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Wednesday, March 31, 2021

Culture of Health - Boil Orders

Our Culture of Health is Relentless

Hello everyone,

One of the activities that we get involved with requires responding to acute public health threats in drinking water that could lead to waterborne disease outbreaks. These events can entail E. coli violations when there is confirmed bacterial contamination in a water system to line breaks that depressurize large segments of a distribution system. When a system loses water pressure contamination can enter and make people sick when full water service is restored. Both of these situations involve issuing what we call a “Boil Water Order,” which is actually a requirement to issue Tier 1 public notice under the Colorado Primary Drinking Water Regulations (Regulation 11). The Tier 1 public notice typically advises the public to boil their water or obtain an alternate source of water, like bottled water. There are other situations including treatment failure and chemical contamination that have resulted in Tier 1 public notices. In the case of certain events, boiling the water could concentrate the contamination, and so an alternate water source is advised.

Fortunately, the number of E. coli violations has decreased significantly in recent years, so they are pretty rare now. In the 1990s, there were 114 E. coli violations at public drinking water systems in Colorado, but in the 2010s that number was reduced to 32. In fact, from 2014 through 2020 there were only 11 such violations and most of those occurred at just a few systems that had not been previously regulated. We believe that water systems and certified operators have done an excellent job improving disinfection, controlling cross connections and protecting storage tanks resulting in the decline in E. coli violations. 

However, our overall numbers of boil water orders has not steadily decreased. Of course, disasters like floods may cause increased numbers of boil water orders to be issued. But boil water orders from main breaks and other distributions system problems appear to have been increasing. It is hard to know if actual infrastructure problems are on the rise, or whether water systems are just more aware of the need to work with us through these situations and issue Tier 1 public notice. Earlier in this century we typically issued 30 to 50 boil water orders per year. That seemed to stabilize in the high teens during the four year period from 2015 to 2018, but since then ticked up to near 40 in 2019, 50 in 2020 and already about 10 in the first quarter of 2021.  

Whether it’s an E. coli violation or main break resulting in pressure loss, department staff help water systems with assessing the situation, assuring compliance with the Tier 1 public notice requirement and reviewing the disinfection, flushing and sampling process that needs to be undertaken to lift the boil water order. Other situations are handled on a case-by-case basis. We provide these services 24/7/365. To get in touch with someone during an emergency, simply call 1-877-518-5608, the department’s incident reporting line and someone will get back to you. We recognize that water system personnel are basically always on the job or on call, and we will be available to help if needed. Our collective Culture of Health is relentless in this way, and never stops. We have helped water systems through natural disaster events, but also other emergencies that have occurred on or near every major holiday on the calendar. I remember that we lifted a boil water order one time on the day before a major holiday, so the public could enjoy the holiday without the terrible disruption that being under a boil water order represents. As always, thanks for all you do to keep tap water safe in Colorado.

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


Wednesday, March 24, 2021

Colorado’s Source Water Protection Plan Data Viewer

Explore this new tool today!

The Water Quality Control Division (division) is pleased to announce a new source water tool to raise awareness of public drinking water protection. The division has coordinated with participating public water providers to display public versions of their source water protection plans. This allows federal, state, and local governments, planning agencies, stakeholders and the general public to more readily access the public water system’s exceptional planning efforts. The protection tool is designed to generally display the designated drinking water protection areas for public water systems and also provide the ability to view and download their detailed source water protection plan.

Click here to access Colorado’s Source Water Protection Plan Data Viewer.   

How to use the viewer

The Source Water Protection Planning Viewer displays an interactive symbol of completed protection plans for public water systems (PWS) in the state of Colorado. The red symbols represent public water systems that have completed a protection plan, but are not directly available on this website. The division suggests that you reach out directly to that public water system if you want more information on their planning efforts. The blue symbols represent public water systems that have provided the protection planning area and plans for the interactive tool.

Selecting the symbols on the map will provide general information about the protection planning status and public water system. The blue symbols will have a direct link to the source water protection plan available for downloading.

There are two tool buttons on the upper left side of the viewer that will allow you to search for publicly available plans and also view drinking water protection planning boundaries on the map application. The viewer allows for various search functions by water system name or county. The viewer is an ArcGIS based viewer and various data layers (ex: layer list) can be accessed utilizing the tool in the upper right portion of the viewer. Additional data layers include: streams & lakes segmentation, Hydrologic Unit Code (HUC) boundaries, county boundaries and Bureau of Land Management Agency coverage showing the various federal, state, public and privately controlled lands in the state.

