The Field Services wrapped up the 2022 inspection year (IY 22) in September and the new IY 23 inspection year started on October 1, 2022. We appreciated all the assistance from public water systems in completing 469 sanitary surveys in 2022! We anticipate completing over 550 sanitary surveys in 2023. In this article we will share the top 10 most frequently cited significant deficiencies and violations to raise awareness and help operators identify and correct issues before they become a potential health threat or citations in a sanitary survey.
According to Regulation 11, Section 11.3(72), a significant deficiency means: any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public served by the water system. Field-based Violations of Regulation 11 have either Tier 2 or Tier 3 public notice requirements that are dependent upon the severity of the violation and any potential public health effects, pursuant to Regulation 11, Sections 11.33(1)(a,b), 11.33(2)(a), 11.33(3)(a) and 11.33(4)(a). All issued notifications must comply with the general content and distribution requirements and notice reporting requirements that are included in Regulation 11.33(5),(6) and (7).
During the 2022 inspection year, 1,155 significant deficiencies and violations were cited in 469 sanitary surveys. The Top 10 most frequent inspection citations were:
Storage tank deficiencies (F310 and T310), in the distribution system and before the entry point (CT tanks) lead the pack with 17% of all citations in 2022. Storage tank deficiencies can include improperly protected screens, hatches and overflows. This underscores the importance of robust routine tank inspections under the Storage Tank Rule and also for tanks that are used for contact time.
The next most frequently cited significant deficiency, with 9% of the total 2022 citations is for wellhead pathways of contamination (S030). This can include loose wellhead seals, missing or damaged vent screens, missing gaskets, broken/open electrical boxes/conduit, cracked sanitary seal plates and wellheads.
Backflow prevention and cross connection control (BPCCC) has several violations and two significant deficiencies that make the Top 10 list, including failure to develop BPCCC annual reports, failure to implement the BPCCC program and failure to meet the assembly testing ratio which is a Tier 2 public notice violation.
Groundwater entry point chlorine monitoring (R212) accounted for 40 significant deficiencies, including monitoring weekly entry point chlorine residual in the wrong location. Chlorine residual monitoring equipment practices (R531) which can apply to both groundwater and surface water systems rounded out the Top 10. Frequently encountered chlorine residual monitoring equipment violations include using expired DPD reagent, caked glassware (grayish tinged), not switching a colorimeter to High Range and using the appropriate vials when needed, and not performing weekly checks of online chlorine analyzers. In accordance with Regulation 11, Section 11.46, 40 CFR 141.74(a), and Policy 4 Guidance, suppliers must field verify online chlorine analyzers once each week by taking a grab sample and analyzing it for chlorine residual.
Please check your water systems for these issues to protect public health and avoid significant deficiencies and violations during your next sanitary survey. If you would like additional assistance on technical issues or sanitary survey preparation, please sign up for individualized coaching here. For any questions or concerns about sanitary surveys please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. Thank you for all your efforts to protect public health!
