Drinking Water Compliance

Reducing Disinfection Byproduct Violations

Disinfecting drinking water ensures that harmful contaminants such as bacteria, viruses, and other microbial pathogens will not exist in the finished water. However, the disinfectant itself can react with naturally-occurring materials in the water to form unintended byproducts that may pose health risks. This means that one operational goal for drinking water systems is maximizing disinfection efficiency while limiting the formation of disinfection byproducts.

There are many types of unregulated disinfection byproducts. For regulated disinfection byproducts, the EPA lists possible health effects that include an increased risk of cancer, liver and kidney problems, anemia, and nervous system problems—especially in fetuses, infants, and children. The EPA also lists possible reproductive and developmental health concerns.

Figure 1. Number of Disinfection Byproduct Violations by Year 

Violations by year

Since 2010, the department has issued the following violations for disinfection byproducts: 

• 86 total haloacetic acids drinking water violations 
• 208 total trihalomethanes drinking water violations 

It appears that after falling from 2010 to 2014, the number of violations increased from 2015 through 2018 before declining again in 2019. The department is not certain of the exact reason this occurred as disinfection byproduct formation may be impacted by numerous factors (e.g., organic content in the source water, water age, disinfectant dose, etc.). 

Minimizing disinfection byproduct formation

Because numerous factors can impact byproduct formation, we provide detailed resources on the Disinfectant and disinfection Byproduct rules webpage. Below are several ways systems can minimize disinfection byproduct formation.

Managing disinfectant dosage. Overfeeding disinfectant can increase disinfection byproducts formation. Eliminating pre-treatment disinfection may help reduce disinfection byproducts formation. Any change in disinfection practices must not sacrifice adequate disinfection for consumers’ protection. Operators that can reduce disinfectant demand can reduce disinfectant dosage without sacrificing water potability. Surface water systems should conduct a disinfection profile before changing disinfection practices. (Reminder: changes in treatment must go through a design review, so please contact the department before changing treatment to discuss.)

Managing water age. The longer finished water sits in storage or in the distribution system, the more total trihalomethanes and haloacetic acids will form. Operators should pay close attention to storage tank turnover and water use and should flush tanks and lines if necessary.

Removing disinfection byproducts precursors prior to disinfection. Naturally occurring organic matter (NOM) reacts with disinfectants to create disinfection byproducts. Operators should understand raw water quality and how it changes. Algae blooms, spring run-off, and human/wildlife impacts in the source water area are examples of activities that contribute NOM to source water. Operators may want to test raw and finished water for various precursors, including total organic carbon (TOC), dissolved organic carbon (DOC), specific ultraviolet absorbance (SUVA) or bromide, to assess if the treatment plant removes disinfection byproducts precursors effectively.

Managing pH. Changing the pH can affect disinfection byproducts formation. Different disinfection byproducts will either increase or decrease as the pH changes.

Being aware. Higher water temperatures can increase disinfection byproducts formation. While operators may not be able to control temperatures, they can carefully manage other factors that form disinfection byproducts while temperatures are high.

Asking for help! Hire an expert to evaluate possible solutions for controlling your water system’s disinfection byproducts formation. Water systems can use disinfection byproducts formation potential tests or pilots to predict the success of a proposed solution.

➽ Emily Clark, Nicole Grazianio and Bryan Pilson, drinking water compliance assurance section

Lead and Copper Rule

Corrosion immersion testing - Chloramine conversion project set-up

In early 2020, the City of Craig’s drinking water treatment plant will switch disinfection treatment from standard chlorination to using chloramines, and to the disinfectant  residual will change from free chlorine to chloramines. This change is being made to address frequently low free chlorine residuals in their distribution system. This change may impact distribution system corrosion as well as lead and copper levels at customer’s taps. Instead of waiting to see if any negative corrosion impacts arise, Craig and the department have teamed up for an experiment to test the potential corrosion impacts of the chloramine treatment change. 

