The Increasing Threat of Toxic Algae

Scientists predict that climate change will have various effects on freshwater environments. This includes catalyzing harmful algal blooms to occur more often in more water bodies, and to be more intense when combined with nutrient loading. This summer, due to increasing temperatures and drought conditions, we saw harmful algae blooms impact many of our water bodies in Colorado. Harmful algae blooms or toxic algae are made up of cyanobacteria, commonly known as blue-green algae. These types of algae in drinking water sources can cause the water to taste or smell bad. Taste and odor are not regulated under the primary drinking water regulations but certainly can create customer concerns about water quality and safety. In addition to taste and odor problems, toxic algae can create a public health risk when they produce toxins.

This summer, between June and August, the Water Quality Control Division coordinated with local water body managers to test lakes and reservoirs suspected of experiencing toxic algae. The following water bodies had detectable levels of toxins: DeWeese Reservoir, Barr Lake, Sloan's Lake, Pikeview Reservoir, Jumbo Reservoir, Prewitt Reservoir, Jackson Reservoir, Joe Moore Reservoir, Summit Reservoir, Windsor Lake, Milavec Reservoir, Pelican Pond (St Vrain State Park), Smith Reservoir, Willow Creek Reservoir, North Sterling Reservoir. The division is not aware of any treated drinking water having detected toxins. 

The only way to be certain if an algae bloom is toxic is to run specific water tests. The Colorado Laboratory Services Division is one lab that can complete these tests. Removing toxins in a safe and cost-effective way can be a challenge for treatment facilities and not all of them are equipped to do so. Drinking water providers can contact the Water Quality Control Division at 303-692-3500 with questions about toxic algae. We can assist water providers that experience taste and odor problems and toxins. This includes ideas about customer communication and the appropriate steps utilities can take to monitor and manage toxic algae and effectively treat their drinking water. Our toxic algae webpage has resources to help drinking water providers and

recreational water managers with toxic algae monitoring and response.

➽ David Dani, Emerging Contaminants Coordinator

Federal Update: Key Issues with the Lead and Copper Rule Revisions

As most of you know, on January 15, 2021, the EPA promulgated its final Lead and Copper Rule Revisions (LCRR) with an effective date of March 16, 2021. Then, on June 10, 2021, the EPA signed a final rule extending the effective date of the LCRR to December 16, 2021 to allow for additional engagement and public comment regarding the final rule. Colorado participated in this process via co-regulator meetings with other states and the Association of State Drinking Water Administrators. EPA completed the process of obtaining additional public input and must make a decision by December 16, 2021 as to whether to maintain its final rule as published in January 2021, revise it, repeal the rule and restart from scratch, or move forward with a hybrid of these approaches. If EPA finalizes this rule in December 2021, Colorado will have two years to adopt a rule no less stringent, with a compliance date of October 16, 2024. 

During the course of 2021 EPA has already been sued twice regarding the LCRR. EPA was sued in March by parties that believed the final LCRR published in January was not sufficiently protective. This lawsuit was stayed pending the outcome of the review process that will end in December 2021. EPA was also sued in August by parties that believe the extension process was not legal, and that the final rule must stand as published in 2021. It is uncertain as to how these lawsuits will ultimately play out and whether they will impact the substance or timing of EPA’s finalization of the rule or state’s ability to adopt the LCRR. If there are no legal impacts to the timing, if EPA finalizes this rule in December 2021, Colorado will have two years to adopt a rule no less stringent. 

In general, Colorado is pleased with the efforts that EPA undertook after the draft LCRR was issued as several of our comments, including adding more flexibility regarding how Optimum Corrosion Control Treatment (OCCT) studies can be conducted. There is no way to be sure what items within the final LCRR EPA may consider adjusting, but we believe some of those items likely involve the following:

• Increasing the proposed 3% Lead Service Line Removal (LSLR) rate after an action level exceedance.
• Not allowing LSLR to stop, once it begins even if lead levels decrease below the action level. 
• How components like pigtails, galvanized pipes, etc. fit into the definition of lead service lines for inventory and removal purposes.
• Sampling procedures including utilizing an approach that would involve evaluating both first draw and 5th-liter samples.
• Simplifying the “find-and-fix” process, especially for non-LSL sample sites.
• Altering the small system flexibility and not allowing avoidance of OCCT for 15 years while an LSLR program is implemented. Providing filters is one option that may be added to the rule.  

