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Wednesday, December 27, 2023

Risk and Resilience Assessments and Emergency Response Plans

While attending the annual conference of the Association of State Drinking Water Administrators (ASDWA), an organization consisting of my counterparts across the U.S. and including territories, presentations were given about drinking water emergencies that generated national attention. These included the train derailment in East Palestine, Ohio and boil water orders in Jackson, Mississippi. At a previous conference I gave a talk about the Marshall Wildfires. I am sure most of us are aware of the tragic Lahaina, Hawaii wildfire that struck Maui earlier this year.

Extreme events like these are exceedingly difficult to consider and plan/prepare for. But there are requirements in the Safe Drinking Water Act (SDWA) for utilities to assess their vulnerability and risks, and to develop emergency response plans. These requirements came in with America’s Water Infrastructure Act (AWIA) that was signed into law in October 2018. AWIA Section 2013 specifies that all Community Water Systems with populations greater than 3,300 must conduct Risk and Resilience Assessment (RRAs) and Emergency Response Plans (ERPs). These documents need to be reviewed and updated at least every five years. Since this provision of SDWA is directly implemented by EPA, water systems must certify directly to EPA every five years that they have completed these required activities. The initial RRA certifications were due to EPA from March 2020 to June 2021 depending on systems size, so the first five-year updates are due from March 2025 to June 2026. For more information about upcoming review deadlines and requirements please visit the EPA’s RRA/ERP website. The ERP is intended to be developed in a way that addresses system-specific elements based on its RRA, so these certifications are due six months after the RRA certifications.

The RRA needs to address the following components:

  • Risks from malevolent acts and natural hazards
  • Traditional water system infrastructure resilience including electronic, computer, or other automated systems (including the security of such systems) utilized by the system
  • Financial infrastructure
  • System monitoring, operations and maintenance
  • Chemical use, storage and handling

Note that item two above essentially includes cybersecurity. EPA has a Vulnerability Self-Assessment Tool (VSAT) to help water systems complete their RRA. The Cybersecurity and Infrastructure Security Agency (CISA) and the Colorado Information Analysis Center (CIAC)also provide numerous tools to help systems address the cyber components of the RRA.

After completing the RRA, the ERP needs to be developed and describe strategies, resources, plans and procedures utilities will use to prepare for and respond to emergency incidents. The incidents can be natural or human-caused and range from line breaks to major disasters like floods or wildfires. The ERP needs to specifically address:

  • Strategies and resources to improve resilience including physical security and cybersecurity.
  • Emergency response strategies and resources
  • Proactive approaches to lessen the impact of emergency incidents
  • Strategies to help detect malevolent acts or natural hazards that could harm the system

Water systems should coordinate with local emergency planning agencies and must retain copies of their RRA and ERP.

This SDWA provision is not part of state primacy, but is overseen by EPA. To date, EPA has primarily overseen compliance with these requirements via ensuring that systems have submitted their certification. However, going forward EPA is conducting inspections at water systems across the U.S. and soon in Colorado to evaluate compliance with these requirements and help systems become better prepared to prevent emergencies, lessen their severity and respond.

We all know that emergency preparedness is the right thing to do, but it can be hard to prioritize in the face of day-to-day tasks and seeming crises. However, recent events like the emergencies at water systems that have gained national attention and cyberattacks that have involved ransomware and attempts to access control systems should raise our awareness of the value of these efforts. Maybe this information can help you gain support in your utility to keep up with risk assessment and emergency planning activities, especially with respect to cybersecurity. It’s clear that assessing cybersecurity risks and planning to address those risks is part of SDWA, even though EPA’s early 2023 memorandum about cybersecurity and sanitary surveys was rescinded. 

Cybersecurity threats appear to be ever-changing and more threatening. Our Drinking Water Security Response Toolbox is designed to help you meet these AWIA requirements and keep your water systems safe and protected. 

Thank you.

