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Wednesday, October 28, 2020

Tips for Drinking Water File Uploads



The Drinking Water Portal is an easy-to-use, online way for water systems and laboratories to submit drinking water compliance data, reports and other files. The Portal is located at wqcdcompliance.com/login. Please note that first-time Portal users must create an account.

Best Portal Practices

  • Water systems and labs should submit compliance data in CSV (comma-separated values) file format. All other files must be in PDF or Excel format. Labs may not submit data as PDF or Excel files. 
  • Systems should always check with the lab first before trying to submit data via the portal. Many labs will submit the data on the system’s behalf. Checking with the lab will help prevent double reporting, reduce any possible errors, and improve data processing. 
  • When submitting files, ensure you select the correct file category type:
    • Certifications - PN or CCR or Seasonal Start-Up: Files related to Public Notification, Consumer Confidence Rule, or Seasonal Start-Up Certifications.
    • Enforcement: Files related to Department-issued Enforcement Orders (only use if the water system has an open enforcement order).
    • Inventory - System Updates: Contact updates, population forms, inactivation forms.
    • Inventory - Rule Updates: Files related to drinking water rules, such as Lead and Copper sample sites or materials evaluation, Total Coliform sample sites, sample site maps, LT2 sampling plans.
    • Requests and Other Certifications: Lead and copper consumer notification forms, construction completion form (as-built),  Level 1 assessments, responses to compliance advisories, DBP OEL report, and other general correspondence.
    • Complete Monitoring Plan: A complete monitoring plan (ALL sections included). Please do not use this category for individual sections.
    • Sanitary Survey Inspection: Responses to sanitary survey inspection items or Cross-connection Control Extension Applications. Please use “Certifications - PN category” if submitting a public notice.

Don’t forget to submit! 

Uploading files to the Portal is a two-step process. First, you will transfer files to your File Cabinet, then use row checkboxes to select files. Once selected, click the ‘Submit selected files button’. Continue to the final confirmation page to complete the submission of the files.

Compliance specialists are unable to accept final data or file submittals via email. Upload of data and files via the Portal is the preferred method, although fax or US mail may be used.

For questions related to your Portal account and file upload, please refer to the help tab at the top of the portal screen.

➽ Haley Orahood and Alex Hawley, Drinking Water Compliance


Wednesday, October 21, 2020

Culture of Health

Enforcement: Helping a Small Town Make Progress 
Our primary purpose under our Safe Drinking Water Program is to protect public health by implementing and assuring compliance with both the federal and state drinking water regulations. Our drinking water regulations establish requirements and standards that every public drinking water system must meet in order to protect public health. When we determine that a public drinking water system is out of compliance, we take steps to ensure the system provides the required public notice and we identify and pursue the next actions that are needed to address the issue (e.g., increased monitoring, treatment upgrades, coaching/assistance efforts, and/or enforcement actions), all with the goal of getting the system back into compliance so that any impact to the public’s drinking water is minimized.

For any violation that may occur at any drinking water system in Colorado, we assess a number of criteria to determine the appropriate action to take in response, including the nature of the violation, the short and long-term impact to public health, how quickly the facility comes back into compliance, and the cause of the violation. As indicated above, our primary goal when a system goes out of compliance is getting the system back into compliance. We first use assistance to achieve this goal. We will, however, use enforcement tools when needed to compel the system to correct the issue. We prioritize our efforts on those drinking water systems that are having the greatest difficulties meeting the regulatory requirements in order to prevent any potential health impacts to consumers.

In a recent example, the Department used a combination of enforcement and assistance to help the Town of Hartman define a path to compliance. The public water system has a history of technical, managerial, and financial (TMF) capacity challenges, including neglected maintenance, equipment problems, lack of a certified operator, and lack of monitoring and reporting. The Department issued the Town an enforcement order with a $7,498.00 penalty in March 2020. While the penalty may seem high for a small town, forty percent of the penalty amount was assessed to remove the economic benefit created by the Town not paying lab costs for the missed sampling. The remainder of the penalty was assessed as the standard base penalty for the 64 violations that the Town accrued in 2018 - 2020. After the issuance of the Order, the Colorado Department of Local Affairs (DOLA) was alerted to several financial practices inconsistent with local government statutes. DOLA also joined the assistance efforts by helping the Town hold a special election for board members and to correct the local government filings. DOLA is now attending Town board meetings until the new leadership is up-to-speed on local government roles and responsibilities. In June 2020, the Town contracted with a certified operator from a neighboring town. In July 2020, we awarded a $25,000 grant to hire a contract engineer to inspect and repair the storage tank, write and implement a backflow prevention and cross-connection control program, collect all overdue compliance samples, prepare public notices, and to respond to the Order. On October 6, 2020, after working with the new Town board and inspecting the storage tank, the contract engineer created an action plan to return the Town to compliance by the end of the 2020 calendar year. The combination of enforcement and assistance seems to have been effective in getting the Town on a path to improving. CDPHE will continue to monitor the Town’s corrective actions to ensure that the drinking water meets regulatory requirements and that the Town implements a strategy to maintain compliance going forward.

