Coordination with Public Water Systems on SCADA Vulnerabilities

In June 2025, the EPA’s Water Infrastructure and Cyber Resilience Division (WICRD) notified the Water Quality Control Division (WQCD) that they had identified potential cybersecurity vulnerabilities at four Colorado public water systems (PWSs). While scanning for vulnerable devices, EPA identified the specific TCP/IP addresses of four BIF3800 SCADA Control Systems that were internet-exposed and could potentially allow a remote user to access the device and disrupt the utility’s operations. WQCD Field Services immediately reached out to the four water systems to notify them of the potential vulnerability so they could take action to protect their systems. 

Many utilities installed SCADA BIF3800 units as early as the 1990s and were controlling ancillary processes in the distribution systems of the water systems. There was a common thought that hackers would not be interested in equipment that is so old, or that the older control systems would be less vulnerable to cyber attacks. Unfortunately, hackers can exploit any internet-exposed interfaces like these. The EPA and the Cybersecurity and Infrastructure Security Agency (CISA) recently published this joint fact sheet, which highlights the risks posed by internet-exposed Human Machine Interfaces (HMIs), including how hackers can find and exploit HMIs with cybersecurity weaknesses easily. The EPA and CISA fact sheet includes recommended mitigations to secure HMIs, including:

• Conduct an inventory of all internet-exposed devices.
• If possible, disconnect HMIs and all other accessible and unprotected systems from the public-facing internet.
• If it is not possible to disconnect the device, secure it by creating a username and a strong password to prevent a threat actor from easily viewing and accessing the device. Change factory default passwords.

Thankfully, the four water systems quickly responded to remove the exposure and did not experience any cyber events due to this issue. The CISA team in Colorado also reached out to the water systems to provide technical support to mitigate the vulnerabilities.  

WQCD encourages water systems to continue to evaluate and protect their systems against cyber threats. Utilities that need support can contact the Colorado CISA Team, including Edward (Charlie) Marmon at edward.marmon@cisa.dhs.gov  or Kindra Brewer at kindra.brewer@cisa.dhs.gov, and the EPA’s Cybersecurity Technical Assistance Help Desk is also available for assistance. The WQCD Drinking Water Security Response Toolbox is a one-stop shop for security resources. 

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

➽ Naheem Noah, Field Services Section

Cyber Alert: Global Conflict Potential to Impact US Critical Infrastructure

EPA Cyber Alert: Iran Conflict is Increasing the Likelihood of Low-Level Cyberattacks Against US Networks

Note: The Water Quality Control Division is posting the following information out in partnership with the Environmental Protection Agency (EPA) .

The U.S. EPA is issuing this alert to inform water and wastewater system owners and operators of the need for increased vigilance for potential cyber activity in the United States due to the current geopolitical environment. The U.S. Department of Homeland Security (DHS) published a National Terrorism Advisory System Bulletin, indicating that low-level cyberattacks against U.S. networks by pro-Iranian hacktivists are likely, and cyber actors affiliated with the Iranian Government may conduct attacks against U.S. networks. Additionally, the Cybersecurity and Infrastructure Security Agency (CISA) published a fact sheet warning that Iranian-affiliated cyber actors may target U.S. devices and networks for near-term cyber operations.

Iranian-affiliated cyber actors have demonstrated the ability to exploit operational technology (OT) devices at U.S. water and wastewater systems, forcing many systems to revert to manual operations and resulting in operational impacts.

All drinking water and wastewater systems are strongly encouraged to implement the following mitigations immediately to enhance resilience against low-level cyberattacks:

• Reduce OT Exposure to the Public-Facing Internet
• Replace All Default Passwords on OT Devices with Strong, Unique Passwords
• Implement Multifactor Authentication for Remote Access to OT Devices

In addition to these immediate actions, drinking water and wastewater systems are encouraged to adopt the actions outlined in the CISA, EPA, and FBI Top Cyber Actions for Securing Water Systems Fact Sheet to further reduce cyber risk and improve resilience against malicious cyber activity.

The U.S. EPA requests that the Water Sector Coordinating Council (WSCC)/Government

Coordinating Council (GCC) review this advisory and pass it along to all water & wastewater entities that may be susceptible to this threat. Additionally, we encourage the EPA Regions share the advisory with the state primacy agencies and direct implementation utilities.

Water and wastewater system owners and operators should direct their IT/OT system

administrators to review this alert for further use and implementation. If you rely on third party vendors for technology support, then you are encouraged to contact them to confirm their awareness of this threat. Organizations are encouraged to report information concerning suspicious or criminal activity to FBI Internet Crime Complaint Center (IC3) at IC3.gov or to CISA via CISA’s Incident Reporting System. If you have questions about any of the information contained in this document, please contact the Water Infrastructure and Cyber Resilience Division, Cybersecurity Branch at watercyberta@epa.gov.

Stay Informed

If you are interested in subscribing to receive security alert notifications immediately upon release, please sign up using this form and select the topics that interest you. This topic is General - Security updates - Water and wastewater systems.

➽ WQCD Security Workgroup

Aqua Answers: Bag and Cartridge Filters in Surface Water Treatment

Dear Aqua Answers,

I’m the operator for a surface water treatment system that uses bag and cartridge filters, and I have a few questions!

___________________________________________________________________________

Question 1: What’s the difference between compliance filters and other bag or cartridge filters at my plant?

For suppliers of surface water or groundwater under the direct influence of surface water (SW/GWUDI), the treatment system must be designed to meet the requirements of Section 11.8 of Regulation 11, also known as the Surface Water Treatment Rule (SWTR). This rule requires the treatment process to remove specific levels of Giardia and Cryptosporidium to ensure public health protection.

