Reg. 11 Policy Updates for Storage Tank, Backflow Prevention and Cross-Connection Control

In August of 2020, the Water Quality Control Commission updated the Colorado Primary Drinking Water Regulations (Regulation 11). While there were a few minor changes to several rules, there were also more significant changes to the Storage Tank Rule (Section 11.28) and to the Backflow Prevention and Cross-Connection Control Rule (Section 11.39).
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 Backflow Prevention and Cross-Connection Control Rule (Regulation 11, Section 11.39) protects public health from contamination associated with cross-connections and backflow events. 
During the stakeholder work for the August 2020 rulemaking, the department acknowledged that several key policies would need to be updated as a result of a successful rulemaking effort. Also, the department acknowledged that additional work on guidance documents (such as the annual backflow report template and the periodic tank inspection checklist) needed to be completed. 

Looking for feedback on policies 

There are four key policy documents that must be updated to reflect the new language in Regulation 11 and we are seeking feedback on the changes. These were established policies the department published after the 2015 Regulation 11 rulemaking, but given the Regulation 11 updates in 2020 there were items that needed updating and clarifying. Once the policy changes are finalized the department intends to launch a second stakeholder process to update the guidance documents associated with the rule.
Policy 7: Backflow Prevention and Cross-Connection Control Policy
Policy 10: Sanitary Defect Policy (section about storage tanks only)
Policy 12: Storage Tank Rule Alternative Inspection Schedule Policy
Policy 15: Storage Tank Rule Inspection Methods Qualified Personnel Policy

Feedback and next steps

The feedback submittal period on the policy changes concluded on February 19, 2021. Thank you for your thoughtful comments on Policies 7, 10, 12, and 15. The department will address these comments soon and post the updated policies and comment response tables to this website. Check back for updates in late March or early April.

The next phase of the project is to update guidance and reporting forms for the Backflow Prevention and Cross-Connection Control Rule. We will issue announcements about that process when we kick it off in April or May. 

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Tyson Ingels | 303-692-3002