Wildfire: Effects from recent fires and division resources

The 2021 fire season included three of the largest wildfires in Colorado’s history:

• Cameron Peak Fire
• East Troublesome Fire
• Pine Gulch Fire

Many other areas were impacted by wildfires also:

• Grizzly Creek Fire
• Williams Fork Fire 

These natural disasters have significant and long lasting impacts on water quality such as sediment/debris flows, decreased soil infiltration and erosion potential, and higher levels of nutrients and metals. The Water Quality Control Division (division) is one of many federal/state and local partners that provide resources and technical assistance when these impacts occur. The division response involves multiple disciplines including public water system acute team support, source water data sharing/evaluation and technical/financial assistance on watershed restoration efforts. 

These fires significantly impact watershed functions and necessitate collaborative work groups in impacted regions. One example is the Grizzly Creek State Recovery Task Force that is focused on the post wildfire effects in Glenwood Canyon and downstream on the Colorado River. In late July/early August of 2021, the post wildfire impacts caused mudslides and highway closures on the I-70 Glenwood Canyon corridor. The division is currently working with the Office of Emergency Management, Colorado Department of Transportation, Colorado Water Conservation Board, and a diverse range of local governments/stakeholders to develop a downstream notification system for Colorado River water users. This system is meant to provide downstream users on the Colorado River with early warning and notification of hazards and potential water quality impacts from watershed events and cleanup operations. This notification system will assist water users to make operational decisions to reduce impacts from the post wildfire conditions.

Other wildfire restoration activities involve the division’s Nonpoint Source (NPS) Program that has provided over $5 million in funding for wildfire related work in the past 20 years. Last year the Nonpoint Source Program’s Request for Applications provided priority points for post-wildfire projects and a waiver from the EPA for the watershed based plan requirement. This year the nonpoint source program is providing additional post-wildfire funding for 2022 projects thanks to the Power Authority Board. To provide context of the long-term process of restoration efforts, a recent Nonpoint Source Post-wildfire project success story is the Hayman Restoration Project. Horse Creek and West Creek were added to the 303(d) list of impaired waters for aquatic life due to post-fire flooding and erosion a decade after the Hayman fire. After the implementation of numerous best management practices, these waterbodies were successfully restored and removed from the 303(d) list for aquatic life in 2020. The NPS Program is also incorporating wildfire risk when prioritizing protection projects into it’s updated NPS Management Plan, such as a source water protection project in Southwest Colorado.

To further assist water providers, counties, tribes and municipalities impacted by wildfires, the Source Water and Emerging Contaminants Unit in the Water Quality Control Division worked with a large stakeholder group led by the City of Boulder Water Utilities Department to develop a Post-Fire Playbook. The playbook is a guidance document to help navigate the complexities surrounding post-fire rehabilitation. For the playbook and other post-fire resources please visit the post-fire playbook website.

 ➽  Kristen Hughes, Source Water Protection Specialist

BPCCC - “Out of business” taps

What do you do when a non-single family residential connection (NSFRC) goes out of business or becomes vacant?

The number of connections in a public water system can often change with new connections being added and old connections no longer being used. But how does this impact a water system's compliance with the backflow prevention and cross-connection control (BPCCC) requirements? Since compliance with the BPCCC rules are evaluated by calendar year, the first thing a public water system needs to figure out is when water was last used at this connection. If water was not used or supplied to that connection at any time during the calendar year then it does not need to be included in the water system’s annual BPCCC report. If water was used at that connection then the water system will need to include it in the annual BPCCC report.

If water has been used at the connection, what does the water system need to do with regard to discovered uncontrolled cross-connections, assembly testing, or method inspection?

If water has been used at a connection within the calendar year, but is no longer being provided service, that connection still needs to be included in the survey compliance ratio, assembly testing ratio, and method inspection ratio calculations. Any identified uncontrolled cross-connections also still need to be controlled. Suspension of service, removing a meter, or locking out a connection is allowed for controlling discovered uncontrolled cross-connections, failed assembly tests, and failed method inspections. However, if a connection has gone out of business in the middle of the year and it never had its backflow prevention assembly tested, the assembly would need to be included in the compliance ratio calculation. Any assembly and/or method used at any time during a calendar year is required to be included in the testing or inspection compliance ratio calculations.

For more information on BPCCC as well as templates, guidance and frequently asked questions, please visit the department’s website. If you ever have any questions regarding the implementation of your system’s backflow program, please direct them to cdphe_wqcd_fss_questions@state.co.us.

