Since Colorado’s storage tank rule went into effect in 2016 we have published many articles on different aspects of finished water storage tanks. Today we would like to focus on another important potential avenue of contamination, corrugated and metal storage tank roofs. 

In recent inspections for systems that have tanks with sheet metal and corrugated metal roofs, the water quality control division (division) has seen an increase in issues with seals between the roof of the tank, and the tank walls, vents, and access hatches. Corrugated tank roofs are of particular concern due to the gaps created by their corrugated ridges. Below are some of our most important lessons learned about metal and corrugated tank roofs.

Corrugated Tank Roofs Can be Difficult to Seal

The voids created between the ridges of a corrugated roof and the walls of a tank can be difficult to effectively seal and may be a desirable shelter for rodents and other small animals. It is also much more challenging to correctly seal roof penetrations for things like tank vents in a corrugated roof. If your system has a preexisting tank with a corrugated roof the division recommends more frequent periodic inspections of these tanks with a particular focus on the seals around the corrugated materials. 

Figure 1 - Improper seal between two corrugated panels

Figure 5 - Improper seal around a tank hatch.

Expanding Foam is not an Effective Method to Seal Gaps in Tank Openings

Figure 6 - Foam used to seal the interior of a tank.

It is not uncommon to see expanding foam used to seal gaps in corrugated tanks because it can easily fill large gaps. The use of this foam can lead to potential public health risks and sanitary defects. Foam used in exterior gaps can degrade rapidly due to weather and may be used by small animals as nesting material. Foam that is used as a sealant on the interior of tanks may deteriorate and flake off into the water posing a contamination risk itself over time. Condensation collecting on the foam can leach contaminants and then drip into the drinking water.

Metal Tank Roofs Can be Challenging to Inspect

We have seen tanks with metal roofs where it isn’t possible to examine the interface between the walls of the tanks and the metal roof without an interior inspection. A dislocation or break in the gasket material or a warpage or dislocation of the metal panels could allow the entrance of contaminants such as plants, insects, birds, and small animals into the tank. A brief walk around a tank is not effective in finding potential openings. An extendable mirror can be helpful for looking at tough to see locations around all storage tanks.

Drinking Water Design Criteria for Tanks

The division has outlined the requirements for tank roofs in the design criteria. This section of the criteria is currency undergoing a stakeholder update process. If you are interested in receiving updates on this process or getting involved you can find more information on our Drinking Water Design Criteria webpage. 

New or modified storage tanks being submitted to the Department for approval must meet the design criteria. Also, the Department intends to update the design criteria to clarify that we will not approve tanks moving forward with corrugated metal roofing. However, during a sanitary survey an inspector will not issue a significant deficiency solely based on your existing tank not meeting the current design requirements unless there is a condition identified during the sanitary survey that is a potential threat to public health (examples include unprotected openings to tanks, missing/damaged screens, unsealed/un-gasketed hatches, improperly sealed tank roofs, etc.).

Figure 7 - Excerpt from the current Design Criteria for Potable Water Systems (2022 Edition)

Identification of Sanitary Defects and Risks to Public Health

If a supplier finds an animal or other concerning debris in an improperly sealed storage tank please contact the division’s emergency line at 1-877-518-5608 as soon as possible but within 24 hours of discovery. The drinking water acute team will consult with you on next steps.

If suppliers identify a sanitary defect, it must be documented upon discovery. Also, a corrective action schedule in accordance with the Storage Tank Plan must be developed to fix it as soon as possible. Take photographs before and after making repairs. By doing so, suppliers can avoid a violation for not correctly implementing the storage tank rule.

Sanitary defects that are discovered during sanitary surveys may be cited as significant deficiencies or possibly even as a Tier 2 (treatment technique) violation of the storage tank rule for permitting a known sanitary defect. The risk of violations is especially present for defects that should be ‘obvious’ to anyone performing a periodic tank inspection.

Additionally, if suppliers do not follow the corrective action schedule that they developed, they will also be in violation of the storage tank rule. Avoid violations of the storage tank rule by proactively identifying sanitary defects and then documenting that the supplier is following a corrective action schedule to fix them.