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


Wednesday, December 20, 2023

Wellhead Deficiencies

In this article, we continue our discussion of 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. At #2 in the Top 10, source construction deficiencies (S030) were cited 9% of the time during sanitary surveys for the 2022 inspection year and 9% in the 2023 inspection year. Groundwater wells are the most common sources of drinking water used in Colorado (70% of public water systems use groundwater wells) and are perhaps one of the most overlooked parts of water systems. Wells can go unnoticed for years since they are often located away from most activities and may only be noticed when the flow of water is altered. The most commonly discovered significant deficiencies with wells are related to electrical conduits, gaskets, vents and vaults.

What are the minimum standards for a properly constructed well? In the “State of Colorado Design Criteria for Potable Water Systems” (Policy DW005), CDPHE actually primarily refers to the Colorado Division of Water Resources’ (DNR) latest edition of “2 CCR 402-2 Rules and Regulations for Water Well Construction, Pump Installation, Cistern Installation, and Monitoring and Observation Hole/Well Construction” (a.k.a. Colorado Well Driller Regulations). The purpose of these regulations is to ensure public health and the safety of groundwater resources. The regulation outlines minimum construction standards for all types of wells in all types of environments, and it defines minimum well height, screening, minimum distance from potential sources of contamination, grouting standards, pump installation and much more.

There are many variations to well heads, but the two primary ones that inspectors come across are the “split-cap” and the “well-cap” (see image below for reference). The “split-cap” has the discharge line, vent and electrical conduit all protruding from the wellhead. The well head is comprised of two metal plates with a rubber gasket in between. When installed, the two plates are compressed, the rubber gasket expands and creates a watertight seal. The “well-cap” has a pitless water connection (below frostline) and a designated female electrical connection, a set of gaskets and a built-in vent (which are typically screened).


*photo courtesy of Oregon State University https://wellwater.oregonstate.edu/well-water/wells/well-check-list

Well head

Well heads must be designed and constructed at the top of well casings to prevent the entry of contaminants into the well. The majority of the wells that the department inspects are located outdoors and are exposed to the elements. It is vital that the wells are constructed and maintained in a manner that will protect the raw water. Some common issues that inspectors observe are missing/damaged gaskets, missing bolts, broken or loose well caps (bolts are missing or not tightened), split-caps not seated on the well casing properly and a split-cap with a rope (used to hold the well pump in position or to assist in pulling the pump out) coming out of the well that is not properly sealed.

The split-cap well head was not properly sealed to the well casing. The supplier applied caulking between the split-cap and the well casing.

The bottom of the well head cap was broken and did not allow for a tight seal. A new well head was installed.

Well Vents

Vents are an integral part of a well as they permit air to freely enter and exit the well. Vents need to be located at a minimum of one foot above ground level, be turned down and be covered with a non-corrodible screen. Screens may not have openings that exceed 0.07 inches (typically 12 or 16 mesh screen). 

The two most common issues observed with vents on wells are that they are broken or missing.


The well-cap has a built-in vent that was broken/corroded. The supplier replaced the broken screen with an acceptable mesh screen.

Electrical Conduit

According to the Colorado Well Driller Regulation, electrical connections are to meet the standards of the NFPA 70: National Electric Code (2014). Some common electrical conduit issues that are observed during sanitary surveys are where the electrical conduit has separated from the well head or the junction box which can typically occur due to the ground settling. Another common finding is missing or partially attached cover plates on electrical junction boxes. Split-cap wells can also have electrical wires penetrating the well top without a properly constructed conduit or a proper seal between the wire and the rubber gasket. All of these situations present a pathway for contaminants to enter the well, which pose a health risk and are significant deficiencies that will be cited during a sanitary survey.


The electrical conduit separated from the electrical junction box, creating an opening. The supplier installed a conduit sleeve to provide a watertight junction.


The electrical junction box was missing a screw. The supplier sealed the hole with caulk.


Split-cap well had the electrical wire enter from an unsealed port. The supplier sealed the gap with caulk.

Well Vaults

Although well vaults are not a common practice these days, the department still observes wells located in vaults. Placing a well in a vault was a common practice to protect the well from the elements. However, having a well in a vault can subject the well to flooding. If a well is located in a vault, the vault cover or lid must be watertight and the vault must either drain to daylight or have a sump. Evidence of water accumulating in the vault and potentially submerging the wellhead is a significant deficiency.