➽ Clayton Moores, PE, Field Unit I Manager

➽ Dominic Delgado, Field Inspector

Colorado Wastewater Surveillance Program

Environmental researchers around the world have demonstrated a correlation between SARS-CoV-2 RNA concentrations found in wastewater and COVID-19 case reports. Since  August 2020, CDPHE’s Communicable Disease branch and Water Quality Control Division have been working with Colorado wastewater utilities and local universities to monitor wastewater for SARS-CoV-2 levels in Colorado communities. The result of this work culminated in the Colorado Wastewater Surveillance Collaborative. This wastewater data is used by the State and local public health agencies (LPHAs), in conjunction with case report data, to more accurately estimate trends of disease within a community. This data also gives local public health partners an early warning system for increasing disease levels in their communities as it can identify cases prior to case report data being available. In addition, the CDPHE lab performs whole genome sequencing on all positive wastewater samples for identification of mutations indicative of variants of concern.

Participating wastewater utilities collect wastewater samples twice per week from 24-hour composite samples collected just before the wastewater enters the water treatment plant. The samples are made up of a mixture from all the homes and businesses served by that wastewater utility, making this form of COVID-19 monitoring more efficient than clinical testing. CDPHE’s wastewater program also has potential to expand to neighborhood or even building-level monitoring. We are currently partnering with the University of Denver to perform wastewater sampling at two major correctional facilities in Denver.

Wastewater data can capture cases in communities where testing is unavailable, underutilized, or from asymptomatic individuals who may not seek testing. Wastewater data has been used by local public health agencies (LPHAs) to target testing and vaccination campaigns. Tri-County Health Department utilized wastewater data in a series of social media posts in nine targeted zip codes. The wastewater data was successful in generating a higher than usual community engagement in these posts. The Wastewater Surveillance Team at CDPHE is creating reports to send to LPHAs when elevated concentrations of SARS-CoV-2 are identified.

Data from the wastewater samples are available to the public via an interactive online dashboard. Currently, CDPHE is partnering with 21 wastewater utilities with plans to expand to more in the future. Wastewater disease monitoring is a vital part of understanding trends in COVID-19. In the future, we hope to expand and monitor for other communicable diseases. To learn more about the CDPHE Wastewater Monitoring Project please visit our frequently asked question page.

➽ Kevin Andresen, MPH Wastewater Surveillance Coordinator  Communicable Disease Branch

What happens if a town runs out of water?

We at CDPHE work with public water systems through all manner of emergencies including: bacterial contamination, forest fires, flooding, tampering events, loss of system pressure, failure of treatment systems, and many more. Working together with water systems to help ensure that waterborne disease outbreaks do not occur is our program’s top priority. However, ensuring that water systems do not run out of water is a more challenging subject.
Long term drought conditions in Colorado have already had tangible effects on water availability with the following events:

• Records have shown some hand-pumped wells operated by the US Forest Service have run dry due to the shallow depth of the well and a dwindling water table. 

• This year a well operated by a commercial operation in northeast Colorado ran dry, leading to them haul water from many miles away. 

• Operators of groundwater systems in northern El Paso County have reported having to lower their well pump depths several times over the years to better reach available water. 

• A town in southwest Colorado served by surface water was at imminent risk of running out of water. This town communicated very closely with us during this event. The Department and the town brainstormed possible solutions. Fortunately, they were able to get water from an emergency water storage supply allocation.  

However, the overarching question remains: If a town totally runs out of water, what is the recourse? It would be a grim situation and anecdotes from a community in California’s Central Valley that ran out of water may offer clues on the true nature of the hardship at the onset, which included the use of emergency bulk water filling or bottled water stations, and communal shower, bathroom, and laundry facilities that residents had to travel to. The water quality control division encourages systems to anticipate emergency events and work with their partners in local public health, emergency management and neighboring utilities to create Emergency Drinking Water Supply Plans.  It is important to remember that CDPHE regulates the safety of the drinking water to ensure that the water is potable and appropriate for human consumption. Regulation 11 does not require a utility to provide a reliable source of water to consumers. 
While the USEPA nationally discusses consolidation and conservation as two mechanisms to combat situations like this, our geography and the arid nature of the state may mean that water sources become unavailable even with best efforts. Water systems and their managers and boards should be evaluating their available water resources to ensure they will be able to meet future demand and should establish restrictions when warranted to lower water use especially in a drought season or perhaps even if it is forecasted. While the Water Quality Control Division ensures water meets quality standards, water systems should be engaging with the Colorado Division of Water Resources to find any available water quantity that can be developed and utilized in the future.
The following resources can be helpful as you work with your partners to address potential source water shortages: 

• Department of Local Affairs: Incorporating Water into Comprehensive Planning

• Department of Local Affairs: Water and Land Use Planning Tools

• America’s Water Works Association: Water Conservation Programs Planning Manual

• America’s Water Works Association: Water Audits and Loss Control Programs

• America’s Water Works Association: Drought Preparedness and Response

• Environmental Protection Agency: Drought Resilience and Water Conservation Resource Website

