2022 State Revolving Fund Eligibility Survey June 1 - June 30, 2021

The State Revolving Fund Eligibility Survey is conducted annually by the Colorado Department of Public Health and Environment’s Water Quality Control Division. The survey is used to identify water and sewer infrastructure improvements, as well as stormwater and non-point source needs, that are eligible for funding through the State Revolving Fund (SRF) grants and loans program. All municipalities, counties, districts, public water systems, not-for-profit water systems and other special districts that own or operate public water, sewer, or stormwater systems in the State of Colorado are encouraged to participate.

The survey will remain open from June 1st through the submittal deadline of June 30th.

Eligible projects can secure competitive, low interest loans with repayment terms of up to 30 years. Completion of a survey is the first simple step towards obtaining funding. It is not an application and it does not obligate an entity to apply for financial assistance; however, identifying capital improvement needs is a required prerequisite of securing funding offered through the SRF programs. SRF loans and grants cannot be extended to applicants who have not responded to this important survey.

Please visit the Division’s website for program details, instructions and other useful information regarding this annual process at the division's WQ eligibility survey and intended use plans website.

Be sure to opt into the notification service using the “Stay informed” link to receive timely information about SRF and other funding opportunities available through both State and Federal sources, including information for any potential Federal stimulus funding that may be made available.

If you have questions or require assistance, contact Erick Worker at (303) 692-3594 or by email at erick.worker@state.co.us.

➽ Erick Worker, Project Manager, Water Quality Control Division, Grants and Loans Unit

Lead and Copper Rule Revisions and Corrosion Control Treatment

On January 15, 2021, EPA released the Lead and Copper Rule Revisions (LCRR), the most substantial overhaul of the 1991 Lead and Copper Rule to date. The LCRR targets further reductions in lead exposure in drinking water that comes via leaching from lead-containing pipes, solders, scales, and fixtures. Lead is a neurotoxin that is especially harmful to brain development in children even at low levels. The LCRR hopes to address many of the deficiencies of the current rule that were exposed during the Flint, Michigan crisis. A summary of changes includes:

• Within three years, completing a materials evaluation of service line materials, both utility and customer owned, that includes identification of galvanized service lines that were previously downstream of a lead service line, 

• Modifications to the tiering criteria for sample sites that prioritizes sampling from lead service lines using a 5th liter sample and removing the date built as a factor in selecting copper pipe with lead solder sites,

• The addition of a new lead “trigger level” at 10 parts per billion (ppb), where systems need to evaluate corrosion control treatment options and/or initiate lead service line replacements, 

• Mandated full lead service line replacement when the lead 15 ppb action level is exceeded at a rate of 3% per year, 

• “Find and fix” water quality testing and investigations at any site above the 15 ppb action level, and 

• Public notification for high lead results to homeowners within 24 hours and to all customers for lead action level exceedances within 72 hours. 

However, after the federal administration change, the LCRR has been put on pause while EPA considers further public comment. At this time, it is unclear if there will be additional changes to LCRR or when the final rule will become effective. However, water systems should be proactive and use this additional time to plan and execute likely required activities recognizing that the rule will likely become more prescriptive within a few years.  

In all likelihood, the first requirement for water systems will be to complete an initial inventory of their service line materials. Water systems will be required to determine if each service line contains lead, galvanized pipe previously downstream of a lead service line, non-lead, or is unknown. While the department asked for a materials survey of service lines in 2016, the galvanized pipe previously downstream of a lead service line is a new requirement that must be reported upon. Secondly, there is a concern that in 2016 some water systems were reporting service line materials on the utility-owned side only, and not the full service line that will likely be required under the LCRR. 

While the majority of water systems in Colorado will not be severely impacted by the new service line materials survey, older water systems with construction prior to 1960 will have to make some effort to demonstrate statistically whether lead or downstream galvanized pipe service lines exist through various records reviews and targeted physical inspection. Furthermore, given the uncertainty of the final LCRR and any future rulemakings, water systems are encouraged to make efforts to identify where lead goosenecks and pigtails exist in their system. 

Another part of the proposed LCRR is optimal corrosion control treatment for large systems serving greater than 50,000 people. Under the current rule, large systems are required to install optimal corrosion control treatment and maintain corrosivity water quality parameters within set ranges or minimums, unless the difference between source and tap lead sampling is less than 5 ppb. The department has begun to evaluate the corrosion control treatment decisions made at large systems when the rule first took effect and is finding that historical decisions may not meet the  recent changes to corrosion control guidance or future oversight from EPA under the LCRR. The department encourages all large systems to re-evaluate their corrosion control treatment. Specifically: 

• If a large system is currently reliant on ambient water quality for their corrosion control, the department highly recommends they consult with the department and collect lead entry point and standard lead and copper tap sampling in two six-month periods to demonstrate that their lead 90th percentiles are below 5 ppb. If the large system adequately demonstrates low levels of lead, completion of a corrosion control study or installation of additional treatment may not be required, even under LCRR.