Colorado has continued to urge EPA to allow for alternative OCCT options considering our experience with the Denver Water variance. Colorado believes water systems should be allowed an alternative if corrosion control treatment is applied, LSL replacement is expedited above required LSL replacement rates, pitcher filters are provided to all customers with LSLs, and the system implements an extensive public outreach and education campaign.

Of course Colorado supports being able to implement a rule that can help improve health protection and reduce lead exposure, especially for children. Beyond the specific content of the rule, we remain concerned about the technical and financial resources needed for water utilities and states to comply with the LCRR. Due to the complexities of multiple handoffs, reviews, sample site changes, and new tracking and reporting requirements, we will all need to work hard to develop needed guidance, tools, and clarifications to implement the LCRR. Once we have a final LCRR, we will begin to plan our stakeholder process to adopt the rule plus develop supporting policies and guidance. 

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

CDPHE Pueblo Office Move

CDPHE’s Pueblo team is moving at the end of September 2021.The CDPHE Pueblo office includes three field inspectors from the Water Quality Control Division Field Service Section, as well as, Health Facilities inspectors and a HIV/STI field representative. Since 2014, CDPHE has leased space on the riverwalk in the historic police station building. The WQCD Pueblo field inspectors have been conducting in-person field based sanitary surveys and cleanwater Compliance Evaluation Inspections (CEIs) since May 2020 using a COVID-19 Standard Operating Procedure to protect operators and staff. 

At the end of September 2021, CDPHE will begin sharing office space with the Division of Water Resources Division 2 office in Pueblo. This move allows for increased coordination between the Water Quality Control Division and the Division of Water Resources Division 2 team while optimizing state funding resources. 

The new address for the CDPHE Pueblo Office is:

310 East Abriendo Ave. Suite B Pueblo, CO 81004

CDPHE WQCD is proud to provide technical services to the southern region. Please continue to reach out to the Pueblo field inspectors for assistance with sanitary surveys, CEIs and technical assistance. The Pueblo field inspectors and manager are:

Paul Hanson, PE

paul.hanson@state.co.us

Monique Morey, PE

monique.morey@state.co.us

Tammy Bruning, CWP

tammy.bruning@state.co.us

Cameron Wilkins, PE

Field Unit II manager - Salida Office

cameron.wilkins@state.co.us

➽ Heather Young, WQCD Field Services Section Manager & Cameron Wilkins, WQCD Field Unit II Manager

Design Criteria Update Project: 2021 - 2022

Design criteria update project starting this fall!

The Design Criteria for Potable Water Systems (Safe Drinking Water Program Policy 5) serves as a key policy document for the department to make decisions on approval of new designs for water sources, treatment, and storage facilities. The document also serves as a guideline for repairing or upgrading waterworks that are cited as significant deficiencies during the department’s sanitary surveys. While systems are not required to modify their waterworks to meet the design criteria unless their current water works are deficient, they are required to consider the criteria as acceptable fixes whenever their current waterworks are found to be deficient. 

The department intends to update the document regularly, approximately every 4 years with input from stakeholders. To assist with updates, we keep a running list of errors and enhancements. The last update was in 2017. The department is initiating a criteria update project in the fall of 2021 to be completed in 2022. The Department has identified the following three key areas of focus for this project but is open to other stakeholder recommendations:

1. Updates of known errors and enhancements since 2017 - including such items as wetwells at pump stations being considered finished water storage, typos, etc.
2. Updates to sections that pertain to corrosion control and the lead and copper rule.
3. Addition of sections pertaining to direct potable reuse and criteria for pertinent treatment processes (e.g. advanced oxidation, ozone/biological filtration, adsorption, etc)

The department will collect initial stakeholder feedback on potential design criteria modifications in September and early October 2021. After collecting initial stakeholder input, the department will host a stakeholder meeting to discuss the identified items and the form of workgroups as needed. The workgroups will meet during Fall 2021 and Winter 2022. In Winter 2022, the division intends to host a second stakeholder meeting to discuss the workgroup outcomes and present the draft design criteria. 

The department encourages stakeholders to participate as they are able to ensure we have the best design criteria policy we can. To participate in the stakeholder process, please sign up to receive notices. To provide ideas or feedback on how the design criteria could be updated, please use this google form no later than Thursday, September 30, 2021.