The department is working diligently with communities who have water shortages in an attempt to find solutions, but the hard truth remains that if a community completely runs out of water for an extended period, then lack of sanitation and fire protection will make that location inappropriate for human habitation. Partnership into the coming decades to find solutions will be required and to avoid a situation arising where a community becomes uninhabitable.
➽ Tyson Ingels, P.E Lead Drinking Water Engineer Engineering Section
➽ Bryan Pilson, Technical, Regulatory Implementation, and Coordination Unit Manager Drinking Water Compliance Assurance Section

EPA Free Cybersecurity Assessment and TA

The Water Quality Control Division is sending the following training opportunity on behalf of the US Environmental Protection Agency:

Sign up for free cybersecurity technical assistance here

Cyber-attacks are striking critical infrastructure across the United States, including water and wastewater systems, with increasing frequency. Recent cyber-attacks on water and wastewater systems have manipulated treatment processes, disabled process control and business enterprise systems, and stolen proprietary data. Cybersecurity best practices and incident response planning can prevent or mitigate many of these attacks and are essential to the sound operation and management of water and wastewater systems. 

What is the assessment and technical assistance? 

With the U.S. Environmental Protection Agency (EPA), Horsley Witten Group (HWG) is offering free, confidential, cybersecurity assessments and technical assistance to interested water and wastewater utilities. The assessment consists of a questionnaire completed with HWG staff, and the technical assistance consists of developing a cyber action plan based on the results of your utility’s assessment focused on best practices to prepare for, respond to, and recover from a cyber incident. Adoption of these practices can reduce the likelihood that a cyber attack will be successful and potentially enable your utility to recover from any cyber attacks faster and at a lower cost. EPA and HWG are offering these assessments and technical assistance virtually, no on-site visit is required. 

What are the expected outcomes?

All individual utility information gathered during the assessment will be protected and remain confidential. Trends in the anonymized, aggregated data will be shared with other utilities and agencies so that lessons learned from the assessments may benefit all. Participating utilities can expect to receive a straightforward overview of their vulnerabilities and suggested best practices to reduce risks to business enterprise, SCADA, and communications systems. Additionally, the utility will develop a cyber action plan with HWG and work to implement any recommended best practices at its own pace. 

What does the utility need to prepare before the assessment and technical assistance?

The assessment will require input from management, information technology staff, operations and control staff, and engineers as appropriate. The utility will also need to compile and provide any existing system documentation and diagrams, policies, and procedures. 

Is there any follow-up? 

Yes, HWG will contact the utility on two separate occasions after the development of the cyber action plan to gauge progress and see if additional assistance is required. 

How does my utility participate? 

To date, EPA and HWG have worked with over 100 utilities across the United States providing free cybersecurity technical assistance. We are continuing to register interested utilities at the link below. If you would like more information about the program, contact Gemma Kite of HWG at gkite@horsleywitten.com, or (508) 833-6600. 

SB20-218 PFAS Grant Program

PFAS are man-made chemicals with chemical properties that make them useful for consumer and industrial use. But those properties also make them persistent in the environment. PFAS chemicals from firefighting foam, personal products, and other substances are toxic and may get into the groundwater and surface water, potentially contaminating Colorado’s drinking water supplies. There is evidence that exposure to PFAS can lead to adverse human health effects including low infant birth weights, cancer and negative effects on the immune system. 

The state continues to address PFAS issues through Senate Bill 20-218. The Colorado Department of Public Health and Environment Hazardous Substances Response Act (SB20-218) was signed into law on June 29, 2020 ( C.R.S. 8-20-206.5(7)). 

The act created fees on the transportation of fuel products and those fees are to be collected between September 1, 2020, through September 30, 2026, when the available balance in the fund is less than eight million dollars. The collected fees that are placed in  the PFAS Cash Fund established by SB20-218. The funding can be used for the PFAS grant program, PFAS takeback program, and PFAS technical assistance.

The PFAS Grant Program, provides funding opportunities to eligible entities through three (3) primary project categories: 

1. Sampling - standard sampling and Independent Environmental Studies;
2. Emergency Assistance - to communities and water systems affected by PFAS; and 
3. Infrastructure -water system infrastructure for the treatment of PFAS and prevention strategies for upstream sources of PFAS.

The sampling category will fund eligible participating entities to work with a state contractor or work independently to develop sampling plans to sample for PFAS. Drinking water providers can also utilize this funding opportunity to test their treated drinking water and source waters. 

The general eligible entities for the PFAS grant program are listed below:

• Governmental agencies
• Tribes
• Public water systems
• Private not-for-profit public water systems
• Counties or local health departments
• Fire Departments
• Not-for-profit Non-governmental organizations
• Domestic Wastewater Treatment Works
• Non-profit educational institutions

Each PFAS grant program category has different criteria and eligible entities must review the request for proposals material and complete the required documents located on the following website PFAS Projects webpage under the PFAS grant program heading. 

