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| Town of Monument, CO |
In 2014 to 2018, Palmer Lake Mobile Home Ranch was struggling to maintain compliance with a variety of regulatory requirements. As a result, in 2018, the Department issued an Enforcement Order due to the system's failure to comply with The Colorado Primary Drinking Water Regulations (Regulation 11) and The Water and Wastewater Facility Operators Certification Requirements (Regulation 100). The purpose of the Order was to provide deadlines and oversight to keep Palmer Lake Mobile Home Ranch on track toward returning to compliance and maintaining long-term compliance with Regulation 11 and Regulation 100.
Later in 2018, water samples collected from a proposed well indicated elevated concentrations of combined radium -226 and -228 and resulted in violations of the maximum contaminant level (MCL). Radionuclides such as these can occur naturally in water sources as a result of the erosion of natural deposits. While they are not an acute health risk for short-term consumption, there are chronic risks including a higher risk of developing cancer if water with elevated radium levels is consumed over a long period of time. Even though Palmer Lake Mobile Home Ranch had resolved all but one of the prior violations, the Department issued an amendment to their Order to bring the new MCL violations into the corrective action oversight provided by the Order.
The owner of Palmer Lake Mobile Home Ranch expressed frustration at the complexity of this new MCL violation but continued to work with their contract Professional Engineer and the Department to explore affordable solutions. Even though this water system serves full-time residents, as a private, for-profit business, the owners could not qualify for funding assistance (grants or low interest loans) from local, state or federal agencies. Collaborative communication between the Department, the system, and contract engineers was dedicated to designing a solution that would effectively reduce the concentration of combined radium in the water. Several ideas were considered, but only a few were realistically going to ensure future compliance. The system decided to install treatment to remove radium, but complications developed throughout the process: the financial burden of the total cost of the project was becoming an increasing concern, and they were not allowed to discharge the removed radium as a waste stream which eliminated some treatment options. The remaining treatment option added extra cost beyond the treatment installation and operation/maintenance. They would need to use a treatment that captured the removed radium in a resin instead of discharging it in a waste stream. This would require obtaining a hazardous waste handler permit for the Palmer Lake Mobile Home Ranch itself, and they would also pay indefinitely for a specially permitted waste hauler service to remove the resin on a regular frequency.
In 2022, a new partner entered the conversation. The Town of Monument informed the Department of plans to construct a water line that was going to run along the property edge of Palmer Lake Mobile Home Ranch as part of a new storage tank construction project. Given the complications that Palmer Lake Mobile Home Ranch was experiencing with installing treatment for their own water supply, they were enthusiastic about this new development. When the Department received confirmation from the Town of Monument that they were willing to provide a connection to Palmer Lake Mobile Home Ranch, as well as confirmation from Palmer Lake Mobile Home Ranch that they would accept the connection and disconnect their wells, the Department readily agreed to the change of plans.
Despite having exhausted significant effort and resources toward implementing solutions for an improved water system and treatment for combined radium, ultimately, Palmer Lake Mobile Home Ranch decided that the best way to return to compliance was to tie in with the Town of Monument. In December 2023, the connection was completed and the wells were disconnected. Palmer Lake Mobile Home Ranch is now classified as a consecutive system receiving finished drinking water from another regulated water system, and the water being distributed to its residents is now in compliance with Regulation 11.
While Palmer Lake Mobile Home Ranch demonstrated admirable determination in attempting to independently return the water system to compliance with all regulations, ultimately, success was found in partnership, as expressed in these testimonials from Palmer Lake Mobile Home Ranch and The Town of Monument. This highlights the important lesson in weighing perseverance against the path of least resistance: sometimes the simplest option is the best option. The Department is committed to a culture of health that prioritizes safe drinking water for all consumers and works hard to facilitate success stories such as these.
It is also important to take into consideration how existing regulations now apply to Palmer Lake Mobile Home Ranch moving forward. Consecutive water systems are still required to comply with Regulations 11 and 100, there are just differences in the applicability of certain rules. Additionally, the new water quality testing program under the Mobile Home Park Water Quality Act will begin this year. This program is designed to address community member concerns, identify water quality issues, and remediate water quality issues at parks throughout Colorado.
Did you know that Colorado has hundreds of small mobile home parks that receive finished drinking water from a regulated water system?
QUIZ: If a mobile home park does not have a well or treatment system, but bills customers for water, what regulations apply? Choose the correct answer:
- The plumbing code alone
- The plumbing code and the new Mobile Home Park Water Quality Act
- The plumbing code, the new Mobile Home Park Water Quality Act, DOLA’s Mobile Home Park Oversight program, and Regulation 11 within the distribution system
- None of the above are fully correct; it’s complicated!
Look for the answer in a future AquaTalk article!
➽ Lauren Fracasso Compliance Specialist for South Unit
➽ Emily Clark Enforcement & Field Findings Compliance Lead
