Coaches Classroom: How to use your monitoring schedule and COC to avoid compliance issues

When we discuss creating a culture of public health among drinking water professionals, a key aspect of this culture is clear communication. This article discusses two tools used to communicate: 

1. Monitoring Schedule. The Drinking Water Compliance Assurance section uses this document to communicate your systems specific monitoring requirements based on Regulation 11. 
2. Chain of Custody. Drinking water systems use this to communicate which chemical or bacteriological analysis they would like performed on their samples, the turnaround time for the results, the location at which the samples were taken, and the order and manner in which the samples have been handled.

These two tools are crucial to ensuring that you are sampling at the correct time, for the correct analyte, and at the correct location, while correctly reporting the information to the division. 

Why is it important to sample? 

As drinking water professionals our main goal is to protect human health by providing safe drinking water to the public. We do this through establishing, maintaining, and monitoring the barriers to waterborne disease outbreaks, lowering levels of lead exposure and mitigating chronic health impacts from chemical and radionuclide contaminants:

• Source water protection
• Treatment
• Monitoring potential contaminants
• Storage
• Distribution
• Public Notification

Compliance sampling generates the data that confirms that the hard work to maintain the multi-barrier approach is working. We all use compliance data to drive our actions.

Monitoring Schedules 

Last year our coaches described the monitoring schedule in detail. To summarize, your monitoring schedule can be used to: 

• Identify where to sample, when to sample, and for what analyte,
• Plan your system’s sampling schedule for the calendar year,
• Verify that your sample results are being received by the division,
• Identify which analytes are required sampling for your system, and
• Help you fill out your chain of custody (COC) for your lab.

The monitoring schedule can also be used to help you budget for your system’s annual monitoring cost. The most up-to-date monitoring schedules can be found by visiting the division’s monitoring schedule website and searching for your system’s PWSID (COXXXXXXX) or name. If you cannot access the internet to find your monitoring schedule please contact the Compliance Assurance Unit’s public assistance line at 303-692-3556. 

Your monitoring schedule will be updated on the division’s website every Thursday to reflect up-to-date schedule and sample results received information. It may take a few weeks for submitted samples to be reflected in the schedule due to lab turnaround and reporting time. 

If you notice something in your schedule that is incorrect such as outdated contact information, incorrect facilities, and sample sites, please submit sections of your monitoring plan that need to be updated. 

Resources: 

• Division’s monitoring schedule website 
• Example monitoring schedule
• Further sampling specifics information

Chain of Custody

The above snap shot is from the most up-to-date CDPHE drinking water COC. 

The best way to ensure that your samples are processed appropriately is to follow these rules: 

1. Contact your lab prior to sampling. We suggest you send them a copy of your monitoring schedule so they can help you fill out your chain of custody accordingly. 
2. Follow hold times and temperature: every analyte has its own specific hold time and temperature. If the samples deviate from the appropriate ranges the lab can no longer use them for compliance analysis as they are no longer valid. Discussing these hold temperatures and times prior to sampling will help you set up your process to return the samples to the lab. 
3. Sample early in the monitoring period. Remember it can take days to weeks for the lab to analyze the samples. Sampling early will ensure you do not miss your compliance sampling and reporting deadlines. 
4. Order extra sampling kits/bottles. This way if you have any issues during the sampling event, you don’t have to wait for new bottles to sample. 
5. Label your sample bottles and fill out your COC prior to sampling.
6. Ensure sample results are submitted in a timely manner – even if they are not due yet!

In some cases, reporting sample results long after they’ve been analyzed can result in violations. For example, if a sample result is high enough to trigger increased monitoring, the supplier will be accountable for all monitoring periods in which they should have been on increased monitoring. Monitoring violations would be issued for all missed monitoring periods and compliance with the maximum contaminant level would be evaluated with the data received over the applicable monitoring periods – even if those quarters did not have data! 

Routinely check your monitoring schedule. You will know that the division has received the sample results because they will be crossed out on your schedule. 

