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Wednesday, October 27, 2021

Positive impacts of enhancing disinfection requirements - 2000s, 2010s, and today

We have written numerous articles over the years about disinfection and maintaining a proper chlorine residual.  Just search the blog for chlorine or disinfection and you will find excellent information and references from simple fixes to profound policy positions on appropriate disinfection residuals. Did you ever wonder how effective chlorination is in preventing drinking water contamination and what happened to disinfection waivers in Colorado?

In Regulation 11 rulemaking in 2010, the Water Quality Control Commission (commission) decided to remove the authority of the department to grant disinfection waivers. So at that time all waivers were evaluated and held static. The rulemaking also established more rigorous regulatory oversight for waivered systems. The rulemaking also required that all disinfecting groundwater systems had to maintain 0.2 mg/L at their entry points (surface water already had that requirement). Then, in the 2015 rulemaking to update the total coliform rule, the commission chose to establish a storage tank inspection regulation and also require that all systems maintain at least 0.2 mg/L chlorine residual throughout the distribution system. All of these rule changes were meant to recognize best practices performed by most water systems and to compel the few systems that were not up-to-speed to better protect their distribution systems. While the yearly data is noisy, it is important to recognize that the overall number of E.coli positive samples reported to us per year went dramatically down around the mid-2010s. See the graph below and table below.


It is also worthwhile to look back further at the trends over a few decades:


It’s apparent that over time E. coli violations dramatically decreased. Since about 2014, the majority of E. coli violations occurred at public drinking water systems that were out of compliance with the state’s disinfection requirements. 

As the 2010s progressed, we developed rigorous protocols to evaluate systems that maintain disinfection waivers to make sure public health was being protected without disinfection present. Therefore, over time, the department revoked waivers at systems that could not maintain compliance with the rigorous regulatory requirements for waivered systems. Other waivered systems voluntarily began chlorinating their water systems based on concerns over liability and realization of the relatively low level of effort that chlorination requires. 

At present, only two public water systems still maintain disinfection waivers. These two systems are the last disinfection waivers that will be used in Colorado. These communities have shown through regulatory compliance and their track record of water quality that the public in those communities has a measure of protection from waterborne disease even though they do not chlorinate. However, these communities ultimately may choose to chlorinate their water in the long term. The department’s position would be that it is always best to chlorinate when possible. Also, through natural disasters, aging infrastructure, or unforeseen events, the two systems may ultimately end up having their waivers revoked due to failure to maintain compliance.  

As discussed in the previous blog postings about the importance of chlorination, Colorado has a proud tradition of protecting our public drinking water supplies to the greatest degree possible.

Tyson Ingels, P.E Lead Drinking Water Engineer

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

Wednesday, October 20, 2021

Program Manager Message: How does equity, diversity and inclusion (EDI) factor into direct potable reuse (DPR)?


Several years ago the Water Quality Control Division (division) became aware of the possibility that utilities with the appropriate water rights portfolio might move forward to directly recycle treated water into the headworks of a drinking water treatment facility. The drinking water facility would deploy additional advanced treatment processes (beyond conventional filtration and disinfection) to purify the water so that it could be safely distributed and consumed by the public. This practice is commonly referred to as direct potable reuse (DPR). Additionally, the division is committed to incorporating EDI considerations into its rules and work processes. How will that be done for DPR? 

Since then, the division has been working with stakeholders to better understand the logistic, technical and public communication challenges associated with DPR and develop mechanisms to address those challenges. We realized that DPR was not prohibited, but that we did not have specific rules to ensure that DPR would be done safely. As the effort progressed we understood that beyond the technical treatment issues, public communication and acceptance of the process was vital. In March 2021 we launched a stakeholder process to develop a specific rule to address DPR. The rule will include requirements that address both the technical and communication aspects. The rule is being drafted this fall and the concepts in this article are considerations as we move forward.


Regarding communication, the draft rule provides that a communication and public outreach program must be developed and implemented. Disproportionately impacted members of the community must not be left out of the process and deserve to have a say in the safety and quality of their drinking water. Therefore, in support of equity, diversion and inclusion, the communications and public outreach program must be conducted in a manner that allows for meaningful involvement and fair treatment of Disproportionately Impacted (DI) communities, as defined in C.R.S. 24-4-109(2)(b)(II), or as approved by the Department.


