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Thursday, March 12, 2020

Ask Aqua Man

COVID-19 and Water Operation Concerns





















Dear Worried, 

Great questions! We are also concerned about the impacts of COVID-19. In fact, we have prepared an Frequently Asked Questions (FAQ) document about exactly your concerns. Please read through it. 


FAQ Highlights


During any type of emergency, the most powerful tool for public utilities is other utilities lending a hand. This was true in the large-scale flooding of 2013 as well as major forest fires and blizzards. Having a network of other utilities that you can rely on is highly valuable. 

Our primary recommendation to utilities is to make both your needs and your resources known on the CoWARN network. CoWARN is an organization that facilitates mutual aid and resource sharing between water and wastewater utilities, and it is free to join. READ MORE ABOUT IT IN THE FAQ.

If you are short-staffed, you would still need to sample, but please contact CDPHE during any specific emergency where sampling will be disrupted. We also recommend sampling early in the month (or monitoring period). That way, if staff become ill later in the month, at least there will be one less thing to worry about for that month. We are more than happy to help you prioritize and also to warn potentially impacted people. Also, it is important to announce your labor shortages during an emergency through the CoWARN network. 

Please check out the FAQ. If you have concerns that are not addressed in the FAQ, please let us know! It’s very likely that someone else has the same question, so we want to add it to the FAQ. You can also check out the news updates on our department COVID-19 webpage for the latest information on Colorado's COVID-19 efforts. 

Best of luck, 
-Aqua Man


Contacts


Drinking water  
Tyson Ingels | tyson.ingels@state.co.us 
Lead Drinking Water Engineer

Wastewater 
David Kurz | david.kurz@state.co.us
Lead Wastewater Engineer


Wednesday, March 11, 2020

Coaches' Classroom

Free online water and wastewater courses available

Mandatory Regulatory Training

On September 25, 2018, the Water and Wastewater Facility Operators Certification Board adopted a new requirement for certified operators: completing “an approved regulatory training course.” This requirement must be met every three years (100.14.5(b)). 

The board adopted Board Guidance 19-1 in June 2019, which established guidelines for the mandatory regulatory training (MRT) requirement and defined specific learning objectives for the MRT courses. The guidance did not apply to courses approved for calendar year 2019, but it does apply to courses submitted for approval in 2020.

The guidance established that there are two MRT tracks, one for water treatment and distribution operators and one for wastewater treatment, industrial wastewater treatment, and collections operators

The guidance also explained that approved MRT courses must include specific minimum content developed by the division. This significantly narrowed the universe of approved MRT courses for 2020. 

To address operators’ need to complete mandatory regulatory training, the board determined that free versions of each MRT course should be available online. Indigo Water Group was awarded a contract to develop the 2020 versions and host them on its website. The Colorado Certified Water Professionals (CCWP) web includes a Mandatory regulatory training courses page with direct links to each course, which can be taken on demand. 

Training units will be awarded through the CCWP Portal within a couple of days of completing an MRT course. Operators must claim the training units before the CCWP Portal will recognize that the MRT requirement has been met. 

If you need assistance finding the links to the MRT courses or using the CCWP Portal, please contact CCWP Office staff. They’re ready to help.


➽ Nancy Horan, operator certification board liaison

Thursday, March 5, 2020

Simple Fixes

Public Notice Requirements from Sanitary Surveys

Sanitary surveys are vital to protecting public health. During sanitary survey site visits, we identify and discuss violations of regulations 11 and 100, which we also report in the sanitary survey letters delivered to each public water system’s administrative contact. Any violation cited during a sanitary survey requires public notification to all of the system’s consumers. 

All public notifications must include the Ten Required Elements of a Public Notice. Distribution requirements vary based on the tier of the violation and the type of system where the violation occurred (e.g., city or town versus a campground). 

To help water systems meet their public notice requirements, we’ve created an online tool to help generate public notifications that are tailored to specific situations. The tool uses a google form to create a notification template, but you do not need a gmail account to use the tool. The tool helps you get started, but you still need to take the steps indicated below to complete the process.

Completing the process


If your system has received a violation during a sanitary survey: 
  1. Use our online tool public notice template generator. This will ensure that you have all of the 10 required elements in your public notice. 
  2. When completing the form, make sure that you select "sanitary survey identified violations - tier 2" or "sanitary survey identified violations - tier 3"  as the violation type.  
  3. After completing the form, you will receive an email with a link to a template for the public notification. The template will be available in Google Docs format so you can easily edit the template. 
  4. You will need to add descriptions for each violation, the date the violations need to be corrected, and the steps you will take (or have taken) to correct them.
  5. After you distribute the public notice(s), please submit a final copy, along with a certificate of delivery, through the department’s Drinking Water Portal

Frequently Asked Questions

What is the difference between tier 2 and tier 3 public notification requirements?


Tier 2 notifications must be distributed within 30 days and repeated every 3 months until the violation is resolved. Tier 3 notifications must be delivered within 365 days and repeated every year until the violation is resolved. Most community water systems meet this requirement by including tier 3 violations in their annual Consumer Confidence Reports (CCRs).


What are the requirements for distributing a public notification?


The requirements are slightly different for community and non-community systems:
  • For a community system (e.g., city or town), the notification must be: 
    • Distributed by mail or another direct delivery method to each customer and to other service connections; AND 
    • Any other method designed to reach all other consumers regularly supplied by the system.
  • For a non-community system (e.g., business, school, or campground), the notification must be 
    • Distributed by posting the notice in conspicuous locations throughout the distribution system frequented by consumers OR by mail or direct delivery to each customer and service connection; AND
    • Any other method designed to reach all other consumers regularly supplied by the system.

I need to include specific health effects language for a tier 2 violation. Where can I find that required language?


Many treatment technique violations do require specific statements warning consumers of the potential related health effects. Table 11.33-VI in Regulation 11, includes all of the standard health effects language. This language is also included in the template for any tier 2 violation as long as you select “sanitary survey identified violations - tier 2” as the violation type in the process to create a public notification described above.


If I distribute a notification for multiple violations and resolve one or more of the violations — but not all of them — can I modify and redistribute the notification?


Yes. This is an excellent way to inform your consumers not only of the violations but of the progress you are making to resolve each of the violations. 


Can I use my annual water quality consumer confidence report  to deliver a public notification?


Yes, as long as you meet the following direct delivery requirements:

  • The public notice must be directly delivered to all consumers and sent by at least one additional method designed to reach those that might not receive it directly. 
  • You must meet the due date for the violation. This may entail delivering the report before the report due date. 
  • You cannot utilize the direct delivery waiver that is available.


Still have questions? 


If you have any questions about sanitary survey-related public notice requirements, please contact the Drinking Water Compliance Assurance Section at 303-692-3556. 


➽ Tim Jones, drinking water compliance assurance