Storage tank, cross-connection control, public notice, and sanitary survey rulemaking information

Updated alternative proposal language

The department has posted documents to the stakeholder website showing the draft alternative proposal language that was discussed during the June 24, 2020 stakeholder meeting. This is located under the heading "July 15 Workgroup DRAFT Alternative Proposal" at the bottom of the page. It includes the changes discussed relating to periodic tank inspections and updates to the basis and purpose statements.

The department intends to submit this language to the Water Quality Control Commission on July 15, 2020. 

Comment Deadline: 
Monday July 13, 2020 at noon

Please email Tyson Ingels, Lead Drinking Water Engineer, with all comments by noon on Monday, July 13, 2020. Please visit the stakeholder website for information from previous stakeholder meetings. 

Upcoming stakeholder meeting

The department is hosting a final stakeholder meeting on the proposed changes to the storage tank, cross-connection control, public notice, and sanitary survey rules. 

Meeting - July 22, 2020, (1 - 2:30 p.m.)

The Zoom meeting will open at 12:30 p.m. so stakeholders have the opportunity to test functions beforehand. 

Online participation: Attend via Zoom

Call-in:  1-669-900-6833

Meeting ID:  846 2373 1238

Materials: Agenda and other materials will be available on the stakeholder website. 

Contact 

tyson.ingels@state.co.us

➽ Tyson Ingels, lead drinking water engineer

Emergency Response Plans

America's Water Infrastructure Act (AWIA)

Replacing vulnerability assessments

Many operators may remember conducting a vulnerability assessment back in 2002 as part of the Public Health Security and Bioterrorism Preparedness and Response Act. A lot has changed since then and many events have brought to light how vulnerable water systems really are and how much we take potable water for granted. Natural disasters, detection of elevated lead and the need to replace aging water infrastructure can all put safe water at risk. Congress decided to look closely at the condition of drinking water infrastructure and water quality along with the financial and technical challenges that many public water systems face today. 

Who is required to develop or update these plans?

In October of 2018 Congress enacted the America's Water Infrastructure Act (AWIA). As part of the AWIA, community drinking water systems serving more than 3,300 people are required to develop or update risk assessments and emergency response plans (ERPs). The AWIA specifies the components that the risk assessments and ERPs must address and establishes deadlines by which water systems must certify to EPA completion of the risk assessment and ERP. Submission deadlines of the certificates that the risk assessment and ERPs are complete have passed or are quickly approaching, as shown in the table below.

Certification Deadlines

 

POPULATION SERVED	RISK ASSESSMENT PLAN	EMERGENCY RESPONSE PLAN
Greater than 100,000	March 31, 2020	by Sept. 30, 2020
50,000 to 99,999	Dec. 31, 2020	by June 30, 2021
3,301 to 49,999	June 30, 2021	by Dec. 20, 2021

Resources

EPA's AWIA - Risk Assessments and Emergency Response Plans

Information and trainings needed to complete a successful risk assessment and ERP, along with deadlines and how-to guidance.

Water Information Sharing and Analysis Center

Free webinars to educate operators and drinking water system owners on AWIA requirements.

➽ Tom Valenta, local assistance unit

Samplegeddon Results

Wrapping up Samplegeddon for 2019

Over the last year the department provided various updates through Aqua Talk articles regarding Samplegeddon – the year all nine-year, six-year, three-year, annual, six-month, quarterly, and monthly monitoring compliance schedules converged. While this convergence potentially created an increased sampling burden on many of our public water systems, it is necessary to ensure that safe drinking water is being provided to the citizens and visitors of Colorado. 

Because this occurrence happens just once every nine years, the department worked diligently throughout 2019 to remind water systems of their monitoring requirements. Now that Samplegeddon is over, here are some updates on the final compliance numbers and lessons learned.

Final Samplegeddon numbers

Based on the figure below, as of March 29, 2020: 

• Overall, approximately 98% of all routine sampling requirements ending on December 31, 2019 were completed.
• Out of the 15,088 sampling requirements, only 349 were not satisfied
• In total, 1,795 monitoring and reporting violations were issued for sampling requirements in the monitoring period that ended on December 31, 2019. For certain sampling requirements such as total coliform, multiple violations may have been issued. Additionally, due to late reporting, violations may have been issued for sampling requirements that are now marked as complete. 

Figure 1: Sampling Requirements for All Schedules Ending December 31, 2019

Lessons learned and recommendations

To avoid potential violations and reduce processing times, the department recommends the following:

• Collect and deliver samples to a certified laboratory early in your compliance period.
• Many samples were collected at the end of the 2019 monitoring period. This caused an increase in demand for laboratory services and made it difficult for laboratories to process sample results prior to the January 10th submission deadline. Several samples, which were collected at the end of the monitoring period, were analyzed and reported over two months after the submission deadline. Submitting results late is not an acceptable practice for future monitoring periods and may result in violations. 
• Collect gross alpha including uranium and combined uranium on the same day.
• Collecting samples on the same day can prevent errors in sample collection and cuts back on our data processing time.
• In order to be eligible to be subtracted in the gross alpha excluding uranium calculation, systems on a three-year, six-year, or nine-year monitoring schedule for gross alpha excluding uranium must collect the combined uranium sample within the gross alpha excluding uranium monitoring period and within 365 days of the gross alpha including uranium sample. In order to be eligible to be subtracted in the gross alpha excluding uranium calculation, systems on a quarterly monitoring schedule for gross alpha excluding uranium must collect the combined uranium sample within the same quarter as gross alpha including uranium. 
• Check the monitoring schedules of seasonal systems and collect required samples prior to depressurization.
• Fill out the chain of custody form for each sample bottle with the appropriate information (PWS ID, Facility ID, Sample PT ID, Collection Date, etc.) This will ensure that sample results are recorded correctly and automatically applied to the corresponding sampling requirement.
• Ensure sample results are submitted in a timely manner – even if they are not due yet!
• In some cases, reporting sample results long after they’ve been analyzed can result in violations. For example if a sample result is high enough to trigger increased monitoring, the supplier will be accountable for all monitoring periods in which they should have been on increased monitoring. Monitoring violations could be issued for all missed monitoring periods and compliance with the maximum contaminant level will be evaluated with the data received over the applicable monitoring periods – even if those quarters did not have data!

Closing Thoughts

Collecting water samples is critical to ensuring safe drinking water and protecting public health. It is impossible to know and, when necessary, improve the quality of our water supplies without sample collection. The department would like to thank water suppliers, operators, samplers, and laboratory analysts for contributing to an outstanding 98% compliance rate. This is something the department is very proud to be a part of. It could not have been achieved without the help of our tremendous partners. Bravo!

➽ Jamie Duvall, drinking water compliance assurance