The application period for the sampling category of the PFAS Grant Program opened in early December 2021. The application period will end on April 1st, 2022 and all applicants will be notified by April 29th, 2022. A potential rolling application for any remaining funds will begin in May, 2022. 

Any questions may be directed towards the cdphe_wqcd_pfas_grant@state.co.us email. Please use the subject line “Grant Program Questions.”

Click here for more information about the PFAS Grant Program.

➽ Sierra Mitchell, PFAS Program Coordinator

Constructed without getting design approval? Please get approval!!!!

Regulation 11, the Colorado Primary Drinking Water Regulations, requires public water systems to receive department approval prior to initiating construction of waterworks. The specific regulatory citation is Regulation 11.4(1)(b) which states:

The requirement to get department approval prior to construction is important for many reasons including but not limited to: ensuring sources and treatment systems provide safe drinking water in a reliable and consistent manner, ensuring the state and the public water system are on the same page regarding what is installed and in operation, ensuring that the facility has an operator at the appropriate level, and ensuring that designs are well thought out and completed by the properly qualified individuals (in most cases a Professional Engineer or Certified Operator). 

Sometimes, water systems install new sources, tanks, or treatment processes without department approval. If this is discovered during a routine sanitary survey, a violation will be issued requiring public notice. The system will be required to submit the design after the fact and get department approval. This can lead to expensive modifications to make sure the design meets our design standards (Policy 5 - Design Criteria for Potable Water Systems). 

If a violation gets cited, the water system is then on a schedule to get department approval. Many times, the department inspector follows up with the public water system until a design is submitted, then the project is handed over to the Engineering Section to finish the approval. On many of the design submittals, the Engineering Section must issue one or more request-for-information letters to the public water system because elements of the design documents are missing or inadequate. 

For systems that are in violation of the regulations by constructing infrastructure without our approval, we are now including deadlines within the request for information letters from the Engineering Section. These deadlines are binding in nature per the regulations and require a response. If a response is not received, the department will issue a reminder, but the system remains in danger of enforcement while there are open violations. 

Resources: 

• To determine if your system has open violations, please check your monitoring schedule at  which will show you open violations. 
• To obtain more information about system design approval, please visit the division's design approval website. 

Thank you for working with us to get your designs approved efficiently!

➽  Tyson Ingels, P.E Lead Drinking Water Engineer

➽  Melanie Criswell, P.E. Corrosion Control Engineer

A Conversation Starter: Safe Water and the Why?

Why do we do the things we do? What motivates us? When it comes to working in the drinking water business, protecting public health is the top priority. Protecting public health should be the key motivation for all of us and never be far from our minds. How can we make this happen? We can think about it, write about it and most importantly talk about it! All this should be happening under our broad umbrella of a Culture of Health. You have probably heard the advice that leaders should “focus on the why?” I agree, but would say that we all need to do that.

Best practices in any business should involve connecting employee’s jobs, duties and activities to the organization's mission, it’s deeply rooted purpose. Employees are motivated by many factors, but chief among them is the mission and purpose of the organization where they work, particularly when the mission and purpose resonates with the employee’s values. While our drinking water jobs are often difficult and almost always under-appreciated, we excel in having a fantastic purpose: providing a vital human need - water, and making sure it’s safe! Safe drinking water delivered to someone’s tap does not happen, it results from the human and physical infrastructure devoted to that purpose. Safe drinking water comes from our Culture of Health. So let’s try to always keep this mission and our Culture of Health in mind and connect to it as we go about our jobs.

 

Beyond thinking about safe water and protecting public health, we can write about it in newsletters, correspondence like emails and in any and all other formats where it makes sense. How about Standard Operating Procedures (SOPs)? Would an SOP be more likely to be understood and performed correctly if it includes a brief description of why it’s important and how it fits into the pantheon of needed activities to ensure that tap water is safe to drink? I believe the answer is yes. By including “the why?” in our written communications we can help everyone understand the importance of what they are doing. We should also consider adding the consequences or risks associated with not performing the activity. For example, if a sample procedure is not followed correctly, then we could get an inaccurate result that leads people to believe the water is safe, when it is actually contaminated. We could also get a result showing a danger, when none exists.

 

We should also talk about our Culture of Health and take those conversations to as many audiences as possible to add as many people under the umbrella as we can. This can include our families and friends, utility managers and executives, and of course each other. Let’s start conversations with discussions of “the why” and consider health risks and risk communication as well. What is the health risk associated with various contaminants? Is the risk an acute or chronic health risk? Are there populations like infants, especially vulnerable to the contaminant? How high or low are those risks? How do we communicate with the public about risks from contaminants like lead, PFAS and disinfection byproducts? What about acute risks? How would we go about communicating the need for people to boil their water or obtain an alternate source of water in an emergency?

