Acute team: How does the WQCD help you prepare for and respond to acute incidents?

Back in October, we discussed different types of acute health risks, what they are, how to report them, and how to prepare your water system. Today, we want to introduce the Drinking Water Acute Team at the Water Quality Control Division (WQCD) that responds to and supports public water systems when acute incidents occur.

What is an Acute Health Risk?

Common situations that may pose an acute health risk include:

• Loss of pressure in a distribution system over a large area, such as from main breaks, power outages, or planned construction
• Detection of Escherichia coli (E. coli) in finished water:
• When confirmed by a repeat sample
• Upon first detection if other information suggests the water may be unsafe
• When follow-up E. coli testing is not completed after a positive total coliform result
• Natural disasters that impact treatment, distribution, or source water quality
• Cross connection or backflow incidents that can create contamination
• Other circumstances that may result in contamination of drinking water

Acute Team Process and Response

When WQCD becomes aware of a situation that may pose an acute health risk, it convenes the Acute Team. This team is made up of experienced staff from multiple sections of the Safe Drinking Water Program.

The Acute Team will:

• Contact the impacted public water system to discuss the situation
• Determine whether the situation qualifies as an acute health risk
• Decide if public notification is required and what type and methods are appropriate
• Work with the system to identify the best course of action
• Specify any additional steps needed to eliminate the health risk

All actions are taken in accordance with Colorado’s Primary Drinking Water Regulations and Safe Drinking Water Program Policy 1: Response to Acute Health Threats at Public Water Systems.

Policy 1 helps WQCD protect public health and implement the Colorado Primary Drinking Water Regulations (Regulation 11). Its purpose is to outline the WQCD’s approach to protecting drinking water consumers from acute health risks using methods such as requiring public water systems to quickly notify customers when an acute health hazard exists.

What a typical Acute Team response looks like:

1. Responding to an incident report 

The Acute Team receives a report, often through the CDPHE Incident Reporting Line (1-877-518-5608), and contacts the impacted water system to gather details.

2. Evaluation of gathered information 

 

The Acute Team reviews the information provided and determines the appropriate response, including whether a boil water or bottled water advisory and associated Tier 1 public notice are needed. Reporting an incident does not automatically result in an advisory. For small water outages, please refer to our Pressure Loss Guidance. 

 

3. Steps to resolve the acute health risk

WQCD staff talk through the necessary actions to resolve the health risk with the water system. This may include:

• Public notice and distribution methods
• Repairing impacted portions of the treatment or distribution system
• Disinfecting and flushing the distribution system
• Identifying the number and location of follow-up samples
• Sampling to ensure the water is safe to drink
• Communicating actions taken and results to the WQCD

4. Ongoing Support 

 

We encourage you to rely on the network of associations, non-profits, county, and state partners as you respond to and recover from acute situations: 

 

WQCD: Acute Team remains available for questions and may check in periodically for updates. Additionally, the WQCD can review materials such as draft customer communications and sampling or flushing plans. We also offer support through our close relationship with Technical Assistance providers throughout the state, including but not limited to: WQCD Local Assistance Unit, Colorado Rural Water Association, Rural Communities Assistance Corp, Water Now Alliance, and many others.

CoWARN: The Colorado Water/Wastewater Agency Response Network is a coalition of drinking water and wastewater providers, engineers, technical assistance providers, and other water sector providers. The network aims to provide assistance between members during emergencies that affect your ability to provide drinking water and/or wastewater services to your customers and communities. Membership is free to join and easy to use.

Local Public Health Agencies and Emergency Managers: Working with your local public health agency is crucial to navigate an acute health risk. Many public health agencies have contacts with critical local customers (healthcare facilities, daycares, restaurants, grocery stores, etc.) and can help you coordinate communication and additional requirements for them. Local public health agencies may also support water delivery efforts and activate their emergency response teams. 

 

5. Resolution 

 

Once the water system has completed all required actions, the Acute Team reviews the steps taken and any sampling results. WQCD uses this information to confirm that the acute health risk has been resolved and will lift the boil or bottled water advisory. 

 

Emergency Planning

Public water systems should prepare for the steps in this response process in advance.
 

1. Work with partners: You have partners in a variety of state and local agencies. We highly suggest that you coordinate with them prior to an acute event to ensure fast and efficient emergency response.

•  Establish contact with local authorities, public health organizations, and other local water/wastewater providers. Identify up-to-date contacts and develop a communication plan.
• Reach out to your Local Emergency Manager and Local Emergency Planning Committee to ensure your system is part of the conversation about interdependencies with other critical infrastructure suppliers. Consider attending Local Emergency Planning Committee meetings to review emergency plans and incident command structure for your local response teams.
• Coordinate with your communications team to draft potential notices and make a plan to navigate delivering tier 1 public notices. 

