Aqua Answers: materials evaluation vs. a lead service line inventory

Dear Aqua Answers,

What’s the difference between a materials evaluation and a lead service line inventory?

Sincerely,

Mat Plumber

Dear Mat,

A materials evaluation is a survey of all lead, copper, galvanized, and cast iron and steel piping, service lines, and interior plumbing within a water system’s distribution system. Community water systems were first required to develop a materials evaluation nearly 40 years ago. Many water systems used the original materials evaluation to help identify sample pool sites when the 1991 Lead and Copper Rule was promulgated. However, over the years, these evaluations were mostly left to languish and were not maintained or at worst lost as water system personnel came and went. In 2016, the department requested the materials evaluations from systems to evaluate the appropriateness of their current lead and copper sample sites in terms of identifying lead service lines, lead pipes, and copper pipes with lead solder. The department worked with systems over several years to update their materials evaluations, which has yielded vast improvements in proper lead and copper sample site selection based on the current tiering levels of the Lead and Copper Rule. 

The Lead and Copper Rule Revisions promulgated in 2021 requires systems to have a lead service line inventory when the rule takes effect, currently slated for the end of 2024. Water systems are required to identify the individual locations of each lead service line, galvanized pipe that is or was downstream of lead service line, non-lead service lines, and unknown service lines for both the publicly and privately owned sides. While much of this information was required for a materials evaluation, the department will expect water systems to take a second look and evaluate if they have their service lines properly identified on both the publicly and privately owned side of service lines.

It’s important that systems work hard on this inventory to develop a high confidence in their categorization of the service line material by 2024. Unknown service lines are treated as possible lead service lines and special notices will be required to be sent to these customers annually if they remain unknown. Ideally, a system has records of installed service line material or physically verifies the materials through pot-holing. Having records or physical verification of all service line materials is very unlikely for many water systems, however. When the rule becomes effective, the department will expect water systems to use a combination of installation and maintenance records, plumbing codes or permits, interviews with experienced system staff and homeowners, and selectively used physical verification when service line materials are unknown. This will allow water systems to make high confidence determinations on the material type to a swath of homes based on installation dates. The lead service line inventory must be updated at least annually as service line materials change and must be made available to the public with systems serving greater than 50,000 required to make them available online, such as a GIS map, unless there are no lead service lines, galvanized pipe downstream of previous lead service lines, or unknown service lines.

Now is the time for water systems to be proactive about their lead service line inventory. Systems should use this time to organize any available paper records and to implement service line identification procedures as part of routine distribution maintenance and repairs and meter reading and to document the findings with location identifying information. Please visit the department’s Lead and Copper Rule general website or Lead and Copper Rule FAQ for more information. 

Happy hunting,

Aqua Answers

Operating Plans for Delegation of Tasks

Task Delegation through written operating plans, the regulatory requirements and inherent responsibilities 

Resources: - Division's delegation plan website with templates and examples On September 29, 2020, disciplinary action was taken against an operator in responsible charge (ORC), in part for their failure to have a written operating (delegation plan). This operator thought they had a perfectly fine delegation plan. They unsuccessfully argued that a generic, stand-alone standard operating procedure that they filed in the facility’s office met the requirements of a delegation plan as laid out in Regulation 100.12.6. It did not. A written operating (delegation) plan is a tool that an ORC can use to authorize certified or uncertified individuals at a facility to perform specific tasks or activities related to the operation of the system. Used correctly, it enables an ORC to meet the regulatory responsibility of supervision over the operation of the facility and over the operational activities and functions of other facility operators, without having to be on-site 24-7. This may translate into cost savings, especially for smaller systems that don’t need, and cannot afford, a full-time ORC. The written delegation plan also helps certified or uncertified operators understand the limits of their tasks and activities. That is, they know when they have to consult with the ORC. Only the ORC is authorized to make process control and system integrity decisions. To be effective, the following elements should be included in a delegation plan. - Name of the facility/system including the PWSID number or Permit number - Name of the ORC who is delegating the task or activity - Date range of delegation (operating plans must be reviewed, and if appropriate, updated annually) - Name and/or brief description of the task or activity - Person(s) or Position Title of the individual(s) being authorized to perform the task or activity at the system - Delegation limits identifying when the individual(s) must contact the ORC for further instructions - Date of training provided by the ORC to the individual(s) being authorized to perform the task or activity - If the task or activity isn’t already included in writing in the individual’s job description, the delegation plan should document the individual’s written acceptance of the delegated task or activity - Written standard operating procedures (SOPs) that provide detailed, step-by-step instructions for performing the task or activity. A blanket statement delegating all operational responsibilities to an on-site individual does NOT meet the minimum requirements in Regulation 100 for an operating plan because it does not identify specific tasks, nor does it identify the limits of each task. Delegation is a specific ORC responsibility. An ORC cannot authorize a system owner or anyone else to delegate tasks to subordinate personnel. An ORC cannot delegate any responsibilities that are reserved to the ORC, such as process control or system integrity decisions. An ORC is accountable for the consequences of tasks performed by individuals acting under a written operating plan. Therefore, it is necessary for the ORC to provide adequate training and to routinely verify that each individual to whom tasks are delegated is performing these tasks correctly. Written SOPs are a best practice to help ensure consistency of performance. Because the ORC has supervisory responsibility, the ORC needs to train the individual, verify the person’s understanding of the task, verify the individual knows where the written SOPs are kept and how to refer to them if memory fails and confirm the individual’s willingness to follow the instructions. If an individual trained by the ORC is unwilling or unable to perform in accordance with the ORC’s verbal and written instructions, the ORC needs to take back the delegated tasks or activities from that person. Then the ORC must perform the tasks personally or find another person to perform them. Regulation 100 states that “certified operators in responsible charge shall protect the public health and the environment in the conduct of their duties.” An ORC who allows untrained or inadequately trained individuals to continue performing tasks or activities incorrectly is not protecting the public health and the environment. An ORC who allows workers that won’t follow clear directions to continue performing delegated tasks or activities is not protecting the public health and the environment. The written delegation plan, when used correctly, is a great resource with benefits for the ORC, the other facility operators and system owners. When used correctly, it provides a lot of flexibility, while still protecting the people we serve. Let’s keep our Culture of Health in mind and take the time to delegate responsibly and effectively. ➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison

Division awards high performing drinking water systems

The division encourages water utilities to operate at their best to protect public health and the environment, and it’s important to recognize those systems that maintain long-term compliance, exceed regulatory compliance, and take proactive steps to overcome challenges.

The Pursuing Excellence Program is designed to recognize these high performing systems via two awards, given out each spring. The Commitment Award recognizes water systems that have either taken impressive steps to overcome a difficult challenge, or have shown an impressive commitment to a culture of health. The Outstanding Compliance award recognizes systems that have long-standing records of exemplary compliance with the Safe Drinking Water Act.  

For 2021, the division awarded the Commitment Award to Parker Water and Sanitation District, Denver Water, and the City of Grand Junction for their efforts in protecting water/wastewater utility workers from COVID-19. In the spring of 2020, FEMA made 70,000 cloth face masks available for Colorado water/wastewater utility employees, but needed utilities to distribute the masks. Parker Water and Sanitation District, Denver Water, and Grand Junction volunteered their time, space, and money to receive these shipments from FEMA, coordinate with water utilities, and distribute masks to every water/wastewater employee who needed them. The dedication of these three utilities (and the Colorado Rural Water Association, who also played an integral role) helped protect Colorado utility workers from COVID-19 and helped ensure Coloradoans continued to have access to clean drinking water and sanitation. 

The division awarded 14 community water systems with the Outstanding Compliance Award. Drinking Water Regulations are designed to protect public health, and long-term compliance with these regulations is worthy of recognition. As of December 31, 2020, each of these systems has been in compliance with the Safe Drinking Water Act for over 20 years. 

Surface water systems:

• City of Central City

• Dillon Valley District

• Montezuma Water Company

Ground water systems:

•  Chateau Chaparrel

• Forrest Grove Estates

• Hermosa Village

• Kingdom Park Court

• No Name Creek Water System

• The River Meadows

• South Adams County Water and Sanitation District

• Town of Sanford

Consecutive systems:

• Town of Crowley

• Homestead Improvement Association Inc.

• North Carter Lake Water District

➽ Kaitlyn Beekman

New Resource: Security resource & response toolbox

We recently posted about security threats that have affected water utilities in Colorado and nationally.

• November 12, 2021 article: Threats on the Rise, Take Action Today!

• June 2, 2021 article: Roxborough Water and Sanitation emerged a champion of cybersecurity 

The Safe Drinking Water Program assembled a security toolbox webpage designed to help water utilities plan for, prevent, and guide responses to security threats including general malevolent acts, cyberattacks, tampering, and violent acts. The tool box has two sections, one for general tampering events, such as vandalism, malevolent acts, introduction of contamination, violent acts, and terrorism attacks and the second is specifically for cybersecurity attacks. All malevolent acts pose a threat to water/wastewater utilities and are sometimes overlooked in Risk and Resilience Assessments as well as Emergency Response Planning efforts. Malevolent acts can affect your critical infrastructure by creating contamination events or by slowing or stopping your facility’s ability to function. The purpose of the toolbox is to help your system build resilience and protect public health by preparing for these potentially dire events. 

Here are some definitions and explanations to help provide more context for this subject: 

• Tampering events can be any of the following:

• Introducing a contaminant into a public water system or drinking water.

• Interfering with drinking water or the operation of a public water system with the intention of harming people or public water systems. 

• Threats of the above items. 

• Per regulation 11.2(1), tampering events or threats of tampering must be reported to the department: 

• As soon as possible but no later than 10:00 a.m. the following day. 

• In writing, no later than five calendar days after an event occurs.

• What does not constitute a tampering event?

• Any vandalism on the exterior of facilities that poses no risk to public health.

• Cybersecurity attacks and events:

• There has been a recent increase in assaults launched by cybercriminals using one or more computers against a single or multiple computers or networks.

• A cyberattack can maliciously disable computers, steal data, lockout users, or use a breached computer as a launch point for other attacks. 

Here are the resources that are provided in the toolbox: 

• Malevolent Act Resources : Documents to aid water utility preparation and response to malevolent acts including tampering, vandalism, and terrorism events

• Cybersecurity Resources: Documents to aid water utilities in preparing for and responding to cybersecurity events

• Guidance: Report and Respond to Tampering Events or Security Threats Drinking Water Facilities Response  

• Guidance: Respond and Report Cyberattacks Drinking Water Facilities Response

• Tampering, Threat, and Incident Form: Use this form to report incidents

The water quality control division is dedicated to helping you and your utility protect the health of all Coloradans. A crucial aspect of this protection is to take action to prevent, plan for, and understand the role you play in responding to security threats and actions taken against your critical infrastructure.