Meaningful engagement with DI communities means more than sending a typical public notice type of document in the mail. Meaningful engagement means that information is provided in  plain language and in a language the community understands. Meaningful engagement means that dialogue takes place, questions are answered, and concerns are addressed to the extent feasible. A description of how the supplier conducted outreach in a manner that allowed for meaningful involvement and fair treatment of DI communities, including a summary of engagement and responses from DI communities, if applicable, must be included in the plan. A certification that states that the supplier has fully complied with the communications and public outreach requirements must also be submitted to the department.


It’s important that the entire community including any DI members be given the opportunity to gain an understanding of:

  • What DPR is and why it’s being done?

  • What treatment processes and sampling will be done to ensure that tap water is safe?

  • What wastewater treatment plant is the source for the recycled, purified water?

  • Where in the community will the recycled water be supplied?

    • The entire community or only certain areas?

    • Are there DI communities in those areas and how will they be impacted? 

  • How will the community be notified if the treatment process fails or sampling results show a problem with the water and how long will that take? 

We realize that many people are often unaware of where their water comes from and how safe it is. Therefore, water utilities will need to embark on a general education process about drinking water and the water cycle before getting into DPR issues. This general public education is long overdue and the department advocates that specific utilities as well as the utility community in general embark on public education about how safe our collective drinking water really is. As time goes on we will learn more about implementing DPR and how best to engage with communities about this subject, including DI communities. Both now and in the future incorporating EDI into the process will not only be necessary, it is and will be the right thing to do. 


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


Inspection Year 22 Begins October 1, 2021


It’s that time of the year again to start a new inspection year for sanitary surveys. The Water Quality Control Division (WQCD) has primacy in Colorado to conduct sanitary survey inspections of public water suppliers covering the Eight (8) Elements of a Sanitary Survey. The inspection year runs on a federal fiscal year which starts October 1st and ends on September 30th. Inspection year 2022 (IY22) starts October 1, 2021 and the Field Services Section has 476 sanitary surveys planned for IY22. We continue to conduct sanitary surveys using our
COVID-19 Standard Operating Procedures with the two part remote file review, followed by the in person inspection. 

When is my Sanitary Survey?

Regulation 11.38(2) outlines the Sanitary Survey frequency requirements as once every three (3) years for Community Water Systems and once every five (5) years for Non-Community water systems. Please remember that these are minimum frequencies, and that the division has the authority to conduct sanitary survey inspections at any time.

You may ask, “we are overdue for a sanitary survey, what do we do?” First of all, do not panic, the WQCD has a backlog of suppliers due for sanitary surveys due to historic resource constraints and the COVID-19 pandemic. Please reach out to the Field Services Section email at cdphe_wqcd_fss_questions@state.co.us if you need to talk to someone about your sanitary survey schedule. A member of the Field Services Section will respond to let you know if you are scheduled for a sanitary survey this year or if it is delayed.

I am scheduled to have a Sanitary Survey, how do I get ready?

The WQCD has many documents to help prepare for the sanitary survey on our website. A great resource to take advantage of is the free Sanitary Survey Preparation training from the Local Assistance Unit. It’s a 3.0 hour course, you get 0.3 TUs and can register by selecting your date

Do you need additional help beyond the basic sanitary survey preparatory class? Are there special treatment issues you could use help on? Please reach out for one-on-one customized coaching and assistance. A coach will come to your facility to take a look and discuss your specific needs. Training units are available, depending on time spent with the coach. Please use the Online training request to register. For more information please see the Local Assistance Unit website.

What changes do I need to be aware of?