The experimental testing approach is an immersion study—also known as a coupon study—which involves putting small metal samples (or coupons) in test waters to see if the lead and copper concentrations are different. For Craig, the test waters are the current free chlorine potable water (control scenario) and future chloramine water (chloramine test scenario). Since materials vary in the distribution system, three materials are being tested: lead, copper with lead solder, and brass. Each material will be tested under current and future water conditions, with the water in the jars being changed out three times per week (see the experimental set up in the photo above). 

For the first half of the 12-week experiment, all of the sample jars are filled with the current free chlorine water. This stabilizes the metal samples and models the current conditions of the distribution system pipes. For the rest of the experiment, half of the jars are filled with the current free chlorine water (control scenario) and half the jars are filled with the future chloramine water (chloramine test scenario). The city’s water treatment staff create the formulated chloramines water and sampling water and refresh the jars three times per week. They then combine the three samples into a single sample per week, which is called taking a weekly composite sample. Each week during the testing period, the Craig staff sends the lead and/or copper composite samples to the state lab for testing. The testing began in early October 2019, and we expect results in early 2020. 

Please note that the experiment will not model the lead and copper concentrations at customer’s taps. Instead, the immersion study will give relative results. In other words, the study as designed will identify if the switch from free chlorine to chloramines will potentially increase the lead and copper from different pipe materials once chloramines are in full-scale use. 

For more information on immersion testing please see the department’s Lead and Copper Corrosion Bench-Scale Testing Guidance Manual.

➽ Tyson Ingels and Melanie Criswell, drinking water engineers

Coming down the pipe

Storage Tank Rule - five year milestone - defects to be cited

The five-year anniversary of Regulation 11, Section 11.28, better known as the Storage Tank Rule, is coming in April 2021. Why does that matter? There are two important things to remember about this milestone: 

1. First, comprehensive inspections of all finished water storage tanks must be completed, as required by 11.28(2)(a)(iii)(B). 
2. Second, after five years of periodic inspections by suppliers, the department will begin citing any sanitary defects observed during sanitary surveys as violations of the storage tank rule.

Increase public health protection

The Storage Tank Rule was designed to increase public health protection by having suppliers routinely inspect finished water storage tanks so that sanitary defects would be rapidly identified and corrected. This goal is achieved through three key activities: 

• Quarterly periodic inspections of all unpressurized tanks downstream of the entry point, unless an alternative plan is approved
• Comprehensive tank inspections conducted at least once every five years.
• Fix any problems detected during these inspections

Remember - the most important activity of these three is to fix any problems detected during these inspections.

Our sanitary surveys over the last three years show that the second most common finding is a sanitary defect at a finished water storage tank - accounting for 12% of all sanitary survey findings during this period. Often these are problems that should have been identified during a periodic inspection and corrected quickly: cracked, missing, or incomplete hatch gaskets; holes or breaches in the tank that are easily identified by rust accumulation; and tank overflows without proper protection.

Identify and Repair

The goal of the Storage Tank Rule is to quickly identify and repair such sanitary defects after periodic inspections. Relying instead on the three- or five-year sanitary survey to identify them does not adequately protect public health. After Oct. 1, 2021, the department will cite sanitary defects identified at finished water storage tanks during sanitary surveys as violations of section 11.28(4)(b)(iv) of Storage Tank Rule. This violation of Regulation 11 is a treatment technique violation and will require distribution of Tier 2 public notice within 30 days.  

What can suppliers do to prepare in the meantime? 

Start with the guidance and forms on the department’s storage tank rule webpage. Read the guidance and familiarize yourself with the forms. These resources describe what the department is looking for regarding sanitary defects and tank inspections. 

During your sanitary survey, discuss the results of earlier periodic inspections with your inspector and describe how you addressed any sanitary defects. Inspectors are more than willing to help suppliers implement their storage tank inspection plans and processes to ensure that sanitary defects are quickly addressed. The department and the supplier share the same goal – Always Safe Drinking Water.

➽ Greg Naugle, former field services manager

Optimal Corrosion Control Treatment

Inter agency stakeholder collaboration for the win!