2. Complete emergency management documents: The EPA has extensive drinking water-specific emergency management planning documents, templates, and checklists. Even if you have already completed some of these documents, please review them to ensure acute scenarios are covered.

• Risk and Resilience Assessment and Emergency Response Plan Templates
• Incident Action Checklists
• CDPHE Pressure Loss Response Guidance

3. Ensure you have CoWARN Access: If your system has had a CoWARN membership for decades or if you are a new member, we highly recommend that you log into the new website to ensure that you have the correct login credentials and that you are set up to activate CoWARN when the need arises.

• How to join CoWARN
• Action to take to log into new website and generate system profile
• How to activate CoWARN
• Please sign the updated Mutual Aid Agreement and submit it to the CoWARN admin - kyra.gregory@state.co.us

➽ Chelsea Cotton, Lead Drinking Water Engineer

➽ Kyra Gregory, Local Assistance Unit Manager

Program Manager message: Infrastructure Funding

During the 2020s, we have seen unprecedented federal support for funding drinking water infrastructure. However, it has also been complicated and challenging, and the future is uncertain regarding the continuation of federal funding. Yet it remains quite certain that water infrastructure needs for the next couple of decades will be enormous. The need stems from both replacing aging infrastructure and meeting new federal public health protection requirements, including lead and PFAS, with another major rule coming out in a couple of years to update the Microbial/Disinfection Byproducts (M/DBP) suite of rules.

As we reported in 2022, President Biden signed the $1.2 trillion Infrastructure Investment and Jobs Act (IIJA) into law in 2021. The IIJA appropriated significant funds to the State Revolving Fund Programs (SRF), which is administered by the Co
lorado Water Resources and Power Development Authority, Department of Local Affairs, and CDPHE. The Authority is the grant recipient for the SRF. DOLA evaluates the financial structure of the applicant’s application to the SRFs, and CDPHE manages the technical and compliance aspects of the SRFs. The funding is being allocated in essentially three “buckets,” including general infrastructure, emerging contaminants, and lead service lines. Initially, Colorado was projected to receive approximately $680 million over the five years. However, the actual awards have fluctuated to some degree due to adjustments made in Congress and reallocations of some of the lead money. 

At this point, we are four years in and have one more to go. This funding represents a major opportunity for Colorado. But the need for continued water infrastructure support is enormous, especially considering the new federal drinking water rules mentioned above. There has been talk across the sector about extending the federal infrastructure investment. At the recent annual conference of the Association of State Drinking Water Administrators (ASDWA), a panel regarding funding and finance recommended emphasizing the following points when communicating about water infrastructure needs:

• Positive impact for affordability. With so much pressure on rate payers these days, supporting water infrastructure is one way to support overall economic vitality and help keep water rates affordable. 
• Impact to small, rural communities. These communities tend to struggle most with tackling complicated, expensive infrastructure projects and these funding sources tend to help small, rural communities the most.
• Share responsibility. Federal, state and local governments all share roles and responsibilities for safe water, and infrastructure investments like IIJA demonstrate that commitment. 
• Fundamental societal need. Adequate infrastructure is a cornerstone of safe water which is foundational for the economy and national security.
• Specifically, for restoring SRF funding, the following points were discussed:
• Without the SRFs, loan forgiveness and many great assistance programs that benefit small, rural communities will be lost.
• SRF funding is vital to ensure the efficacy of many state primacy programs, which is a preferred option compared to direct federal implementation.
• The SRFs support water affordability in small, rural communities that cannot afford modern water infrastructure. 
• Commitment to the SRFs is needed because they provide below-market loans, even 0% interest loans and loan forgiveness (like grants), especially to small, rural communities.

We share a collective commitment with local governments to protect public health and ensure safe tap water for all. Sustained infrastructure funding can help us move forward toward that goal. Contact us if your community is interested in pursuing this funding. Thank you.

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

Dear Aqua Answers - Why are unknown service line materials bad?

 Dear Aqua Answers,

I submitted the Lead Service Line Inventory (LSLI) for my water system in October 2024, as required. We were unsure of the construction materials used in some service lines. So, there are some unknowns. Why do I still need to refine my inventory? I heard that unknown line materials are bad. Why?  

Please help. 

Thanks,

Lea D. Line

Dear Lea,

Thank you so much for submitting your initial Lead Service Line Inventory (LSLI) last year. We understand that many systems do not know all the construction materials used in all their service lines. The Lead and Copper Rule Improvements (LCRI) finalized by EPA in 2024 requires ongoing effort to identify service line construction materials and submitting a baseline service line inventory, including connectors, by November 1, 2027. This inventory is different than the initial inventory submitted in 2024. The baseline inventory submittal will establish your system’s baseline for identifying, prioritizing, and replacing lines that contain or may contain lead. 

