From: Ron Perrin To: SFIWebinar@cadmusgroup.com. Subject: Final Comment and poll Results in regards to Distribution System Storage Facility Inspection and Cleaning. Date: Wednesday, December 31, 2014 1:57:46 PM

Final Comments and poll results from Ron Perrin for the proposed Revisions to the Total Coliform Rule (75 FR 40926, July 14, 2010)

Over the pst few months I have been conducting a poll on my blog that ask these questions.

1

. 

### Do you think the EPA should require all potable water storage tanks and towers to be inspected?

Total Votes as of 11:40am 12-31-14 269

YES 259 (96.28 %)

No 10 (3.72%)

2. 

### Do you think the EPA should require tanks to be cleaned? Do you think the EPA should require tanks to be cleaned?

Total Votes as of 11;:0am 12-31-14 304

YES 282 votes (92.76 %)

No 18 (5.92%)
Not Sure 4 votes (1.32%)

3. 

### How often do you think Potable Water Storage tanks should be cleaned?

Total Votes as of 11:40am 12-31-14 303

Once a Year 209 votes (68.98 %)
Once every three years 51 votes (16.83%)
Once every five Years 43 votes (14.19%)
The Polls are still up if you would like to get an updated count we will be continuing to take the poll until a regulation or guidance paper is set by the EPA. The polls have been shared on social media over 100 times.
The poll can be seen at www.tankdiver.us or http://www.cleanwatertankproject.com The general public was ask to participate in this poll from an ad on Facebook and these two blogs developed by Ron Perrin.
The polls were also promoted through Ron Perrin Water Technologies Company Facebook page https://www.facebook.com/ronperrinwatertechFinal Comments
My company has inspected over seven thousand water storage tanks and towers using underwater cameras since 1997. We have used a potable water dive crew to clean hundreds of tanks and towers in multiple states.
Recently a CDS News crew did a story on this subject. Please see my blog at www.tankdiver.us for more details. The first post is about the local CBS news coverage and the second is about the EPA asking for comments. with the poll. The CBS NEWS STORY is interactive and reviews the cleaning practice of 40 water utilities in the DFW area:

See: http://dfw.cbslocal.com/2014/11/19/water-towers/
The CBS 11 DFW Report was televised on November 19th, 2014 and to-date has been shared over 400 times on their web site.
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.

The other big surprise was that their is not a clear definition of what a TANK INSPECTION IS. Some people are under the impression that you can look at a tank on the outside and call it inspected, others look at the outside and then open the top hatch while it if full of water and call that an inspection. The fact is until you have fully inspected the interior of the tank including the internal roof walls and interior floor of the facility the tank has not been properly inspected. Every tank inspection should include facts about the interior floor if sediment keeps the floor from being inspected it should be removed. An inspection should document the interior of the tank by draining the facility and having a confined space entry team inspect it, using commercial potable water dive team or remote underwater camera to document tank conditions.

Using Potable Water Divers saves time, water, and money. In Texas, the 750,000 gallon water tower featured in Ginger Allen's Story was cleaned for $2450.00, Prices vary across the country but the cost is not prohibitive when you consider how much water was saved compared to draining the facility. The facility was locked out of service for a few hours instead of the days it would take to drain it. Once the floor was cleaned and all the sediment was removed, the diver was able to inspect the previously hidden floor space.

I have been working hard to get to make tank cleaning a priority for water utilities since 1997. P lease look at my other blog at: The Clean Water Tank Project: http://www.cleanwatertankproject.com

. I think all tanks should be inspected at leaf ONCE every five years.
The EPA has known for years that sediment on the floor of water storage tanks and towers is a seriousproblem. The white paper read titled: "Health Risks from Microbial Growth and Biofilms in Drinking Water Distribution Systems", was published in 2002. The summary copied below concludes that we can not stop microbes from getting into the drinking water distribution systems. (my point is we can keep microbes from having a habitat to live in, sediment on the floor provides both food an shelter from disinfection chemicals allowing growth).
On page 34, they site "Proper Management" as a cure, but the problem is that some people think tanks can be inspected from the outside, while others do not see the need for cleaning as long as they can add enough chlorine to keep it drinkable. My customers tell me time and again they use less chlorine to meet standards after I clean their water storage tanks.
http://www.epa.gov/ogwdw/disinfection/tcr/pdfs/whitepaper_tcr_biofilms.pdf 

### XI. Summary 35 JUNE 17, 2002 A wide range of primary and opportunistic pathogens have demonstrated the ability to survive, if not grow, in biofilms. These pathogens are of both fecal and non-fecal origin, and have a multitude of pathways through which they can enter the distribution system. Some of the pathogens identified as growing or potentially surviving in biofilms include Legionella
, Mycobacterium avium complex, Pseudomonas aeruginosa , poliovirus 1, coxsackievirus B and several species of fungi. Microbes can enter the distribution system through inadequate treatment, cross-connections, leaking pipes and appurtenances, as well as other means. Once becoming established as part of the biofilm, pathogens can be protected from disinfection. Systems may select from a range of measures which can limit the growth of microbes in the biofilm, prevent microbes from entering the distribution system, and/or minimize the number of microbes present. Some of these measures are most effective if performed regularly. Systems can also choose from a range of methods to detect biofilm problems.

Page 34 

### 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).

Thank You

Ron Perrin, CSHO Owner Ron Perrin Water Technologies Fort Worth, Texas www.ronperrin.com

Reference:

In the Federal Register notice for the proposed Revisions to the Total Coliform Rule (75 FR40926, 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]