One way to meet these requirements is by using bag or cartridge filtration. These filters use a straining process where water passes through a disposable bag or cartridge housed in a permanently installed filter housing. Each filter and housing combination used for compliance filtration must be approved by the Colorado Department of Public Health and Environment (the Department) through the alternative technology approval process. Typically, this approval is obtained by the filter manufacturer rather than through a site-specific approval.

Every installation of bag or cartridge filters at a public water system (PWS) must also be reviewed by the Department as part of a design submittal.

Additional filters, sometimes called “roughing filters” may be installed upstream of the compliance filters. These do not require separate Department alternative technology approval but usually still require review as part of the design submittal.

For more details on design requirements, see the State of Colorado Design Criteria for Potable Water Systems (DCPWS), Section 4.3.9.

Question 2: How do I know which cartridges or bags I should use in my compliance filters?

Many SW/GWUDI suppliers have been issued a Record of Approved Waterworks (RAW) that lists all the supplier’s approved treatment and storage facilities and water sources. To find your facility’s RAW, visit the Department’s RAW webpage and enter your PWSID or facility name.

If you don’t have a RAW, you can find this information in the approval letter issued by the Department for your filtration system, or you can contact the Engineering Section for assistance.

Your RAW (or approval letter) will specify the approved filter manufacturer, model number, and the Department’s alternative technology acceptance letter. You can find the acceptance letter on our drinking water alternative technology website.

Important: Many bag and cartridge filters on the market have not been approved by the Department. Using unapproved filters or filter/housing combinations for compliance filtration can result in a treatment technique violation or a significant deficiency noted during a sanitary survey—both of which would require the supplier to issue a public notice.

Question 3: I have a sanitary survey coming up. Is there anything I should know about my bag or cartridge filters?

Yes! Suppliers using alternative filtration technology must continuously meet the design, performance, and operation and maintenance requirements in Sections 4.3.9.6 – 4.3.9.8 of the DCPWS and in the Department’s acceptance letter for the specific filtration technology.

For bag and cartridge filtration systems, this typically includes:

• Not exceeding the maximum specified pressure differential.
• Keeping daily records of pressure differentials and filter change-outs. These records will be reviewed during the sanitary survey.
• Maintaining specific spare parts on-site, which may also be checked during the survey.

Be sure to review your RAW and acceptance letter to understand all conditions of approval and ensure you’re keeping the required records. Both your RAW conditions and site-specific records will be evaluated during the sanitary survey.

Question 4: I’m a contract operator managing multiple public water systems. Do the requirements for bag and cartridge filters differ by system type?

Yes, the requirements can vary based on system size and type (e.g., community, non-community, or transient systems). These differences may include NSF 61 certification, the number of redundant filters required, and other system-specific considerations. The DCPWS outlines these requirements in detail, but if you have any questions, please reach out to the Department’s Engineering Section for assistance.

Sincerely,

Aqua Answers

Being prepared for toxic algae season

As climate conditions continue to shift, Colorado has seen increasingly warm and nutrient-rich waters during the summer months — conditions that remain ideal for toxic algae to form in standing or slow-moving water. Toxic algae or harmful algae blooms (HABs) are made up of cyanobacteria, commonly known as blue-green algae. Although these organisms naturally occur in Colorado waters, they become a problem when they multiply rapidly, resulting in a dense cyanobacteria concentration or “bloom.” In drinking water sources, cyanobacteria blooms can cause the water to taste or smell bad. Taste and odor in drinking water is not regulated but creates customer concerns about water quality and safety. Most complaints that water utilities receive are about taste and odor, and these issues can last for prolonged periods. In addition to taste and odor problems, the blooms can become harmful and create a public health risk when they produce toxins. Removing toxins in a safe and cost-effective way can be a challenge for treatment facilities, and not all water providers are equipped to do so. 

Drinking water providers can contact the Water Quality Control Division at 303-692-3500 with questions about toxic algae. We can help water providers who experience taste and odor problems and toxins. This includes ideas about customer communication and steps that utilities can take to monitor and manage toxic algae and best treat their drinking water. If you detect microcystins above 0.3 μg/L and/or cylindrospermopsin above 0.7 μg/L (EPA’s cyanotoxin health advisory values), call the CDPHE 24-hour incident reporting hotline at 1-877-518-5608 so the division can provide you with immediate assistance.

We have resources to help drinking water providers and recreational water managers with toxic algae monitoring, response and public education and created a map to show recent toxic algae conditions for select waterbodies in the state. 

This 2019 AquaTalk article remains especially relevant today as cyanotoxins still pose a public health concern, even without being formally regulated. While EPA is continuing to evaluate the need for national regulation, the core takeaways from past events like Salem, Oregon’s microcystin advisory remain vital reminders for proactive communication, monitoring, and response. Whether you manage a public drinking water system or recreate on Colorado lakes and reservoirs, this piece offers timeless lessons for navigating toxic algae season safely.

Program Manager Message: An Open Letter to the Drinking Water Community - An Opportunity to Say THANK YOU!!!!

Hello everyone, 

In the May 2008 issue of Aqua Talk we ran an open letter of thanks to the drinking water community after the waterborne disease outbreak in Alamosa, Colorado. We have not had a waterborne disease outbreak at a public water system in Colorado in the 17 years since. We thought it would be a good time to rerun this article as a reminder of what happened and how the water utility community came together in response. We have had some disease outbreaks from drinking water, but they have happened in buildings or other situations that did not involve regulated systems. The Alamosa event was the first use of the Colorado Water and Wastewater Response Network (Co-WARN), which has been used many times since 2008 by utilities in need, and those needs have been met by other utilities. So, I say again - THANK YOU!

