Aqua Answers: PFAS and Biosolids

Dear Aqua Answers,

Please help! I have multiple questions about PFAS and biosolids. 

Thanks,

Newt R. Sludge

__________________________________________________________________________

Dear Newt,

I have listed your questions and the answers below:

Question 1:

Can you remind me, what are biosolids? 

Biosolids are a product of domestic wastewater treatment processes. They are rich in nutrients and organic matter; farmers can use them as fertilizer to improve soil quality. The Colorado Department of Public Health’s Water Quality Control Division and the U.S. Environmental Protection Agency require biosolids to meet regulatory requirements for pathogens, pollutants, and land application to protect human health and the environment. Biosolids produced in Colorado are either land applied to agricultural fields as a soil amendment/fertilizer (70+%), composted (20+%), or disposed of in landfills.

Question 2:

How do PFAS get into biosolids?

Industrial, commercial, and residential use and disposal of PFAS products can allow these chemicals to enter wastewater treatment facilities. As a result, researchers have found PFAS in treated wastewater and biosolids. PFAS can move in the environment and potentially impact the soil, water, and crops.

Question 3:

What is the department’s approach to reducing PFAS levels in biosolids? 

The department has taken a proactive approach that aligns with EPA’s newly released Draft Sewage Sludge Risk Assessment recommendations and focuses on measuring and understanding levels of PFAS in biosolids and identifying and reducing significant sources of PFAS migrating to wastewater treatment facilities. The department began implementing its Biosolids-PFAS Interim Strategy on January 1, 2023. It establishes monitoring requirements for biosolids preparers and a threshold level for requiring biosolids preparers to develop and implement a source control program to evaluate potential industrial or commercial sources of PFAS. More information about our interim strategy and biosolids test results the department has received are available on our PFAS and biosolids web page.

Question 4:

What can people living in our beautiful state do to reduce the amount of PFAS entering the environment? 

Over the past several years, Colorado has committed to identifying where PFAS are entering the environment, stopping new releases, and protecting Coloradans. In many ways, Colorado has led the way in its efforts to track and reduce exposure to PFAS. The department is now focusing on carrying out actions in the 2024 PFAS Action Plan to continue our work as a leader among states addressing widespread PFAS pollution. To learn more, please visit the 2024 PFAS Action Plan webpage.

To protect the environment and reduce the amount of PFAS entering our wastewater treatment plants, we need to phase out the production and use of products containing these chemicals and find safer alternatives. Recent legislation in Colorado has banned the sale of certain products containing PFAS. We encourage people to get the facts and take steps to limit their exposure from other sources and avoid PFAS when purchasing consumer goods and new household products. This will protect your health and further prevent the chemicals from entering our environment. We have resources at our PFAS public health website.  

Sincerely,

Aqua Answers

Early 2025 CoWARN updates

The WQCD is sending the below updates in partnership with the CoWARN steering committee. We encourage all water and wastewater providers in Colorado to join the mutual aid network to enhance your preparedness for emergency incident preparation, response, and recovery. Please reach out to CoWARN administrator Kyra Gregory with any questions or if you have interest in joining the CoWARN steering committee made up of volunteers from water/wastewater providers in CO: kyra.gregory@state.co.us 303-908-7519. 

New CoWARN website launched, take action today!

Colorado's Water/Wastewater Agency Response Network launched a new and much-improved website in fall 2023! However, the new website could not retain all the information from the old website. So, all CoWARN members need to please update their membership profiles on the new website. So far, only 63 out of 246 CoWARN members have updated their membership information. Because of this there have been multiple CoWARN activations that many CoWARN members did not receive: Two Buttes 8/27/24, Gardner 8/29/24, Genoa 11/19/24. If you did not receive text or email notification of these activations, please take action today to update your contact information and system membership through the new CoWARN website.

How does the new website work?

As a CoWARN member your water or wastewater facility will have a profile on the website. Each member profile will assign primary users who can activate CoWARN to send out email/text messages to the CoWARN network. As a user under your facility’s membership, you will need to: 

1. Reset your personal password
2. Navigate to your dashboard by clicking on the red icon in the top right hand corner of the screen. 
3. Update your personal information - be sure to add a cell phone number as you will need to receive a text message to log into the site. 
4. Create your facility’s membership profile - Under “my systems” click “Add”. You are now the primary user for the membership profile. 
5. Assign other primary users by clicking “Add” under “System Contacts” 

For more information and videos explaining the process, please follow these instructions and reach out to Kyra Gregory with any questions or issues you encounter. 

