Why do some utilities NOT clean their water tanks and towers? On the Missouri Department of Natural Resources Water Protection Program fact sheet they state: “Routine inspection, cleaning and maintenance of finished water storage facilities are clearly necessary to protect public health.” Isn’t that just common sense? Some states do not have rules on when you inspect or clean tanks. Water storage tanks and towers are the last stop water makes before it comes to the tap at your home. These tanks need to be inspected inside and out every year. We have been using underwater cameras to get that done since 1997. If our cameras find sediment build-up we can remove it with a potable water dive team. Our services are efficient and affordable but still many communities choose to do nothing at all. Check this video out and let us know what you think.
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.
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.
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.
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.
This is a great article that ask a great question. It also points out that the Alabama Department of Environmental Management has certain recommendations about routine water tank and tower maintenance that include tank inspection at least once every five years.
But they have gotten it WRONG. Alabama requires the tank to be inspected by draining and disinfecting the interior a minimum of once every five years.
What is wrong with that you ask?
Disinfecting is NOT CLEANING. We are not all speaking the same language here. Many say disinfecting assuming when that is done the tank will be clean. This is not the case. From the engineers who build water storage tanks down to the managers who run the systems there has been a major break in communications with what is actually in water storage facilities.
The tanks & towers are designed to be CLOSED SYSTEMS, they store the crystal clear clean water that comes from the water plant. When Alabama DEM requires operators to drain & inspect the water storage tanks and then disinfect the interior, that disinfection process is to kill whatever contamination may have been introduced into the tank during the inspection. Sediment that was on the floor of the facility before the inspection is there after the tank is disinfected and placed back into service.
Disinfecting is not Cleaning, if you have contaminates like bacteria, protozoa or even viruses buried in the sediment before the disinfection the majority of them are going to be there after the disinfection. The only way to remove them from the facility is to CLEAN the TANK.
Most tanks and water towers were not designed to be cleaned. There are no handy cleaning ports to open up and wash things into. It was assumed by the designing engineers that only clean water would be stored in these facilities and there was no need.
The reality is that over time sediment accumulates on the floor of water storage tanks and towers. They need to be Cleaned out, not looked at and disinfected.
Once sediment is de-watered a few inches of soft simi -liquid sediment can become 1/2 inch of hard clay like coating stuck on the floor of the tank. An underwater inspection can offer more information about the facility without any disruption in service. Divers deployed to clean the tank can remove everything that is loose in the floor of the facility and provide video documentation confirming the job was done and the floor is now clean.
Washing a tank out after draining it for an inspection is not a viable way to clean a tank. For example on an elevated tower, where is the sediment being washed to? We have seen many cases where it was washed down the center standpipe only to return when the facility is put back in service.
The other option is a bucket and shovel, where even the most dedicated crew can not get 100% of the sediment out. The shovel is also hard on the painted surface of the floor. Divers removing the sediment OUT of the facility and onto the yard of the tank is really the best option. When you consider the disruption in service, man hours and cost of water divers are also the most economical option to clean a water storage tank or tower.
This is a great article that ask a great question. It also points out that the Alabama Department of Environmental Management has certain recommendations about routine water tank and tower maintenance that include tank inspection at least once every five years.
But they have gotten it WRONG. Alabama requires the tank to be inspected by draining and disifecting the interior a minimum of once every five years.
What is wrong with that you ask?
Disinfecting is NOT CLEANING. We are not all speaking the same language here. Many say disinfecting assuming when that is done the tank will be clean. This is not the case. From the engineers who build water storage tanks down to the managers who run the systems there has been a major break in communications with what is actually in water storage facilities.
The tanks & towers are designed to be CLOSED SYSTEMS, they store the crystal clear clean water that comes from the water plant. When Alabama DEM requires operators to drain & inspect the water storage tanks and then disinfect the interior, that disinfection process is to kill whatever contamination may have been introduced into the tank during the inspection. Sediment that was on the floor of the facility before the inspection is there after the tank is disinfected and placed back into service.
Disinfecting is not Cleaning, if you have contaminates like bacteria, protozoa or even viruses burried in the sediment before the disinfection the majority of them are going to be there after the disinfection. The only way to remove them from the facility is to CLEAN the TANK.
Most tanks and water towers were not designed to be cleaned. There are no handy cleaning ports to open up and wash things into. It was assumed that only clean water would be stored in these facilities and there was no need.
The reality is that over time sediment accumilates on the floor of water storage tanks and towers. They need to be Cleaned out, not looked at and disinfected.
Once sediment is de-watered a few inches of soft simi -liquid sediment can become 1/2 inch of hard clay like coating stuck on the floor of the tank. An underwater inspection can offer more information about the facility without any disruption in service. Divers deployed to clean the tank can remove everything that is loose in the floor of the facility and provide video documentation confirming the job was done and the floor is now clean.