➽ Chelsea Cotton, P.E., Lead Drinking Water Engineer

The division solicited feedback from stakeholders in May 2024 on the proposed changes to Board Guidance 19-1 and its associated content and presented the subcommittee’s proposed revisions to the board at its June 25, 2024 board meeting. The board approved the proposed revisions to Board Guidance 19-1 and its associated Specific Curriculum Elements. 

To allow time for implementation, the revised version will become effective on January 1, 2025, and the current Board Guidance 19-1 remains effective through December 31, 2024. 

The revisions that were approved: 

• Provide more detail, clarification, and consistency.
• Remove the two-hour cap on MRT courses. 
• Swap the term “required minimum content” with “specific curriculum elements.” 
• Change the format of the specific curriculum elements from PowerPoint slides to a “Reference Guide” that specifies which information is required and which is optional.
• Only allow an MRT course to count as core Training Units (TUs) once per certificate renewal cycle to ensure operators are diversifying their learning by not only taking MRT courses to renew their certification(s). 

Although not yet in effect, you can view the revised guidance document and associated Reference Guide on the board’s website. 

What does this mean for certified operators?

Operators are still required to complete an MRT course when applying for a certification examination, applying for reciprocity, or renewing a certification. As mentioned above, come January 1, 2025, the completion of an MRT course will count as core Training Units (TUs) only once per renewal cycle. Operators may continue to take an MRT course more than once per renewal cycle but any additional attendance at an MRT course within that three-year cycle would count as flexible (or “flex”) TUs. This change helps ensure certified operators are diversifying their learning and not only taking MRT courses to renew certification(s). 

What does this mean for course providers? 

Should a training provider, utility, or other entity desire to provide MRT in 2025 (and thereafter), they must include all the Specific Curriculum Elements outlined in the Reference Guide during each MRT course delivery. The process for submitting and obtaining MRT course approval remains the same. 

As mentioned above, the content of the Reference Guide is not materially different from the current required course content provided in the PowerPoint slides. The format of the content was changed and now indicates which information is required and which is optional (items with a check box and in bold font are required course content; the optional content is bulleted and not in bold font). 

One approved change was to simplify instances where course providers are to show operators where to find division compliance tools, regulations, policies, and guidance documents. Course providers are still required to explain the differences and importance of each and where to find more information when needed. However, walking through examples, including providing the links, click-paths, and/or keywords to search for online, will now be considered optional content and not required course content. Clarification was also added to indicate that all courses, not only online courses, are required to have assessments, and examples of acceptable types of in-person assessments were added. 

Other important changes to note for course providers relevant to the learning objectives is that a certified operator’s mission to protect public health and the environment was added to the sections covering the role of a certified operator (Regulation 100), and for wastewater treatment, industrial wastewater treatment, and wastewater collection, an overview of the tables located at the end of each permit was added to the section on understanding how to read a permit. 

For questions related to these updates, feel free to contact Jessica Morgan at cdphe.facilityoperator@state.co.us. 

➽ Jessica Morgan, Facility and Operator Outreach and Certification Board Liaison

The Field Services Section (FSS) wrapped up the 2023 inspection year (IY 23) in September 2023 and the new IY 24 inspection year started and is almost halfway over! We appreciate all the assistance from public water systems in completing 491 sanitary surveys in 2023. IY24 started October 1, 2023 and FSS inspectors have completed 297 site visits to date. In this article we will share the top 10 most frequently cited significant deficiencies and violations from IY23 and a sneak peek into IY24 trends to raise awareness and help operators identify and correct issues before they become a potential health threat or citations in a sanitary survey. 

According to Regulation 11, Section 11.3(72), a significant deficiency means: any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public served by the water system. Field-based Violations of Regulation 11 have either Tier 2 or Tier 3 public notice requirements that are dependent upon the severity of the violation and any potential public health effects, pursuant to Regulation 11, Sections 11.33(1)(a,b), 11.33(2)(a), 11.33(3)(a) and 11.33(4)(a). All issued notifications must comply with the general content and distribution requirements and notice reporting requirements that are included in Regulation 11.33(5),(6) and (7).

During the 2023 inspection year, 1,256 significant deficiencies and violations were cited in 491 sanitary surveys. The Top 10 most frequent inspection citations were:

Storage tank deficiencies (F310 and T310), in the distribution system and before the entry point (CT tanks) combined account for 16% of all citations in IY23 and 17% of all citations in IY22. Storage tank deficiencies can include improperly protected screens, hatches and overflows. This underscores the importance of robust routine tank inspections under the Storage Tank Rule and also for tanks that are used for contact time or before entry point. 

