Coaches Classroom: Writing and Implementing a Storage Tank Plan

Over the last decade, since the Storage Tank Rule was adopted into the Colorado Primary Drinking Water Regulations, much progress has been made by Public Water Systems to protect their finished water quality by conducting more frequent and thorough tank inspections. 

Since that time, rule implementation has been clarified and improved via policies and tools as questions have arisen. These policies can be accessed through the Colorado Department of Public Health and Environment’s (CDPHE) storage tank website or by searching your favorite web browser for “CDPHE drinking water storage tank rule.” You can also try use these useful links: 

• Inspection Plan Template
• Storage tank handbook
• DW010 - Sanitary Defects
• DW015 - Storage tank rule inspection methods and qualified personnel

For new operators or systems who are unaware, a significant aspect of the rule specifies that systems create and implement a written plan for their inspections of these vital distribution assets. The written plan is a requirement that ensures all storage tanks after the entry point are adequately inspected and maintained, and that work is done within the timelines set forth in the regulation and done by qualified personnel. The importance of a written plan is that it helps guide you and your team through the entire storage tank rule by providing a roadmap that defines procedures and outcomes of the process.

Common questions operators and systems have regarding the Storage Tank Rule include:

Q: Who does it apply to?

A: Section 11.28 of the Storage Tank Rule states that all Public Water Systems (PWS) that utilize finished water storage tanks located after the entry point must comply with the requirements specified in this rule.

Q: Are storage tanks now inspected as part of the sanitary survey process?

A: Yes. The division reviews the tank inspection work being done by the public water system during sanitary surveys. All storage tanks, including finished water storage tanks, are subject to inspection during a sanitary survey, but these inspections do not take the place of the inspections that water systems need to complete. In addition, the system’s storage tank plan will be reviewed during the sanitary survey. 

Q: What are some of the other requirements of the rule?

A: As part of the rule, all public water systems must create a written storage tank plan, including inspection intervals.

• Other aspects of the written plan are;
• An inventory of finished water storage tank(s), including the following information for each:
• Tank type and construction materials (e.g., elevated, buried, etc.). 
• Volume in gallons. 
• Approximate dimensions. 
• Location. 
• Number of inlets, outlets, overflows, hatches, and vents. 
• Coating systems. 
• Date put in service. 
• Rehabilitation and major maintenance history. 

Q: Who oversees the certification requirements for storage tank inspections?  

A: In summary, there is no certification/license required for personnel conducting either periodic or comprehensive storage tank inspections. The PWS is responsible for vetting the individual or contractor that is inspecting their tanks to ensure that they are qualified and will be using the correct methods for inspection. More detailed information can be found in the Policy 15 if you have further questions.

Q: Is a tank cleaning the same thing as doing a comprehensive inspection?

A: No. Tank cleanings regardless of how robust do not constitute comprehensive inspections. Regardless of whether hired contractors or internal personnel are used to perform comprehensive inspections, a written preparation plan needs to be developed and utilized. To have the inspection count as a comprehensive inspection it must include a documented evaluation of sanitary, structural and coating systems conditions, as well as security and safety concerns. Please see Policy DW-015 section 4.11 for more information.

Q: Does the Storage Tank Rule apply to my clearwell?

A: Although the rule applies only to tanks after the designated entry point (EP), CDPHE recommends using a similar approach for all storage prior to the EP such as clearwells. When conducting Sanitary Surveys, inspectors are finding significant deficiencies associated with clearwells that are  similar to those found on tanks in the distribution system.

Q: What are some of the common tank deficiencies during sanitary inspections?

A: Common findings during Sanitary Survey Inspections of storage tanks include:

• Improperly screened vents, damaged vent screens
• Access hatches without complete gaskets or gaskets that have shrunk and do not seal against the frame.
• Overflow pipes with missing screens or flap valves that do not seat and form a seal when closed. 
• Failures of interior coatings 
• Sediment buildup exceeding 1-inch

Q: What is a sanitary defect? If a sanitary deficiency or defect is found, how long do I have to fix the problem?

A: A Sanitary Defect as defined in Regulation 11, section 11.3(68) means a defect:

• That could provide a pathway of entry for microbial contamination into the distribution system; or
• That is indicative of a failure or imminent failure in a barrier that is already in place.

Examples of common sanitary defects found at storage tanks can be found in the CDPHE”s storage tank inspections checklists and drinking water policy 10 section 4.2. 

The timeline for fixing sanitary defects is determined by the supplier in the corrective action schedule section of the supplier’s storage tank inspection plan.  The schedule should be both reasonable and practical and is affected by various factors including: severity of the sanitary defect, complexity of the correction, tank accessibility and corrective action costs. Corrective action schedules range from short turnarounds for quick and easy corrections such as vent screen replacements to longer scheduled completions such as hatch replacements and possible longer completions for more complex corrections such as replacing a tank roof. We recommend identifying potential sanitary defects in DW policy 10 and the storage tank handbook to draft your corrective action schedule. 