 

By thinking, writing and talking about our Culture of Health including health and communication risks we can imbed this culture deeply within our organizations and expand its influence to everyone it touches. I encourage you to “focus on the why?” everyday. Thank you for all you do make tap water safe in Colorado!

➽ Ron Falco, P.E. Safe Drinking Water Program Manager

Reporting Waterborne Disease Outbreaks

Cooperation between water systems and healthcare facilities within their service areas can help prevent waterborne disease and detect potential outbreaks early to minimize harm. The following information outlines the basics for how to recognize and report waterborne disease outbreaks (WBDOs). 

What are waterborne disease outbreaks?

Waterborne disease outbreaks (WBDO) can be categorized by etiologic agent (the organism making people sick), type of water use (drinking, recreational, other), routes of entry (ingestion, inhalation, intranasal, or skin contact) and means of water contamination.

WBD agents may cause gastrointestinal, skin, respiratory or systemic illness. Symptoms may include abdominal cramps, vomiting, diarrhea, hives, rashes, irritated eyes, sore throat, pneumonia, or systemic illness.

Purpose of Reporting and Monitoring

• To detect WBDOs that can be controlled with appropriate public health measures (boil or bottled water advisory, pool closure). 
• To confirm the type of WBDO, thereby guiding treatment and control measures to prevent further exposures and additional cases of illness. 
• To assess whether implemented control measures are effective in stopping further transmission.
• To expand current understanding of the transmission, pathogenesis, and community impact of illness caused by WBD agents. 
• To identify new WBD agents, hazards, or gaps in the water safety system.

Responding and Reporting

What actions can health facilities take?

In most instances, consult with state/local environmental and public health staff, who can provide situation specific guidance and assist an owner/operator in treating water and cleaning the facility as needed.  With guidance from environmental health staff, immediate control measures could include (but are not limited to) the following:

• Drinking water: Issuing a boil or bottled water advisory, recalling a commercial product like bottled water
• Recreational water: Closing a facility or beach, posting warning signs at a lake, super-chlorinating pool water, backwashing the filter, draining the water, sanitizing the bathrooms or other likely-contaminated areas, cleaning the entire facility, and refilling the water and treating the water as required or feasible (for treated water facilities)
• Any water source: Issuing a press release to advise citizens who may develop illness

How to report the event?

• Water systems and local public health departments: Report known or suspected WBDO to CDPHE immediately upon receiving a report of a known or suspected outbreak. CDPHE will review the situation with you and assist if there is agreement that an investigation is needed.
• Health care facilities: Immediately notify your local health jurisdiction of outbreaks or suspected outbreaks.
• Per statute 6 CCR 1009-1, appendix A: "Outbreaks - known or suspected of all types - including those transmitted from food, water, person-to-person, and related to a healthcare setting." 

Who to contact at the department?

• Contact the department’s 24-hr emergency line: 1-877-518-5608. 
• Call as soon as possible but no later than 10 a.m. of the day following the incident.
• CDPHE Communicable Diseases
• 303-692-2700
• 303-370-9395 (after hours only)
• CDPHE Toxicology Line
• ToxCall 303-692-2606, cdphe_toxcall@state.co.us
• ToxCall is a good resource if toxic algae is suspected

Additional details including what information to include when you report an incident and what to expect after reporting can be found here.

➽  Chelsea Cotton Source Water & Emerging Contaminant Engineer

Emergency Response Plans and Security Considerations

America's Water Infrastructure Act (AWIA)

America’s Water Infrastructure Act (AWIA) passed Congress and was signed into law in 2018 to improve drinking water and water quality, deepen infrastructure investments, enhance public health and quality of life, increase jobs, and bolster the economy. The AWIA provisions are the most far-reaching changes to the Safe Drinking Water Act since the 1996 Amendments, with over 30 mandated programs. One aspect of this federal act was the Community Water System Risk and Resilience Assessments aimed at community water systems serving more than 3,300 people. These water systems are required to develop or update risk assessments and emergency response plans (ERPs). The law 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. 

Where do we stand with AWIA requirements now?

Many of the AWIA risk and resilience assessments and emergency response plan deadlines have come and gone for larger systems. However for systems serving populations ranging from 3,301 to 49,999 the deadline to certify that your emergency response plan has been completed or updated is December 20, 2021. 

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

Special Considerations - Security 

Recently, special attention has been paid to increasing the importance of security planning within general emergency response plans. And with good reason, 2021 alone has demonstrated that drinking water infrastructure is susceptible to cyberattacks which have potentially catastrophic results. Many small to medium systems may think that they are not susceptible to cyberattack. However, many cybercriminals are moving to attack smaller systems because they know there are less barriers in place to prevent attacks. The division encourages you and your system to incorporate robust cybersecurity measures into your emergency response plan. Please see the below resources to help you in these vital efforts. 