The next most frequently cited significant deficiency, with 9% of the total IY23 and IY22 citations, was for wellhead pathways of contamination (S030). This can include loose wellhead seals, missing or damaged vent screens, missing gaskets, broken/open electrical boxes/conduit, cracked sanitary seal plates and wellheads. 

Backflow prevention and cross connection control (BPCCC) has four violations and a significant deficiency that make the Top 10 list, including failure to develop BPCCC annual reports, failure to develop or implement the BPCCC program (both Tier 3 public notice violations), and failure to meet the assembly testing ratio and method inspection ratio which were a Tier 2 public notice violations. Combined, all the BPCCC violations and significant deficiencies make up 26% of the citations in IY23. In 2023 the Division streamlined the BPCCC rule with the Water Quality Control Commission and the assembly and method compliance ratios were combined. In IY24 the M614 and M615 violation codes were replaced with one code, the M619 for Inadequate Backflow Prevention Annual Compliance Ratio due to combining assembly testing ratios and method inspection ratio.

A newcomer to the Top 10 is the Bacteriological Sampling Plan R518 violation which can include not performing representative sampling of the distribution system, not having a sampling plan, not rotating sample locations or not following the plan. 

In IY24 to date, 673 significant deficiencies and violations have been cited. The majority of these citations are the same as the IY23 Top 10 with the addition of two other findings:

• Violation R536 - MONITORING DISINFECTION (T3); Failure to Monitor Groundwater EP Residual Disinfectant.
• Significant Deficiency T116 - GROUND WATER TREATMENT; Supplier could not demonstrate adequate operation of approved groundwater treatment processes which are being used for compliance with Regulation 11.

Please check your water systems for these issues to protect public health and avoid significant deficiencies and violations during your next sanitary survey. If you would like additional assistance on technical issues or sanitary survey preparation, please sign up for individualized coaching here.  For any questions or concerns about sanitary surveys please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. Thank you for all your efforts to protect public health!

➽ Heather Young, PE, CWP, Field Services Section Manager

Town of Monument, CO

In 2014 to 2018, Palmer Lake Mobile Home Ranch was struggling to maintain compliance with a variety of regulatory requirements. As a result, in 2018, the Department issued an Enforcement Order due to the system's failure to comply with The Colorado Primary Drinking Water Regulations (Regulation 11) and The Water and Wastewater Facility Operators Certification Requirements (Regulation 100).  The purpose of the Order was to provide deadlines and oversight to keep Palmer Lake Mobile Home Ranch on track toward returning to compliance and maintaining long-term compliance with Regulation 11 and Regulation 100.

Later in 2018, water samples collected from a proposed well indicated elevated concentrations of combined radium -226 and -228 and resulted in violations of the maximum contaminant level (MCL). Radionuclides such as these can occur naturally in water sources as a result of the erosion of natural deposits. While they are not an acute health risk for short-term consumption, there are chronic risks including a higher risk of developing cancer if water with elevated radium levels is consumed over a long period of time. Even though Palmer Lake Mobile Home Ranch had resolved all but one of the prior violations, the Department issued an amendment to their Order to bring the new MCL violations into the corrective action oversight provided by the Order.

The owner of Palmer Lake Mobile Home Ranch expressed frustration at the complexity of this new MCL violation but continued to work with their contract Professional Engineer and the Department to explore affordable solutions. Even though this water system serves full-time residents, as a private, for-profit business, the owners could not qualify for funding assistance (grants or low interest loans) from local, state or federal agencies. Collaborative communication between the Department, the system, and contract engineers was dedicated to designing a solution that would effectively reduce the concentration of combined radium in the water. Several ideas were considered, but only a few were realistically going to ensure future compliance. The system decided to install treatment to remove radium, but complications developed throughout the process: the financial burden of the total cost of the project was becoming an increasing concern, and they were not allowed to discharge the removed radium as a waste stream which eliminated some treatment options. The remaining treatment option added extra cost beyond the treatment installation and operation/maintenance. They would need to use a treatment that captured the removed radium in a resin instead of discharging it in a waste stream. This would require obtaining a hazardous waste handler permit for the Palmer Lake Mobile Home Ranch itself, and they would also pay indefinitely for a specially permitted waste hauler service to remove the resin on a regular frequency. 

