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The Water Quality Control Division Field Services Section participated in the Colorado Rural Water Conference on March 18th during the WQCD round table discussions and received really great questions and feedback from operators attending the session. We wanted to share some of the questions related to Backflow Prevention and Cross Connection Control and Storage Tanks for those operators that were not participating in the conference.
Backflow Prevention and Cross Connection Control Rule (BPCCC)
BPCCC Resources
- Frequently asked questions
- Updated Backflow Guidance Document
- CDPHE Backflow Prevention and Cross Connection Website
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
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