In 2012, Denver Water exceeded the lead and copper rule’s action level of 15 ppb for lead in drinking water. For each set of tap water samples collected by a water system during a given monitoring period, the 90th percentile concentration of lead is calculated and compared with the action level. If the action level is exceeded, then a public water system must take action. 

The lead and copper rule is unique in several ways:

• It requires “first-draw” sampling at kitchen sinks
• There is no maximum contaminant level (MCL), but rather action levels for both lead and copper
• Public education on lead exposure is part of the treatment technique
• There is a requirement to reduce the overall corrosivity of the water

EPA did not set a drinking water maximum contaminant level for lead because the Centers for Disease Control has deemed there to be no safe level of lead in drinking water. Therefore, when a system exceeds the action level for lead, it is required to take steps to reduce lead and ensure its treatment processes are optimal for minimizing lead exposure at customer’s taps. 

In such cases, the Safe Drinking Water Act and the Colorado Primary Drinking Water Regulations (Regulation 11) require the water provider to install and operate optimal corrosion control treatment (OCCT). A treatment is called “optimal” when it is identified as the best option to reduce lead at the customer's taps while not causing the water system to violate any other part of the Colorado Primary Drinking Water Regulations. If the division determines that a provider’s current treatment is not optimal and a different treatment is designated as OCCT, then the system must install the new OCCT to reduce lead at a customer's drinking water taps within 24 months. 

OCCT Study

After 2012, Denver Water undertook multi-year studies to determine what the best treatment is for lead control in their system. After an initial desk-top study proved inconclusive,  a pipe-loop study was conducted that involved harvesting lead service lines from their system and testing them with different treatment regimes. The study took multiple years to complete because harvesting lead service lines is time consuming and difficult, and running a pipe loop study takes large investments of staff time and expertise. 

In September 2017, Denver Water submitted their report showing that orthophosphate reduced lead by approximately 70% while pH reduced lead by approximately 45%. Despite this difference, Denver Water suggested that the department designate pH as OCCT largely because phosphorus could have negative impacts on waterways. In accordance with Regulation 11 and consultation with EPA, the department designated orthophosphate as Denver Water’s OCCT in March 2018.  

Community concerns

The water and wastewater communities had notable concerns about the long-term implications of adding phosphorus including watershed impacts (e.g. large treatment costs at wastewater plants to remove phosphorus, algal blooms in receiving waters, etc.) and downstream drinking water impacts. Because there were many shared concerns, the department signed a memorandum of understanding (MOU) with several parties agreeing to work together to avoid litigation, discuss additional studies, and investigate potential opportunities to implement OCCT and reduce environmental impacts. The MOU included the following success statement:

MOU Stakeholders will collaboratively seek long-range regional solutions that maintain public trust and protect public health and the environment per the Safe Drinking Water Act and the Clean Water Act, while additionally minimizing impacts to water supplies, wastewater treatment plants and watersheds.

The department organized a stakeholder process to investigate whether the OCCT designation could be modified to protect both public health and the environment. During this effort, stakeholders reviewed findings and recommendations from technical working groups regarding drinking water, wastewater and watershed interests. This stakeholder process concluded in September 2019. The final Watershed and Wastewater Stakeholder Summary Report provides the results of this effort. 

During the stakeholder work, Denver Water, CDPHE, and EPA explored whether pH adjustment alone could achieve similar public health protection. Based on study results for lead service lines, pH adjustment is not equivalent to orthophosphate. However, at homes served by copper with lead solder (pre-1988 homes) that don’t have a lead service line, both orthophosphate and pH adjustment (adjusting pH to 8.8) will result in lead levels below 5 ppb for copper with lead solder homes. Below 5 ppb, the difference between the performance of orthophosphate and pH adjustment was very low in terms of risk to public health. Therefore, the department concluded that if customers with lead service lines could be provided filters and the lead service lines eventually removed, Denver Water could use pH adjustment as OCCT. 