Source Water Assessment and Protection is here for you

The Division strongly supports the SWAP program and is committed to working with public water systems, local governments, and federal/state agencies to implement strategies to protect one of our most valuable resources; “Colorado’s Drinking Water!”

If you are a public water system that is interested in protection planning or have completed a protection plan and would like to post a public version of your plan on the website, please email us at  cdphe.wqswap@state.co.us help to complete those processes.

John Colbert SWAP program 

Wednesday, March 17, 2021

Storage Tank Air Vents

Spring is getting near and the snow we’ve received this winter will soon begin to melt, if it hasn’t already in your part of the state. Now would be a great time to give some thought to your storage tank air vents, evaluate whether they are properly protected to prevent contaminants from entering the tank and, if not, make a plan to fix them. In addition to being a risk to public health, improperly protected air vents also put your water system at risk of being cited for a significant deficiency during a sanitary survey or perhaps even a Tier 2 violation for permitting a known sanitary defect.

What factors should suppliers consider when evaluating their storage tank air vents? 

Air vents allow the pressure inside a storage tank to equalize as the water level inside it fluctuates. Tanks without air vents or with vents that become blocked can buckle from the differential pressure.

Keep in mind that the air vent opening needs to be located up above the top of the ground surface or roof of the tank to prevent contaminants such as dirt or bird feces from being drawn into the tank. Case in point, the specs in the photo below are bird feces around the air vent on the roof of a tank.


Additionally, the average snow accumulation for the area should be considered and the air vent should be designed to prevent an accumulation of snow (or ice) from blocking the opening(s).

One particular issue that is frequently discovered during sanitary surveys are air vents that are not fully covered to protect from rainwater or that do not open downward. This could allow contaminants that have collected on the screen to be washed off of the screen and carried into the interior of the storage tank by rainwater. Several more examples of improperly protected air vents are discussed below. 

Example 1: The photos below (and the one above) show air vents that are not fully covered to properly protect the air vent from the entrance of contamination from rainwater and blowing debris. “Mushroom” type air vents that are not fully covered to protect from rainwater must be corrected by being modified so that the screened area is fully covered.


Example 2: The photos below show another improperly screened air vent. In this case, the screen is installed horizontally underneath the “mushroom” cap but there is no secondary screen to keep birds, animals and insects from perching or nesting on top of the screen under the mushroom lid. Also, there is a hole in the middle of the screen for cables to pass through. Both conditions are sanitary defects which must be corrected by 1) removing or relocating the cables and installing an intact screen, and 2) installing a secondary screen to keep out insects, birds, squirrels, etc.


Example 3: The photos below show storage tank air vents that are not downturned. Air vents that open sideways are not permitted and must be corrected by being modified to open downward.


  • Air Vent issues to check for and correct if found (the following conditions are not allowed):
  • Storage tanks with no air vent
  • Storage tanks with the overflow pipe also used as the air vent
  • Storage tanks with open construction between the sidewall and the roof
  • Air vents that are not screened or that have damaged or blocked screens
  • Air vents that are made of corrodible materials that can rust
  • Air vents with screen openings that exceed 0.07 inches (typically 12 or 16 mesh screen is needed for the openings to be smaller than 0.07 inches)
  • Air vents that do not open downward or are not fully covered to protect from rainwater (see examples 1-3 above)
  • Air vents with openings that are less than 24-inches above the top of the ground surface or roof
  • Air vents that are susceptible to vandalism
  • Air vents that are not accessible for replacement

(Deviations from the requirements above may be allowed in certain cases, such as for storage tanks that are stored in clean climate controlled rooms and have a total volume of less than 11,000 gallons or other situations.)

If suppliers identify a sanitary defect, it must be documented upon discovery. Also, a corrective action schedule in accordance with the Storage Tank Plan must be developed to fix it as soon as possible. Take photographs before and after making repairs. By doing so, suppliers can avoid a violation for not correctly implementing the storage tank rule.

Sanitary defects that are discovered during sanitary surveys may be cited as significant deficiencies or possibly even as a Tier 2 (treatment technique) violation of the storage tank rule for permitting a known sanitary defect. The risk of violations is especially true for defects that should be ‘obvious’ to anyone performing a periodic tank inspection.