Most labs report data directly to the division through the drinking water portal. Please check with your lab to make sure they will do this for you. This will help ensure that your data is processed in a timely manner and avoid duplication in the data processing.  You must provide the following required information to the lab on the chain of custody if they are reporting the data on your behalf:

• PWS ID - if you do not know you PWSID it is listed on your monitoring schedule
• Facility ID - exactly as listed on your monitoring schedule
• Sample Point ID - exactly as listed on your monitoring schedule
• Collection Date.
• For total coliform bacteria samples:
• Free Chlorine in mg/L.
• Total Chlorine in mg/L (only needed for systems with chloramines).

How to correct errors made in data submission?

Sample reporting errors with facility ID, sample point ID, chlorine residual type, or incorrect measurements can be corrected by resubmitting a revised CSV, creating and submitting a Sample Correction Form, or submitting a copy of sample results with corrected information clearly indicated, via the Drinking Water Portal, fax, or mail or by having your lab resubmit corrected results. Any corrections must be received by the applicable reporting deadline. The collection date, lab name or ID, lab sample ID, analyte, facility ID, sample point ID, and residual must be submitted correctly or the requested correction will not be processed, resulting in a monitoring and reporting violation. Updated CSVs with the same Lab ID, Lab Sample ID, and Analyte are considered revisions, and the most recent submission is used.

If a deletion is needed, please send a PDF through the drinking water portal, using the “Requests and Other Certifications” category or a fax, or mail. The request must include the unique lab sample ID, collection date, analyzing lab, analyte, and the reason for the requested sample to be deleted.

➽ Kyra Gregory Drinking Water Training Specialist

Lead and Copper Rule Revisions: Start Preparing for Upcoming Requirements

Lead has long been recognized as a toxic metal that can be harmful to multiple body systems, even at low exposure levels. Lead is particularly harmful to the developing brain of small children and can result in functional impairment. Lead can enter drinking water through the corrosion of lead-containing plumbing materials such as pipes, faucets, and fixtures. 

On December 16, 2021, EPA finalized the Lead and Copper Rule Revisions (LCRR), which further strengthen the protections against lead in drinking water. The LCRR requires water systems to meet a number of new requirements, including:

• Water systems must develop a system-wide lead service line inventory and lead service line replacement plan by October 16, 2024.
• Compliance with a lead “trigger level” of 10 ppb that triggers additional planning, monitoring, and treatment requirements.
• Lead testing in schools and childcare facilities.
• “Find and Fix” at any individual tap above the 15 ppb lead action level to quickly investigate and potentially remediate the source of the lead.
• Strengthened corrosion control treatment, lead service line replacement, lead sampling, and public education measures. 

The lead service line inventory (LSLI) and lead service line replacement (LSLR) plan are key elements that support the LCRR’s overarching goal of proactive lead service line removal and more equitable public health protection.

What is a Lead Service Line Inventory (LSLI)?

The LCRR requires all water systems to submit a lead service line inventory by October 16, 2024 of every service connection in the distribution system to classify the material, of both customer-owned and utility-owned portions of the service line, as one of the following:

• Lead: All or a portion of the service line is lead.
• Galvanized requiring replacement: Galvanized iron or steel service line that is or was at any time downstream from a lead service line or is unknown to have ever been downstream from a lead service line.
• Non-lead: No portion of the service line consists of lead or galvanized requiring replacement.
• Lead status unknown: Service line is not known to be lead, galvanized requiring replacement, or non-lead.

Water systems must take steps to verify service line materials to ensure a complete and accurate inventory. Systems should verify as many “lead status unknown” service lines as possible since unknown service lines are treated as lead service lines unless proven otherwise. Most suppliers should be able to use a combination of knowledge of prohibitions, such as the federal lead ban in 1986, and local ordinances, records review, physical verification, and/or statistical modeling to determine service line materials without physically verifying each line. Only when there is a lack of records and great inconsistency in identified materials during physical verification would a system need to physically verify a large number of their service lines.

The LCRR aims to expand customer awareness, and as such, water systems must make their lead service line inventory available to the public, and systems serving greater than 50,000 people must also make their inventory available online.

Who needs to complete the LSLI?

