground Water and Drinking Water announces a public meeting and webinar on distribution system storage facility inspection and cleaning. The purpose of the meeting and webinar is to gather input and information from the public and stakeholders on the appropriate frequency of distribution system water storage facility inspection and cleaning, current practices, and the risk management approaches that can be taken to assure that inspection, cleaning and corrective action occur as necessary to help maintain facility integrity and finished water quality. The presenters and panelists will provide background information concerning storage facility inspection and cleaning, existing state programs and available guidance documents. For additional background information, please refer to the Federal Register notice published on Thursday, September 4, 2014 (79 FR 52647).

Public Comments: This meeting is open to the public. EPA encourages public input and will allocate time on the agenda for public comment. To ensure adequate time for public involvement, individuals or organizations interested in making a statement should mention their interest when they register. All presentation materials and statements should be emailed to SFIWebinar@cadmusgroup.com by October 8, 2014, so that the information can be incorporated into the webinar as appropriate. Only one person should present a statement on behalf of a group or organization, and statements will be limited to five minutes. Availability to make public comments will be provided on a first-come, first-served basis in the time available. Additional comments from attendees who did not pre-register to make comments will be taken if time permits. Comments, written statements, data or information can also be sent to SFIWebinar@cadmusgroup.com after the public meeting and webinar.

 

1. Background

In the Federal Register notice for the proposed Revisions to the Total Coliform Rule (75 FR

40926, July 14, 2010), the EPA requested comment on the value and cost of periodic distribution

system storage tank inspection and cleaning. The EPA received comments regarding unsanitary

conditions and contamination that can be found in storage facilities, which are not routinely

inspected and cleaned, including breaches and accumulation of sediment, animals, insects and

other contaminants. Some commenters suggested the need for a Federal regulation requiring

systematic inspection and cleaning because the existing practices are not successful in all cases.

Others suggested that regular sanitary surveys conducted by States and the adherence to existing

industry guidance could resolve such issues. The comments can be reviewed in the docket for the

rule at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2008-0878-0283. This

meeting and webinar and the subsequent opportunity to submit comments are intended to collect

more data and information about the frequency of distribution system water storage facility

Page 4 of 4

inspection and cleaning and the need for more or better risk management approaches.

Dated: August 25, 2014.

Eric Burneson,

Acting Director,

Office of Ground Water and Drinking Water.

BILLING CODE 6560-50-P

[FR Doc. 2014-21073 Filed 09/03/2014 at 8:45 am; Publication Date: 09/04/2014]

All water tanks accumulate sediment over time.

All water tanks accumulate sediment over time.  The soft sediment in the floor of water tanks and towers becomes a safe habitat for bacteria, protozoa and even VIRUSES!   *** see reference at bottom of the page.

Out of sight out of mind-

No one thinks about the sediment.   Most have no idea it is even there.

Not the water utility administrators, not the mayor not the elected city council members.  Many times elected officials vote to clean or  repaint the exterior of a water tower and never consider the inside condition.  The popular view is that Pure Treated drinking water is pumped into the water storage tank or tower where it is held, until the end user opens a tap at their kitchen sink and gets a glass of crystal clean water.

The Truth-

All water distribution systems accumulate sediment in tanks over time.

The water is often tested daily, if the chlorine residual goes down – operators do not ask why, they just add more chlorine, over time the additional chlorine breaks down and itself becomes a contaminate in the tank that can cause cancer.   *** See References below

Instead of constantly adding more and more treatment chemicals, simply cleaning the sediment from the floor of the tanks is the solution.

A countless number of biological contaminates can use the sediment in the floor of water tanks and towers to get a foot hold in a municipal drinking water system and grow into a real health concern.  Why should we care what is on the bottom of a water storage tank?

We drink off the bottom of water storage tanks!  Of course like many things the adverse health effects are unequally distributed to poor communities where drinking store bought bottled water is not a given, It is also these communities who have underfunded water systems that suffer from lack of maintenance.

Many utility systems that can afford inspection and cleaning of their systems simply do not allocate the funds for it because there are no regulations requiring them to do so.

In Texas yearly inspections of water storage tanks and towers are required.

Tanks get inspected in Texas.  The problem in this state is there is no rule or regulation requiring tanks to be cleaned. So while thanks get inspected every year,  most are seldom if  ever cleaned.

The AWWA (American Water Works Association)  recommends that water storage tanks be cleaned every 3 to 5 years or as needed.  The EPA has published multiple white papers about contamination public water systems and the importance to keep tanks free of sediment.

Few ever read EPA white papers and AWWA recommendations are largely ignored when there are no rules or regulations backing them up.