Article from May 2008: 

In March, the Water Quality Control Division in conjunction with numerous emergency response agencies and city of Alamosa officials were deeply involved in responding to a waterborne disease outbreak within the community. While a definitive identification of the cause has not yet been determined and investigative activities are ongoing, I want to take this opportunity and use this forum to tell everyone involved...Thank you!!

The city of Alamosa and the division could not have accomplished what they did without the assistance and dedication of all the agencies, groups and individuals involved with this response. The request for resources was placed to public water systems though our COWARN network, and the response was overwhelming and immediate. As new resource needs were identified, requests were made, and the resource materialized. Events and circumstances constantly evolved, and the response of the drinking water community was unwavering.

The boil/bottled water order was in place for 23 days and had an impact on the entire community of approximately 9,000 citizens. A staggering amount of work was accomplished within those 23 days including the following:

• An evaluation of the distribution system, including a review of potential cross­ connections.
• A multi-staged systematic disinfection and flushing of the storage tanks and entire 49 miles of distribution piping.
• Extensive monitoring for a number of water quality parameters throughout the distribution system including Salmonella, total coliform, Giardia, cryptosporidium, arsenic, lead and copper, and chlorine residuals.
• The Consumer Protection Division worked with restaurants and other businesses to keep many of them operating during the event.
• Bottled water and bulk water was distributed to residents.
• Communications personnel made substantial public notice efforts with the media to keep people informed.

The drinking water community should be proud of its response.

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

Coaches Classroom: How to Take a Water/Wastewater Operator Certification Exam?

Did you know that to become certified as a water/wastewater professional in Colorado or to take an exam to obtain a higher certification, you will work with a company called Professional Service Industry (PSI)?

As mentioned in previous Aqua Talk articles (4/2/25 article, 10/30/24 article), to become a certified water professional, you will first determine which certification you need and then work within the Colorado Certified Water Professionals (CCWP) portal to submit an examination application. Once CCWP approves the exam application, applicants have 100 days to sit for and pass the exam. If an applicant doesn’t pass the exam, they may schedule a re-test at any time, however, the operator must wait 30 days to retake the exam.

Notes on working within PSI’s website

After you receive your application approval from the folks at CCWP, you will receive an email from PSI letting you know that you can now create a login and schedule your exam. You can follow the link and instructions provided in the email. Once you have logged in, select “New Booking” if you need to schedule your exam or “Reschedule” if you need to move the date you originally planned to sit for the exam. 

This will take you to a list of tests you are eligible to schedule based on your exam application through CCWP. 

What if I have issues with my PSI account? 

PSI customer service is best accessed through their “Contact Us” email form. To access this, click on the “Contact Us” icon in the upper right-hand corner of the screen. Be sure to provide the correct email address and phone number for them to reach you and a clear explanation of the issue you are encountering.  You can also visit their Quick Start Guide website, which offers specific information on how to navigate their platform. 

Additional tips and good information: 

• Where/how do I take an exam: You can either go to a testing center (Find a Testing Center) or use PSI’s remote proctoring option (PSI Online Proctoring Compatibility Check) to take your certification exam. Be sure to know the rules and expectations before you choose which option is best for you. More information can be found on CCWP’s website or in PSI’s Candidate Handbook for Colorado. 
• Plan accordingly! Winter weather can greatly impact travel to test centers, and PSI may not issue refunds due to inclement weather. Consider contacting PSI to verify your test center is open before you travel. 
• The CCWP exam application fee is $50; the PSI examination fee is $104 per exam attempt. All payment for the exams is managed through the PSI portal. 
• Formula sheets - Please note there are two formula sheets, one for water and one for wastewater. It's the test-taker’s responsibility to be sure that the proctor gives them the correct formula sheet.
• Test takers cannot leave the testing site with notes or scratch paper.
• CCWP is happy to help all operators as they become certified and advance in their profession. However, the CCWP staff does not have access to PSI's system nor can we help with remotely proctored tech support.

What resources are available to help me study for my exam? 

PSI does a great job at proctoring exams for Colorado’s certified water professionals, but they don’t provide the testing materials. CCWP contracts with Water Professionals International (WPI) to write and standardize exams. So, to study, we recommend visiting WPI’s  Examination Study Resources website. Here you can  access important information that will help you plan your studying process: 

• Need-to-Know Criteria
• Formula/Conversion Tables
• Exam References
• Study Guides
• Sample Exam Questions

Once you know what information you need to study and how the questions will be asked, you can form a study plan that is right for you! Below are some examples of helpful resources. This is by no means an exhaustive list. We recommend that you mix a variety of study materials! 

1. Textbooks 
• Sacramento State Drinking Water Manuals
• New Mexico Water System Operator Certification Study Manual
• American Water Works Association - Operator Cert and Training Textbooks 
• USA Bluebook Water/Wastewater Training Books (textbooks, flash cards, and math-specific offerings)  
2. Courses 
• Technical Assistance providers in Colorado that offer in-person and online exam preparation: 
• Colorado Rural Water Association 
• Indigo Water Group 
• Rural Communities Assistance Corporation 
• Other prep courses 
• American Water College Exam Prep courses 
• AWWA Remote eLearning Options
3. Other resources 
• Water Sifu - online training resources with videos and podcast-style training
• AWWA OpCert Exam Prep App  - flashcard style sample test questions that immediately display the correct answers and explanations, including formulas/equations 
• Water Wise Pro - Company offering online training via Zoom,  study guides, and helpful podcasts for operators  
• Kentucky Energy and Environment Cabinet - Water Certification Test Prep Materials 
• Michigan Department of Environment, Great Lakes, and Energy - Exam Study Guides with practice tests and answer keys 

Please don't ever hesitate to reach out to our coaches! 