• If a large system is adding chemicals for the purpose of corrosion control or cannot demonstrate that their 90th percentiles for lead are below 5 ppb, the department recommends completing a full corrosion control study prior to the effective date of the final LCRR. The reasoning is that the requirements for a corrosion control study under LCRR will likely be more onerous than under the current rule.  

In summary, the LCRR is a step forward in reducing lead exposure from drinking water. It is a complex rule that will require considerable resources from the department to implement and from water systems to comply. Water systems should be proactive and begin taking action now to inventory their service line materials. Large systems should also address their corrosion control treatment status in consultation with the department prior to the LCRR being effective.  

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

Do I need to respond to significant deficiencies/violations from my sanitary survey? - Yes!

Don’t wait to address a significant deficiency or violation until it becomes a risk to public health. Reach out for help to achieve compliance and ensure safe drinking water! 

Do I need to respond to significant deficiencies/violations from my sanitary survey? 

YES, absolutely! 

Unresolved significant deficiencies and field based violations of Regulation 11 may pose a serious risk to public health, require additional (and potentially ongoing) public notice to customers and can result in enforcement and significant penalties. Please avoid this situation by proactively working with the Division to address unresolved significant deficiencies and violations.

Sanitary surveys are conducted at least every 3 years for community water systems and every 5 years for non-community water systems. During the sanitary survey, significant deficiencies and violations of Regulation 11 may be identified during the review of the 8 elements of the sanitary survey (see Regulation 11 Section 38). Significant deficiencies are any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public. The inspector may also identify violations of Regulation 11 in the field that require Tier 2 or Tier 3 public notice. Your inspector will review any significant deficiencies or violations identified with you during a close out meeting. The inspector will also send a sanitary survey letter that includes all findings of the inspection and the required responses. If significant deficiencies or violations are cited in the letter, the supplier must provide a written response within 45 days, documenting resolution of all significant deficiencies and violations, and/or propose a corrective action plan with a corrective action plan (CAP) schedule. All significant deficiencies must be resolved within 120 days of the date of the letter or by a Division approved corrective action plan schedule.  

Not sure if you have open significant deficiencies or violations? First, review your system’s latest sanitary survey letter. Sanitary survey letters can be found by searching for the Public Water System Identification (PWSID) number on the Division’s online record management system located here. Your Monitoring Schedule is also a great resource to review your Compliance and Public Notice Schedules. These schedules clearly list deadlines for resolving any open significant deficiencies or field based violations. 

Have open significant deficiencies and field violations and don’t know where to start? Contact your Field Services local field staff by county listed here or email us at cdphe_wqcd_fss_questions@state.co.us. Field service inspectors are available to review your sanitary survey with you and discuss options to gain compliance. 

Can’t get the issue fixed within 120 days? Field services works with suppliers to establish corrective action plans (CAP) for significant deficiencies or violations that require additional time for resolution. Please submit any information regarding your sanitary survey follow up to the DW portal here. Your Field Services follow up staff member will be alerted to your submission and will contact you.

Are you under enforcement for open significant deficiencies or violations from a sanitary survey and have questions? Please reach out to the compliance specialist listed in the enforcement order cover letter. 

For more information about sanitary surveys in Colorado, please visit our website.

➽  Heather Young, PE, CWP Field Services Section Manager and Nicole Graziano, PE, CAS Section Manager

EPIC’s Lead-Free Water Challenge Sets Sights on Small Systems

The Environmental Policy Innovation Center (EPIC) is launching a Lead-Free Water Challenge to help small municipalities and water systems (with a population size of roughly 5,000-35,000) interested in replacing lead service lines launch programs by offering technical assistance, connections to resources and funders, policy guidance, and information-sharing through peer networks. EPIC welcomes submissions from public water systems (either directly or through their municipality) willing to make a commitment to remove all of their lead pipes. EPIC will select five municipalities who will be eligible for up to 100 hours of technical assistance to aid in the development and support of their lead service line replacement program.

Interested municipalities and water systems should apply online by June 15, 2021. Learn more about EPIC’s Lead-Free Water Challenge at http://policyinnovation.org/water/leadfree.