Concurrent to this stakeholder work, Denver Water, CDPHE, and EPA cooperatively negotiated a possible alternative to OCCT where Denver Water would undertake large-scale public health interventions in lieu of implementing orthophosphate. For an alternative like this to be allowable, both CDPHE and EPA would have to take regulatory action. CDPHE would have to modify our 2018 OCCT designation and USEPA would have to grant a variance from the requirement to install and operate OCCT. Denver Water submitted a request to EPA for a variance from the Safe Drinking Water Act in September 2019. Also in October 2019, Denver Water requested that the department modify their original designation acknowledging the new data that had been generated over the two year period. 

Denver Water's Variance Request - Key Elements

• Comprehensive outreach and education about lead in drinking water, and the steps taken to reduce exposure, to the 1.4 million customers served.
• At-home pitcher filters, replacement cartridges, and follow-up surveying for all users who drink water from a lead service line.
• Refinement of Denver Water’s existing inventory of homes that have lead service lines to ensure accuracy.
• Replacement of all lead service lines within 15 years, including cities served by Denver Water (e.g. Wheat Ridge).
• Implementation of pH control at a high level (near 8.8 vs. currently 7.8) to further reduce lead.
• Focus on health equity and environmental justice in rolling the program out, for example, prioritizing neighborhoods where cultural factors may inhibit filter use.

In November 2019, the department submitted two documents to EPA and Denver Water in response to Denver Water's request for variance. The department sent EPA a letter of support for the variance and a modification letter to Denver Water with regards to the March 2018 department decision. 

On Dec. 16, 2019, USEPA granted Denver Water's variance request.

The department views the outcome of this process to be best for public health and the environment while also being more cost effective and addressing an inherent environmental justice issue (lead in drinking water). The department is looking forward to working with the agencies to oversee Denver Water’s implementation of this variance and to partner with Denver Water to remove a major source of lead from the region’s drinking water.

➽ Tyson Ingels, lead drinking water engineer

Funding Opportunity

Lead testing in schools and daycare

In January and February 2020, the Water Quality Control Division (WQCD) will launch a new voluntary program to provide grant funding for lead testing in drinking water at both schools and child care facilities (CCF) across the state.

The program will award grants primarily to local public health agencies (LPHAs) and county governments for sampling in their local jurisdictions, prioritizing elementary schools and child-care facilities in low-income areas and disadvantaged communities as much as possible. 

Sampling locations will target:

• exposures for children age 6 or younger
• older facilities that are more likely to contain sources of lead
• established and sustainable child care programs

This program, which will run through September 2021, is based on EPA’s 3T’s guidance document for training, testing, and taking action. Test results will be shared with our department, local health departments, school district representatives, parents, teachers, and the general public.

Our goal is to reduce lead exposure at these facilities by raising awareness of lead risks, testing for lead concentrations in drinking water, identifying potential lead sources, and taking action to reduce lead exposure to children and the general public. 

We are currently developing guidance, procedures, and requirements for implementing the program. For further information, watch for outreach material and upcoming announcements of this program on our lead in drinking water webpage.

➽ Mike Beck, community development & partnership manager

Drinking Water Compliance

Lead Outreach Verification Effort (LOVE)

Background

In response to the events in Flint, Michigan, the Department of Public Health and Environment established the lead outreach and verification effort (LOVE) to improve implementation of the lead and copper rule in Colorado. The rule requires water suppliers to maintain a sampling pool of high-risk sites based on a tier schedule and materials evaluations that identify lead, copper, and galvanized steel within their distribution system. LOVE, which began in 2016, was designed to ensure compliance with these requirements.

The department set LOVE in motion with a letter in July 2016 to all community and non-transient non-community water systems required to comply with the rule. The department explained the events in Flint and the rationale for undertaking the LOVE process, ultimately requesting that water suppliers review and update their sampling pool based on the information compiled during completion of the materials evaluation form. The letter also included forms that described the tier schedule for sample sites and their corresponding characteristics, including construction date, interior plumbing materials, and service line composition. 