Additionally, if suppliers do not follow the corrective action schedule that they developed, they will also be in violation of the storage tank rule. Avoid violations of the storage tank rule by proactively identifying sanitary defects and then documenting that the supplier is following a corrective action schedule to fix them. 

Conclusion: Unprotected or improperly designed air vents can provide a pathway for contamination to enter the water stored in the tank and can be a source of contamination. Properly protected storage tank air vents are a critical part of the multiple barrier approach to providing safe drinking water and are a safe and effective way of protecting our communities and promoting a culture of health.

Does your storage tank have an improperly protected air vent? If so, identify and document problems with air vents and develop a corrective action schedule with appropriate timelines to correct the sanitary defect(s) that were identified and include it as part of the supplier’s storage tank inspection plan. Otherwise, don’t be surprised if improperly designed air vents are cited as significant deficiencies and/or violations of the storage tank rule during sanitary surveys.

Please reach out to the field services section at cdphe_wqcd_fss_questions@state.co.us with any related questions.

Guidance & Resources: 

Monique Morey, PE, field services section

Facility Reclassification: Make sure you have an ORC with the correct level of certification!


In November 2018, the Water and Wastewater Facility Operators Certification Board updated the criteria for facility classification in Regulation 100. These revisions are important because treatment facility and distribution/collection system classification establishes the minimum certification level for operators who act as the certified operator(s) in responsible charge (ORC). 

All facilities are required to have an operator certified at the appropriate level on file with the department who is performing the required duties as specified in Regulation 100. To change operators, a contact form must be submitted to the department (links below for drinking water and wastewater). The division has gathered information and resources to assist operators and facilities meet the ORC requirements for their systems: 

Upgrade operator certificate through examination

Hire a contract operator until your ORC tests up: 

Be sure to keep designated ORC contact info up to date with division 

Any additional questions

  • If you have additional questions  please contact: 
    • Drinking water: contact your facilities compliance officer. To find your compliance officer visit the Compliance Assurance website and select your county from the drop down list. 
    • Wastewater: contact your facilities compliance officer. To find the compliance officer appropriate for the permit type, please see the list on the last page of the DMR Guidance document on the Clean Water Guidance website.

Do you think your classification is incorrect?

  • To find the information on which your facility classification is based:
    • Drinking water: Use the drinking water monitoring plan generator form and select your treatment processes. You will then receive an emailed template that lists your facilities treatment specifications the division has on file. 
    • Wastewater: contact David Kurz david.kurz@state.co.us to discuss what the division has on file for your facility
  • To learn more about facility classification visit the division’s facility classification website and the factsheet
  • To find the criteria for classification in Regulation 100
    • Drinking water: 100.4
    • Distribution: 100.8
    • Waste water: 100.5
    • Collection: 100.9
  • If you think your facility classification was made in error please contact:
Kyra Gregory Drinking Water Training Specialist



Wednesday, March 10, 2021

Coming Down the Pipeline - Direct Potable Reuse Rule & Facility Classification Update

Direct Potable Reuse Rule - Stakeholder Process
Process kicks off March 16, 2021
Resource: Regulation 11 - Direct Potable Reuse Website

The state of Colorado expects to double its population by the year 2050, adding to demands on the state’s most precious resource (water). The state Colorado Water Plan lays out strategies to address projected gaps in water supply and demand, and direct potable reuse (DPR) is one of those strategies. DPR involves an extensive public outreach process and the installation of advanced water purification steps to ensure that wastewater can be safely reused for drinking water. There are no DPR systems approved in Colorado to generate potable water currently, but some utilities have previously operated pilot projects to showcase DPR's ability to address water needs for future generations. 

While DPR is not prohibited in the state, there are no federal or state regulations specifically for DPR. Regulated entities have requested that the division begin developing a DPR-specific rule through an engagement process to help ensure consistent implementation and outreach across the state. The addition of a DPR rule will allow water systems across the state to partner with the department to properly plan and communicate with their public about what is needed to safely accomplish DPR. Stakeholders have been actively helping develop the appropriate foundation for a Colorado DPR Rule. They have supported the development of a key guidelines document authored by the National Water Research Institute and an independent panel of national experts (December 2019).

The department will host virtual stakeholder meetings with public members and regulated entities to obtain feedback and begin drafting a proposed DPR rule for insertion within the Colorado Primary Drinking Water Regulations (Regulation 11).