In 2022, a new partner entered the conversation. The Town of Monument informed the Department of plans to construct a water line that was going to run along the property edge of Palmer Lake Mobile Home Ranch as part of a new storage tank construction project. Given the complications that Palmer Lake Mobile Home Ranch was experiencing with installing treatment for their own water supply, they were enthusiastic about this new development. When the Department received confirmation from the Town of Monument that they were willing to provide a connection to Palmer Lake Mobile Home Ranch, as well as confirmation from Palmer Lake Mobile Home Ranch that they would accept the connection and disconnect their wells, the Department readily agreed to the change of plans.

Despite having exhausted significant effort and resources toward implementing solutions for an improved water system and treatment for combined radium, ultimately, Palmer Lake Mobile Home Ranch decided that the best way to return to compliance was to tie in with the Town of Monument. In December 2023, the connection was completed and the wells were disconnected. Palmer Lake Mobile Home Ranch is now classified as a consecutive system receiving finished drinking water from another regulated water system, and the water being distributed to its residents is now in compliance with Regulation 11. 

While Palmer Lake Mobile Home Ranch demonstrated admirable determination in attempting to independently return the water system to compliance with all regulations, ultimately, success was found in partnership, as expressed in these testimonials from Palmer Lake Mobile Home Ranch and The Town of Monument. This highlights the important lesson in weighing perseverance against the path of least resistance: sometimes the simplest option is the best option. The Department is committed to a culture of health that prioritizes safe drinking water for all consumers and works hard to facilitate success stories such as these.

It is also important to take into consideration how existing regulations now apply to Palmer Lake Mobile Home Ranch moving forward. Consecutive water systems are still required to comply with Regulations 11 and 100, there are just differences in the applicability of certain rules. Additionally, the new water quality testing program under the Mobile Home Park Water Quality Act will begin this year. This program is designed to address community member concerns, identify water quality issues, and remediate water quality issues at parks throughout Colorado.

Did you know that Colorado has hundreds of small mobile home parks that receive finished drinking water from a regulated water system? 

QUIZ: If a mobile home park does not have a well or treatment system, but bills customers for water, what regulations apply? Choose the correct answer:

1. The plumbing code alone
2. The plumbing code and the new Mobile Home Park Water Quality Act
3. The plumbing code, the new Mobile Home Park Water Quality Act, DOLA’s Mobile Home Park Oversight program, and Regulation 11 within the distribution system
4. None of the above are fully correct; it’s complicated!

Look for the answer in a future AquaTalk article!

➽ Lauren Fracasso Compliance Specialist for South Unit

➽ Emily Clark Enforcement & Field Findings Compliance Lead

In late 2023, EPA released the proposed Lead and Copper Rule Improvements (LCRI). See this article for more information on the proposed LCRI.The LCRI is intended to improve upon the requirements promulgated in early 2021 in the Lead and Copper Rule Revisions (LCRR). The LCRR/LCRI will affect more than 1,050 community and non-transient, non-community public water systems in Colorado, serving nearly 6.5 million people. The LCRI public comment period is closed and EPA is planning to finalize the rule in October 2024. The LCRI compliance date is estimated to be late 2027. This gives water systems time to prepare and optimize their corrosion control treatment (CCT) before the LCRI requirements take effect. 

What is corrosion control treatment (CCT)? CCT is chemical treatment at the water treatment plant that makes the potable water less corrosive to water lines and premise plumbing. CCT is typically achieved by adding a phosphate-based corrosion inhibitor or with pH/alkalinity adjustment. The Lead and Copper Rule (Section 11.26 of Regulation 11) requires installation of CCT for systems with action level exceedances (ALE) and requires optimal corrosion control treatment (OCCT) for all systems serving more than 50,000 people. Approximately 65 systems in Colorado are operating OCCT with Department set optimal water quality parameters (OWQP) to comply with the current Lead and Copper Rule. 