New Mutual Aid Agreement 

The CoWARN steering committee has revised the CoWARN Mutual Aid and Assistance Agreement. Please sign and return a copy of the updated agreement to CoWARN administrator Kyra Gregory (kyra.gregory@state.co.us). See new MAA here. Please note this is the new agreement that went into effect on January 8th, 2025 regardless of received signatures. 

A short description of the updates is below. 

• Correct Colorado Revised Statutes references 
• Revise definitions of operational structure to better reflect current operations and create flexibility for any future structural changes
• Remove specific language regarding agreement expiration
• Clarify CoWARN’s role in activations and that CoWARN is not a guarantor in any transactions nor an administrator of transactions.

Program Manager message: Looking ahead after the 50th Anniversary of the Safe Drinking Water Act

In 2024 we celebrated the 50th anniversary of the Safe Drinking Water Act signed by President Ford in 1974. This landmark legislation set unified standards for water systems across the United States to protect public health. The Act set up a now time-tested framework in which EPA largely sets the rules and requirements via a defined process and with stakeholder input, and then states implement via primacy. As our work to improve public health continues, what factors and principles do we need to consider on our path through the next 25 to 50 years?

In December 2024, I had the opportunity to participate in and speak at a symposium at the University of Wisconsin on just this topic. The symposium was sponsored by the Water and Health Advisory Council, a multidisciplinary group of water professionals involved in drinking water and public health protection. The title of the symposium was: The Next 50 Years of Drinking Water in America. I participated in the “Prioritizing Risk” panel. 

Two of the risk reduction opportunities were identified as legionella and manganese. The upcoming federal revisions to the microbial and disinfection byproducts (M/DBP) rules should help us to start addressing legionella. Legionella is now a major cause of waterborne disease outbreaks, and the illness is sometimes fatal. At this point in time, it does not appear that a rule to address manganese is in the pipeline. Manganese has a health advisory, and some nervous system health risks similar to lead. However, another big risk was identified as losing the progress we have made due to aging infrastructure. Attendees were particularly concerned about distribution systems. Again, the M/DBP rules may help with some operational aspects of those, but the overall drinking water infrastructure situation is a serious concern. 

Are we approaching a time when affordability, especially for small systems, will jeopardize the ability to comply with rules for new contaminants and keep up with the fundamental infrastructure that a safe water supply relies on? Many people believe that we have already passed a tipping point in that regard and that small systems face truly daunting challenges over the next few decades.

So the question arises, how do we (as individuals, communities, states and a nation) pay for safe drinking water? It appears that all options need to be on the table. Currently, the Drinking Water State Revolving Funds that involve large infusions of federal dollars combined with the state programs that operate them and keep the money “revolving” through more and more loans is a great help, especially for small, rural communities. But this funding source is not enough. How much more funding can be gained from state and federal sources? Should we be exploring more public/private partnerships? Should drinking water be treated like education where small, rural systems are supported from the broader state population? What about individual assistance programs, like those that occur for power utility bills?

The answers to these questions are not known at present, but it’s important to ask them and work on solutions for the next decade and beyond. Look for more information about the next 50 years in drinking water in this space throughout 2025. Thank you in advance for your efforts to keep drinking water safe for the next half a century!

➽ Ron Falco, P.E. Safe Drinking Water Program Manager

Inspection Year 25 and Free TUs to Help Prepare are Here!

The Field Services Section (FSS) started the new Inspection Year 2025 (IY25) inspection year in October 2024 and the inspection year will end on September 30, 2025. A total of 506 sanitary surveys are planned for IY25. The list of suppliers included in the IY25 sanitary survey plan takes into consideration a number of factors including:

• Last sanitary survey date and EPA required frequency for sanitary surveys - community water systems are required to have a sanitary survey every 3 years, non-community systems are required to have a sanitary survey every 5 years.
• Recently activated public water systems are prioritized for sanitary survey.
• Other conditions or concerns may also lead to a prioritized sanitary survey.

Please note that if your system is due for a sanitary survey, your inspector may reach out to schedule the survey with you anytime during the IY25 inspection year (October - September) and that the scheduling is not based on the date of the previous inspection (i.e., will not be in March or after March every 3 years).