EPA Region 8 performed a review of the CDPHE WQCD drinking water program to determine if CDPHE is in compliance with the National Primary Drinking Water Regulations (NPDWR). This review included sanitary survey letters and entry of sanitary survey findings into SDWIS. The EPA evaluation found that the historic practice of downgrading Significant Deficiencies to Observations if resolved prior to the letter issuance is not acceptable and must be discontinued. Therefore, in IY22 starting October 1, 2021, if a significant deficiency is identified during the Sanitary Survey Site Visit, CDPHE must cite it as a Significant Deficiency even if it was resolved the day of the sanitary survey. If the supplier is proactive and resolves it during the sanitary survey or before the sanitary survey letter is issued, we still have to cite the significant deficiency but will make sure to memorialize the resolution in the sanitary survey letter. The supplier will also need to include it in their Consumer Confidence Report (CCR). With this in mind, it will be critical that water system operators do a walkthrough of the facilities before the Sanitary Survey site visit date to identify any significant deficiencies and resolve them. A future Aqua Talk article will be coming that identifies the most frequently cited significant deficiencies and violations. We understand that this is a big change, but a necessary change to maintain compliance with our primacy agreement with EPA. If you have any questions or concerns, please reach out to me at heather.young@state.co.us.

Thank you for all your efforts to protect public health and we look forward to seeing you at your next sanitary survey.

Heather Young, PE, CWP, Field Services Section Manager

Wednesday, October 13, 2021

Equipping Operators with Skills to Manage and Overcome Testing Anxiety



We have all experienced it, that feeling of dread and foreboding before taking an exam; a myriad of scenarios running through your head outlining the worst possible outcomes.

These feelings of testing anxiety are very real and can have detrimental effects on an operator’s exam performance. In fact, a recent survey of operators conducted by the Ohio Water Environment Association found that nearly 30 percent of respondents cited testing anxiety as a main cause for not passing the exam.

To examine why testing anxiety is such a prevalent phenomenon, especially in high stakes vocational testing such as an operator certification exam, I spoke with Dr. Ian MacFarlane of Elizabethtown College. Dr. MacFarlane is an Assistant Professor of Psychology, as well as a clinical psychologist. With more than 1,000 hours of therapy work with college students and adults, he has helped countless individuals recognize and overcome testing anxiety.

Why do Operators worry?

Taking a certification exam is different from a high school biology or chemistry final: the stakes are exponentially higher. Psychologically, operators may feel that taking an exam related to their everyday job duties raises a question about their professional competence. This spark of anxiety will be fanned further if a passing score on the exam is mandated for their current job or required for promotion potential.

When asked how test anxiety manifests, Dr. MacFarlane pointed to both cognitive and physical (or somatic) symptoms stating, “The most detrimental effects of anxiety are cognitive. The human brain is limited to a certain amount of processing power at one time. The more your brain is occupied with the anxiety of the exam, the less ability it has to process the exam content. It would be akin to going into a wrestling match with one hand tied behind your back. Anxiety is a ‘mental suck’ or leech draining your brain power and limiting your ability to recall information or facts that might be as familiar to you as the names of your parents.”

One particularly common manifestation of testing anxiety Dr. MacFarlane cited is detachment–an operator is likely to avoid the discomfort of test anxiety by simply not thinking about the exam. Just as your body will pass out instead of coping with a lack of oxygen, you are likely to avoid the discomfort of test anxiety by simply not thinking about the exam.  He noted, “This can be quite detrimental as this avoidance loop can cause you to disengage from exam preparatory practices which can seriously hinder performance on the exam.”

Other effects of anxiety can be seen as physiological symptoms such as nausea, stomach cramps, or lightheadedness. To explain this, Dr. MacFarlane offered, “Our bodies lack the ability to differentiate between real life and mental simulations. So, if we are extremely worried or anxious about something, our minds can create physiological manifestations that are directly associated with the negative mental simulations.”

Why do some operators who excel in their jobs perform poorly on the exam?

Even though the exam is measuring the knowledge and application of tasks that an operator performs daily, while in the testing environment, they lose the contextual cues that would normally assist them in everyday operations.

Without those additional sources of information, operators must work harder to draw parallels between the tasks on the exam and the tasks they perform in their job. In other words, because an operator is not being tested in the environment in which he/she normally performs a task (a water or wastewater system), it can be difficult to recognize and solve the same problem in a test environment.

What can operators do to help with testing anxiety?