Several changes in the proposed LCRI may impact systems that either have corrosion control treatment (CCT) installed currently or that may need to install CCT as a result of elevated lead or copper levels. Proposed LCRI changes that may impact CCT include:

• Setting a lower lead action level at 10 parts per billion (ppb).
• 1st and 5th liter lead sampling at lead service lines may result in higher lead levels than seen under the current rule. 
• Corrosion control study required for large systems without OCCT that exceed the practical quantitation limit (PQL) of 5 ppb based on 90th percentile lead levels.
• Medium and large systems with lead service lines that are required to conduct a corrosion control study must use harvested lead pipe in a pipe loop rig.
• Deferred OCCT installation or re-optimization for systems that replace 100 percent of lead service lines within five years of the date they trigger CCT steps.
• Removal of hardness as a corrosion control treatment option and specifies any phosphate inhibitor must be orthophosphate.
• Small system compliance options (e.g., point of use devices, replacement of all lead-bearing plumbing materials) for community water systems with 3,300 people or less and all non-transient, non-community systems.
• Review of CCT during sanitary surveys.

While these changes were part of the proposed LCRI, we will need to wait for the final rule to see if all of these items are included and if new items are added. Also, under the proposed LCRI, water systems will also have to provide Tier 1 public notice to consumers within 24 hours after a lead action level exceedance.

Possible actions to take:

• Review your 90th percentile lead results: One of the key changes in the draft LCRI is setting the lead action level at 10 ppb; the current lead action level is 15 ppb. Since 2010, approximately 115 systems had 90th percentile lead levels that were between 10 ppb and 15 ppb. Investing in operational controls, treatment, and/or treatment optimization now may allow you to lower your lead levels below the 10 ppb action level before the LCRI takes effect.  
• Evaluate treatment at large systems that are deemed optimal: Systems that have a population of more than 50,000 people “large systems” are required to have optimal corrosion control treatment (OCCT). The majority of Colorado’s systems that serve over 50,000 people have been “deemed” to have OCCT based on low source water lead and 90th percentile lead concentrations less than 5 ppb. The proposed LCRI requires large systems with a 90th percentile lead value greater than 5 ppb to complete a corrosion control study (CCS). For systems with lead service lines, the proposed LCRI requires the CCS be completed using harvested lead lines in a pipe loop. Many large systems have treatment processes that may impact corrosion. If possible, you should work on optimizing any existing treatment to lower lead levels as much as possible. 
• For systems with CCT,  determine if you can optimize your treatment process: Analyze your treatment process and determine if your corrosion control treatment could be optimized. A great tool for this is a bench scale immersion coupon study.  
• pH/alkalinity CCT systems: Systems using pH/alkalinity adjustment may want to more tightly control pH and/or find the optimal target pH. The EPA guidance document recommends a pH range at the entry point of 0.4 s.u. (for example: 7.8 to 8.2 s.u.) and a 0.6 s.u. range within the distribution system. Maintaining a tighter pH range may also improve other water quality contaminants such as disinfection byproducts. Conducting an immersion study to determine the optimal pH target may also be beneficial.
• Phosphate-based inhibitor systems: Phosphate-based inhibitor systems may want to optimize their dosing. Orthophosphate is the chemical that is effective at corrosion control and the EPA generally recommends a minimum orthophosphate concentration of 1.0 mg/L as PO4 in the distribution system. Blended phosphate inhibitors are a blend of orthophosphate and polyphosphates, which are typically used to sequester iron and manganese. These systems may want to review the percentage of orthophosphate in their chemical to better control corrosion. A bench scale immersion coupon study may be advantageous to determine the more effective dose and/or chemical.  
• Systems with CCT and OWQPs should review their OWQPs: Systems with OWQPs should review their monitoring schedule to verify the required OWQPs at the entry point(s) and in the distribution system. You may want to request an OWQP modification if you have additional water quality data or immersion coupon study results. 

Making changes to your CCT now can help you meet the LCRI requirements that are coming down the pipe. If you have any questions, please contact Melanie Criswell at melanie.criswell@state.co.us.

Resources:

• LCRR guidance, FAQs, and forms are available on the department’s Lead and Copper Rule & Revisions Webpage.
• Review the department’s initial service line inventory development policy.
• Visit the department's drinking water training and assistance website to register for upcoming Lead and Copper Rule courses (online and in-person options available) and other free training opportunities.

