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