Practice, Practice, Practice

There is no better way of reducing test anxiety than to spend an adequate amount of time preparing and practicing. Test-taking is a skill—one that must be practiced and honed. Dr. MacFarlane noted that in many cases, due to inefficient study techniques, people have a tendency to work on areas in which they are already proficient and to avoid areas that could use improvement. Operators should make better use of their study time by taking periodic practice tests to help gauge the areas they need to work on. As an added benefit, the practice tests will train them to work under the pressure of a time constraint. Because the time limit on most certification exams can create a state of panic, it is important that operators learn to perform under these stressors and to control the feelings of unease.

Don’t “cram”

Countless studies have been done over the years on the ineffectiveness of “cramming,” or waiting until the last available opportunity to study for an exam. Say an operator spends the last six hours before the exam reviewing material. It is easy for them to think that they have everything committed to memory; the material is “fresh” in their mind. The reality is that nothing could be further from the truth. Reviewing this way gives an operator a familiarity with the material, meaning he/she will be able to recognize it when they see it on paper. Unfortunately, the ability to recognize concepts is not the same as being able to recall it. The ability to recall or reconstruct information accurately when an operator needs it requires exposure to the information over a long period of time.

The best course of action is to build a study plan that spans the course of several weeks prior to the exam. The more time an operator spends reorganizing the material so it has a structure, the more likely they are to commit the information to long term memory. Operators should aim for 45-60 minutes per day with their study material for at least six weeks prior to the exam.

How can an operator cope with anxiety on test day?

Even the most prepared test-takers can feel anxiety on test day, but there are proven methods to counteract the effects. Operators should start with getting adequate sleep the night before. Studies have shown that people perform better on memory tasks when they are well-rested. Some people will suffer from interrupted sleep when particularly worried about something. To help with this, operators can try exercising for 30 minutes before bed. Doing so will help their bodies release excess cortisol (stress hormone) in their systems caused by anxiety and will allow them to sleep better.

An operator should ensure their body is well nourished the day of the exam. This means do not skip breakfast and eat healthy foods such as grains or fruit and avoid foods with high fat content. The goal here is to eliminate as many distractors as possible so an operator can dedicate all their attention to the exam. If an operator is tired or his/her body does not have enough fuel, it can drastically hinder their performance.

Breathing – The 5-5-7 Method

During the exam, it can be extremely beneficial to stop at regular intervals (perhaps every five questions) and take deep breaths. The 5-5-7 is a breathing exercise performed by inhaling for five seconds, holding your breath for another five seconds, then exhaling for seven seconds. Dr. MacFarlane suggested that completing this exercise at regular intervals during a test session can physiologically stimulate the central nervous system, which can heighten an operator’s awareness and push anxiety from their mind. He also stressed the importance of practicing this technique for several weeks prior to the exam during their preparation, saying “The more practiced you are in this technique, the more effective it will be during exam time. Your body and mind will have a Pavlovian response to the exercise which increases its effectiveness.”

Muscle Relaxation

Another proven technique outlined during our discussion was progressive muscle relaxation, or PMR. This is done by deliberately applying tension (by clenching) to certain muscle groups and then releasing the induced tension. During this process, all of an operator’s attention should be focused on how their muscles feel as the tension is released. As operators learn to distinguish the feelings of a tense muscle as compared to a completely relaxed one, they are able to recognize the physical effects anxiety has on their bodies and can quickly alleviate it with this technique. Operators should be encouraged to practice PMR both when preparing for the exam and on the day of testing. They should spend 15-20 minutes at a time performing this technique on their major muscle groups (feet, legs, hands, arms, neck, and shoulders) and it will help mitigate anxiety.

The Bottom Line

While these methods have been shown to help with anxiety, they may not work for everyone. There are many more techniques that may offer relief, and operators can use these tips as a starting point to find what works best for them. Above all, operators should make sure they spend adequate time studying and reviewing the material. The better command they have of the content, the less anxious they will be about the exam, and the better they will perform.

Tom Healy, Director of Certification Services for The Association of Boards of Certification

Note: This article has been reposted with permission from the author, Tom Healy, Director of Certification Services for The Association of Boards of Certification 

Original article published here: Summer 2021 Arkansas Drinking Water Update.

Wednesday, October 6, 2021

Trying to Find Your Drinking Water Records? We Can Help!

