The five-year anniversary of the Storage Tank Rule (Regulation11, Section 11.28) is just a few months away - April 1, 2021. It will get here fast!
Updates to Regulation 11
The department proposed modifications to improve the Storage Tank Rule and two other sections of the regulations, Public Notification and Sanitary Survey rules. The department completed a stakeholder effort and presented these modifications to the Water Quality Control Commission. The Commission approved all proposed modifications in August 2020. The new regulation was effective on October 1, 2020. The Storage Tank Rule (Regulation 11, Section 28) protects public health and public water systems from potential contamination associated with unprotected storage tanks within the public water system’s drinking water distribution system.
The storage tank rule helps ensure public health protection by having suppliers routinely inspect finished water storage tanks so that sanitary defects are rapidly identified and corrected. This goal is achieved by requiring two key activities:
- Periodic inspections of all unpressurized tanks downstream of the entry point, unless an alternative plan is approved; and
- Comprehensive tank inspections no more than every five years.
The intent of the rule modifications in the summer was to provide additional flexibility to water suppliers while continuing to protect public health. Feedback from suppliers over the three-plus years of implementation also contributed to the regulation improvements. The most important change is that periodic inspections are now only required twice per year, evenly spaced, instead of quarterly. However, the department still recommends that these be conducted quarterly if the tank is safely accessible year-round.
Comprehensive Inspections
Also, as the April 1, 2021 deadline approaches for comprehensive inspections, it is important to remember that there are key responsibilities that the supplier of water or operator have rather than the tank inspection company:
- Properly identifying sanitary defects - based on Safe Drinking Water Policy 10, suppliers should interpret all tank inspections and accurately identify sanitary defects. Violations will be issued during the Sanitary Survey if a supplier reviews a tank inspection report and fails to identify a sanitary defect when it is clearly a defect.
- Appropriately setting a schedule to correct any defects identified and documenting their resolution.
Often, sanitary defects identified at storage tanks that are found during a sanitary survey are issues that should have been identified during a periodic or comprehensive inspection and corrected relatively quickly. Common issues include things like cracked, missing, or incomplete hatch gaskets, holes or breaches in the tank that are easily identified by rust accumulation, over an inch of sediment in tanks and tank overflows without proper protection. The goal of the Storage Tank Rule is to have sanitary defects such as these identified and corrected quickly after a periodic or comprehensive inspection. Allowing sanitary defects to persist and instead rely on the three- or five-year sanitary survey frequency to identify them is not protective of public health and goes against the public health goal of the finished water Storage Tank Rule. Therefore, the department is citing all sanitary defects at finished water storage tanks that are identified during a sanitary survey as violations of section 11.28(4)(b)(iv) of the Storage Tank Rule. This violation of Regulation 11 is a treatment technique violation and will require that Tier 2 public notice is distributed.
How can you comply with the Storage Tank Rule?
The first place to start is the guidance and forms on the department’s website. Read the guidance and familiarize yourself with the forms. These resources describe what the department is looking for with regard to sanitary defects and tank inspections. During your sanitary survey, engage with your inspector regarding your periodic and comprehensive inspection program. Discuss the results of earlier periodic inspections and relate how you addressed discovered sanitary defects. Inspectors are more than willing to assist suppliers with implementing their storage tank inspection plan and the process in place to ensure that sanitary defects are quickly addressed. If you have questions regarding implementation of the Storage Tank Rule, please email the Field Services Section at cdphe_wqcd_fss_questions@state.co.us. The department and the supplier share the same goal – “Always Safe Drinking Water”.
➽Tyson Ingels, Lead Drinking Water Engineer