Under the LCRI, each system must track its progress by calculating a service line replacement rate, which is based on the number of lead, galvanized requiring replacement (GRR), and lead status unknown service lines identified in the baseline inventory. The required Lead Service Line Removal (LSLR) calculation method and required percent removals of lead lines may jeopardize future compliance if you have a high number of unknown service lines that are later confirmed to be non-lead. This lowers the total number of lines in the replacement pool without crediting overall progress in identifying service line materials. This structural flaw risks forcing systems to meet unrealistic replacement rates and/or face non-compliance, even when they have effectively removed all known lead or GRR service lines or ultimately determine all unknown service lines to be non-lead. Customer refusals to allow service line material identification or line removal will also heavily influence system compliance into the 2030s.

This means that unknown service lines are bad for future compliance with LCRI. CDPHE will be communicating with EPA about these concerns and seeking additional flexibility. 

What can you do in the meantime? Make as much progress as possible on your system’s service line (and connector) inventory before the baseline inventory is due on November 1, 2027. Try to reduce the number of unknowns, especially by 2030.

The division continues to support water systems serving up to 15,000 persons by offering technical assistance provided by WSP. The program is currently operating on a wait list, and suppliers can sign up here to be contacted by WSP in the event that the division is able to provide additional funding for the program. Enrolled suppliers can request remote support or hands-on assistance, offered at no cost. The division has selected only one contractor to provide technical assistance to eligible water systems, and it will not reimburse systems for the costs of hiring outside contractors. Waitlisted suppliers should continue to work on their inventories while they await potential additional funding for the program. 

In addition, the division has a team of drinking water coaches available to help you with LSLI project management. Our team can coach your system as you: 

Identify and navigate grant and loan funding for service line identification and replacement 

 Navigate regulatory requirements, including inventory templates, communications tools, public notice and drinking water portal 

Draft and update your LSLI 

If you are interested in working with one of our coaches on your LSLI please fill out a coaching request form, and one of our coaches will reach out to assist you and your team. 

Thank you for your efforts to identify service line materials in your water system. 

Sincerely,

➽ Aqua Answers

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 

New Monitoring Schedule Website

The Drinking Water Compliance Assurance Section (DWCAS) is updating how Monitoring Schedules are displayed. Monitoring Schedules communicate water system’s sampling and reporting requirements, as well as additional compliance requirements. DWCAS recognizes that this is a significant change. Which is why the rollout of this change will be implemented in phases. Please share this article with others who may not have received it.

The new schedules come with added features (listed below) that will be beneficial to many users. The reasons for the change are complex: First, the current system has been in place since 2012, and is intertwined with our aging data system. Second, with our data system potentially nearing its end-of-life, and to ensure continuity with any potential future changes, we are transitioning to a new adaptable platform. Lastly, the new system will allow us to make updates faster, increase accessibility, and offer an interactive display. 

The new schedules are now available, along with the current system, at our drinking water monitoring schedule website.

Before diving into the features this new system has to offer, we encourage water systems to refer to our new Drinking Water Schedules Information and Guide or overview video. 

As a part of the update, the new schedules system allows for interactive tables. The tables within the monitoring schedule can be filtered by water system, operator, facility, analyte, monitoring period, frequency, and compliance schedule type. This means, associated contacts can filter to view all systems they are linked to. This will be helpful for contract operators managing multiple systems.

After using the filters, water systems are able to create a specific link that can be bookmarked or saved for future use. For more information about creating your own unique link, please refer to our Drinking Water Schedules Information and Guide. Using the link will automatically filter the report. The new system retains the ability for PDF downloads. For more information about downloading the report, please refer to our Drinking Water Schedules Information and Guide. The new system also allows for individual table exports for offline access. This feature will be helpful for large public water systems with requirements across numerous facilities. 

DWCAS recently made updates to the AIMS (Am I Missing Something) Tool. This update now shows all satisfied sampling schedules. The satisfied schedules section in the monitoring schedules links directly to the AIMS tool without extra filtering (this link is also available in SWIFT). This process is also more consistent as it uses the same system we use internally for determining compliance. Next, compliance schedules are linked to the website for systems to easily get to the relevant information and form. The new platform is better aligned with Colorado’s digital accessibility requirements (CDPHE digital accessibility).

Anticipated Questions:
Q: Why is this happening?
A: Our data system is nearing its end-of-life. Updating now positions us for continuous service regardless of the future data system. In addition, this will help us better meet accessibility requirements established by State law.