Partner with Us to Protect Safe Drinking Water!

Access to safe drinking water is a basic human necessity that we want all residents and visitors in Colorado to experience. Everyday, we aim to make that a reality by partnering with water professionals and regulated entities on our shared mission to protect public health. 

➽ Emily Clark, Enforcement & Field Findings Compliance Lead

Wednesday, October 14, 2020

New Census and Possible Changes to Population Served

Knock, knock! Oh, is that the census volunteer at my door?

It is the year 2020 and we all know what that means. Sometime in 2021, cities and towns across the country will have updated population counts. You may be asking yourself, why is this relevant to your public water system? The simple answer is that the monitoring requirements established for your water system by Regulation 11 of the Colorado Primary Drinking Water Regulations and the department are based on the total population served by the public water system. The regulation categorizes populations into three different types: resident, non-transient, and transient populations. 

  1. Resident populations are identified as the people regularly served year-round by the water system. This applies to people whose primary residence is in the service area and applies even if the individuals do not live in the service area year-round.
  2. Non-transient populations are identified as the people that regularly commute into a supplier’s service area throughout the year and have a regular opportunity to consume the water. The non-transient population is generally made up of working professionals or students who travel into the service area but do not live in the service area. Regular opportunity means four or more hours per day, for four or more days per week, for six or more months out of the year.
  3. Transient populations are determined by attempting to identify the daily average of individuals served by the public water system that are neither resident nor non-transient in nature. This generally applies to tourists and visitors to your water system service area, along with customers of businesses in your water system that do not live in the water system’s service area. 

Many community water systems rely on census counts to better determine the resident population served. The department is aware that there are many instances where not all of the town or city residents are served by the same public water system; however, generally in Colorado, many systems have relied on the census population to better determine the resident population served by the system.

What could change?

The department anticipates various changes to the suppliers’ population types, which can trigger increased or decreased monitoring requirements for total coliforms, lead and copper, disinfection byproducts, and turbidity. 

Many of the population-specific monitoring requirements can be found in the following tables in regulation 11:

     

The most likely impact change will be to the total coliform rule sampling requirements:






























For many systems, now may be an opportune time to evaluate any anticipated population increases and how it may impact the supplier’s monitoring requirements. Many suppliers may have to adjust future budgets in order to account for increases in sampling requirements.

It is the responsibility of the supplier to notify the department, via an updated monitoring plan, of any identified changes to the system’s population and/or inventory within 30 days of the effective date. For many systems, this date may likely occur sometime in 2021.

➽ Jorge Delgado, P.E., North Unit Compliance Manager 

Wednesday, October 7, 2020

Design Criteria Update Project - 2020 - 2021

Design and update critical drinking water infrastructure!

The Design Criteria for Potable Water Systems (Safe Drinking Water Program Policy 5) serves as a key policy document for the department to make decisions on approval of new designs for water sources, treatment, and storage facilities. The document also serves as a guideline for repairing or upgrading waterworks that are cited as significant deficiencies during the department’s sanitary surveys. While systems are not required to modify their waterworks to meet the design criteria, they are required to consider the criteria as acceptable fixes whenever their current waterworks are found to be deficient. 

The department intends to update the document regularly, approximately every 4 years with input from stakeholders. To assist with updates, we keep a running list of errors and enhancements. The last update was in 2017. At this time, the department is initiating a criteria update project in late 2020 to be completed in 2021. The Department has identified the following three key areas of focus for this project but is open to other stakeholder recommendations:

  1. Updates of known errors and enhancements since 2017 - including such items as wetwells at pump stations being considered finished water storage, typos, etc.
  2. Updates to sections that pertain to corrosion control and the lead and copper rule.
  3. Addition of sections pertaining to direct potable reuse and requirements for pertinent treatment processes (e.g. advanced oxidation, ozone/biological filtration, adsorption, etc)

More communication will follow and the department encourages stakeholders to participate as they are able to ensure we have the best design criteria policy we can.  For more information, please contact Tyson Ingels at 303-692-3002 or tyson.ingels@state.co.us

Tyson Ingels, Lead Drinking Water Engineer