Well vault was subject to flooding. Supplier installed a sump pump.

Concrete Pads

Inspectors are frequently asked if concrete pads are required? The Colorado Well Driller Regulation along with the department do not recommend that wells have concrete pads with the exception of hand-pumped wells. Well pads were commonly installed if well depths were less than 100 feet or to keep vegetation down around the well head. However, the department has observed that concrete pads tend to attract animals that burrow underneath the pad creating a source of contamination. Concrete pads also tend to crack and shift, which can create a funnel effect and divert surface water to the well casing. Minor cracks can be repaired; however, the department recommends that a supplier remove their existing concrete pad if they notice animals burrowing or if the concrete pad begins to divert surface water to the well casing. Evidence of burrows under a concrete pad or severely damaged pads capable of channeling surface water to the well casing are significant deficiencies that would be cited during a sanitary survey.


Burrow located under the concrete pad, the burrow was filled in and will be monitored in the future.

Drainage and Slope

According to the Colorado Well Driller Regulation, well locations should incorporate proper positive drainage from the well casing. As a rule of thumb, the department has historically viewed positive drainage 20 feet in all directions from the well if possible. Wells should not be located in depressions as surface water can pool around the well casing and be a source of contamination. If a well is built on a slope, a berm is recommended uphill to divert runoff and surface water away from the well casing. 


Well was located in a depression that could allow for water to pool around the well casing. The supplier added pea gravel around the well head and created positive drainage away from the well casing.

For more information the department recommends that suppliers utilize DNR’s latest edition of “2 CCR 402-2 Rules and Regulations for Water Well Construction, Pump Installation, Cistern Installation, and Monitoring and Observation Hole/Well Construction” for proper well construction, maintenances and fixes. In addition, suppliers may email the Field Services team at cdphe_wqcd_fss_questions@state.co.us if they have any questions or concerns.

➽ Tom Valenta, CWP, Field Services Work Group Leader

Wednesday, December 13, 2023

Cybersecurity: simple steps to protect your system

Cyberattacks on critical infrastructure in the US continue to be a major concern and present a potential disruption to the critical work that water and wastewater systems provide for their communities. On October 12, 2023 the US EPA withdrew their Cybersecurity Rule citing legal challenges. However, cybersecurity planning and preventing attacks continues to be a central focus of the federal government. EPA and CISA continue to provide technical support to water systems. Regardless of federal requirements, the division wants to emphasize the significant financial and operational risks that cyberattacks pose to systems. The division continues to partner with state and federal entities to provide cybersecurity planning tools, resources, training opportunities, and self-evaluations.

Who is vulnerable?

According to a recent Waterfall Security Report, in 2022 the critical infrastructure sector experienced a 140% surge in cyberattacks resulting in more than 150 incidents. The majority of these assaults were in the form of ransomware, encrypting critical computer systems and invaluable data across Informational Technology (IT) networks. However, the attacks impacted operational technology (OT) as well. Any system that uses OT and or IT is vulnerable to cyberattacks. These attacks can negatively affect treatment, distribution, collections, administrative support, and financial/billing systems. These effects can impact your ability to protect public health and the environment and often cost large sums of money. Here are some examples of OT and IT:

  • OT = Industrial Control System (ICS), Supervisory Control and Data Acquisition (SCADA), Programmable Logic Controllers (PLCs),Remote terminal units (RTUs), Internet of things (IoT) devices, Industrial internet of things (IIoT) devices, also known as Industry 4.0, building management systems, fire control systems, and physical access control mechanisms.
  • IT = Laptops, Desktops, Tablets, servers, computer hardware, software, electronics, semiconductors, internet, telecom equipment, and e-commerce.

What are some basic steps you can take to protect your system?