For more information, please contact Melanie Criswell at 720-383-7138 or melanie.criswell@state.co.us. 

➽Melanie Criswell, Corrosion Control Engineer

Coaches Classroom: Preparing for Your Next Sanitary Survey

A sanitary survey is an inspection of a public water system (PWS) to assess their capability to supply safe drinking water. As the state primacy agency implementing the federal Safe Drinking Water Act, the Colorado Department of Public Health and Environment is required to have a program to conduct sanitary surveys of the PWSs in the state. The safe drinking water program’s field services section conducts these inspections. This article will explore the basics of a sanitary survey, some of the most common issues identified, and give you resources to help prepare your PWS for your next sanitary survey. 

Goals of the inspection 

The primary goal of the sanitary survey is to protect public health. This is accomplished by identifying what is functioning well and what needs work in your facility to provide and distribute safe drinking water to the public. Another goal of the division is to use the survey as a way to build trust and establish good relationships with systems. The field services section aims to build those relationships by providing assistance and resources to help systems comply with regulations and protect public health.  

The criteria that the survey is based on are:

• Regulation 11

• Regulation 100

• Colorado design criteria for potable water systems

Who, what, when and where?

All public water systems are required to have a sanitary survey. At a minimum, the surveys take place once every 3 years for community systems and once every 5 years for non-community systems. Field services can conduct surveys more frequently based on water quality concerns or to follow up on previous sanitary surveys. While typically the field services section schedules sanitary surveys in advance, in rare cases  sanitary surveys are performed without advance notice. Not sure of your system type? Visit the division’s monitoring schedule website and search for your system name or PWSID. 

Generally, your inspector will get in touch with you a few weeks before the survey to schedule your survey via email or phone (usually the ORC or AC is contacted). And the survey can take anywhere from several hours to multiple days depending on the size of your system and any issues that may arise during the survey. Your system’s Operator in Responsible Charge (ORC), Owner,  Administrative Contact, and any key management and operators should attend. Basically you want to have all personnel in place to answer questions about general operations, management, security, and technical questions about your system.

The sanitary survey will be a three part process. The first step is to ensure that your system has accurate and up-to-date records, developed written plans for regulatory compliance, and maintains adequate operator certification. The second step is to do a field review in which the inspector will be looking at the entire water supply system. They will evaluate the entirety of the system including the water source, treatment facilities, storage tanks, and distribution system. Also, the on-site review covers monitoring, reporting, and data verification (i.e. are you sampling at the correct locations). The last step of the process is the post-survey follow up. Your inspector will send you a letter and you then need to follow up with a response form and address any issues that come up. 

Common issues identified

Any issues identified in the survey will be documented in your post survey letter as the following:

1. Significant Deficiencies and Violations: The inspector who performed the sanitary survey will follow up on these items. The sanitary survey letter will specify when a written response is due from your water system and what needs to be addressed. 

2. Observations/Recommendations: We won\'t directly follow up on these items, but we strongly recommend the water system address them.

The field services section has identified the most common violations and significant deficiencies at systems in recent years as: 

• Backflow & Cross Connection Control Incorrectly implemented 

• Lack of written program 

• Lack of annual reports 

• Inadequate tracking mechanism

• Chlorine sampling 

• Inadequate records 

• Expired reagents

• Failing to calibrate monitoring equipment per manufacturer requirements

• Storage Tanks: Unprotected vents and overflows

• Vents do not terminate in a downward direction

• Improper hatches

• Lack of normal maintenance and inspection schedule

• Tank Rule and Tank Deficiencies

• Design Review 

• Construction of new waterworks

• Change in treatment process without approval

• TC sampling not representative of distribution 

• Lack of up-to-date monitoring plan

How to prepare for your next survey

The division has prepared several resources to help you prepare for your next sanitary survey: 

• Monthly sanitary survey preparation training. Click here to see a schedule of upcoming training and to register.

• If you still have questions after attending one of the monthly sanitary survey preparation trainings, consider one-on-one assistance provided by the Local Assistance Unit, a team of coaches specializing in drinking water regulatory compliance. Click here to request a coaching visit (virtual or in-person options available).

• We also have these helpful documents on our website to help  you:  

• Sanitary survey prep checklist 

• Sanitary survey brochure

➽  Kyra Gregory Drinking Water Training Specialist