The Field Services Section also performs Level 2 assessments or Level 2 sanitary surveys as they are triggered under the Total Coliform Rule. Level 2 assessments are triggered by either an E. coli MCL violation or two Level 1 assessment situations occurring within 12 consecutive months. Level 2 assessments are site visits that include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired. Items also evaluated include changes in distribution system maintenance and operation, including water storage, that could affect distributed water quality, source and treatment considerations that affect distributed water quality, existing water quality monitoring data, and inadequacies in sample sites, sampling protocol, and sample processing. Level 2 sanitary surveys are a combination of the Level 2 assessment and a sanitary survey. Level 2 assessments/sanitary surveys must be performed within 30 days of the date of issuance of the violation that triggered the Level 2 assessment. More information on Level 2 assessments can be found in Regulation 11.16 - the Total Coliform Rule. Thankfully due to Colorado’s disinfection requirements, there are typically under five (5) of these events a year. 

Field Services recommends that suppliers take advantage of the free sanitary survey preparation course from the Local Assistance Unit on the third Wednesday of every month. Operators who participate will receive 0.3 training units. The training provides concrete steps for your system to prepare for your next sanitary survey including:

• The ability to recognize, address, and eliminate potential violations and system deficiencies
• Actions to take to address potential violations and system deficiencies before your survey

If you are interested in this FREE training, please visit this document and click on the date that you would like to attend and fill out the associated registration form. Please reach out to cdphe.wqdwtraining@state.co.us with any questions or feedback or if you do not receive an invitation email.

For any questions or concerns about sanitary surveys please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. We look forward to working with you on your next sanitary survey and thank you for all your efforts to protect public health!

➽ Heather Young, PE, CWP, Field Services Section Manager

Design Criteria Update 2024

The Design Criteria for Potable Water Systems (Safe Drinking Water Program Policy 5) are a key policy document for the department to make decisions on approval of new designs for water sources, treatment, and storage facilities. The document also serves as a guideline for repairing or upgrading waterworks that are cited as significant deficiencies during the department’s sanitary surveys. While systems are not required to modify their waterworks to meet the design criteria unless their current waterworks are deficient, they are required to consider the criteria as acceptable fixes whenever their current waterworks are found to be deficient.

The Design Criteria were last updated in 2022. While the Department generally performs updates every 4-5 years, the department decided that a limited update was needed in 2024 because the Environmental Protection Agency (EPA) set maximum contaminant levels (MCLs) for five per and polyfluoroalkyl substances (PFAS) in April 2024. 

This update incorporated PFAS treatment criteria into Chapter 4 - Treatment, and added PFAS to the source water testing requirements in Chapter 1.2.3 Water Quality Data. The Department also used the update project as an opportunity to address internal and external feedback on Chapter 7 - Storage Tanks, and Appendix A, and align these sections more accurately with our existing business processes. Editorial changes were made throughout these sections to correct errors and inconsistencies and clarify language.

Like in previous updates, the department convened groups of stakeholders to work on the criteria. There were two external workgroups and one internal workgroup: Storage Tanks, PFAS Treatment, and Appendix A (design review submittal requirements). Generally, the overall structure of this document remained the same between 2013, 2017, 2022, and 2024 including section headings and names. The following describes the updates to each section that came out of the workgroups:

• PFAS Treatment: The PFAS treatment workgroup incorporated treatment requirements for PFAS removal to align with EPA’s PFAS MCL. This update primarily focused on 4.10 Adsorptive Media. The updates to this section include minimum empty bed contact times and maximum flow rates for granular activated carbon, non regenerating ion exchange, and engineered resin media. Additional design submittal requirements were added for media selection justification, design capacity, operations and control strategy. Language was also added outlining when piloting is and is not required for adsorptive media treatment systems. The workgroup took into consideration the impacts that the updated requirements would have on small public water systems. 
• Storage Tanks: The storage tank workgroup focused on updating Chapter 7. The workgroup added language in 7.0.10 Roof and Sidewall that no longer allows corrugated roofs on storage tanks and clarified the requirements for storage tank interior construction materials due to difficulty protecting these types of roofs from contamination. The workgroup also further clarified requirements for vents, overflows, drains, and access openings after gathering internal and external feedback since the last update. 
• Appendix A: The internal Department workgroup updated Appendix A which covers the design review submittal requirements. This workgroup aligned Appendix A with the current Department business practices. Appendix A, Table A.1 was updated and now outlines if a waterworks project needs: Department design review, monitoring plan updates, professional engineer for community water systems, and the corrosion category. The workgroup's effort resulted in changes to the Design Criteria and not just Appendix A. 
• The Introduction and Chapter 1 were updated to reflect the changes to Appendix A including the removal of the limited scope process. 
• Chapter 4, Section 4.4.2 was updated related to 4-log virus inactivation capacity for triggered groundwater systems. Section 4.4.2 was updated to align with the Regulation 11 requirement for groundwater systems to maintain 0.2 mg/L at the entry point instead of requiring the capacity for 4-log virus inactivation. The Department still strongly recommends 4-log virus inactivation for triggered groundwater systems but the Department does not have staff resources to devote to this requirement given the limited amount of Fecal Indicator-Positive monitoring events in Colorado. The Department also has a strong and long-standing approach to evaluating water sources for being under the direct influence of surface water, so we do not view this change as jeopardizing public health protection.