All community and non-transient, non-community water systems must complete and submit a LSLI to the department. The department is requiring that water systems submit an inventory summary with the total number of service lines in each material category (e.g. lead, non-lead, lead status unknown). Systems with lead or galvanized requiring replacement service lines must also submit a detailed inventory of each lead or galvanized requiring replacement service line with a location identifier (i.e., address or block) and the material classification.

Resource: Lead service line inventory forms and a requirements/FAQ document are available on our website.

What is a Lead Service Line Replacement (LSLR) plan? Do all systems need to complete a LSLR plan?

Water systems with lead, galvanized requiring replacement, or lead status unknown service lines must submit a lead service line replacement (LSLR) plan to the department by October 16, 2024. Completing the LSLR plan will help systems prepare to remove sources of drinking water lead exposure and for identifying the material of unknown service lines. The LSLR plan must be sufficiently detailed to ensure the system is able to comply with the lead service line replacement requirements in the LCRR.

Water systems that have verified that their distribution system contains only non-lead service lines are not required to complete a LSLR plan.

Resources: A lead service line replacement plan template and requirements/FAQ document are available on our website .

The department encourages water systems to begin working on the LSLI and LSLR plan as soon as possible as these will require substantial resources to complete. Stay tuned for additional information on forms and guidance as well as upcoming public meeting opportunities.

➽ Haley Orahood, Regulatory Development and Implementation Specialist

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

Lessons learned from boil advisories: What language do your customers communicate in?

Accomplishing robust public notification: considering your community

In the Aqua Talk post on April 6 about the total coliform rule and potential for boil advisories, we discussed that we will publish additional articles about these large-scale boil advisories and the specific challenges and lessons learned. As a reminder, the four-part series is covering the following topics:

1. Total coliform perfect storm - incidents that could lead to a boil advisory - April 6, 2022
2. Public notice to thousands - Special steps for large scale advisories - April 20, 2022 
3. What language do your customers communicate in? - Accomplishing public notification considering your community (today)
4. Do you really want to sample a home for compliance?  - Total coliform special sample stations (coming soon)

Both the Englewood boil advisory event in August, 2021 and the Marshall Fire that started on December 30, 2021 led to boil advisories affecting more than 25,000 people each. To read more about the Marshall Fire boil advisories, see our April 13, 2022 article.  

In our April 20 article, we reviewed the reasons why the public may need to be warned not to drink the water and why that notice needs to go out quickly to thousands of people.  The question we are exploring today further builds on that concept: “Do you know what language your customers communicate in?” If the water is potentially unsafe to drink, it is important to warn the public in a way that the people will understand. A key aspect in understanding is meeting the public on their terms, which also means in a language that can be easily and readily understood. 

In the interest of public health and to achieve environmental justice, health equity, and climate justice for all communities, CDPHE recommends as a best practice that notifications to consumers are translated into the top two languages spoken in the community. There are multiple potential data sources for making this determination and more information can be found in this previous Aqua Talk Article.

The department will assist any water system with brainstorming ideas to better reach their respective communities. It is critical that public outreach occurs regularly before the emergency happens. Understanding your community and how to reach them begins with all outreach you do – from your consumer confidence reporting to your public outreach and public relations events. Even your water billing is a form of outreach.

In any community outreach efforts, following communication best practices is key. To make sure important information reaches your community, consider the following:

• Know your audience/community: what languages does your community speak? Can you get information translated into those languages? There are online resources (ArcGIS has a Living Atlas of the World, for example) that can help identify which languages are spoken in your community, but it is important to keep in mind that anecdotal and qualitative information is also valuable. Coordinating with local community groups (churches, schools, nonprofits) can be a great way to learn more about the languages and dialects spoken in your community. 
• Have a communications plan: It can be stressful to complete public notification within the allotted time during an event – having a plan in place will help. 
• Think about different communications channels. Consider using a variety of communication channels to reach the entire community. Social media platforms, text messaging, WhatsApp messaging, emails, billboards, and road signs are a few options to consider. Further, consider tracking where the outreach is taking place and sending staff to do door-to-door outreach in areas that may otherwise not receive the information. 
• Consider hosting a mock emergency scenario: the department is available to participate in a mock emergency scenario to better understand how to best accomplish all of the above activities

Communicating with your community in the language they understand can be a powerful way to build trust and strengthen relationships. This can also help ensure that traditionally underserved communities receive important information that relates to their health. 