Regardless of the size of your system or the scope of your technology use. please take the following basic cybersecurity steps at your facility to help prevent cyberattacks: 

  1. Change passwords regularly (at least once every 3 months). 
  2. Use multi-factor authentication for access.
  3. Take away system access when staff leave the utility.
  4. Implement regular staff training on cybersecurity fundamentals (especially how to recognize phishing attempts).
  5. System maintenance
    • Do frequent back-ups
    • Keep up to date with software and install patches

According to EPA and CISA, taking these low-cost steps can prevent many cyberattacks.

In addition to the above basic preventive measures you and your system can explore the many available free cybersecurity tools and resources: 

Thank you for all that you and your system do to protect the public health and environment of Colorado’s communities! Please reach out to the division’s security contact kyra.gregory@state.co.us with any questions. 

➽ Heather Young Field Services Section Manager 

➽ Kyra Gregory Drinking Water Training Specialist 


Wednesday, December 6, 2023

Backflow Prevention and Cross Connection Control Regulation Updates


The updated Backflow Prevention and Cross Connection Control Program (BPCCC) rule (in Regulation 11 Section 11.39) was officially active as of October 15, 2023! The Division greatly appreciated all the stakeholder support in developing the updated BPCCC regulation and also the updated DW007 BPCCC Policy that accompanies the regulation changes. Major changes that were adopted with the BPCCC updates include: 

  • Suppliers have 1 calendar year to test assemblies not tested in previous calendar year (must still test at least 90% each year)
  • In specific situations, suppliers can self-issue extensions of the 120-day deadline for controlling discovered cross-connections (see section 4.11 of Policy 7
  • Assemblies and methods are now one combined compliance ratio (see new annual report template)
  • Cleaned up regulation to remove old dates and tables from delayed implementation schedules
  • Updated Policy 7 to include more detail on permitting cross connections, surveying, self issued extensions, and more

The Division is currently working on major updates to the Backflow Guidance Documents to incorporate the new BPCCC regulation and policy update. The guidance document updates and associated templates will be posted to the CDPHE WQCD BPCCC Website. Please stay tuned for updates! If you have any questions in the meantime, please email us at cdphe_wqcd_fss_questions@state.co.us.

➽ Heather Young, PE, CWP, Field Services Section Manager

➽ Clayton Moores, PE, Field Unit I Manager


Wednesday, November 22, 2023

Reporting Requirements: tampering and security breaches in your water system

In early 2022 the Water Quality Control Division published a Drinking Water Security Response Toolbox website designed to help water utilities plan for, prevent, and guide responses to security threats including threats of tampering, suspected tampering, general malevolent acts, cyberattacks, confirmed tampering, and violent acts. Physical security breaches and tampering events continue to pose a significant risk to Colorado’s public water systems and their ability to provide safe drinking water to their communities. The division would like to emphasize that it is critical for systems to: 

  1. Take measures to prevent security incidents.
  2. Plan their response to an attack.
  3. Know what constitutes a tampering event or a suspected tampering event.
  4. Understand the regulatory requirements for reporting tampering to the division. 

In response to recent tampering incidents and in an effort to clarify when it is required to report security events to the division, we have updated the Guidance: Report and Respond to Tampering Events or Security Threats. The guidance provides the following information for public water systems: 

  • Regulatory details and requirements for reporting tampering or suspected tampering events. 
  • Explanation of what constitutes an attempted, suspected, or confirmed tampering event.
  • Simple actions to help prevent tampering events.

For the purposes of this article, we will focus on the requirements for reporting tampering or suspected tampering and examples of what constitutes an attempted, suspected, or confirmed tampering event. 

Reg 11 requires PWS to report tampering (suspected or confirmed) to the division

Per Regulation 11.2(1), tampering events, suspected tampering, or receipt of a tampering threat must be reported to the Colorado Department of Public Health and Environment (department). The supplier must notify the department as soon as possible but no later than 10 a.m. of the next calendar day and notify the Department in writing no later than 5 days after any attempted, confirmed, or suspected tampering, or receipt of a tampering threat. Failure to report attempted, suspected, or confirmed tampering in a timely manner may result in a violation of Regulation 11. The guidance offers information on what information to submit. For ease of reporting, the department has created the Tampering Threat and Incident Report Form. If you have issues accessing the form please fill out the pdf version of the form and submit it to cdphe.wqacutes@state.co.us.