Of course there is always someone who is doing the right thing out there, just because it is the right thing to do.  In this case that would be the City of Arlington, Texas.

According to surveys conducted by the Environmental Working Group, Arlington, Texas has The best water in the United States, probably making it the best water in the world.  Arlington is located in the middle of the DFW metroplex getting its water from the same source as 50 other systems.   The water is treated in two water plants using similar treatment chemicals and methods as surrounding systems.

What sets them apart?  For the past 18 years But they  have made a commitment to keep their tanks clean,  Every year a Potable Water Dive crew is contracted to vacuum the tanks clean while they remain full of treated drinking water.    The divers literarily clean dust from the floor of water storage tanks, while surrounding cities allow multiple inches to accumulate before cleaning.

Too many water utilities in this country have no idea how much sediment if  any  is in the floor of their water storage tanks because they have never hired an inspection crew with underwater cameras to check it out.  It is never thought of so they stay caught in the cycle of adding more and more treatment chemicals when contamination is detected.

Lack of regulations in this overlooked undervalued part of our infrastructure is needlessly putting millions of people at risk for illness, cancer and even death.  When the solution is as simple as cleaning the floor of a storage area.  It just so happens that this area stores water, and it is often 150 foot or more up in the air.

The City of Arlington has proven the effectiveness of keeping water storage tanks clean,

According to the research I did for my book “Inspecting and Cleaning Potable Water Storage”  the majority of states do not have regulations requiring inspection or cleaning.

Do you think the EPA should require tanks to be Cleaned?

Take the poll :     CLICK HERE AND TAKE THE POLL AT THE BOTTOM OF THIS BLOG

Please share this with friends check out my Videos posted on you tube:

RPCWTP (Ron Perrin Clean Water Tank Project) VIDEO https://youtu.be/RrngivTqdIs

https://youtu.be/RrngivTqdIs

Out of sight out of Mind on Facebook 

https://www.facebook.com/cleanwatertankproject/ 

This is a vastly complicated subject, that can be pulled down to three very simple terms.

1. If you have a water storage tank or tower in your town there is sediment in it.
2. Sediment bad,
3. Remove Sediment and you remove the inorganic contaminates the habitat that organic contaminates can grow in.

See:  Disinfection byproducts list at: http://water.epa.gov/drink/contaminants/index.cfm#Byproduc

Reference: Health Risk From Microbiological Growth and Biofilms in Drinking water Systems.  Published by  the EPA office of Water  June 17, 2002.

http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper_tcr_biofilms.pdf

QUOTE:

PAGE 26        G. Sediment Accumulation

Significant microbial activity may occur in accumulated sediment (USEPA, 1992b). Organic and inorganic sediments can also accumulate in low-flow areas of the distribution system, and enhance microbial activity by providing protection and nutrients (USEPA, 1992b). Biofilms that slough can accumulate in the periphery of distribution systems leading to sediment accumulation and the proliferation of some microorganisms (van der Kooij, 2000). Sediments may be an important source of nutrients in open finished water reservoirs, by accumulating slowly biodegrading materials which

are then broken down and released into the water column (LeChevallier, 1999b). The opportunities for biofilm development may be more abundant in storage tanks than in distribution system piping. Frequently, water is drawn from storage tanks only when water demand is high, such as during drought, fire flow, and flushing operations. This intermittent use results in prolonged storage times that may lead to increased sediment accumulation and lack of a disinfectant residual in the finished water storage vessel. Biological and aesthetic effects can be observed following the release of accumulated sediments from low flow areas of the distribution system (Geldreich, 1990).

Many studies have identified microbes in accumulated sediments, including both pathogens and non-pathogens. These include bacteria, viruses, protozoa, algae, fungi and invertebrates. Opportunistic pathogens that have been detected, and can multiply in sediments, include Legionella and mycobacteria (van der Kooij, 2000). Some primary pathogens can also survive for some time in sediments. Hepatitis A virus survived more than four months in sediments at both 5/C and 25/C (Sobsey et al., 1986). Other opportunistic pathogens found in sediments include Pseudomonas fluorescens

and Flavobacterium spp. (Berger et al., 1993). Sediments can also release nutrients into the water which stimulate biofilm growth downstream (LeChevallier, 1999b).

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Page 34      I. Proper Storage Vessel Management and Alteration

Proper storage vessel management and alteration, when necessary, can prevent contamination of the distribution system. Following TCR violations in 1996 in Washington D.C., one measure that proved effective in bringing the system back into compliance was the cleaning, inspection and disinfection of storage tanks and reservoirs (Clark, et al., 1999).

END QUOTE