CoWARN update early 2021

What is CoWARN?

Colorado’s Water/Wastewater Agency Response Network (CoWARN) is a statewide network of “utilities helping utilities” to prepare for and respond to a natural or human-caused emergency. Utilities know that their equipment can be specialized and their talented staff often possess unique skill sets. In times of need, gaining assistance from utilities is often the best option. CoWARN is led by utilities for utilities and the mission of the CoWARN network is to support and promote statewide emergency preparedness, disaster response and mutual aid assistance for public and private water and wastewater utilities. CoWARN facilitates a formalized system for water and wastewater utilities to help each other with mutual aid during emergency situations. CoWARN is a partnership between utilities, various state and local agencies, and water and wastewater organizations. CoWARN is not owned or led by the state of Colorado, but CDPHE does support the network by helping with administration duties.

CoWARN provides water and wastewater utilities with:

• A Mutual Aid Agreement and process for sharing emergency resources among water and wastewater agencies statewide.

• A mutual assistance program consistent with other statewide mutual aid and assistance programs and the National Incident Management System.

• The resources to respond and recover more quickly from a natural or human caused emergency or disaster.

• A forum for developing and maintaining emergency contacts and relationships.

How to participate in CoWARN?

Joining CoWARN is as simple as filling out a Mutual Aid Agreement and submitting it to the CoWARN website administrator, Kyra Gregory (kyra.greogry@sate.co.us). The CoWARN Mutual Aid Agreement is available to all public and private water and wastewater utilities in Colorado. When you become a member of CoWARN, participation in any emergency response is voluntary, and membership in CoWARN does not obligate members to offer or accept aid. All actions, recommendations, etc. are made in accordance with the articles of the CoWARN Mutual Aid Agreement. 

CoWARN’s 2020 response 

The global pandemic that began in 2020 presented many significant challenges to water and wastewater services in our state from COVID-19 itself, in response to heightened cybersecurity concerns, and devastating forest fires. The CoWARN steering committee took action to provide valuable resources to their members. 

In spring 2020 CoWARN took swift action to respond to the COVID-19 pandemic by distributing face coverings and establishing a list of individual operators willing to assist in staffing shortages caused by illness. In partnership with the Federal Emergency Management Agency (FEMA) CoWARN leadership and members worked to distribute over 60,000 cloth face masks. The mask distribution was in response to a general request for additional personal protective equipment from multiple water and wastewater utilities, as well as water industry organizations in the state of Colorado. CoWARN members volunteered and created four distribution sites across the state to ensure all water and wastewater utilities, regardless of type, size or affiliation, had an opportunity to obtain free PPE for workers. Special thanks to Parker Water and Sanitation District, Denver Water, Colorado Rural Water Association, and the city of Grand Junction for volunteering their time and resources to help protect water and wastewater employees in Colorado.

Due to the potential labor shortages that may accompany the COVID-19 pandemic, the CoWARN steering committee decided to invite individual water system personnel (contract operators, retired water system personnel, etc) to join CoWARN under an associate member account. The same tactic was used during the 2013 flood state emergency and it worked well. These individuals would be able to respond to assistance requests. Thank you to the over 180 operators who offered their assistance!  

In addition to their COVID-19 response, CoWARN provided resources and guidance to systems to prepare for and potentially respond to security threats to their systems including cybersecurity as well as physical security threats. The CoWARN steering committee also provided outreach and resources to systems that experienced wildfires this summer and fall. 

Looking ahead

CoWARN and its steering committee, made up of volunteers from the network’s members, now look to the future of emergency response in Colorado. The coming years will no doubt present new challenges to water and wastewater treatment. As you and your system look ahead to protect public health in the coming years CoWARN invites you to join their network of utilities helping utilities. Water and wastewater systems provide our communities with a life-sustaining resource that is of vital importance to maintaining public health, sanitation and safety. By restoring water and wastewater service in the most efficient manner possible, CoWARN provides renewed hope for fast recovery from disasters. Who is more likely to have that specialized pump or valve your system needs to get back on line in a hurry, and the staff with expertise to help get the job done right? That’s right, another water or wastewater system. 