Q: How do I use the new system?
A: It is available at the same website. A detailed Monitoring Schedules Help Guide and overview video have been created to help users. It also includes steps for downloading as a PDF and exporting tables.

Q: How will I know that samples have been received in the new system?
A: Schedules in the new system contain a direct link to the recently updated AIMS Tool, providing confirmation of satisfied monitoring requirements. This has the following improvements:

• Fully aligned with how compliance is determined internally.
• Includes monthly schedules, so all analytes and frequencies are in one location.
• Shows the number of samples received (instead of just stating the schedule was satisfied).

Q: Will the data still be updated weekly?
A: Yes, there is no change to the data update frequency. The updated schedules and AIMs tool will be available every Thursday morning.

Q: When is this happening?
A: We are targeting a complete implementation of the new Monitoring Schedule platform in Winter 2025. However, to ease the transition to the new system, from now through January 2026, both monitoring schedules are available online. 

Q: I am having issues accessing my schedules. How can I fix this?
A: The monitoring schedules do not require a Google account to view. If you run into an issue, then your browser might not be up-to-date or a Google account might be tied to your browser. To fix this, you can try updating your browser, try a different browser (Chrome, Edge, Firefox, and Safari are all supported), or open a new window using Private or Incognito Mode (this will remove any saved login information). In the new Private window or Incognito Mode window, then try accessing the monitoring schedules.

Please do not hesitate to contact us during this transition for assistance. Thank you all for your commitment to Colorado’s drinking water and for your continued support as we update the Monitoring Schedule system. 

➽ Phillip Stanwood; Data, Records, and Reporting Unit Manager 

Colorado Adopts Federal PFAS Rule

Resources: 

• Frequently asked questions on PFAS Initial Monitoring 
• PFAS in Finished Drinking Water for PWS interactive and dynamic map 

The State of Colorado’s Water Quality Control Commission recently took final action in August 2025 and has adopted the April 2024 EPA PFAS National Primary Drinking Water Regulation into the Colorado Primary Drinking Water Regulations (Regulation 11). EPA has indicated that they plan to make changes to this rule and finalize them in 2026.  Colorado’s PFAS Rule will adjust to these changes, but remain at least as stringent as the federal rule to maintain program primacy. However, no changes are expected to the initial monitoring rule’s timeline. Many drinking water systems have already started these efforts. For the PFAS rule, all community and non-transient, non-community water systems are required to complete initial monitoring for PFAS in all entry points by April 1, 2027.

This is a public health protection measure to facilitate positive public health outcomes (and environmental protection) in Colorado and the nation. This class of omnipresent chemicals and their serious effects on human health have been recently addressed with this regulation, both in drinking water and PFAS reductions in source waters. Thanks to the new PFAS regulations, this class of chemicals can be monitored and public exposure issues addressed. 

The Water Quality Control Division (WQCD) wants to help water systems start sampling for per- and poly-fluoroalkyl substances (PFAS) now, reducing the sampling demand as systems prepare for this upcoming deadline. To this end, WQCD has been reaching out to systems that have yet to start PFAS sampling to notify them that we are offering to fund one-time sampling through the PFAS Grant Program. The deadline to apply for this free sampling opportunity is January 9, 2026. After this deadline passes, funding for one-time sampling will no longer be available, and systems will need to contact a certified lab and complete the sampling requirements as required under the regulation at their own expense.

The current six regulated PFAS chemicals and their respective Maximum Contaminant Levels (MCLs) include:

• PFOA - 4.0 ppt
• PFOS - 4.0 ppt
• PFHxS - 10 ppt
• PFNA - 10 ppt
• HFPO-DA (GENX) - 10 ppt
• Mixture of two or more: PFNA, PFHxS, GenX, and PFBS - Hazard Index of 1.0

Sampling results from initial monitoring will be used to determine the future compliance monitoring schedule for each system. If PFAS results are found to exceed the current MCLs, completing initial monitoring will also allow systems to fully understand their PFAS system issues and begin the appropriate planning to address the contamination. If treatment is necessary, funds like the PFAS Grant Program, the Emerging Contaminants in Small or Disadvantaged Communities Grant Program (EC-SDC Grant Program), and the State Revolving Fund are available to assist systems.

Unfortunately, some drinking water wells in remote rural areas have been shown to be vulnerable to PFAS contamination due to a variety of potential sources such as fire fighting foams, individual sewage disposal systems (ISDS), biosolids applications on farm fields, various industries, and landfills. PFAS compounds are pervasive in the environment, and early sampling can provide more opportunities for funding support. Fortunately, PFAS in drinking water is treatable, and the Division is here to assist public water systems and communities with technical and financial support.

➽ Adam J. Taubman Emerging Contaminants Coordinator 

➽ Claire Wadler PFAS Program Specialist