It is really important to emphasize that attempted or suspected tampering is reportable even if the event is not successful or confirmed. When in doubt, please contact the department. The role of the department during actual or suspected tampering events is to: 

  1. Help water system asses any possible impacts to water quality,
  2. Support the system experiencing the event(s) by connecting them with state and federal agencies that specialize in tampering and security issues in the water sector. 
  3. Support the industry and gather information to identify trends across the water sector. 

What constitutes an attempted, suspected, or confirmed tampering event?

What are some examples of tampering events?

  • 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 intent to harm people or the public water system infrastructure. 
  • Vandalism that physically damages storage tanks, fire hydrants, locks on well buildings, wellheads, intake structures, pump stations, treatment plants, backflow devices, or any other part of the physical infrastructure of the drinking water system. 
  • Any action that damages the integrity of a drinking water system or causes harm to the system including expending resources (staff’s time, funding to replace or repair damaged infrastructure, water loss, etc.).  
  • Unapproved removal of critical records, equipment, or chemicals. 

What are some previous tampering events that required reporting to the department?

  • Verbal threat of damaging the water system infrastructure. 
  • Malicious damage to fire hydrants in the distribution system. This can create a cross connection or cause pressure loss. 
  • Cybersecurity attack - ransomware attack that withheld SCADA system and billing system. 
  • Tank hatch alarm sounding to indicate the tank hatch is opening frequently with no system staff in the area.
  • Vandalism of security fencing and a well-house.
  • Purposefully attempting to drain the distribution system or storage tank, opening and closing valves without permission, intentional damage. 

What does not constitute a tampering event?

  • Any vandalism that poses no potential risk to public health, like non-destructive tagging which does not result in excessive costs to the system for removal/repair.
  • Accidental damage to the system such as a car accident that results in damage to a hydrant. 
  • Water theft is not considered tampering unless there is intent to damage or interfere with the system. Regardless of whether theft is tampering or not, please contact your local law enforcement. 

➽ Kyra Gregory Drinking Water Training Specialist  


Wednesday, November 15, 2023

Asset Management - the Key to a System's Capacity

The Water Quality Control Division’s Local Assistance Unit is charged with assisting Colorado’s public water systems with building their capacity to provide safe drinking water to their communities now and into the future. Capacity can be defined  as the amount that something can hold or produce, whether it is applied to people, things or systems. In a public water system (PWS), capacity is an indicator of the overall health of a system. A PWS’s capacity is assessed using 3 criteria: Technical, Managerial, and Financial or T-M-F. Just 3 little letters, sounds simple, right?  

Don’t let the  simplicity of those letters fool you, they are powerful. The key to a successful and healthy water system is T-M-F capacity. Every part of a water system can be classified under one (or more) of these criteria areas. So, it makes sense that understanding your system's capacity is essential to running a successful water system. In fact, when applying for funding an in depth capacity assessment may be required, depending on the funding source.  Beyond funding however, it is a tool that helps you manage and assess your system’s needs both short and long term.  

How can you determine your system's capacity?  

CDPHE’s TMF capacity worksheet tool can assist you. This worksheet offers a condensed, quick-tool version of the more robust TMF assessment done when applying for funding. By completing each question you will generate an estimate of your capacity percentage for each criteria area TM & F.  Using this percentage you can determine which areas are in good shape and which areas require more focus. Good TMF capacity is often tied to good asset management.  Understanding your system as a whole is critical to short- and long-term planning. Assets are everything your system is composed of from the physical infrastructure, pipes, meters, tubing, valves, etc. to the people that work in your system. Asset management is a cumulative inventory of your system as a whole that allows you to critically assess each piece, its lifetime, cost, and to generate a prioritized needs assessment. There are a variety of tools available for developing your asset management plan:

Need assistance with asset management or capacity development?