Q: What should I do if I or my system finds something that is concerning during a routine inspection or an issue is reported to us?

A: In cases where contamination or defects are discovered within the distribution system that could adversely affect public health, suppliers of water should immediately notify CDPHE by calling the 24-hour incident Reporting Line at 1-877-518-5608. 

If you are looking for additional easy read information regarding the Storage Tank Rule, previous articles of Aqua Talk can be found by using the “Search This Blog” function at the right of this article.  

If you have not started the process of creating a storage tank plan or are stuck and needing assistance, the Local Assistance Unit (LAU) Coaches are here to help. Please reach out to us via the Online Assistance Request form and we will be happy to assist you through the process.

➽ Steve Folle, Drinking Water Coach 

Why the Delegation of Duties is so Important

Resources: 

• You can find more information on the delegation of duties, including guidance documents, templates, and examples, on the Operator Resources webpage or on CCWP’s website.
• If you have any questions about the delegation of duties, feel free to contact Jessica Morgan (cdphe.facilityoperator@state.co.us). 

A written delegation plan is a tool that an ORC can use to authorize certified or uncertified individuals at a facility to perform specific tasks or activities related to the operation of the system. When used correctly, it enables an ORC to meet the regulatory responsibility of supervision over the operation of the facility and over the operational activities and functions of other facility operators, without having to be on-site 24-7. This may translate into cost savings, especially for smaller systems that don’t need and cannot afford a full-time ORC.

The written delegation plan also helps certified or uncertified operators understand the limits of their tasks and activities. That is, they know when they have to consult with the ORC. Keep in mind that only the ORC is authorized to make process control and system integrity decisions!

What makes an effective delegation plan? 

• Name of the facility/system, including the PWSID number or Permit number
• Name of the ORC who is delegating the task or activity
• Date range of delegation (delegation plans must be reviewed, and if appropriate, updated annually)
• Name and/or brief description of the task or activity
• Person(s) or Position Title of the individual(s) being authorized to perform the task or activity at the system
• Delegation limits identifying when the individual(s) must contact the ORC for further instructions
• Date of training provided by the ORC to the individual(s) being authorized to perform the task or activity
• If the task or activity isn’t already included in writing in the individual’s job description, the delegation plan should document the individual’s written acceptance of the delegated task or activity (regardless, this is best practice)
• Written standard operating procedures (SOPs) that provide detailed, step-by-step instructions for performing the task or activity.

A blanket statement delegating all operational responsibilities to an on-site individual does NOT meet the minimum requirements for a delegation plan because it does not identify specific tasks, nor does it identify the limits of each task.

Delegation is a specific ORC responsibility. An ORC cannot authorize a system owner or anyone else to delegate tasks to subordinate personnel. An ORC cannot delegate any responsibilities that are reserved to the ORC, such as process control or system integrity decisions. 

Keep in mind that an ORC is accountable for the consequences of tasks performed by individuals acting under a written delegation plan. Therefore, it is necessary for the ORC to provide adequate training and to routinely verify that each individual to whom tasks are delegated is performing the tasks correctly. Written SOPs are a best practice to help ensure consistency of performance.

Because the ORC has supervisory responsibility, the ORC needs to train the individual, verify the person’s understanding of the task, verify the individual knows where the written SOPs are kept and how to refer to them if memory fails, and confirm the individual’s willingness to follow the instructions. If an individual trained by the ORC is unwilling or unable to perform in accordance with the ORC’s verbal and written instructions, the ORC needs to take back the delegated tasks or activities from that person. Then the ORC must then perform the tasks personally or find another person to perform them.

Regulation 100 states that “certified operators in responsible charge shall protect the public health and the environment in the conduct of their duties.” An ORC who allows untrained or inadequately trained individuals to continue performing tasks or activities incorrectly is not protecting public health and the environment. An ORC who allows workers who do not adequately adhere to the training and follow established SOPs to continue performing delegated tasks or activities is not protecting public health and the environment.

Division field and compliance staff are seeing an influx of inadequate delegation by ORCs, uncertified operators making process control and system integrity decisions, or even instances where the ORC is a so-called “paper operator.” These are operators who are designated as operators in responsible charge (ORCs) but fail to adequately supervise the operation of their facilities. They are ORCs on paper only, or “an operator in name only.” The Water and Wastewater Facility Operators Certification Board (board) has revoked operators’ certificates for posing risks to public health and the environment when, as the certified operator in responsible charge, they have been inadequately and/or inappropriately delegating essential ORC duties and/or failing to provide adequate supervision of a facility. In Colorado, this behavior is considered negligence; it constitutes operator misconduct that can result in loss of certification. 

The bottom line is that the written delegation plan, when used correctly, is a great resource with benefits for the ORC, other facility operators, and system owners. When used correctly, it provides a lot of flexibility while still protecting the people we serve. Let’s keep our mission in mind and take the time to delegate responsibly and effectively!

➽ Jessica Morgan, Liaison for the Water/Wastewater Operator Certification Board