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.