The Colorado Department of Public Health (CDPHE) Water Quality Control Division (WQCD) has capacity coaching available for free through the Local Assistance Unit (LAU). A PWS can request assistance by filling out the Coaching Assistance Form. Please welcome the newest member of our capacity development team Angela Green Garcia. Angela will be focusing on asset management and financial readiness.  

➽ Angela Green Garcia - Drinking Water Training Specialist






Wednesday, November 8, 2023

Lead and Copper Rule Revisions and Service Line Inventories

On August 14, 2023, the Water Quality Control Commission adopted the Lead and Copper Rule Revisions into Regulation 11. The changes to Regulation 11 are effective as of October 15, 2023, but the Lead and Copper Rule Revisions have a delayed start date and won’t take effect until October 16, 2024. The Lead and Copper Rule Revisions are a comprehensive update to the EPA’s 1991 Lead and Copper Rule.

Prior to adoption the division conducted an extensive stakeholder process with 26 meetings that provided opportunities for public feedback about the proposed changes. Overall, the division gained stakeholder consensus on adopting the Lead and Copper Rule Revisions into Regulation 11 within two years after promulgation of the revisions, and many of the stakeholder comments related to clarity of the rule requirements. The division reorganized the structure of the Lead and Copper Rule Revisions and incorporated stakeholder comments into the draft rule, where possible, to increase readability and clarity.

The Lead and Copper Rule Revisions affect more than 1,050 community and non-transient, non-community public water systems in Colorado, serving nearly 6.5 million people. A key requirement due by October 16, 2024 is that all systems subject to the rule must complete an initial lead service line inventory to classify the material of each service line entering a building, regardless of ownership.

To aid systems, the division has made many resources available to systems. First, we have posted EPA and state guidance for systems on how to complete a lead service inventory and reporting forms to submit to the division once completed. Second, the division contracted with Corona Engineering and worked with stakeholders to develop an initial lead service line inventory development policy that details the expectations for completion of an inventory and clarifies many lingering issues that remained unanswered in EPA guidance. Some examples include: 

  • When can galvanized pipe be considered non-lead versus galvanized requiring replacement?
  • How does a system use predictive modeling to complete their inventory?
  • When can a system indicate all service lines installed after 1959 are non-lead?

Third, we are contracting with WSP USA Inc to provide no-cost technical assistance to systems serving less than or equal to 15,000 people and allowing systems serving 7,500 or more people to apply for grants to assist with completing their service line inventory and service line replacement planning. This money cannot be used for physical replacement of lead service lines. Grants will be awarded on a first-come, first-serve basis to eligible applicants over several application periods. 

It’s important to note that with less than one year left to complete an initial lead service line inventory and recognizing the resources necessary to diligently complete an inventory, water systems may categorize service lines as “lead status unknown” when they cannot determine the material through an evidence-based approach. However, additional requirements, including customer outreach and planning, are triggered under the new rule if any service lines are listed as “lead status unknown.”

  • Other key changes under the LCRR include, but are not limited to:
  • Compliance with a new lead “trigger level” set at 10 parts per billion (ppb).
  • Tap sampling requirements that target lead service lines.
  • Testing water for lead in schools and childcare facilities.
  • Strengthened corrosion control treatment, lead service line replacement, and public education requirements.

Please note that these key requirements (e.g., lead trigger level and sampling changes) may be revised under another new rule, the Lead and Copper Rule Improvements (LCRI). The EPA plans to finalize the LCRI by October 2024. The department is awaiting more information about the LCRI in late 2023 or early 2024. Therefore, the department will provide communication and resources related to these requirements once more is known about the LCRI.

Resources:

➽ Bryan Pilson Technical & Regulatory Implementation & Coordination Unit Manager

Wednesday, October 25, 2023

Getting the lead out of drinking water - one fixture at a time

National Lead Poisoning Prevention Week is October 22-28, 2023

Certified Water Professionals across the state are our front line for promotion of the Culture of Health in drinking water. They work hard to protect water consumers at public water systems from all kinds of contaminants, from bacteria to uranium. One of the most complicated rules for protecting water consumers is the Lead and Copper Rule (LCR). Even when this rule is fully-implemented, it relies on careful sampling at a representative number of sample sites. No public water system is required to test at every point where consumers drink water to see if lead is present. 