Considerations

In the summer of 2018, the department began reviewing all lead and copper sample pools to determine if water suppliers were sampling at appropriate high-risk sites. Those reviews were based on whether or not water suppliers submitted a sufficient materials evaluation, verified their sample site materials, maintained the appropriate number of sites in their sampling pool, and actually sampled at the sites specified in their sample pool. 

As water suppliers began reporting their materials evaluation forms and sample pool information, the department found that many water suppliers did not retain construction material records over the years and lacked a true understanding of the rule’s tier-level criteria for identifying high-risk sample sites. The department also found that many public water systems submitted inadequate materials evaluations or no materials evaluations at all, had not verified the plumbing materials at their sample sites, did not have enough sampling sites to satisfy monitoring requirements, or had sampled from sites that were not listed in their sampling pool. Throughout this time, we helped numerous public drinking water systems address these issues and better comply with the lead and copper rule via compliance assistance. We used the Lead and Copper Materials Evaluation & Sample Pools Fact Sheet to help us explain terminology and concepts. 

Findings and Progress

Through the LOVE process, the department reviewed all 956 water systems in Colorado that are subject to the rule and offered assistance to those that had not met all requirements. Beginning in July 2019 (three years after LOVE launched), the department issued 146 violations for systems that remained out of compliance with the rule. To date, 75 of those open violations have been resolved and 71 remain outstanding. The department continues to work with those 71 systems to bring them into compliance with the rule. Systems that have already complied with the lead and copper rule requirements must make an ongoing effort to ensure that their sample pool always includes the highest risk sample sites within their distribution system and to sample from those highest risk locations. Doing so is critical to ensuring safe drinking water for the citizens of Colorado. 

➽ Jamie Duvall, B.S., and Alex Hawley, M.P.H., drinking water compliance assurance 

Facility Operator Certification

2020 Approval of Courses for Training Units

We want course providers to have all of the information they need to design training courses and get them approved without difficulties or delays. Hopefully we’ve answered your questions below. 

If not—or if you’re having problems using the CCWP portal—please get in touch with the Colorado Certified Water Professionals office at 719-225-7339.

Submitting courses for training unit approval

Course providers must use the new CCWP portal to submit 2020 courses for training unit approval. Please do not create new portal accounts without contacting the CCWP office first (719-225-7339). When we migrated the old course catalog data to the new system, we created course provider accounts so the migrated courses could be associated with the appropriate providers. 

Once the CCWP office has verified your login credentials, you can begin to prepare your application. You can find video tutorials on the portal’s course provider information page along with written instructions to help you prepare and submit your application.  

Fees for course approval

Regulation 100 sets the fee for training unit course approval at $50 for individual courses or one-day events.  However, you may submit a batch of up to 10 courses on the same application for $50, and there is no extra charge for multiple offerings of the same course. The fee for multiple courses given as part of a single event—such as a conference or multi-day workshop—also is $50.

Getting your courses approved

The CCWP office’s guidance document for course providers, also available on the course provider information page, includes information about appropriate subject matter, fees, information to be included in your application, reasons why courses could be denied or approval rescinded, best practices, and expectations of the training provider.  

Issuing training units

After teaching a course, the trainer or course provider issues training units to participants directly through the CCWP portal using either the Uploading a Course Roster (for multiple course participants) or Entering Results (in situations where there are only a few course participants) options.

Trainers need to have operator ID numbers for every course participant to issue training units through the CCWP portal. Therefore, a new best practice is for the trainer to collect operator ID numbers as part of their pre-registration or sign-in process. Trainers may also find it helpful to collect email addresses. Course participants who are not yet certified can obtain operator ID numbers by registering in the CCWP portal.

Video tutorials and written instructions on the course provider information page will help trainers master the process of issuing training units via the CCWP portal.

Questions?

For assistance with the CCWP portal contact the CCWP office at
info@coloradocwp.com 
719-225-7339

➽ Nancy Horan, operator certification board liaison