Success Story: Seasonal Start-up Procedures

Reopening Your Seasonal Water System

Of the approximately 2,050 active public water systems in Colorado, nearly 20% (407) are seasonal. Unfortunately, roughly 10% of all our state’s public water systems have reported that they are temporarily closed or have delayed their seasonal operations due to the pandemic. It seems there is light at the end of the tunnel as Colorado’s COVID-19 Dial has been retired and the responsibilities of restrictions have been handed over to counties. In addition, vaccination is now available to all. Many seasonal and year-round water systems are gearing up to reopen for the summer. We here at the Department wish for everyone to prosper and stay safe while doing so; we would like to remind all seasonal systems of their requirement to complete the Department’s seasonal startup procedures prior to serving water to the public.  

On April 1, 2016, the Revised Total Coliform Rule (RTCR) of the Colorado Primary Drinking Water Regulations (Regulation 11) became effective. One item that was incorporated or modified was the seasonal systems and start-up procedures. The Department created the “Department’s Revised Total Coliform Rule Start-up Procedure for Seasonal Systems Handbook” (seasonal system handbook) to help guide these systems on how to evaluate and ensure that their waterworks and water have been properly inspected, disinfected and treated prior to service to the public. (See below for specific information about hand-pumped well systems). Here are some key highlights of what can be found in the seasonal system handbook: 

• Conduct a waterworks inspection: look for any damage or evidence of contamination and ensure all sanitary seals are intact.
• Integrity check: identify leaks in the waterworks as these pose a potential avenue for contaminants to enter the water system. 
• Disinfection and flushing: disinfect the water system prior to opening to kill any microorganisms that could’ve been introduced during the offseason. 
• Special Purpose Sampling: collect a “special purpose” total coliform (TC) sample within the distribution system prior to opening (must test absent for the presence of coliform bacteria). Please note that this sample does not count as your “routine” compliance sample. 
• Routine Sampling: A routine TC sample must be collected within the first month of operation. This TC sample must be collected after seasonal start-up procedures have been completed. For example if a supplier collects a special purpose TC sample on May 10,  but does not complete start-up procedures till May 12, and the supplier begins serving water to the public in May the supplier must collect a routine TC after May 12 to satisfy that month's monitoring requirement.
• Certification: submit a “Certification of Completion of Start-up Procedures” to the Department no later than the 10th day of the following month after startup.
• Record keeping: hold onto your “Seasonal System Start-up Log” along with the special purpose total coliform sample result, as these will be reviewed during sanitary surveys. For these reviews, please note that it would be beneficial if you add details to your start-up log concerning your disinfection and flushing procedures such as chlorine dosing levels and hold times. 
• What’s new: seasonal systems with finished water storage tanks, two periodic tank inspections are required each year. One must be conducted while completing the seasonal startup procedures and another while serving water to the public and at least 30 days after the pre-opening inspection.

Since the RTCR rule came into effect, Colorado seasonal water systems have been increasingly successful at doing a great job of following the seasonal system handbook and submitting their certificate of completion. The Department is appreciative and hopeful that operators and systems continue this trend moving forward.

For those year-round systems that have been closed due to COVID-19, in the interest of public health the Department strongly encourages that procedures matching the seasonal startup procedures in the handbook be completed prior to opening. Even if water pressure and treatment have been maintained while closed, a thorough system super-chlorination and flushing to remove any stagnant water should be conducted due to Legionella contamination concerns. For suppliers who own and/or operate premise plumbing systems, the system flushing should also include a thorough flushing of the hot water distribution system and tanks. A pre-opening special purpose total coliform sample should be collected prior to serving the public. The Department also expects a routine total coliform sample to be collected within the first month of operation if monitoring is less frequent than monthly. 

Together we can make the summer of 2021 a much-needed period of renewal and growth. As a resource for water systems restarting operations, the seasonal systems handbook along with the certificate of completion can be found here under Guidance.

Did you know: Did you know that there are roughly 75 hand-pumped active water systems in the state of Colorado? You may have seen one or more of these hand-pumps if you’ve ever enjoyed any of our state’s stunning campsites. But did you also know that these hand-pumps, much like seasonal systems, have their own policy, sampling requirements and guidance that they follow to ensure that the water that is served to the public is safe? One of these requirements is to conduct a seasonal start-up. For more information on hand -pumps please visit the division's RTCR website. 