In addition, CoWARN is also inviting it’s members to participate in its steering committee. This is a group of volunteers who meet every-other month to discuss current issues arising in our state and communities. Steering committee members typically engage with CoWARN for less than 5 hours a month. This is a great way to impact the direction of emergency management response in your state with minimal additional work added to operator’s busy schedules. For more information on volunteering for the CoWARN steering committee contact kyra.gregory@state.co.us. 

➽ Kyra Gregory, Drinking Water Training Specialist

Simple Fixes - chlorine addition points and hydropneumatic tanks

In Colorado there are approximately 2,100 public water systems ranging from a small gas station with a drinking water well up to Denver Water serving 1.4 million residents. Nearly 1,600 of those 2,100 public water systems serve 500 or less people. Many times, those very small systems consist of a simple groundwater well, hydropneumatic pressure tank (pressure tank), and a small distribution system. Oftentimes the distribution system at the smallest systems is only one building. Other than hand-pumped wells at campgrounds (which operate under a special rule), the remainder of public water systems must continuously chlorinate their source water and provide a chlorine residual throughout distribution greater than 0.2 mg/L. 

For some water systems, the appropriate location for the chemical injection point can be a point of confusion. This confusion may be exacerbated by the fact that the Colorado Division of Water Resources rules for well drillers has traditionally defined the scope of the water well supply system as being part of the well driller’s responsibility. Typically this is up to and including the pressure tank if installed. The definition from the well driller’s rule is as follows:

 5.2.56 “Water well supply system” includes all components of a groundwater well, pump, drop pipe, pitless adapters or units, other pumping equipment, storage tanks or cisterns, and piping and connections between the well and its point of discharge from the pressure tank, if such a tank is installed. 

Based on the above definition, a well driller may install a water well, pressure switch, and a pressure tank. Then, when a system becomes a public water system, it must add chlorine feed. Typical installation of chlorine feed involves linking the feed pump to an existing pressure switch that turns on both the well pump as well as the chlorine injection pump. In some cases, we have discovered that a public water system has installed their chlorine injection point at a location after the hydropneumatic pressure tank. 

The main issue with having the injection point after the pressure tank, but the chlorine feed pump linked to the well pump is that the pressure tank can discharge water to the distribution system even when the well pump isn’t running. This means that raw water (unchlorinated well water) would be fed to distribution without a chlorine residual, which may not be safe.  Per Sections 11.11 and 11.8 of the Colorado Primary Drinking Water Regulations (Regulation 11), water must be continuously chlorinated at the entry point. Therefore, whenever our field inspectors discover a situation where the pressure tank may be located in the potentially unsafe configuration, the issue is cited as a significant deficiency in the inspection findings and must be repaired.  

Fixes to the improper chlorine feed point:

Solution #1: Move the injection point:

Many public water systems choose to simply relocate their chemical injection location to a location prior to the pressure tank. This change will solve the significant deficiency of having unchlorinated water enter the distribution system. A typical schematic after correction is as follows:

*image courtesy of University of Georgia Extension

In the above example, please note that a carbon filter may remove all the chlorine residual, which is not allowed in Colorado because a 0.2 mg/L chlorine level must be maintained throughout the distribution system. Also, the chlorine metering pump can continue to be linked to the well pump on a pressure switch. 

Some water systems and water professionals have expressed concerns about the chlorine feed degrading the rubber bladder in the pressure tank and have indicated they prefer to keep the chlorine feed location after the pressure tank. If that is the case, then solution #2 may be a better option.