Facility Classifications 
Effective March 1, 2021
Resource: division's facility classification website

Regulation 100 has updated facility classifications defining the required level for the Operator in Responsible Charge (ORC) that became fully effective on March 1, 2021. The change was adopted in 2018 when the Water and Wastewater Facility Operator Certification Board modified regulation 100 at the November 27, 2018 Rulemaking. The regulation included a phased application of the revised facility classification table.  First, the Engineering Section began using the regulatory update on March 1, 2019 to specify facility classifications for new/modified facilities.  Second, the facility classification tables became effective March 1, 2021 for all water and wastewater facilities. As a result of these regulatory updates becoming effective, some systems have a change of water and/or wastewater facility classification(s) that may cause a subset of drinking water and wastewater facilities to not have operators certified at the appropriate level to be the ORC. Not having an operator in responsible charge certified at the proper level will result in violations being issued. A summary of the violations that are anticipated is as follows:

  • Drinking water: ~124 systems of the ~2100 systems regulated by the department will receive a violation (~6%). Of the 2100 systems regulated, about 460 systems have a changed classification starting on March 1.  
  • Clean Water: ~122 of the ~764 permitted entities requiring ORC will receive a violation (~16%). Of the 764 permitted entities, about 153 systems have a changed classification starting on March 1. Note: By the same estimating method, ~96 of the ~764 permitted entities requiring ORC would receive a violation in February based on the current classification (~12.6%), or an increase of 3.4% with the classification change. 

The division urges you to verify your facility classifications per Regulation 100 and verify that your operator(s) has the correct certifications to be the ORC of your system.  If you have any questions, first check our webpage or your drinking water monitoring schedule to make sure you have the proper certification for your facility. Also, feel free to contact us - see below.

Contact 

Wednesday, March 3, 2021

New EPA Administration Considerations















Federal Rule and Funding Update

In January 2021 a new EPA administration began. As is common practice, the new administration placed all the latest activities from the prior administration on hold. This has significant implications for drinking water. In this article, we will briefly explore a couple of these actions and discuss funding as well.

Actions Placed on Hold

Before the change in Administrations, EPA published the final Lead and Copper Rule Revisions (LCRR) in the Federal Register. This means that the rule becomes effective March 15, 2021 and states have until January 2023 to adopt the rule with a compliance date of January 2024. However this action was placed on hold, so now  we are all in a bit of limbo. EPA has at least a few options to consider.


  1. After review, EPA can let the rule stand as is. If the review takes a long time, we hope that they allow states a concomitant amount of extra time to adopt the rule and similarly extend the compliance deadline.

  2. EPA can withdraw the rule and publish a revised final rule without additional public comment if it believes that the changes are within the scope of the prior public notice opportunity. For example, EPA might believe that raising the required minimum Lead Service Line Replacement (LSLR) rate higher than 3.0 percent would not require a new public notice period and move that forward as a part of the final rule with other similar changes. This would likely change the adoption and compliance dates in accordance with a new final rule publication date in the Federal Register.

  3. EPA can withdraw the rule and determine that it wishes to make changes substantial enough to be outside of the scope of the prior public notice opportunity. In this case, EPA  would need to promulgate a new draft rule and take public notice on that draft prior to finalizing LCRR. Obviously, this could cause a significant delay.


At present we have no way to know which direction EPA will go or how long the review will take. We are certainly hoping to hear something from them in March 2021.


After reviewing the previous administration’s final actions to regulate PFOA and PFOS and include 29 PFAS contaminants plus Lithium in the fifth Unregulated Contaminant Monitoring Rule (UCMR5), EPA decided to move forward with these at the present time. However, EPA will be holding public meetings and taking comments on UCMR5, so the contaminants that will be tested could change. EPA is required to promulgate a draft for PFOA and PFOS within two years.


Additionally, EPA indicates that they will revisit their prior decision not to regulate perchlorate in drinking water. If EPA changes that decision, then it might need to accept public comment on that decision, but would definitely need to accept public comments on a draft rule before finalizing it with a Maximum Contaminant Level (MCL). 


Funding

With the new congress and new administration it is likely that EPA’s funding and the funding provided to states to implement the Safe Drinking Water Act will increase, but this may not happen until at least 2022. This could help shrink current resource gaps that states experience, but the new funding needed to support LCRR implementation is substantial. It is also possible that funding for infrastructure could increase significantly as that was being discussed prior to the pandemic. There could also be additional funding dedicated to removing lead service lines across the nation. Again, if any of these funding initiatives move forward, the dollars might not actually flow until 2022.


Ron Falco, P.E., safe drinking water program manager