Resources

• EPA's AWIA - Risk Assessments and Emergency Response Plans: Information and training 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.
• CDPHE Drinking Water Security Response Toolbox: This toolbox is designed to help water utilities plan for, prevent, and guide responses to security threats including general malevolent acts, cyberattacks, tampering, and violent acts.
• WQCD Free One-on-one Assistance: Free one-on-one coaching at your facility to meet your specific needs. Training units are available, depending on time spent with the coach.

➽ Kyra Gregory Drinking Water Coach 

PFAS: EPA roadmap and Possible sources database from EPA

Resources: 

• Click here to view the EPA roadmap
• Click here for more information about the PFAS bills and get involved in the stakeholder process to create a certificate of registration program

On October 18, 2021, EPA Administrator Michael S. Regan announced the agency’s PFAS Strategic Roadmap which entails how the EPA will address the issue of PFAS. PFAS are man-made chemicals that have properties that make them useful for consumer and industrial use, but also make them persistent in the environment. PFAS chemicals from firefighting foam, personal products, and other substances are toxic and can move into the groundwater and surface water, contaminating Colorado’s drinking water supplies. There is evidence that exposure to PFAS can lead to adverse human health effects including low infant birth weights, cancer and effects on the immune system.

The actions EPA plans to take with their PFAS Strategic Roadmap from 2021 through 2024 are guided by three goals to address PFAS:

• Research: Invest in research, development, and innovation to increase understanding of PFAS exposures and toxicities, human health and ecological effects, and effective interventions that incorporate the best available science.
• Restrict: Pursue a comprehensive approach to proactively prevent PFAS from entering air, land, and water at levels that can adversely impact human health and the environment. 
• Remediate: Broaden and accelerate the cleanup of PFAS contamination to protect human health and ecological systems.

The department supports key actions in the EPA’s newly released PFAS roadmap, including their efforts to develop regulatory limits for PFAS in drinking water ahead of their statutory deadline. They propose a draft rule in fall 2022 with a final rule in fall 2023.

Additionally, the EPA identified more than 120,000 facilities that may expose the public to PFAS. Colorado was at the top of the list for states with potential PFAS sources. It’s important to remember a few things about potential sites identified in Colorado:

• The data represents facilities in industries that may handle PFAS chemicals. This does not necessarily mean that every location identified is handling PFAS chemicals, or that PFAS has ever been released into the environment from these sites.
• Identifying where we have releases of PFAS in the environment that impact drinking and irrigation water is a top priority for CDPHE.
• These potential sources do not tell us whether people have been exposed to levels that might harm their health. We are developing a potential vulnerability map to further investigate drinking water sources that have the potential to be impacted and our upcoming grant program will support further testing. 
• Colorado’s oil and gas regulations are more restrictive than many other states, which may result in more facilities reporting to the EPA. This could be a reason why Colorado has been identified as having more potential PFAS sites than other states.

The state continues to address PFAS issues through House Bill 20-1119 and Senate Bill 20-218. A PFAS Takeback Program launched in September to pay Colorado fire departments to take firefighting foam containing these chemicals out of service and have them safely stored until we can properly dispose of it. The grant program for Senate Bill 20-218 will launch later this fall and will provide funding opportunities for sampling efforts to test groundwater and surface water, water treatment infrastructure, and support emergency assistance for communities and water systems affected by these chemicals. Drinking water providers will be able to use this funding opportunity to test their treated drinking water and source water. 

➽ Sierra Mitchell, PFAS Program Coordinator

Lead Service Line Inventories and Private Property and Access Concerns

After a recent Aqua Answers article about the difference between lead service line inventories and materials evaluations, several water operators raised questions about the feasibility of completing the activities due to access issues and private property concerns. 

Let’s start with a primer on the requirements for a lead service line inventory under the Lead and Copper Rule Revisions, likely to be finalized in December of 2021. It is almost guaranteed that by the end of 2024, suppliers will be required to create at least an initial lead service line inventory for their system, with ongoing updates required as well. Each service line, including both the utility and private side, would need to be evaluated and categorized as having lead, galvanized downstream of lead, non-lead, or unknown. 

It’s important to note that physical verification at all service lines is not required and not expected. Suppliers should consider all available information before determining physical verification is warranted. This includes reviewing any installation records, building codes or ordinances dictating the service line material. In addition, observations of line materials when doing maintenance and repair at water mains or along the service line can be used. For example, if an external meter pit has copper or PEX on both sides of the yoke, this material is likely running from the corp or curb stop, depending on the location of the meter pit, and to the building. 

While lead service lines weren’t banned until 1986, their use was falling out of favor in the late 1940s. The latest known lead service line installation in Colorado based on reported information to the department is currently 1956. Therefore, the department would accept with high probability that unknown service lines installed after 1955 with some supporting records or observations can be categorized as non-lead in the lead service line inventory. This date cutoff should greatly limit the scope of a system’s investigation. 