➽ Melanie Criswell Lead Service Line, Corrosion, and Emerging Contaminants Engineer

➽ Haley Orahood Regulatory Development and Implementation Specialist

As systems prepare to submit their Lead Service Line Inventories (LSLI) this October, it has become abundantly clear that the water sector needs to put more resources into identifying what resources and assets they have and where they are located. Ideally, a bulk of the LSLI should have been completed using documentation. However, many systems lack records for their distribution systems. This gap in asset inventory is making the task of documenting their service line material types more costly and difficult. In the past many systems have taken a reactive approach, - “when it breaks, we fix it”, to manage their system. However, with the changing regulatory requirements, increasing financial hardships, and increasing climate and resource challenges, it has become necessary to plan ahead to ensure the health of public water systems into the future. It is necessary to know what resources you have and maximize their usefulness.  

AM is a scalable, thoughtful approach to systems management and can be applicable to any size system. It can help with coordination across an organization to help ensure that the right work is done in the right order at the right time. 

Not sure where to start, feeling intimidated? Come to one of the free training sessions offered by the Local Assistance Unit (LAU). Asset management will be presented this summer during the State Revolving Fund (SRF) Regional Workshops in partnership with the Department of Local Affairs and the Grants and Loans Unit. Additionally, the LAU will be rolling out an asset management course as part of the regular course offerings in 2025. The Asset Management course curriculum will review the 5 core criteria of asset management and demonstrate how to apply each of them to your system. You will learn how to get started and review some tools to assist you in developing an asset management plan. No need to reinvent the wheel when it comes to AM, there are many tools and templates available that fit the needs of every sized system. 

Join us!

Asset Management: A Management Framework and the associated toolkit will be presented as part of the SRF Regional Workshops scheduled for:

• July 11, 2024 - Alamosa, CO - Adams State University 
• Register Here
• July 23, 2024 - Akron, CO - Akron Senior & Community Center 
• Register Here

The workshop will cover topics related to SRF basics, funding options for drinking water and waste water infrastructure, asset management planning and tools, current and upcoming regulations and much more.   

Can’t make a workshop and need assistance with asset management or capacity development?

The Colorado Department of Public Health (CDPHE) Water Quality Control Division (WQCD) has free capacity coaching available for public water systems through the Local Assistance Unit (LAU). A PWS can request assistance by filling out the Coaching Assistance Form. 

➽Angela Green Garcia, Drinking Water Training Specialist 

Backflow Prevention and Cross Connection Control Rule (BPCCC)

BPCCC Resources 

• Frequently asked questions
• Updated Backflow Guidance Document
• CDPHE Backflow Prevention and Cross Connection Website(opens in new window)

1. Under the new Backflow Rule updates, do I still have 15 months to get 100% of all my devices tested every year?

This question relates to the untested 2-year rule in the 2023 updated regulation as opposed to the 90-day rule from the old BPCCC regulation. With the 2023 regulation update, the “90 day rule” is gone. Under the updated rule, the supplier must achieve a backflow prevention annual compliance ratio of greater than or equal to (≥) 0.90 and with that remaining 0.10, the supplier must ensure that no backflow prevention assembly is present for more than two consecutive calendar years without being tested, service being suspended to the customer, or the cross-connection being removed.

2. What happens if a device fails a test and tests good 7 days later? What if the device fails and is fixed and passes on the same day?

This is a great question and the backflow policy DW007 helps answer this. An assembly that fails testing and is repaired and receives a passing test will be reported in the combined compliance ratio (Report lines 8-10) AND as an uncontrolled cross connection that has been controlled (Report Line 7.A) in the annual report. A violation does not occur for a failed assembly unless the assembly is not repaired within the required timeline. If an assembly fails but is repaired and passes a test on the same calendar day, the supplier may exclude reporting the assembly as having failed in the annual report and only count it in the compliance ratio (Report Lines 8-10) in the annual report. 

3. How do I handle if a place closes and is no longer in use but they had a backflow device?

If it was in use at any time during the year it must be included in the annual report. The supplier can suspend service to the location to remove the cross connection concern for future years while the business is not occupied or using water.

4. Can PWSs have their operators certified as backflow testers? What are the pros/cons?

There are no Colorado state limitations on whether an operator can also be the certified backflow tester. Some utilities administer their backflow program where the operators perform device testing. Other utilities consider it to be a conflict of interest. Each water system can work with their management and legal team to decide the best path for their water system. Some pros to having operators test backflow devices may include having some level of control over the timing of when the assembly is tested, immediate test results, and prioritized testing. However some of the “Cons” of having operators test devices are potential conflicts of interest, it’s another certification to test and maintain.

