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Friday, November 1, 2019

Program Manager's Message

Getting Ready For New Federal Rules


Colorado has not added any new or revised federal rules to the state’s Primary Drinking Water Regulations (Regulation 11) since the Revised Total Coliform Rule in 2016. That will change soon, though, as there are five new or revised federal rules on the horizon.

These include a new maximum contaminant level (MCL) for perchlorate, updates to the Lead and Copper Rule, an improved Consumer Confidence Report Rule, a new rule for consolidating drinking water systems, and a new PFAS rule that might set MCLs for some of these compounds.
What follows is a high-level overview of the expected changes, which we hope will help get ready for them.

Perchlorate Rule


The EPA probably will set an MCL for perchlorate and establish the necessary supporting provisions such as monitoring location and frequency, analytical methods, and compliance requirements. This rule was available for comment in the summer of 2019 and should be finalized in 2020 or 2021. States typically have two years to adopt a rule before initial monitoring begins, and the compliance date comes after that, probably in 2025.

Lead and Copper Rule


In October of 2019, the EPA proposed major updates to the Lead and Copper Rule, which has remained mostly unchanged since the 1990s. We expect substantial changes for lead service line inventory and removal, a new action level for lead, new sampling requirements, and new requirements such as corrosion control treatment if high levels are found. The EPA plans to finalize the rule in 2020.

Improved Consumer Confidence Report (CCR) Rule


America’s Water Infrastructure Act (AWIA), signed by President Trump in October 2018, requires the EPA to revise the old CCR rule to include bi-annual reporting in simplified language, with additional information on lead in tap water. The revisions must be issued by October 2020, so we expect implementation of the final rule in 2023 or 2024.

Consolidating drinking water systems


AWIA also requires the EPA to develop new rules allowing states to mandate assessments for consolidating or restructuring water systems that persistently violate health standards. This rule will also introduce financing incentives related to the Drinking Water State Revolving Fund (DWSRF). The timeline for these changes should be similar to the timeline for the improved CCR Rule.

PFAS Rule


We expect the EPA to make a regulatory determination regarding whether to establish MCLs for PFOA and PFOS late in 2019. Because these rules involve MCLs, their structure should be similar to the new perchlorate rule. There is a great deal of public and political interest in these contaminants, which could mean the rule will move faster than normal, putting it on a similar timetable to the perchlorate rule.

All of these rules could take effect in the early to mid-2020s. We will keep you updated on future developments in upcoming Aqua Talk posts.


➽  Ron Falco, safe drinking water program manager

Cover Story

Filtration and Disinfection Monitoring Requirements

Man wearing protective eye equipment, checking numbers on an electric instrument panel and using buttons to adjust the settingPublic water systems that use surface water—or groundwater that is directly influenced by surface water—must remove or sufficiently inactivate microbiological contaminants to ensure that drinking water is safe. This requires at least two pathogen barriers, one to filter and one to disinfect. Water systems confirm proper filtration and disinfection by monitoring for turbidity, chlorine, pH, and temperature. We may cite systems during sanitary surveys if they are not properly monitoring for each parameter. 

For filtration, the state’s drinking water regulations establish performance criteria based on surrogate monitoring of turbidity, which is the industry standard. For chemical disinfection, performance criteria are based on pH, temperature, and chlorine residual, which correspond to an estimated treatment using log inactivation equations. Appropriate monitoring consists of several key steps.

Key steps

  1. Monitoring in the correct locations
  2. Selecting appropriate equipment/instruments to monitor the parameter in question
  3. Using proper techniques to monitor
  4. Calibrating and verifying instruments in accordance with state and federal requirements
Most of the requirements for turbidity and chlorine residual calibration originate in the federal Safe Drinking Water Act. Therefore, the state cannot set less stringent requirements. Below are summaries of the requirements for each parameter.

Turbidity 

  • Online turbidity analyzers must be calibrated quarterly
  • Continuous monitoring means that measurements must be recorded at least every 15 minutes
  • Signals should be averaged over about 30 seconds to 1 minute but must not be averaged over 3 minutes
  • Results should be verified once per week with an alternative method, but this is not required

Chlorine analyzers 

  • Online chlorine analyzers must be verified with a handheld method once per week
  • Continuous monitoring means that measurements must be recorded at least every 15 minutes
  • Signals should be averaged over about 30 seconds to 1 minute but must not be averaged over 3 minutes

pH/Temperature 

  • Must be analyzed immediately after collection and never sent to the lab
  • pH must be calibrated daily 

A few systems in Colorado disinfect with ultraviolet light, chlorine dioxide, or chloramines, which require additional monitoring that will not be covered in this article. We work with systems that use these technologies on a case-by-case basis. Additional information can be found in our Policy 4 Guidance on Proper Operations of Water Treatment Processes.

Below are some resources that will give more specific information about the requirements outlined above. If you are concerned about your instrument monitoring system and calibration protocols, please contact Tyson Ingels at tyson.ingels@state.co.us.

Additional Resources


Colorado Primary Drinking Water Regulations
Safe Drinking Water Act


➽ Tyson Ingels, lead drinking water engineer