➽ Kyra Gregory, Drinking Water Training Specialist 

PFAS Rule and CCR Revisions: Update on Stakeholder Engagement on Rulemaking

In Spring 2024, EPA finalized the Per- and Polyfluoroalkyl Substances (PFAS) Rule and Consumer Confidence Report (CCR) Rule Revisions. The PFAs Rule will protect public health by requiring ongoing monitoring of “forever chemicals” beginning in 2027 and setting health-based limits starting in 2029. The CCR Rule Revisions modernize the content and delivery methods for all community systems and increases the frequency and accessibility of water quality reports for consumers served by larger systems beginning in 2027. 

In August 2024, the division launched a stakeholder engagement process in support of a rulemaking hearing before the Water Quality Control Commission to adopt these federal rules into the Colorado Primary Drinking Water Regulations (Regulation 11). Between August 2024 and January 2025, we held a total of seven stakeholder meetings and two workgroup meetings in support of the stakeholder process. We appreciate the significant contributions from water providers, environmental organizations, and members of the public. This collaboration is essential for developing effective and sustainable regulations that address the specific needs of our state.

Through the stakeholder process, we have:

• Developed Draft Regulatory Language: The feedback received from stakeholders has directly informed the development of draft language for the upcoming PFAS Rule and CCR Rule Revisions. 
• Created PFAS Rule Resources: To aid water providers in navigating the complex requirements, we have developed a PFAS Rule page with guidance and a frequently asked questions document, an initial monitoring compliance check worksheet to help understand the timing requirements for monitoring, and are in the process of developing tools to allow submission of UCMR 5 PFAS data for use in meeting initial monitoring requirements.
• Updated CCR Content: While most content changes under the CCR Rule Revisions are not required until 2027, there are a few changes to CCRs distributed in 2025 required under the Lead and Copper Rule Revisions. The division has updated CCR draft templates for 2025 to capture the language and content required to be included in CCRs.

Looking ahead, the next major milestone is the rulemaking process before the commission. This is a crucial stage where the commission will review the draft regulations, consider public input, and ultimately make a decision on whether to adopt these rules into Regulation 11.

Important Note: There has been some recent developments at the federal level. EPA has been granted abeyances by the DC Circuit Court concerning lawsuits regarding the federal PFAS Rule. These abeyances were granted to allow the new administration time to review the rule and the plaintiff’s petition to the Court. On May 14, 2025, EPA announced that it was considering delaying compliance with the PFAS standards but no specific mention was made about the testing requirements. We are actively monitoring this situation and will provide updates as they become available. None of this impacts the CCR rule. 

We recognize that navigating these regulations can be complex. Therefore, we are committed to keeping you informed throughout the process. We will provide updates on the rulemaking process and opportunities for public comment.

How to Stay Informed:

• Visit the Division's Engagement Website and sign up for notifications
• Attend Commission Meetings: Commission meetings are open to the public, and your participation is encouraged. For more information about upcoming meetings and hearings please visit the commission's website.

We believe that everyone plays a vital role in shaping water policy. By staying engaged, we can collectively work towards ensuring clean and safe drinking water for all Coloradans.

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

CDPHE, EPA, & Wigwam Partnership for PFAS Treatment

Resources: 

For more information please visit 

• CDPHE PFAS Proarjects Website
• WQCD Grant Website

The Colorado Department of Public Health and Environment (CDPHE) is excited to highlight Wigwam Mutual Water Company’s PFAS pilot project as an excellent example of the Division’s culture of health initiatives. Wigwam is a small public water system, located in El Paso, County just south of Colorado Springs, that serves approximately 1,300 people. Their source water is drawn from the Fountain Creek alluvial aquifer and through pro-active testing the public water system detected elevated levels of certain PFAS in its drinking water. The test results came back above the established EPA Maximum Contaminant Level (MCL) of 4.0 parts per trillion (ppt) for Perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). To address this emerging contaminant issue, CDPHE provided the community with point-of-use treatment to reduce PFAS levels to below the MCL while working towards the implementation of a more permanent treatment solution. This effort was promoted to ensure the community was provided with safe drinking water during the next planning and design phases of the project. 

Last year, CDPHE awarded Wigwam a $300,000 grant to pilot PFAS treatment technologies through the Emerging Contaminants in Small for Disadvantaged Communities (EC/SDC) grant program. This project has been a collaborative approach with direct assistance from the CDPHE, PFAS team and Engineering staff, the Environmental Protection Agency (EPA), and the EPA’s Office of Research and Development (ORD). Wigwam is planning to conduct pilot testing with Granulated Activated Carbon (GAC), Anion Exchange (AIX), and a new emerging technology, namely Electrocoagulation (EC). This innovative pilot project will compare the different treatment technologies and assist Wigwam in determining if the new EC technology is feasible and able to effectively treat PFAS in its drinking water. This collaborative approach will help ensure that this community has the best information to help them find a viable treatment solution to address this water quality challenge. After the study, EPA and CDPHE will utilize the treatment piloting results to provide an assessment of the treatment options for communities in order to effectively remove PFAS and other contaminants with reasonable and sustainable costs. 

CDPHE is excited to promote the partnership between EPA ORD and Wigwam to assist in this effort.

➽ Sierra Mitchell, PFAS Program Coordinator

PM Message: Addressing High Nitrate Levels in Groundwater

Last month I attended the annual member meeting of the Association of State Drinking Water Administrators (ASDWA) in Washington, D.C. This group consists of all my counterparts in other U.S. states and territories. It is a great opportunity for me to learn about how other states are working to address similar challenges to what we may be facing in Colorado. This year three states, Wisconsin, Minnesota and Nebraska, shared information about what they are doing to address high nitrate levels in groundwater. Significant portions of these states experience this problem that impacts both community and non-community groundwater systems, plus private wells. Nitrate is known as an acute health risk contaminant for infants. However, more research is being done about chronic impacts as well.