But there is another program in Colorado that is doing just that. In 2022, the state legislature wanted to make sure that Colorado’s children were protected from lead in drinking and cooking water sources in the locations where they spend most of their time away from home: child care facilities and schools. The legislature passed House Bill 22-1358, implemented by the Water Quality Control Division as the Test & Fix Water for Kids program. This program, launched during the 2022-2023 school year, has conducted outreach to the nearly 6,000 licensed child care facilities and public or facility schools across the state serving children fifth grade and under. Each facility was asked to identify every water fixture used for drinking or cooking, and they were provided free test kits and analyses for lead. Over the past year, the program analyzed lead at over 53,000 fixtures across the state, representing about 600,000 children at 4,700 licensed facilities and schools. Ninety three percent (93%) of the samples collected were below the program action level of five parts per billion, and the remainder, about 3,700 fixtures total, are working through remediation funded by the program.

Why focus on fixtures?

In most cases, older brass fixtures are the cause of lead in water at schools and child care facilities. Older fixtures are not certified as lead free, and the materials in the fixture, when in contact with water, can leach lead. Replacing these fixtures can be a good solution. While lead service lines or copper pipe with lead solder can also be a source of lead, testing elevated locations with a follow up flush sample can help determine if premise plumbing is a cause. Almost none of the over 3,000 flush samples collected in this program showed elevated lead due to water contact with premise plumbing, and lead service lines were not commonly used for non-residential buildings. After repairs are made, each location is retested to confirm that lead is not present. The program is expanding to middle schools in the 2023-2024 school year.

How does this program affect compliance for public water systems with the LCR? 

The short answer is, it doesn’t! The results from this program are not reportable as part of the LCR and sampling conducted as part of this program do not “count” for sampling under the LCR. The good news is that when water systems do sample at these facilities, the Test & Fix Water for Kids program has already worked to get the lead out - one fixture at a time!

What can I do to protect myself and my family from lead in drinking water?

  • Before drinking, run the tap for 30 seconds.
  • Use only COLD water for drinking, cooking, and making baby formula. Boiling water does NOT remove lead.
  • Regularly clean the aerators on your faucets.
  • If you use a filter to remove lead, maintain it regularly.

➽ Margaret Talbott Infrastructure Unit Manager

Wednesday, October 18, 2023

Equipping Operators with Skills to Manage and Overcome Testing Anxiety

In the Summer of 2021, this article was originally published in the Arkansas Department of Health’s Drinking Water Newsletter. With permission from the author, Tom Healy, Vice President of Water Professionals International, the article was reposted on Aqua Talk on October 13, 2021. We thought it would be a good time to revisit this information and highlight its importance. Note: This article has been reposted with permission from the author, Tom Healy, Vice President of Water Professionals International

➽ Jessica Morgan, Facility and Operator Outreach and Certification Board Liaison

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, Vice President of Water Professionals International (formerly known as, The Associated Boards of Certification) 

Wednesday, October 4, 2023

Ready, set, go - the WQCD provides assistance for lead service line projects

On December 16, 2021, EPA finalized the Lead and Copper Rule Revisions (LCRR), which further strengthened the protections against lead in drinking water. The LCRR requires community and non-transient, non-community public water systems to develop a service line inventory (LSLI) to identify the materials of service lines connected to the public water distribution system. If one or more lead, galvanized requiring replacement, or lead status unknown service lines are identified, systems must submit a lead service line replacement (LSLR) plan. Both documents are due to the Drinking Water Compliance Assurance Section by October 16, 2024.

The Water Quality Control Division (division) is providing free technical assistance and grants to help eligible public water systems with the service line inventory and lead service line replacement planning process. Additionally, there are low interest loans available for lead service line removal construction costs.