Are you looking for records for your drinking water system? We have an easy online way to help! Using the instructions below, you will be able to access all of your publicly available drinking water system files. 

  1. On the Drinking Water Information page, open the data table by clicking on the "Water System Search" hyperlink.

  2. Enter the name of the Public Water System into the table. 

  3. Clicking on the PWS ID number takes you to all the online records. 

  4. Scroll down, and there's a list of violations (click Records for violation documents). Below violations are a list of inspection deficiencies and sample results.

We also recommend that you always have up-to-date contact information (e.g., owner, operator, and administrative contact) for your system. This ensures that you receive important updates, reminders, and correspondence from the Department. Using the same website above, you can also check that your Owner and Administrative Contact names, phone numbers, and email address are correct. The website also lists your treatment and distribution system operator. 


If you need to make an update, please use our online Monitoring Plan Wizard and select “Contacts” under the Individual Template Section. Please submit any contact updates using our drinking water portal (this is the preferred method as this ensures the document is submitted and received), by fax at (303) 758-1398, or by hardcopy mail. We cannot accept any contact updates, other documents, or data through email. 


If you have any questions, please contact your compliance specialist. Current drinking water compliance assurance contact information can be determined by county and system type on our website or by navigating to page 4 (CAS Contacts) of the Public Water System table.

  Stephanie Hosie and Amy Schultz, Drinking Water Compliance Assurance Section


Simple Fixes - Chlorine Monitoring with Pocket Colorimeters

Whether you're a large system or small, surface water or groundwater, free chlorine or total, monitoring at the entry point or in the distribution system, water quality monitoring of disinfection residual is an important part of the job. Disinfection residuals are vital to protecting public health and must be reported to the state to show compliance with drinking water regulations. If your go-to monitoring equipment is a Pocket Colorimeter, here are some important things to keep in mind when monitoring chlorine residual.

  1. My pocket colorimeter is flashing “2.2”; what does that mean? Some pocket colorimeters have the option of low range and high range. For chlorine values less than 2.0 mg/L, it’s best to use low range for the greatest accuracy as high range is subject to variable levels of interference. But

    if the instrument consistently reads 2.2 or flashes 2.2, the high range procedure needs to be followed. Using the special high range sample cell, follow the normal steps of zeroing the sample prior to adding the reagent. For Pocket Colorimeters, you’ll add two 10-mL doses of reagent to a 5-mL sample and read. It’s always good practice to review (or re-review) the procedure as a reminder of the proper sequence for analyzing samples.


  2. Have you checked your glassware lately? Dirty glassware can lead to erroneous readings. Hold the glassware up to a white sheet of paper.  Does the glassware look clear or can you see a black film build up? If so, it might be time to purchase some new glassware. You can also try an at home remedy with a 50/50 mix of white vinegar and water. Leave the glassware to soak overnight and rinse out in the morning. Do not use a scrub brush or abrasive cleaning utensil of any kind as that may scratch the glassware.
  3. Free? Total? There’s a difference? There is a difference and you want to make sure you are analyzing for the correct chlorine based on your monitoring schedule.  Free chlorine reagent reacts with free chlorine in the sample, and should be read immediately. Total chlorine reagent reacts with ALL the chlorine present in the sample and requires a 3 minute hold time before reading. If your system uses chloramines or receives water from a chloraminated system, then you need to monitor for TOTAL chlorine. Performing a free chlorine residual reading for a chloramine system, will result in a reading of little to no chlorine. This is because
    most of the free chlorine has bonded with ammonia to produce chloramine. If you operate a free chlorine system and use total chlorine reagent, you won’t see a significant difference, but generally the total will be higher as it has reacted to ALL the chlorine in the sample, and not just the free chlorine. The important thing is to make sure you are using the correct reagent that corresponds to your monitoring schedule.
  4. Is your reagent current? Check expiration dates. Make sure your reagents used for analyzing and reporting residuals to the state are current. A lot of systems out

    there like to use the Swiftest Dispensers. Make sure you know what the expiration date is on the DPD, especially if you’ve acquired the product from a secondary market. 

Aspen Coombs, PE, Senior Field Engineer