Though our nitrate concerns in Colorado tend to be more localized, we have had a number of water systems exceed the nitrate Maximum Contaminant Level (MCL) of 10 mg/L over time as well. In the 2010s almost 50 communities had a nitrate MCL violation and 65 non-community water systems also had nitrate MCL violations. Fortunately, those numbers are considerably lower so far in the 2020s. A nitrate MCL violation represents a serious challenge for those systems as immediate Tier 1 public notice must be provided advising customers to stop drinking the water. Addressing this issue can be time consuming and expensive. If treatment is needed then ion exchange or reverse osmosis is typically used, which requires a higher level operator for the system and creates a concentrated waste that must be handled and disposed of as well on top of all the added cost for the treatment infrastructure.

Given these concerns, I thought I would share a brief summary of this issue in these states and some of the steps they are taking to address this challenge

Wisconsin is “America’s Dairyland” and #2 state in the country in growing potatoes, which is a nitrate intensive crop. Ten percent of its 800,000 private wells exceed the nitrate MCL which would cost over $400,000 million to replace those wells. Wisconsin public water systems receive 30 to 40 new nitrate MCL violations every year, dwarfing our problem in Colorado. While there is a sense that this problem cannot be fully “solved” in the near future, Wisconsin is taking numerous steps with many partners and projects help with it. Most of these efforts come from their source water protection protection program and include:

• Teacher workshops through universities educating kids about groundwater with specific lesson plans and hands on models
• Nitrogen budget and leaching calculator
• Decision tools that can evaluate application rates
• Developed a well water quality map view with largely private well data
• Evaluating nitrate depth guide drilling to often deeper unimpacted locations
• Numerous projects with with farmers and universities
• Replacing wells

In Minnesota corn and bean crops are main nitrate sources and the southeastern portion of the state with its karst geology is most vulnerable to contamination. Minnesota has fewer violations than its neighbor but last year, 60% of those water systems had to install treatment. Minnesota enacted a new groundwater protection rule that limits fall fertilization applications and is working on a mitigation process in vulnerable areas. The state also developed a number of programs designed to help private well owners and developed simple communication materials. These efforts involve: 

• Well inventory including private wells
• Substantial Outreach/communications including realtors
• Free nitrate testing
• Free treatment available, with 140 reverse osmosis systems installed
• Health-based guidance including:
• New studies showing nitrate association with numerous conditions
• Historical information regarding blue baby syndrome cases in the 1940s

Nebraska recently commissioned a study of nitrate in groundwater showing large areas of the state with nitrate levels above 10 mg/L. They have about 170 public water systems currently  treating for nitrate. Nebraska developed a predictive model to predict how far away a system might be from having a source that exceeds the nitrate MCL and categorized the systems with certain actions:

• 0-3 years out = get started on funding applications
• 3-6 years = provide assistance
• >6 years = Emphasize source water protection

Nebraska offered free testing to private well owners and a rebate program for reverse osmosis treatment systems. They also developed an outreach toolbox with an emphasis on risk assessment.

In Wisconsin and Minnesota EPA got involved to pressure the states to take action to address this acute health risk, and also partnered with the states in the efforts to address it. As you can see, tackling this challenge requires a great deal of effort. I am thankful that we can draw on the experiences in these states to help us when we face similar issues in Colorado. Thank you for your efforts in keeping our drinking water safe.

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

Nominate Someone for the Walter A. Weers Award!

In the past, the Water and Wastewater Facility Operators Certification Board (board) annually issued the Walter A. Weers Outstanding Achievement Award to honor individuals who have made outstanding contributions to the Colorado Water and Wastewater Facility Operators Certification Program (program) and to the water professionals operating facilities under the program.     

You can find more information about this award on the board’s website, as well as a link to the nomination form, submission instructions, and previous recipients. 

The award is named after Walter A. Weers, who devoted a half-century of outstanding volunteer service to the advancement of the certification of professionals in the Colorado water and wastewater industry. The award is intended to honor truly exceptional contributions and may not be presented each year or may be awarded to more than one recipient per year (at the discretion of the board). The award was last presented in 2019, and the program would like to raise awareness of this award in hopes of honoring an individual in 2026. 

This outstanding achievement award recognizes those individuals who:

• Have given their time unselfishly to educate operators,
• Have provided their expertise to the examination of operators, or
• Have used their creativity and tenacity to build Colorado’s certification program into one of the premier programs in the country. 

Anyone who has had a direct impact on the program and the water professionals operating Colorado facilities under this program can be nominated for this award. Nominations must be submitted before October 15th of each year to be considered and acted on by the board at its November meeting. If the board decides to honor an individual, the award will be presented in conjunction with the Colorado Rural Water Association (CRWA) annual conference in March of the following year. 

Consider taking a few minutes of your time to submit an award nomination that can inspire others to continue providing outstanding service to the program and to highlight the importance of the profession and its impact on Colorado communities. Anyone can submit a nomination form, and nominations can be as short as one to two paragraphs. You never know what great acts of service and kindness you may inspire!   

If you have any questions about this award or the nomination process, feel free to contact Jessica Morgan - cdphe.facilityoperator@state.co.us. 

➽ Jessica Morgan, Liaison to the Water & Wastewater Facility Operators Certification Board

Operator Exam Satisfaction & Feedback Survey - We want to hear from you!

At the Colorado Rural Water Association (CRWA) annual conference in March 2025, the Colorado facility operator certification program distributed a survey to gather feedback from Colorado operators about their exam experiences. For those of you who were unable to attend, we’d like to share the survey to gather your feedback. 

Click here to access the survey. 

Your responses will help the program identify trends and areas for improvement. All answers are completely anonymous and will be reported only in aggregate, meaning that individual answers will not be identified or linked to any specific participant. The data will be presented as a group to ensure privacy and confidentiality. 