Solution #2: Install a flow switch to inject chlorine when there is flow

A second solution is to leave the chlorine injection point after the pressure tank and install a flow switch so that the chlorine feed pump is activated when flow is detected rather than when the well pump is turned on. A typical installation of a proportional flow meter or flow switch can be seen in our pre-accepted groundwater disinfection design document and is in the following schematic:

Typically, flow switches can be purchased from a variety of locations including usabluebook, amazon, grainger, omega, and more. The department strongly recommends small water districts employ personnel who have experience working with and installing such components if they choose to configure their system to work with a flow switch and it has been previously plumbed to use a pressure switch. Certified plumbers may also have the expertise necessary to perform the system upgrades.  While we do not require design approval to convert from a pressure switch to a flow switch, the department is happy to provide technical assistance if there are questions about the installation.

Coming Down the Pipe - Policy Updates

2021 Storage Tank and Cross Connection-Control Policy Updates 

In August 2020, the Water Quality Control Commission updated the Colorado Primary Drinking Water Regulations (Regulation 11). While there were a few minor changes to several rules, there were significant changes to the Storage Tank Rule (Section 11.28) and to the Backflow Prevention and Cross-Connection Control Rule (Section 11.39). 

During the stakeholder work for the August 2020 rulemaking, the department acknowledged that several key policies would need to be updated as a result of a successful rulemaking effort. Also, the department acknowledged that additional work on guidance documents like the annual backflow report template and the periodic tank inspection checklist needed to be completed.

As a first step in these updates, the department identified minor changes in four policy documents to reflect the updates to the regulation. The department considers these changes relatively minor and is seeking stakeholder feedback on the changes. Once the policy changes are finalized, the department intends to launch a second stakeholder process to update the guidance. 

There are four key policy documents that must be updated to reflect the new language in Regulation 11. These were established policies the department published after the 2015 Regulation 11 rulemaking, but given the Regulation 11 updates in 2020, there were items that needed updating and clarifying. Please check our engagement page for more specific details on the minor modifications to these 4 policies:

Policy 7: Backflow Prevention and Cross Connection Control Policy

Policy 10: Sanitary Defect Policy (section about storage tanks only)

Policy 12: Storage Tank Rule Alternative Inspection Schedule Policy

Policy 15: Storage Tank Rule Inspection Methods Qualified Personnel Policy

➽Tyson Ingels| tyson.ingels@state.co.us

Program Manager Message

Looking Ahead to the 2020s

A few months ago, we republished an Aqua Talk article I authored in late 2009 entitled “Perspectives on a New Decade.” It looked back on what happened in the 2000s and attempted to look forward to what might happen in the 2010s. Then, in December we published an article titled “Perspectives on the 2010s” reviewing what actually happened in the 2010s. Now let’s  look forward to the 2020s. I know this is coming out a year late, but considering what happened in 2020, that worked out for the best as no one could have predicted the start to this decade that we actually experienced. 

In the 2020s we will not take our eye off the ball in terms of focusing on preventing waterborne disease outbreaks. We intend to continue vigorous implementation of our rules regarding disinfection waivers, storage tanks, backflow prevention and cross connection control, disinfectant residual in distribution, hand pumps, and water haulers. We hope to see a continued positive track record of no waterborne disease outbreaks and only rare E. coli violations in drinking water. However, new challenges will arise on this front as well. Pathogens present in biofilms have recently been shown to cause most of the serious health problems and health care costs related to waterborne disease in the United States. As EPA reviews the suite of Microbial/Disinfection Byproducts Rules in the early to mid-2020s, they will be considering these pathogens like Legionella and also more disinfection byproducts and different health endpoints, such as fetal development.

The 2020s will involve continued focus on lead and PFAS. EPA just finalized the Lead and Copper Rule Revisions (LCRR). The new administration is going to review this rule, and once it is truly finalized, Colorado will have two years to adopt the federal rule. Adopting this rule will involve a thorough stakeholder process, and of course our final rule must be at least as stringent as the federal rule. However, once the rule is final it will take years of effort to fully implement the rule, especially for systems with lead service lines. The revised rule will include efforts to sample at schools and daycares, and we will be able to provide some support in that area using a federal grant program. 