5. How do I become a certified backflow tester?

Regulation 11 allows for two certification organizations; ASSE and ABPA. They are national organizations with testing/certifications in Colorado. Just google ASSE or ABPA backflow tester and it will bring up testing, schools and how to sign up.

6. Yard hydrants - I installed one with a “Y” adapter with a hose attached to one end with a HBVB installed. Is this ok?

When not in use, the hydrant can be shut down with the non-used side of the “Y” left open to allow for the yard hydrant’s weep hole to work correctly. As long as the non-used side of the “Y” has no hose attached this should be acceptable.

7. Do I have to use your forms?

No, suppliers can develop their own forms as long as they meet the Regulatory requirements and include all the required information.

8. Can I use GIS to track my methods/assemblies?

WQCD does not mandate how suppliers track their methods/assemblies. As long as all required information needed in completing the annual report and maintaining a backflow program are achieved we see no issue with using GIS. One area of concern when using locational software to track assemblies/methods is that one location may have multiple assemblies/methods (isolation versus containment or multiple service connections).

Storage Tank Rule

Storage Tank Rule Resources 

• CDPHE Storage Tank Rule Website
• Storage Tank Guidance Handbook 
• Inspection summary instructions(opens in new window)

1. Overflows - do I need a flap and a screen or are screens banned? Are you going to issue me a significant deficiency during my next sanitary survey for this? 

This highlights the difference between a significant deficiency associated with Sanitary Surveys and changes in the design criteria for designs submitted to the Engineering Section. New or modified water facilities must meet the design criteria, but the Field Services Section does not issue significant deficiencies if an existing tank does not meet the current design requirements unless there is a condition that is a potential threat to public health (flap valve is stuck open, screen is torn or missing). During a sanitary survey, tank overflows with flap valves or screens are fine as long as they are in good operating condition (flap valve functions, seats completely, flap valve is not propped open/submerged; screens are non-corrodible 12-16 Mesh and intact).

2. Do I have to use 24-Mesh non corrodible screen - I can’t find it.

Screens may not have openings that exceed 0.07 inches (typically 12 or 16 mesh) and have to be non-corrodible.

3. Can I use actual plastic window screen to screen my vents, overflows, etc?

Plastic window screen can be easily damaged/torn by rodents and should not be used. Non-corrodible metal screen should be used.

4. My tank is 20 years old and does not meet the current design criteria. Are you going to cite me for a significant deficiency or violation during my next sanitary survey?

New or modified water facilities must meet the design criteria, but your inspector will not issue a significant deficiency if your existing tank does not meet the current design requirements unless there is a condition that is a potential threat to public health (examples include unprotected openings to tanks, missing/damaged screens, unsealed/un-gasketed hatches, etc.).

5. Does the Storage Tank Rule apply to all my tanks?

The storage tank rule applies to finished water storage tank(s). “FINISHED WATER” or “FINISHED DRINKING WATER” means water that is supplied to the distribution system of a public water system and intended for distribution and human consumption without further treatment, including disinfection contact time, except treatment as necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition of corrosion control chemicals). If you need help determining if a tank is considered to be part of the treatment system or part of the distribution system, please email us at: cdphe_wqcd_fss_questions@state.co.us

6. What should I do to maintain my Contact Time tanks that are not part of the distribution system?

We recommend that you consider following the Storage Tank Rule guidelines for Contact Time (CT) tanks to avoid a potential risk to public health but it is not a requirement. Your inspector will be looking at all tanks including the contact time tanks during your next sanitary survey and any potential risks to public health (example: unprotected openings, missing/damaged screens, unprotected overflows, sediment buildup) will be cited as significant deficiencies.

7. When are you going to make me do the Storage Tank Rule for my Contact Time Tanks?

The Division does not have any current plans to re-open the Storage Tank Rule however, the tanks must still be maintained and will be inspected during sanitary surveys.

We hope sharing these questions and answers from the Colorado Rural Water Association helps all operators. If you have any questions please feel free to reach out to us at: cdphe_wqcd_fss_questions@state.co.us.

➽ Tom Valenta Field Services Section Work Group Lead, Unit 3 

➽ Heather Young Field Services Section Manager