The results of this survey will be shared with the responsible parties, and a sub-committee will review the feedback to make recommendations to the Water and Wastewater Facility Operators Certification Board for improving the exam process. Additionally, these insights will play a crucial role in shaping the decision regarding the adoption of the 2025 operator certification examinations.

We value your input and appreciate your honesty in helping us enhance the exam experience for everyone!

If you have any questions, feel free to contact the facility operator certification program at cdphe.facilityoperator@state.co.us. 

➽ Jessica Morgan, Liaison to the Water & Wastewater Facility Operators Certification Board

Backflow Device Testing and HB25-1077

In January and February 2025, the Water Quality Control Division (WQCD) provided testimony to the Colorado legislature in support of HB25-1077 that would allow certified cross-connection control technicians to inspect, test, and repair backflow prevention devices as they had up until the 2024 Colorado legislative session. House Bill 24-1344, which became effective on July 1, 2024, included a change that required licensed plumbers to inspect, test, and repair backflow prevention devices. The WQCD received widespread concern from public water systems and certified cross-connection control technicians about the legislation. CDPHE Executive Director Jill Hunsaker Ryan sent a letter to the Colorado State Plumbing Board requesting that the Board prioritize public health by delaying disciplinary actions against certified cross-connection control technicians (who are not licensed plumbers) that test and repair backflow prevention devices, per longstanding practice. The letter also underscored the risk to public health, as it is estimated that approximately 200,000 devices are subject to Regulation 11, but there are only 2,400 certified cross-connection control technicians in Colorado, and only approximately 20% of these certified technicians are also licensed plumbers. An estimated 20% of existing devices fail testing on average, and 80% of new devices fail testing due to remnants such as teflon tape and plumbing putty. Failed devices can allow water systems to become contaminated, which underlines the importance of this overall effort. The State Plumbing Board responded to the request in July 2024 by issuing a temporary enforcement policy to allow the administrative dismissal of complaints against certified cross-connection control technicians until April 1, 2025. In February 2025, the State Plumbing Board extended the temporary enforcement policy until June 1, 2025 (policy statement dated February 26, 2025 at Section 2.4.9).

Amendments to HB25-1077

Two amendments were presented to and passed by the House Committee on Business Affairs & Labor. Amendment L.002 establishes that installations of backflow prevention devices on stand-alone fire suppression systems would not require a licensed plumber. Amendment L.004 requires tagging of devices with certain information when services are performed, starting on July 1, 2025. This requirement applies when licensed plumbers install, test, inspect, repair, or reinstall backflow prevention devices, as well as when certified cross-connection control technicians or licensed plumbers with a cross-connection control technician certificate test or repair a backflow prevention device. The amendment also specifies information that must be included on the tag: the name and contact information for the business, the date the service was provided, a description of the service, and the ASSE or ABPA certification number of the cross-connection control technician. If the certified technician who performed the service is also a licensed plumber, the tag must include the plumber’s license number, along with the plumbing contractor’s registration number or the license number of the master plumber attached to the contractor.

What does this mean for my water system?

Consistent with Section 3 of Amendment L.004, the WQCD does not intend to perform inspections or enforce the tagging requirements. WQCD Field Services inspectors frequently observe testing tags on backflow devices while conducting sanitary surveys; however, we also recognize that tags can be removed or fall off. Upon HB25-1077 becoming law, CDPHE encourages water systems to check that the licensed plumbers and certified cross-connection control technicians are complying with the tagging requirement as they have their own devices in water treatment plants and other facilities serviced. 

What happens next?

HB25-1077 was signed into law by Governor Polis on March 28, 2025 and the bill can be seen here. This is a major win for safe drinking water in Colorado. Water suppliers are encouraged to continue to implement their Backflow and Cross Connection Control Programs (BPCCC) utilizing certified cross-connection control technicians to test and repair devices to ensure they are protecting the public. For any questions or concerns about BPCCC please email our Field Services team at cdphe_wqcd_fss_questions@state.co.us. Thank you for all your efforts to protect public health!

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

Go with the Flow: Your Guide to Becoming a Certified Water Operator

Imagine you are a small business owner operating a water system that is located in a remote area of Colorado, away from major population centers. You have a certified water operator running your water system, and you’re planning on opening another business, but your trusted contract operator just told you that they cannot take on any more work. You got to thinking - maybe we can move operations in-house? What would it take to get someone on my team who lives in the area certified as a water operator? Here’s what it takes!

Remember, proper operation of a water system is vital to protect public health. It takes considerable knowledge and skills, but these can be gained with a reasonable amount of time and effort. On average, it takes about 6-12 months to become certified, depending on how much time you can invest in the process. This article includes the following information relevant to becoming a certified operator in Colorado:

1. Regulations governing drinking water (DW) and wastewater (WW) operators.
2. Obtaining an operator ID from the Colorado Certified Water Professionals (CCWP).
3. Minimum qualifying experience.
4. Training resources to prepare for an operator certification exam.
5. Training Units (TUs).
6. Operator certification exam.
7. Compliance assistance - CDPHE’s Drinking Water Portal, sampling and resources.

1. Regulations governing drinking water (DW) and wastewater (WW) operators

Regulation 100, Water and Wastewater Facility Operators Certification Requirements,  specifies the pertinent information about being an operator, including owner & operator duties, facility classifications, certification qualifications, education, experience, and fees. Colorado-certified operators are subject to the Colorado Certified Water Professionals Code of Conduct and are also responsible for being knowledgeable of the Water and Wastewater Facility Operators Certification Board (board) Policies and Guidance documents, which you can find on the board’s website. 