EPA also finalized their regulatory determination for PFAS compounds and indicated that they will move forward with MCLs for PFOA and PFOS. Again, the new administration may revise this approach. Additionally, many more PFAS compounds must be included in the fifth Unregulated Contaminant Monitoring Rule (UCMR5) sampling efforts under federal law. Fortunately, the sampling that we have done proactively in the late 2010s shows that we likely do not have a large number of water systems with high PFAS levels, but only about half of the community systems have been sampled so far.

As climate change continues to impact Colorado’s water supplies and the temperature of state waters, we could also see more harmful algae blooms and the threat of cyanotoxins being present in drinking water sources and possibly tap water. We have good programs in place to try to address underlying nutrient pollution and monitor for blooms, but these programs are not comprehensive so we are at some risk.

During the 2020s, we also intend to develop a regulatory framework including regulations, policies and guidance to assist water systems in planning and implementing direct potable reuse if needed. Direct potable reuse can help Colorado move forward with our State Water Plan. The framework for direct potable reuse is intended to have flexibility and ensure safe drinking water and help with public support. But we also intend to prevent communities without adequate technical, managerial, and financial capacity from undertaking such a serious effort.

While drinking water in Colorado is safer today than ever before, the world is not necessarily safer. In 2020 we saw considerably more vandalism and cyberattacks against drinking water infrastructure than normal. I hope that trend does not continue, but unfortunately I believe that this will be an added pressure on all of us for the foreseeable future.

It will take resources for water systems to continue their track record of improving water quality and for the Safe Drinking Water Program to enhance our services in support of those efforts. I am hopeful the recently increased federal funding will continue and be increased further to help us with implementing the expected new LCRR and PFAS rules plus help us support security needs.

Even with all these expected challenges ahead and those that we cannot anticipate as well, I am not losing sight of the fact that, as mentioned before, our tap water is safer than ever and that is something to celebrate and be proud of. We launched a Culture of Health, and I believe it is catching on. We will continue our partnership with water systems, EPA, local health departments and operators to foster a Culture of Health throughout the community of water suppliers. With a Culture of Health firmly entrenched in all of us, we will be ready to face challenges and succeed! I cannot predict what the drinking water world will look like in 2030, but hope we have some fun this decade on that journey!  

➽Ron Falco, Drinking Water Program Manager

Indroducing the new Aqua Man: Aqua Answers

Aqua Man recently retired but fear not, your questions about all things water can now be directed to the new Aqua Talk feature “Aqua Answers.” This new title is intended to serve as a respectful, gender neutral name to reflect the diverse water professionals and champions in Colorado. 

Dear Aqua Answers,

I heard recently that operators now need to report storage tank rule violations to the state, and not wait for the sanitary surveys that take place every few years. Is that right?

Respectfully,
Hope N. De'Fecte'

Dear Hope,

Yes. That is correct. However, that requirement is not new. Revisions to the storage tank rule were proposed as a result of our recent work with stakeholders prior to the August 2020 rulemaking before the Water Quality Control Commission. During that process, everyone agreed that within the storage tank rule, we should reference back to an existing requirement in the regulations that covers reporting violations. Section 11.35(2)(c) of the Colorado Primary Drinking Water Regulations (Regulation 11) already required that suppliers report all violations within 48 hours, unless a different timing is specified in the regulations. This means that violations of the storage tank rule were already required to be reported within 48 hours. It was agreed to reference back to this requirement in the storage tank rule. The purpose of this change was to add clarity and help avoid finding out about a violation until a sanitary survey that takes place a couple of years later, which makes the timing of public notice more awkward and more challenging for the public.

Hope, as I am sure you know, we are working with water systems across Colorado and at all levels to institute a Culture of Health. The Culture of Health needs to be adopted at the state level, but even more importantly by all the people working that design, operate, manage and own public drinking water systems. We all need to work together to help make sure that drinking water is always safe, and that if there is an issue we will let people know. So, yes it is important to make sure that storage tanks are free from defects to keep drinking water safe. But it is also important to work with us at the health department to implement all the drinking water rules and report violations to us in accordance with the regulations. Thank you so much for your question!

Sincerely,
Aqua Answers