For unknown service lines installed before 1955, suppliers can still categorize the materials without physical verification if there are any records on installed material type or there were ordinances banning lead materials. While there may be illegal installations or deviations in listed materials used, there is a high probability that lead materials were not used if there were records or standing ordinances.  

Even if there are remaining unknown service lines, these service lines are not all required to be physically verified. In the absence of EPA guidance and expectations for states, the department currently supports Michigan’s approach to lead service line inventory as they undertake a state-specific lead service line replacement program. Their verification effort requires that 20% of unknown service lines be randomly selected for verification to create a statistically sound, probabilistic determination of service line material as lead, galvanized downstream of lead, or non-lead. Please note that physical verification only pertains to the remaining unknown service lines. For example, if you have 100 total service line connections, and you determine with high probability through installation dates, records, and observations that 80 are likely non-lead, then you would have 20 remaining unknown service lines, leaving a minimum of 4 (20% of 20) to be physically verified.

Michigan’s approach on physical verification is to conduct three or four points of inspection that includes:

• The interior portion of the service line up to the first shutoff valve, usually the main shut off valve located in a wall cutout or in a crawlspace, 

• The line from the building to the curb stop, 

• The line from the curb stop to the water main, and

• If present, the gooseneck or pigtail connector at the water main.

The points to target for physical verification may vary depending on the layout of components along the service line. For in-ground physical verification, suppliers may utilize hydrovacuum excavation, air-knifing, trenching, or hand digging to inspect the material. If there were controls on materials for a portion of the service line then physical inspection at that point in the line is not warranted. For example, if the utility has records or had mandates on the utility-owned portion of the line, but the homeowner was responsible for selecting their material, only the customer side would have to be physically verified. 

Now we get to the crux of the problem: disturbing the ground on private property or requesting access from the homeowner to the inside of a home. These bring up sensitive issues and safety concerns for suppliers as they interact with their customers. First let’s discuss options related to the interior portion. If the homeowner does not allow access or the supplier wishes not to enter a home for safety reasons, the supplier can ask the homeowner to take a photo of the pipe material entering their home or at the main water shutoff to share with the supplier. Additionally, the supplier can provide a magnet to help determine the difference between similar appearing lead pipe and galvanized steel, as a magnet will not be attracted by lead. For exterior verification, you may need to explain the importance of this one-time verification and, if necessary, provide an incentive on their water bill for the disturbance to their ground. Based on feedback from utilities in other states, the new rule will be quite onerous to systems with lead service lines after 2024 and some systems are considering replacing a customer’s lead service line for them if found. If the system is willing to bear this cost to minimize future requirements, this cost incentive as well as public health protection could be shared with a homeowner who is reluctant to participate.

It’s important to note that if a homeowner refuses to cooperate, the supplier may move to the next randomly selected customer to see if they are willing to participate. Even if a supplier is unable to verify the material of their unknown service lines to make a probabilistic determination, there is a provision in the rule that allows the supplier to continue to list these sites as unknown in their inventory. However, in this case, the supplier has to assume the unknown service lines likely contain lead and will have to conduct ongoing special notices to these customers about the health effects of lead and prepare a lead service line replacement program for the sites, if ever triggered by the rule. Lastly, these sites would not be sampled for compliance under the new rule, due to the lack of confirmation on materials.

In conclusion, the department hopes that this more thorough description of what’s required of a lead service line inventory shows that it is not expected that every service line be physically verified as long as there is supporting documentation that gives the supplier high confidence on the materials at each line. Homeowner access is a touchy subject for suppliers and may mean some difficult conversations, but failure to gain access will not put the system out of compliance, as long as a credible effort to gain inventory information takes place. We recommend that utilities work with their customers and help them understand the importance of assisting with this process and the risks of lead in drinking water for both children and adults. As always, we are happy to discuss and help. Once the lead and copper rule revisions are final, we will be working with EPA to develop guidance for water systems that includes a reasonable approach to meet the lead service line inventory requirement.

➽ Bryan Pilson Technical, Regulatory Implementation, and Coordination Unit Manager

Coming Down the Pipe: Reg. 11 Backflow Guidance Updates

Please see updates on the division’s webpage

In early 2021, we ran a stakeholder process to update policies both for backflow prevention and cross connection control as well as storage tank regulations. After those updated policies were published, we began an effort over the summer to update guidance materials for both rules. We prioritized the backflow prevention and cross connection control guidance materials because more systems are struggling with them.

• In early October, we published the first in the series of several guidance documents for stakeholder review and comment - the backflow prevention and cross connection control annual reporting template for community water systems - available on the webpage. 