➽Chelsea Cotton, Lead Drinking Water Engineer

What’s special about the Safe Drinking Water Act 50th Anniversary and Colorado?

Dear Aqua Answers,

When I read the recent Program Manager message about the 50th Anniversary of the Safe Drinking Water Act, I wondered how Colorado has specifically fared on that journey? Please let me know. Thanks,

Fan Attic

Dear Fan,

Thanks so much for your question! Indeed, a journey it has been. President Ford signed the Safe Drinking Water Act on December 16, 1974 after passage in both houses of Congress. President Ford had deep connections in Colorado, particularly in Eagle County. Ski runs at Vail and Beaver Creek ski resorts are named in his honor. But the story of safe drinking water in Colorado goes back much further than 50 years.

Before we were a state, typhoid and cholera were common killers in Colorado Territory and Denver was known as the filthiest U.S city. In 1890 almost 300 people in Denver died from typhoid when the population was 10 times less than today. This is not a count of people sick, but people dead! Drinking water filtration and disinfection eliminated typhoid deaths in Denver by 1940.

But waterborne disease outbreaks continued in Colorado even after the Safe Drinking Water Act (SDWA) became law with 40 outbreaks in the 1980s alone. Indeed implementing the SDWA in Colorado has been very challenging. EPA conducted an audit of what was then called Colorado’s Water Supply Program in 1974 and found that Colorado experienced “Disease outbreaks due to deficiencies at water systems” and that “Colorado is not meeting its responsibility” as a “direct result of lack of resources.” Over the next 20 years, the resource situation did not improve sufficiently relative to the workload attached to maintaining primacy (the authority to enforce the SDWA). In the early 1990s, EPA began the process of formally stripping primacy from Colorado due to “many problems with implementation and enforcement” directly “attributable to inadequate resources.” The program got a few more resources in that decade and hung onto primacy, but struggled again with the new rules that came in after the 1996 SDWA amendments. None of the rules was adopted on time, and in 2005 the Rocky Mountain News ran a front-page story stating that the program’s “staff shortage threatens the state’s future water supply.” Finally, by the end of the 2000s, things started to turn around; the program gained funding and resources from both state and federal funding sources. 

Unfortunately, disease outbreaks continued in Colorado up to 2008 when 1,300 people got sick and 1 person died in Alamosa. This event triggered big changes in the Safe Drinking Water Program and water systems across the state, and no regulated water systems have had an outbreak since. But outbreaks are a challenging metric to measure safety because so many epidemiological variables are involved. We believe this chart of E. coli violations by decade since the 1990s better reflects our progress. E. coli violations in Colorado are now rare and most of them in the 2020s have been in water systems that were previously unregulated. 

Undoubtedly, we have made great progress in Colorado in improving tap water safety. Our tap water in Colorado is safer than ever. We have adopted all new EPA rules adopted on time since the early 2000s. This is what EPA has said about Colorado’s program in recent audits:

• Colorado “manages a very effective drinking water program.”
• “The State continues to maintain good data quality ….”
• “EPA, once again, commends” Colorado “for … taking formal enforcement actions.” 

But as we move forward into 2025, the Safe Drinking Water Program and water utilities in general face considerable challenges spread over a number of areas. This is a partial list of challenges we will be facing over the next few years:

• Climate change
• Cybersecurity threats
• New federal rules involving lead, PFAS and the Consumer Confidence Reporting (CCR) rule
• Additional new rules expected to be finalized or drafted in 2025 including the Water System Restructuring Rule, M/DBP Rules and Perchlorate Rule.
• Struggling small systems including mobile home parks
• Aging workforce issues
• Increased demand for assistance and funding
• Aging infrastructure
• Addressing Environmental Justice
• Enhanced public and media scrutiny
• Emerging contaminants

Funding needs are substantial to address these challenges. We’ve seen great federal investment via the Bipartisan Infrastructure Law (BIL), which Colorado provided match funding to gain. But the BIL funding is slated to end in a few years, and Congressionally directed spending has led to considerable cuts in the base Drinking Water State Revolving Fund (DWSRF) that we normally rely on to support both the Safe Drinking Water Program and community infrastructure needs across Colorado. We must not let history repeat itself and allow a lack of investment to risk drinking water safety. 