Governor's 2021 Drinking Water Week Proclamation

 

Updates to the Storage Tank and Cross Connection Control Guidance Documents: Stakeholder Information

 Updated rules and policies from 2020/2021

In August 2020, the Water Quality Control Commission (commission) updated the Colorado Primary Drinking Water Regulations (Regulation 11). While there were a few minor changes to several rules, the commission made more significant changes to the Storage Tank Rule (Section 11.28) and to the Backflow Prevention and Cross-Connection Control Rule (Section 11.39). Subsequently in early 2021, the department updated several policies related to Backflow Prevention and Storage Tanks. These policies included:

• 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

As part of the process used to update the above policies, the department solicited feedback on the draft policies in February 2021 before issuing the final policies in April 2021. Please get acquainted with the updated policies. The department’s responses to the feedback we received on the draft policies are located here.

Plan to update guidance in accordance with updated rules from August 2020

During the stakeholder work for the August 2020 rulemaking, the department heard from stakeholders that additional work on guidance documents, such as the annual backflow report template and the periodic tank inspection checklist is needed.

As the next step in these updates, the department is taking a two phased approach to updating guidance documents. Phase 1 includes updates to templates and guidance for the Backflow Prevention and Cross Connection Control Rule (BPCCC), especially the annual report template. The  majority of field-identified violations we cite are related to BPCCC reporting. Phase 2 will then focus on Storage Tank Rule inspection guidance and checklists. A tentative schedule for these documents are as follows:

• Phase 1: BPCCC guidance and report template updates - May through August, 2021

• Phase 2: Storage tank guidance and inspection checklists - September through December, 2021

For more information, to read draft material, or comment; please go to: The Regulation 11 Updates website.

Drinking Water Week 2021 - Honors Drinking Water Professionals

Thank you for the work you do to protect public health in CO!

In honor of Drinking Water Week, we partner with American Water Works Association (AWWA) to recognize the hard work of Colorado’s water professionals and operators. Water operators continue to play a critical role in protecting public health and the environment through water utility work during the pandemic. A job in the water sector can provide meaningful, stable employment with the opportunity to make a difference in communities across the country. 

Currently, between 30% and 50% of the nation's water protection specialists are eligible to retire in the next five to 10 years. The EPA has launched America’s Water Sector Workforce Initiative to prevent a potential shortage of water professionals. Want to make a difference in your community by becoming a water professional? Let’s take a look at what you need to know.

Getting started

• There is no experience required - you do need to be physically able to complete the work

• There is no certification required - you do need a High school diploma or GED

• You may be required to have an active driver’s license or test for a commercial driver’s license to operate machinery

• You may be required to obtain certification after a certain amount of time on the job

Anyone can apply for entry-level positions and work their way up to higher operator levels.

Our Colorado Certified Water Professional’s Program webpage has a multitude of resources for anyone considering the profession. Just a few categories are: getting started in the profession, advancing in the profession, and active duty military and veterans. The information available walks you through which certificate is right for you, general requirements in Colorado, steps to becoming certified, and more.

While a college degree is not required to get started in the profession, you may be interested in special training at two local community colleges. These colleges currently offer a water quality course curriculum for those interested in pursuing education and certification first.

Local education opportunities

Pikes Peak Community College

Water Environmental Technology

DEGREES

• Associate of Applied Science - Water Environmental Technology

CERTIFICATES

• Wastewater Collection and Treatment

• Water Distribution and Treatment

Red Rocks Community College

Water Quality Management

DEGREES 

• Bachelors of Applied Science - Water Quality Management Technology

• Associate of Applied Science - Water Quality Management

CERTIFICATES

• Distribution and Collection Certificate

• Introduction to Water Treatment Certificate

• Introduction to Wastewater Treatment Certificate

• Laboratory Analysis Certificate

• Mathematics in Water Quality Certificate

CONTINUING EDUCATION

Red Rocks Community College also offers continuing education in the form of Training Units. Training Units are required by the State to maintain valid water operator licenses.

Career postings

In addition to EPA’s initiative discussed above, our Drinking Water Week partner, the American Water Works Association, is also dedicated to promoting water operator jobs as a lifelong career path. AWWA has a helpful webpage for operators, as well as a Career Center dashboard for water professionals nationwide. Take a look at current opportunities to see how the job listings sound! Positions range from maintenance technicians to plant operators, and even utility operations managers. There are many routes to get your foot in the door.

Regardless of the road taken, a professional career in the water industry will continue to be a necessary and secure job for anyone that pursues it. We will always need water!

Check out our Water🌢Works flyer for more information.

➽  Water Quality Control Division's communications team