If you are thinking about becoming a drinking water operator, you will want to develop an understanding of Regulation 11. This document houses the state of Colorado’s primary drinking water regulations. It is not expected that you memorize this information, however, this regulation is a good resource to understand why requirements are put into place at specific water systems. 

2. Obtaining an operator ID from the Colorado Certified Water Professionals

After reviewing the above information, your first step will be to create a Colorado Certified Water Professionals (CCWP) Portal account and obtain an Operator ID number. The instructions on how to do so and how to apply for certification and sit for an exam can be found on CCWP's website. You can also find helpful videos on operating the CCWP Portal. 

If you need assistance setting up your operator account in the CCWP Portal or entering your information into your portal account, please contact CCWP at (719) 225-7339 or info@coloradocwp.com.

3. Minimum qualifying experience

Applicants for entry-level certification examinations (Class D, Class 1, or Class S) must satisfy a one-month experience requirement or the successful completion of an approved training course of study that is designed to prepare the operator to operate Class D or Class 1 facilities. Per 100.14.5(k)(i), Regulation 100, experience needs to be obtained under the supervision of a certified operator in responsible charge.

The division provides other free training opportunities that include various online options. You can also find several other training providers in Colorado that provide approved courses by simply Googling "water operator training Colorado." All approved courses can be found in the Course Catalog, and you can also filter for those courses that have been "Approved for regulatory water training" and "Approved as substitution for entry-level operating experience." All individuals seeking their professional water operator certification are required to have either 30 days of relevant operational experience, or the substitutive educational credit. The CCWP portal will allow you to calculate your relevant experience and educational hours to determine that you have met the requirements. Please reach out to CCWP if you have any questions about this process.

4. Training resources to prepare for an operator certification exam

The CCWP Need to Know Criteria Page contains information on the exam and study resources to prepare for your exam. It is recommended that you work in the CCWP portal and contact the CCWP office to see how your previous work experience translates. CCWP staff are extremely knowledgeable and more than happy to assist in understanding the portal application process or to answer any questions on whether information is being accurately represented on an application.

The CCWP’s Certification Exam Guidance outlines the certification requirements necessary for becoming an operator.  It covers the education, training, exam review process, and exam procedures. Be sure to identify what level of certification your facility will require. If you are a small business owner, many small systems may require a Class “D” treatment certification & Class “1” distribution system certification, which would mean you will be applying for entry-level certification. Depending on the population served and treatment & distribution requirements, you may also be able to obtain a Class “S” or small systems certification per regulation 100.10.5 (d).

Some free resources for training and exam prep include: 

• EPA training system on Drinking water
• EPA Resources for small systems
• WaterOperator.org
• Water Professionals International 
• CDPHE offered free training courses 
• WPI exam prep website
• Sacramento State Drinking Water Manuals
• New Mexico Water System Operator Certification Study Manual

There are some at-cost options for training as well, such as the American Water Works Association (AWWA), which has an operator certification exam prep app to prepare for the examination.

5. Training Units (TUs)

Certified operators are required to obtain Training Units (TUs) to obtain their initial certification; they are also required to meet continuing education requirements to maintain each certification. To determine the appropriate number of training units required for certification renewal, please refer to table 100.16.7 provided in Regulation 100. 

You will be required to sit for a Mandatory Regulatory Training (MRT) course to apply for a certification.  Once you have your Operator ID. The CDPHE has contracted with Indigo Water group, you can also take the free, on-demand virtual Mandatory & Regulatory Training courses by following the instructions provided on the MRT website. 

6. Operator certification exam

Once you have met all of the certification and training unit requirements, and you feel adequately prepared to take the exam, schedule your exam at one of the ten locations or online. You will get a registration email from CCWP for this step. The exam will take the better part of the day, but you worked so hard to prepare, so don’t be nervous. You can do it!

This handbook for Colorado candidates breaks down all of the expectations for taking the exam. You can find additional information from CCWP about the exam process here. 

7. Compliance assistance - CDPHE’s Drinking Water Portal, sampling, and resources

You will want to be familiar with the CDPHE's Drinking Water Resources for Water Systems page. This page houses many of the links that you will find yourself regularly using in your interactions with the state. The Compliance Assurance page can help you find your Compliance Specialist for your water system, sign up for a Drinking Water Portal account, and find guidance for a variety of topics. The Drinking Water Portal is where you will submit all of your water systems’ documentation to the state. Your compliance specialist is your direct contact at the State for all things drinking water regulations and can help you with any questions you may have. We’re here to assist you!

Another important page is the monitoring schedule page, which outlines all required testing for your water system. This is where you can check if your sample results have been received or if there are any upcoming deadlines for your water system. Since your primary duty as an operator is collecting and reporting samples, here is a list of certified laboratories approved for testing and information on appropriate sample reporting to the state. You can find many other resources on operator certification in our Aqua Talk Articles.

If it's the right time for you or someone on your team, we salute the choice to become a member of the respected certified operator community and wish you the best of luck as you navigate this new challenge. We welcome you as you take on a new role in helping us meet our public health protection mission and helping assure that drinking water is always safe.

➽ Leah York, Drinking Water Compliance Specialist

➽ Lisa Pietrangelo, Drinking Water Compliance Specialist

Small Victories - Our Culture of Health in Action!

Culture of Health in the drinking water industry means that we look at our daily routines and emergencies through a lens of protecting people’s health. We are an industry that works 24 hours a day to provide safe drinking water to everyone, and crucially to maintain societal functionality for sanitation and fire fighting. As we continue to promote our culture, we would like to share with you small examples that demonstrate how we put our culture into action! 