To secure the needed investments in drinking water infrastructure: human, regulatory and constructed. We need public trust and confidence that this funding is merited and beneficial. We believe that adopting an industry-wide Culture of Health can support this goal. 

What is culture?

• Culture is a shared belief that connects our past, present and future. 
• Culture is a way of life. It’s how we do things.
• Culture is about our shared experiences, stories and history.
• Culture shapes our behavioral norms and institutions

Thus a Culture of Health in the drinking water industry means that we look at our daily routines and emergencies through a lens of protecting people’s health. We are an industry that works 24/7/365 to provide safe drinking water to everyone, and crucially to maintain societal functionality via sanitation and fire fighting. We are relentless!

Thanks for everything you have been doing to protect public health in Colorado. Remember:

We are all vital public health infrastructure!!

Sincerely,

Aqua Answers

State Revolving Fund Improvements

The State Revolving Fund (SRF) is implementing improvements to the prioritization process that will go into effect in 2025. The goal of these improvements is to ensure that the highest priority projects have the best chance at receiving SRF funding throughout the year. This article covers the upcoming changes and some helpful reminders as you begin preparing your application for funding.

• To receive updates about the SRF Program and reminders about the upcoming eligibility survey, please sign up for the Grants and Loans mailing list here. 

What is changing?

The current process is based on a first-come, first-serve process and does not utilize priority points until the end of the application process. As a result, it can prevent projects that score a high number of priority points from receiving funding because they apply too late in the funding year when funding capacities are lowest. The new prioritization process will implement priority scoring early in the process and provide advance notice of project priority and funding opportunities. The criteria for project scoring can be found in Attachment 1 of the Drinking Water Revolving Fund and Water Pollution Control Revolving Fund Intended Use Plans (IUPs).

Under the new process, priority points will be used to determine when a project may submit a loan application. Projects that score at or above the threshold may apply at any loan cycle during the year. Also, any borrower that qualifies as a disadvantaged community (DAC) is eligible to come in at any cycle. Projects that score below the threshold may only apply at the “Open” cycles. The priority point threshold for the WPCRF program is 100 and the threshold for the DWRF program is 110 points. Applicants will be provided a preliminary score at the prequalification stage and a final score at the project needs assessment stage. Please see the proposed schedule for "Open" and "Limited" cycles:

• January 5th (leveraged) - Open
• February 5th - Open
• April 5th - Limited
• June 5th (leveraged) - Limited
• August 5th - Limited
• October 5th - Limited
• November 5th - Limited

When will this go into effect?

The changes will go into effect in 2025. The current process will remain unchanged until that time. The 2025 IUP’s have been approved by the Water Quality Control Commission and will be posted on the website later this year. A list of FAQs can be accessed here. 

Helpful Tips & Reminders

In order to apply for SRF funds, you have to complete the eligibility survey which is the first step in the SRF process. The eligibility survey should be completed the year prior to be eligible for funding. The eligibility survey for funding in 2025 has been completed. If you are interested in future funding, be sure to complete the 2026 eligibility survey that will be open during the early summer of 2025. You will want to get signed up in the Colorado Environmental Online Services (CEOS) system to access the forms. The eligibility survey is not an application and completing it does not guarantee your project funding.

If you completed the 2025 eligibility survey and are planning on applying for funding in 2025, be sure you complete the Pre-Qualification form which triggers the next step of the process, the pre-qualification meeting. The Pre-Qualification form can be found in CEOS. During your pre-qualification meeting, your project manager will walk you through the loan process and the next steps. Here are links to the loan program steps for the Drinking Water Revolving Fund (DWRF) and Water Pollution Control Revolving Fund (WPCRF) and the main program page. 

If you have any questions about the SRF loan process, feel free to email cdphe_grantsandloans@state.co.us. If you need assistance navigating CEOS or form submission you can contact Angela Garcia  angela.garcia@state.co.us.

➽ Angela Green Garcia, Drinking Water Training Specialist

➽ James Wheatley, Project Manager