Aqua Answers: PFAS and Biosolids

Dear Aqua Answers,

Please help! I have multiple questions about PFAS and biosolids. 

Thanks,

Newt R. Sludge

__________________________________________________________________________

Dear Newt,

I have listed your questions and the answers below:

Question 1:

Can you remind me, what are biosolids? 

Biosolids are a product of domestic wastewater treatment processes. They are rich in nutrients and organic matter; farmers can use them as fertilizer to improve soil quality. The Colorado Department of Public Health’s Water Quality Control Division and the U.S. Environmental Protection Agency require biosolids to meet regulatory requirements for pathogens, pollutants, and land application to protect human health and the environment. Biosolids produced in Colorado are either land applied to agricultural fields as a soil amendment/fertilizer (70+%), composted (20+%), or disposed of in landfills.

Question 2:

How do PFAS get into biosolids?

Industrial, commercial, and residential use and disposal of PFAS products can allow these chemicals to enter wastewater treatment facilities. As a result, researchers have found PFAS in treated wastewater and biosolids. PFAS can move in the environment and potentially impact the soil, water, and crops.

Question 3:

What is the department’s approach to reducing PFAS levels in biosolids? 

The department has taken a proactive approach that aligns with EPA’s newly released Draft Sewage Sludge Risk Assessment recommendations and focuses on measuring and understanding levels of PFAS in biosolids and identifying and reducing significant sources of PFAS migrating to wastewater treatment facilities. The department began implementing its Biosolids-PFAS Interim Strategy on January 1, 2023. It establishes monitoring requirements for biosolids preparers and a threshold level for requiring biosolids preparers to develop and implement a source control program to evaluate potential industrial or commercial sources of PFAS. More information about our interim strategy and biosolids test results the department has received are available on our PFAS and biosolids web page.

Question 4:

What can people living in our beautiful state do to reduce the amount of PFAS entering the environment? 

Over the past several years, Colorado has committed to identifying where PFAS are entering the environment, stopping new releases, and protecting Coloradans. In many ways, Colorado has led the way in its efforts to track and reduce exposure to PFAS. The department is now focusing on carrying out actions in the 2024 PFAS Action Plan to continue our work as a leader among states addressing widespread PFAS pollution. To learn more, please visit the 2024 PFAS Action Plan webpage.

To protect the environment and reduce the amount of PFAS entering our wastewater treatment plants, we need to phase out the production and use of products containing these chemicals and find safer alternatives. Recent legislation in Colorado has banned the sale of certain products containing PFAS. We encourage people to get the facts and take steps to limit their exposure from other sources and avoid PFAS when purchasing consumer goods and new household products. This will protect your health and further prevent the chemicals from entering our environment. We have resources at our PFAS public health website.  

Sincerely,

Aqua Answers

Early 2025 CoWARN updates

The WQCD is sending the below updates in partnership with the CoWARN steering committee. We encourage all water and wastewater providers in Colorado to join the mutual aid network to enhance your preparedness for emergency incident preparation, response, and recovery. Please reach out to CoWARN administrator Kyra Gregory with any questions or if you have interest in joining the CoWARN steering committee made up of volunteers from water/wastewater providers in CO: kyra.gregory@state.co.us 303-908-7519. 

New CoWARN website launched, take action today!

Colorado's Water/Wastewater Agency Response Network launched a new and much-improved website in fall 2023! However, the new website could not retain all the information from the old website. So, all CoWARN members need to please update their membership profiles on the new website. So far, only 63 out of 246 CoWARN members have updated their membership information. Because of this there have been multiple CoWARN activations that many CoWARN members did not receive: Two Buttes 8/27/24, Gardner 8/29/24, Genoa 11/19/24. If you did not receive text or email notification of these activations, please take action today to update your contact information and system membership through the new CoWARN website.

How does the new website work?

As a CoWARN member your water or wastewater facility will have a profile on the website. Each member profile will assign primary users who can activate CoWARN to send out email/text messages to the CoWARN network. As a user under your facility’s membership, you will need to: 

1. Reset your personal password
2. Navigate to your dashboard by clicking on the red icon in the top right hand corner of the screen. 
3. Update your personal information - be sure to add a cell phone number as you will need to receive a text message to log into the site. 
4. Create your facility’s membership profile - Under “my systems” click “Add”. You are now the primary user for the membership profile. 
5. Assign other primary users by clicking “Add” under “System Contacts” 

For more information and videos explaining the process, please follow these instructions and reach out to Kyra Gregory with any questions or issues you encounter. 

New Mutual Aid Agreement 

The CoWARN steering committee has revised the CoWARN Mutual Aid and Assistance Agreement. Please sign and return a copy of the updated agreement to CoWARN administrator Kyra Gregory (kyra.gregory@state.co.us). See new MAA here. Please note this is the new agreement that went into effect on January 8th, 2025 regardless of received signatures. 

A short description of the updates is below. 

• Correct Colorado Revised Statutes references 
• Revise definitions of operational structure to better reflect current operations and create flexibility for any future structural changes
• Remove specific language regarding agreement expiration
• Clarify CoWARN’s role in activations and that CoWARN is not a guarantor in any transactions nor an administrator of transactions.

