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2. It is unclear who will clean and inspect the tanks prior to being filled with water <br />produced by the proposed pump test. <br />Powertech has provided the EPA with a one and a half page document titled "Produced <br />Water Vessel - Cleaning and Inspection Procedure" which is a purported standard <br />operating procedure (SOP) to insure that the tanks will be decontaminated prior to use. <br />The document does not indicate who has been selected to conduct the cleaning and <br />decontamination, nor does it spell out the qualifications of the contractor selected to do <br />the work. <br />Powertech employees would be responsible for inspecting the tanks, according to the <br />document. The SOP is silent on which employees would conduct inspections, and <br />whether such employees are qualified to detect chemical or biological contamination. <br />3. The cleaning and inspection SOP does not explain how residual solids and liquid <br />films will be removed from the tanks prior to chemical disinfection. <br />The SOP fails to describe the manual or mechanical processes to be used to remove <br />residual solids from interior surfaces of the tanks. The SOP calls for pressure washing <br />after, but not before, chemical disinfection. According to Centers for Disease Control <br />guidelines on decontamination in healthcare facilities, "Thorough cleaning is essential <br />before high-level disinfection and sterilization because inorganic and organic materials <br />that remain on the surfaces of instruments interfere with the effectiveness of these <br />processes (emphasis added)." <br />No mention is made in the SOP of removing oil and grease contamination, rust, mineral <br />deposits, or biological films prior to chemical disinfection. <br />In addition, the SOP does not address how to remove residual solids, films, and liquids <br />from difficult to clean areas such as joints, cracks, crevices, channels, fasteners, valves, <br />manways, etc. These areas can harbor organic material and chemical residues which act <br />as a physical barrier to protect microorganisms from decontamination, and which can <br />inactivate certain chemical disinfectants such as bleach. <br />The Statement of Basis for the Draft Permit mentions that the storage tanks will be <br />steam-cleaned, but there is no reference to steam cleaning in Powertech's SOP. <br />4. The SOP's "bleach wash" procedure is vague and does not conform to accepted <br />decontamination guidelines. <br />The storage tanks for the injectate may have previously contained hazardous biological <br />wastes, including raw sewage. Powertech's SOP for chemical sterilization simply calls <br />for "Perform(ing) bleach wash on interior and valves." <br />2