Direct Technical Assistance

Through a competitive bid process, the division has selected WSP, in partnership with Sunrise Engineering, to support water systems serving up to 15,000 persons. Suppliers can request remote support or hands-on assistance, offered at no cost until funding is depleted. The division has selected only one contractor to provide no-cost technical assistance and support to eligible water systems, and under this assistance program it will not reimburse systems for the costs of hiring outside contractors. Suppliers can sign up here to be contacted by WSP. 

Technical Assistance Grants

The division has additionally made grant funding available to assist public water systems with the service line inventory and lead service line replacement planning process for those systems who elect to perform work outside of the technical assistance program above. Grants range from $10,000 to $250,000, and cover 90% of the project cost. Applications will be accepted at four upcoming deadlines, beginning October 1, 2023. Grants will be awarded on a first-come, first- served basis during each application review period, until funds are depleted. Reimbursements will only be made for expenses incurred after the grant agreement is executed. Smaller water systems are encouraged to make use of the technical assistance provider before applying for grant funding. 

Eligible applicants for the grant program include:

  • Publicly owned water systems and private not-for-profit public water systems whose service area is between 7,500 persons and 50,000 persons and whose Median Household Income is less than 120% of the State’s Median Household Income.
  • Publicly owned water systems and private not-for-profit public water systems whose service area is larger than 50,000 persons, and whose Median Household Income is less than 80% of the State’s Median Household Income.
  • Applicants must proceed with work within 30 calendar days of contracting. 

For more information on grant funding and application materials, please visit the division’s Water Quality Grants Webpage

SRF Program Loans for lead service line projects

For public water systems who know they have service lines that require removal and who are interested in construction funding or a combination of inventory work and concurrent removal work, please visit the State Revolving Fund web page for more information. Eligible applicants to the SRF program must have indicated lead service line funding needs on the annual SRF Eligibility Survey. 


Wednesday, September 27, 2023

Update on EPA Requirement to Address Cybersecurity in Sanitary Surveys

In our April 2023 Aqua Talk article, we reviewed highlights from the March 3, 2023 US EPA Office of Water memorandum, “Addressing PWS Cybersecurity in Sanitary Surveys or an Alternate Process” issued to all State Drinking Water Administrators requiring cybersecurity evaluations during each sanitary survey. Sanitary surveys are “an onsite review of the water source, facilities, equipment, operation, and maintenance of a PWS for the purpose of evaluating the adequacy of such source, facilities, equipment, operation, and maintenance for producing and distributing safe drinking water.” In Colorado, CDPHE conducts sanitary surveys of all public water systems (PWS) every 3 years for community systems and every 5 years for non-community systems. 

What happened since the Memo was issued by EPA?  

In April 2023, the States of Missouri, Arkansas, and Iowa filed a petition with the US Court of Appeals for the Eighth Circuit against the EPA legally challenging the EPA Cybersecurity Rule. In July 2023, the U.S. Court of Appeals granted a motion for stay requested by the American Water Works Association (AWWA) and the National Rural Water Association (NRWA) to stop the U.S. Environmental Protection Agency’s Cybersecurity Rule from going into effect until the current case filed by Missouri, Arkansas and Iowa, challenging the rule has been decided. Basically, the EPA cybersecurity memo requirements are on hold until the petition has been decided. However, EPA is continuing their assistance, training and cybersecurity assessment services as described below, which is great!

What does this mean for my water system?  

Colorado will not be including cybersecurity as part of the sanitary survey process in the upcoming inspection year. However, cyber threats are a continuing concern and Colorado water systems have been attacked by cyber criminals. CDPHE strongly encourages all PWSs with industrial control system capabilities to assess their cybersecurity programs with an established method if they have not already done so. EPA is still available to conduct assessments and PWSs can request information about their evaluation services here. CISA also has cybersecurity evaluation services available and more information can be found here.

Public Water Systems should implement measures recommended from any cybersecurity assessment to ensure continued production and distribution of safe drinking water. 

Additional resources can be found: 


For more cybersecurity training resources, please contact Kyra Gregory at kyra.gregory@state.co.us.

➽ Heather Young, PE, CWP, Field Services Section Manager

➽ Cameron Wilkins, PE, Field Unit II Manager