Program Manager message: Looking ahead after the 50th Anniversary of the Safe Drinking Water Act

In 2024 we celebrated the 50th anniversary of the Safe Drinking Water Act signed by President Ford in 1974. This landmark legislation set unified standards for water systems across the United States to protect public health. The Act set up a now time-tested framework in which EPA largely sets the rules and requirements via a defined process and with stakeholder input, and then states implement via primacy. As our work to improve public health continues, what factors and principles do we need to consider on our path through the next 25 to 50 years?

In December 2024, I had the opportunity to participate in and speak at a symposium at the University of Wisconsin on just this topic. The symposium was sponsored by the Water and Health Advisory Council, a multidisciplinary group of water professionals involved in drinking water and public health protection. The title of the symposium was: The Next 50 Years of Drinking Water in America. I participated in the “Prioritizing Risk” panel. 

Two of the risk reduction opportunities were identified as legionella and manganese. The upcoming federal revisions to the microbial and disinfection byproducts (M/DBP) rules should help us to start addressing legionella. Legionella is now a major cause of waterborne disease outbreaks, and the illness is sometimes fatal. At this point in time, it does not appear that a rule to address manganese is in the pipeline. Manganese has a health advisory, and some nervous system health risks similar to lead. However, another big risk was identified as losing the progress we have made due to aging infrastructure. Attendees were particularly concerned about distribution systems. Again, the M/DBP rules may help with some operational aspects of those, but the overall drinking water infrastructure situation is a serious concern. 

Are we approaching a time when affordability, especially for small systems, will jeopardize the ability to comply with rules for new contaminants and keep up with the fundamental infrastructure that a safe water supply relies on? Many people believe that we have already passed a tipping point in that regard and that small systems face truly daunting challenges over the next few decades.

So the question arises, how do we (as individuals, communities, states and a nation) pay for safe drinking water? It appears that all options need to be on the table. Currently, the Drinking Water State Revolving Funds that involve large infusions of federal dollars combined with the state programs that operate them and keep the money “revolving” through more and more loans is a great help, especially for small, rural communities. But this funding source is not enough. How much more funding can be gained from state and federal sources? Should we be exploring more public/private partnerships? Should drinking water be treated like education where small, rural systems are supported from the broader state population? What about individual assistance programs, like those that occur for power utility bills?

The answers to these questions are not known at present, but it’s important to ask them and work on solutions for the next decade and beyond. Look for more information about the next 50 years in drinking water in this space throughout 2025. Thank you in advance for your efforts to keep drinking water safe for the next half a century!

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

Inspection Year 25 and Free TUs to Help Prepare are Here!

The Field Services Section (FSS) started the new Inspection Year 2025 (IY25) inspection year in October 2024 and the inspection year will end on September 30, 2025. A total of 506 sanitary surveys are planned for IY25. The list of suppliers included in the IY25 sanitary survey plan takes into consideration a number of factors including:

• Last sanitary survey date and EPA required frequency for sanitary surveys - community water systems are required to have a sanitary survey every 3 years, non-community systems are required to have a sanitary survey every 5 years.
• Recently activated public water systems are prioritized for sanitary survey.
• Other conditions or concerns may also lead to a prioritized sanitary survey.

Please note that if your system is due for a sanitary survey, your inspector may reach out to schedule the survey with you anytime during the IY25 inspection year (October - September) and that the scheduling is not based on the date of the previous inspection (i.e., will not be in March or after March every 3 years).

The Field Services Section also performs Level 2 assessments or Level 2 sanitary surveys as they are triggered under the Total Coliform Rule. Level 2 assessments are triggered by either an E. coli MCL violation or two Level 1 assessment situations occurring within 12 consecutive months. Level 2 assessments are site visits that include review and identification of atypical events that could affect distributed water quality or indicate that distributed water quality was impaired. Items also evaluated include changes in distribution system maintenance and operation, including water storage, that could affect distributed water quality, source and treatment considerations that affect distributed water quality, existing water quality monitoring data, and inadequacies in sample sites, sampling protocol, and sample processing. Level 2 sanitary surveys are a combination of the Level 2 assessment and a sanitary survey. Level 2 assessments/sanitary surveys must be performed within 30 days of the date of issuance of the violation that triggered the Level 2 assessment. More information on Level 2 assessments can be found in Regulation 11.16 - the Total Coliform Rule. Thankfully due to Colorado’s disinfection requirements, there are typically under five (5) of these events a year. 

Field Services recommends that suppliers take advantage of the free sanitary survey preparation course from the Local Assistance Unit on the third Wednesday of every month. Operators who participate will receive 0.3 training units. The training provides concrete steps for your system to prepare for your next sanitary survey including:

• The ability to recognize, address, and eliminate potential violations and system deficiencies
• Actions to take to address potential violations and system deficiencies before your survey

If you are interested in this FREE training, please visit this document and click on the date that you would like to attend and fill out the associated registration form. Please reach out to cdphe.wqdwtraining@state.co.us with any questions or feedback or if you do not receive an invitation email.

For any questions or concerns about sanitary surveys please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. We look forward to working with you on your next sanitary survey and thank you for all your efforts to protect public health!

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