Washing a tank out after draining it for an inspection is not a viable way to clean a tank. For example on an elevated tower, where is the sediment being washed to? We have seen many cases where it was washed down the center standpipe only to return when the facility is put back in service.
The other option is a bucket and shovel, where even the most dedicated crew can not get 100% of the sediment out. The shovel is also hard on the painted surface of the floor. Divers removing the sediment OUT of the facility and onto the yard of the tank is really the best option. When you consider the disruption in service, man hours and cost of water divers are also the most economical option to clean a water storage tank or tower.
Potable Water Diver in DRY SUIT
Sand & Sediment being removed from a Potable Water Tank
If you have any more details about rules for inspecting & cleaning water storage tanks in Alabama or any other state contact me- Im always glad to share information.
By Photos by Ron Perrin (c) Ron Perrin 2010 all rights reserved
Tap water in 42 states is contaminated with more than 140 unregulated chemicals that lack safety standards, according to the Environmental Working Group’s (EWG’s) two-and-a-half year investigation of water suppliers’ tests of the treated tap water served to communities across the country.
In an analysis of more than 22 million tap water quality tests, most of which were required under the federal Safe Drinking Water Act, EWG found that water suppliers across the U.S. detected 260 contaminants in water served to the public. One hundred forty-one (141) of these detected chemicals — more than half — are unregulated; public health officials have not set safety standards for these chemicals, even though millions drink them every day.
EWG’s analysis also found over 90 percent compliance with enforceable health standards on the part of the nation’s water utilities, showing a clear commitment to comply with safety standards once they are developed. The problem, however, is EPA’s failure to establish enforceable health standards and monitoring requirements for scores of widespread tap water contaminants. Of the 260 contaminants detected in tap water from 42 states, for only 114 has EPA set enforceable health limits (called Maximum Contaminant Levels, or MCLs), and for 5 others the Agency has set non-enforceable goals called secondary standards. (EPA 2005a). The 141 remaining chemicals without health-based limits contaminate water served to 195,257,000 people in 22,614 communities in 42 states.
To date only the State of Florida has set standards for cleaning water storage tanks. Not only should standards be set for additional contaminates I thisnk is is just as or pehaps more important that standards be set for keeping tanks clean. At this time it is just not understood how much sediment accumulates in an average water storage tank over a few years. That sediment becomes a habitat where bacteria and other contaminates can thrive.
Once in your tank bacteria can grow rapidly if it finds a place to hide from the treatment chemicals sent to destroy it.
The EWG’s report also points out that “90 percent compliance with enforceable health standards on the part of the nation’s water utilities, showing a clear commitment to comply with safety standards.” If standards are put in place giving water utilities a time table that water storage tanks should be cleaned and or inspected the water utilities will comply. For the most part they or the people controling their funds do not understand the improtance of inspection & cleaning.
Even after the Environmental Working Group’s (EWG’s) two-and-a-half year investigation of water suppliers’ tests of the treated tap water served to communities across the country. No one looked at the effects of Sediment in the water storage tanks. It apparently was not an issue, never thought of, the investigation only looked at reports of what the water utilitys found in their systems.
Keeping your water storage tanks clean may be one of the most overlooked maintenance procedures in the water industry. Out of sight and out of mind, sediment in the bottom of your water storage tanks is never seen and rarely thought of.
In 2002 The EPA Office of Ground and Drinking Water issued a paper on distribution systems titled “Health Risk From Microbial Growth and Biofilms in Drinking Water Distribution Systems”. See the link below to read the full report.
That report sited –
Hepatitis A is a primary pathogen that has been documented to survive more than four months in the sediment of a potable water storage tank.
Bacteria, protozoa, and viruses can find sediment in the floor of a water storage tank an inviting habitat.
So if the EPA knows all of this why are most water storage tanks so dirty? Like most thisngs in comes down to MONEY.
If you live in a new progressive community the likelyhood of your water storage tanks being inspected and cleaned on a regular basis is much better than if you are in a older, smaller and les affluent community. If regulations are put into place money would need to follow to allow ecanomically depresed communities to maintain there systems properly.
I have been inspecting and cleaning water storage tanks since 1992. What I have seen is the more ecanomically depresed the community is the more likely they are to need their tanks cleand. They are also more likely to drink more tap water. I would think that the more affluent a community the more bottled water is consumed. So we end up with the people who need clean tap water the most getting it the least. I have found something important to do but I cand only help a very small % on my own. The health concerns associated with sediment in the water supplies are much biger than I am. It is bigger than papers written and published by the EPA detailing the problem. It will take the general public to be concerned and perhaps a little sikened and outraged wouldnt hurt. It will take people like you and me making noise and getting attention on this subject before the proper action will be taken. The Mission of this blog is to make some noise on this subject. Let me know what you think.
If you are interested in this subject there are a few things to do:
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The EPA has published many reports on this subject. The work has been done to establish the problem. Its up to us to make sure something gets done about it.
Ron Perrin Clean Water Tank Project 