➽ Tyson Ingels Lead Drinking Water Engineer 

➽ Kaitlyn Beekman Communications and Special Projects Unit Manager

Upcoming EPA Webinar: Tips for Supply Chain Challenges

Tips to Prepare for and Respond to Supply Chain Challenges

May 26, 2022

12:00-1:00 PM MDT

Click here to register for the free webinar

Recent disruptions caused by the pandemic, various climate events, and unexpected equipment failures have had downstream consequences for water and wastewater utilities trying to procure treatment chemicals and other critical supplies.

Join the U.S. Environmental Protection Agency for a webinar on new resources to prepare for and respond to chemical and equipment supply chain disruptions. Through a real-world scenario, speakers will demonstrate the following:

• How utilities can understand their supply chain better using the new Water Treatment Chemical Suppliers and Manufacturers Locator Tool (above)
• Key best practices for future supply chain challenges
• How to access updates on potential and ongoing supply chain disruptions through EPA's website
• Ways to tap into EPA’s technical assistance to resolve supply chain challenges

This webinar is offering CEU’s for pre-approved states.

Dear Aqua Answers - Reporting data help!

Dear Aqua Answers,

Please help! I have multiple compliance and reporting questions. 

Thanks,

Cam Pliance

Dear Cam,

I have listed your questions and the answers below:

Question 1:

I sampled for my radionuclides early but the lab didn't submit the results in time. Will I still get a violation? 

Any sample results submitted after the reporting deadline is a candidate violation. Radionuclides samples have long holds times and laboratories may not prioritize analysis. Suppliers need to coordinate with their laboratories to ensure that samples are analyzed and that results are reported to the department within the specified regulatory time frame. 

 Question 2:

I sampled early but the lab didn't submit the results in time because I did not fill out the chain of custody form correctly. Will I still get a violation? 

Any sample results submitted after the reporting deadline is a candidate violation. Please note that many of these issues can be avoided if the supplier provides the correct PWSID, Facility ID, and Sample Point ID information on the chain of custody to the certified laboratory. Separate chain of custody forms should be provided for samples collected from different facility locations or sample points, (i.e entry point vs distribution system). Suppliers will need to coordinate with their laboratories if the chain of custody form does not clearly provide a location for the PWSID, Facility ID, and Sample Point ID. The department expects the supplier to identify the Facility ID and Sample Point ID (listed on the online monitoring schedule) when submitting sample results. Facility and Sample Point IDs are needed to identify the exact sample site locations and demonstrate compliance.

Question 3:

When am I supposed to report compliance samples and compliance actions to the department?

Section 11.35(2)(a)(ii) of Regulation 11 requires the submission of sample results no later than the first 10 calendar days following the end of the monitoring period specified by the Department which is generally no later than the 10th of the month following the end of the monitoring period. (Example: Monitoring period ending June 30 - results required to be received by July 10). Similarly, Regulation 11 also has submission deadlines for lead consumer notice, CCRs, public notices, seasonal start-ups documentation, and others. Please sample early. This will give you time to correct issues and will afford your laboratory enough time to analyze and report your results. We recommend that you discuss the reporting deadlines with your laboratory to ensure they understand your reporting requirements and expectations.

Question 4:

How do I correct a misreported sample result?

Sample reporting errors with facility ID, sample point ID, chlorine residual type, or incorrect measurements can be corrected by resubmitting a revised CSV, creating and submitting a Sample Correction Form, or submitting a copy of sample results with corrected information clearly indicated, via the Drinking Water Portal, fax, or mail or by having your lab resubmit corrected results. Any corrections must be received by the applicable reporting deadline. The collection date, lab name or ID, lab sample ID, analyte, facility ID, sample point ID, and residual must be submitted correctly or the requested correction will not be processed, resulting in a monitoring and reporting violation. Updated CSVs with the same Lab ID, Lab Sample ID, and Analyte are considered revisions, and the most recent submission is used.

Sincerely,

Aqua Answers