Newly Regulated Water System

Recently, we identified a newly registered public water system that was not disinfecting. The water system had indicated to the department that they would not be installing the disinfection system until they received approval from the department for the permanent design. Representatives of the water system reached out to the department to inquire if they could remove the two bathroom sinks in order to not provide human consumption and therefore not be regulated. While the department does not enforce the plumbing code, we are aware that not having sinks in the bathroom could create other sanitary health risks. We worked with the local public health officials and the city having jurisdiction to evaluate the situation further. We notified the water system that if the bathroom sinks were removed, the facility would be in violation of local building codes by not providing running water for sanitation in the bathrooms. The system decided to not remove the bathroom sinks. They installed the chlorination system and added a barrier to help lower bacterial contamination risk in their system. This is a small example of how we utilize our resources and partner with everyone involved to make sure that our water systems are well-informed. 

Broken Well Casing

During a sanitary survey, one of our inspectors identified that a water system's well was leaking significantly. The well cap was split open where an active electrical connection was penetrating the cap. The well was cycling every two minutes, causing water to pour out of the cap every time the well ran. The well pad and well cap was covered with water, algae, and leaves. When the well was not pumping, it was possible that water containing contaminants could leak back into the casing. This led to a concern that contaminated water could be entering the protected groundwater source. 

Our inspector referred the findings to our acute drinking water response team and coordinated with our compliance assurance section to evaluate the situation and identify a path forward. The system prioritized the well casing repair. However, we wanted to identify if there was an imminent health risk present. We requested that the system provide bacteriological samples from the source and at the entry point, increase the chlorine residual, and that the leak be addressed as soon as possible especially given an upcoming inclement sub-zero weather event. The next day, we followed up with the system to confirm that they had collected their samples as they were working to identify a repair contractor. All of the bacteriological samples came back absent for coliform and the water system repaired their casing very promptly. While the regulations officially allowed for a longer timeframe to respond, this quick action by everyone involved aligned with our culture of health and helped minimize risk to the public. 

➽ Drinking Water Compliance Team

Fluoride: A public health benefit and the role of the CDPHE

The Centers for Disease Control and Prevention (CDC) named fluoridation of drinking water one of the 10 great public health interventions of the 20th century. Since 1945, when the addition of fluoride to drinking water began, there has been a dramatic decline in tooth decay among children and reduction in tooth loss among adults. At optimal levels, water fluoridation improves the oral health of all residents, regardless of dental insurance coverage, access to health care, age, gender, income, race or ethnicity. 

What is drinking water fluoridation? 

Drinking water fluoridation is the adjustment of fluoride to an optimal level in accordance with scientific and dental guidelines. The US Public Health Service (PHS) has determined a fluoride concentration of 0.7 mg/L as the optimal concentration of fluoride in drinking water that maximizes fluoride’s oral health benefits while minimizing potential harms, such as dental fluorosis. Fluoride is a naturally occurring mineral present in varying amounts in almost all soil, water, plants and animals and a normal constituent of many diets. Naturally occurring levels of fluoride in drinking water sources are often too low for the benefit of cavity prevention and so water systems have the choice to add fluoride to the recommended optimal level. Water fluoridation is practical, cost-effective, and equitable for all members of the community. For every $1 invested by water systems in water fluoridation, Coloradans save an estimated $61 per person per year in dental care costs. Fluoride improves oral health by helping to prevent tooth decay through strengthening the tooth enamel and helping to remineralize tooth enamel lost to the acids in food and beverages. Fluoride also makes it harder for harmful bacteria to adhere to the teeth. Good oral health is an important part of good overall health and an essential part of our everyday lives. Diet, sleep, psychological status, social interaction, school and work are all affected by impaired oral health.

What is CDPHE’s role in water fluoridation?

The Colorado Department of Public Health and the Environment’s (CDPHE) Water Quality Control Division (WQCD) provides technical support to systems that add fluoride as part of their treatment process. WQCD also performs inspections of the fluoride treatment system as part of the sanitary survey process for regulated public water systems. WQCD performs these inspections under a “Memorandum of Understanding” with CDPHE’s Oral Health Unit (OHU) in the Prevention Services Division (PSD). Much like the monthly operating reports (MOR) surface water systems submit to show compliance with the Surface Water Treatment Rule, participating water fluoridating systems submit a monthly fluoride report to OHU for tracking optimal fluoride levels. CDPHE follows the PHS recommendation of 0.7 mg/L for the optimal fluoride level in drinking water. While water fluoridation in the state of Colorado is voluntary, the decision to add fluoride is held to the same drinking water standards; additives must meet NSF/ANSI standards, fluoride levels are monitored daily and reported monthly to OHU. 

The Environmental Protection Agency (EPA), through the Safe Drinking Water Act, has established national drinking water standards for public water systems. The EPA requires public water systems to comply with the maximum contaminant level (MCL) of 4.0 mg/L for fluoride in drinking water, with a secondary MCL of 2.0 mg/L. Public water systems that exceed the secondary MCL but are below the MCL are required to distribute public notice regarding the health effects of the elevated levels of fluoride. Recommended fluoride levels for the efficacy of cavity prevention are well below the EPA’s secondary MCL. A recent District Court case out of Northern California ordered the EPA to evaluate the public health risk of fluoride in drinking water under the amended Toxic Substances Control Act. Following the announcement of the Court’s opinion, the American Water Works Association, the American Dental Association, the American Academy of Pediatrics and the American Fluoridation Society have each reaffirmed support for optimal water fluoridation as safe, effective, and essential to the protection of the public’s health. CDPHE issued its own statement on October 14, 2024 in support of water fluoridation and will continue to review new and emerging research on water fluoridation.

For additional information about water fluoridation or further inquiries on the Court ruling, please reach out to the CDPHE OHU community water fluoridation program at cdphe.psfluoridationsmf@state.co.us.

➽ Aspen Coombs, P.E. WQCD Fluoride Liaison