• The stakeholder community has valuable insight and we would like to receive stakeholder feedback about the template. Please navigate to the page above and review the annual report template. The deadline to provide feedback to the division is November 20. 

Professionalism and the Colorado Certified Water Professional Code of Conduct

For the past several years, the Colorado Certified Water Professionals (CCWP) Program has been experiencing what some might call growing pains. The transition to the CCWP Portal was traumatic to some operators and a relief to others. Some are still figuring it out. What has been a little more subtle than the CCWP Portal is the growing emphasis on professionalism. To acknowledge that there is more going on than simply “operation,” operators are referred to as “certified water professionals.” Many facilities now utilize electronic monitoring and data collection. Certified water professionals need to be computer literate, as well as able to apply biological and chemical principles to transform raw water into safe water for drinking and/or recreation. They need to use mathematical equations to calculate appropriate chemical dosages, flows, pressure, etc. The qualifications for certification, (including education, experience, on-going training and sufficient knowledge to pass a specialized examination) separate certified water professionals from less skilled workers.

For these reasons, in 2018, the Water and Wastewater Facility Operators Certification Board (board) adopted the Colorado Certified Water Professionals Code of Conduct, to which every applicant for certification or certificate renewal must agree.

A code of conduct clarifies a profession’s mission, values and principles. It is both an internal guideline and an external statement of values and commitments. Internally, a written code of conduct provides benchmarks against which individual performance can be measured. Externally, it serves as a public statement of the profession’s commitment to high standards and proper conduct.

The Colorado Certified Water Professional Code of Conduct emphasizes the profession’s commitment to protecting public health and the environment. It holds certified water professionals to standards of behavior that include honesty, excellence, responsibility and compliance with state and federal laws, rules, regulations and permits. At all times, certified water professionals are expected to use their knowledge to help safeguard water quality for Colorado residents and visitors.

The importance of this professional code is underscored by the fact that every certified water professional must agree to it. Failure to follow the code of conduct can be grounds for disciplinary action by the board. If you haven’t reviewed the Colorado Certified Water Professional Code of Conduct lately, take a couple of minutes to do so now.

➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison

Positive impacts of enhancing disinfection requirements - 2000s, 2010s, and today

We have written numerous articles over the years about disinfection and maintaining a proper chlorine residual.  Just search the blog for chlorine or disinfection and you will find excellent information and references from simple fixes to profound policy positions on appropriate disinfection residuals. Did you ever wonder how effective chlorination is in preventing drinking water contamination and what happened to disinfection waivers in Colorado?

In Regulation 11 rulemaking in 2010, the Water Quality Control Commission (commission) decided to remove the authority of the department to grant disinfection waivers. So at that time all waivers were evaluated and held static. The rulemaking also established more rigorous regulatory oversight for waivered systems. The rulemaking also required that all disinfecting groundwater systems had to maintain 0.2 mg/L at their entry points (surface water already had that requirement). Then, in the 2015 rulemaking to update the total coliform rule, the commission chose to establish a storage tank inspection regulation and also require that all systems maintain at least 0.2 mg/L chlorine residual throughout the distribution system. All of these rule changes were meant to recognize best practices performed by most water systems and to compel the few systems that were not up-to-speed to better protect their distribution systems. While the yearly data is noisy, it is important to recognize that the overall number of E.coli positive samples reported to us per year went dramatically down around the mid-2010s. See the graph below and table below.

It is also worthwhile to look back further at the trends over a few decades:

It’s apparent that over time E. coli violations dramatically decreased. Since about 2014, the majority of E. coli violations occurred at public drinking water systems that were out of compliance with the state’s disinfection requirements. 

As the 2010s progressed, we developed rigorous protocols to evaluate systems that maintain disinfection waivers to make sure public health was being protected without disinfection present. Therefore, over time, the department revoked waivers at systems that could not maintain compliance with the rigorous regulatory requirements for waivered systems. Other waivered systems voluntarily began chlorinating their water systems based on concerns over liability and realization of the relatively low level of effort that chlorination requires. 

At present, only two public water systems still maintain disinfection waivers. These two systems are the last disinfection waivers that will be used in Colorado. These communities have shown through regulatory compliance and their track record of water quality that the public in those communities has a measure of protection from waterborne disease even though they do not chlorinate. However, these communities ultimately may choose to chlorinate their water in the long term. The department’s position would be that it is always best to chlorinate when possible. Also, through natural disasters, aging infrastructure, or unforeseen events, the two systems may ultimately end up having their waivers revoked due to failure to maintain compliance.  

As discussed in the previous blog postings about the importance of chlorination, Colorado has a proud tradition of protecting our public drinking water supplies to the greatest degree possible.

➽ Tyson Ingels, P.E Lead Drinking Water Engineer

➽ Ron Falco, P.E. Safe Drinking Water Program Manager