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

Colorado Water Loss Initiative: Training and Technical Assistance for Water Loss Control

Water loss is water that is lost in a municipal distribution system between treatment and consumption. There are two types of water loss that lead to lost revenue and resources for systems and customers, real loss (leaky pipes) and apparent loss (metering inaccuracies, data handling errors). Real water loss typically occurs before any water meters, which are often located as the water enters buildings. This means that a utility is paying for all the cost of transporting the water from source to treatment plus treatment and distribution costs, but getting no revenue in return. 

Globally, water losses from drinking water supply networks account for 9 billion gallons a day of water use. Cost effective water loss management reduces cost and increases revenue, which improves a systems bottom line and better serves its customers. The Colorado Water Loss Initiative (CWLI) is a program developed by the Colorado Water Conservation Board (CWCB) that provides training and technical assistance to water providers. In November 2023, the Colorado Water Conservation Board instituted an annual water loss reporting requirement for systems supplying at least 2,000 acre feet of water per year to their customers. The CWLI was established to provide a comprehensive training program for systems as part of the Colorado Water Plan strategic objective to support water management activities for all water providers and drive water loss implementation to address future water needs.  The benefit to you, a training course on how to identify water loss, collect water loss data, audit and validate data, along with technical assistance to develop solutions to decrease water loss in your system. 

CWLI Training Program

The CWLI offers a training program to assist systems in learning the AWWA Free Audit Software and implementing the American Water Works Association (AWWA) M36 methodology to quantify water loss. Once systems have completed the data collection, auditing, and validation phase of training, they are then provided technical assistance opportunities to implement controls and tools to minimize water loss. Technical assistance can include activities such as meter testing and design analysis or billing data analysis and prorating. Grant assistance is available to program participants to remedy prioritized water loss interventions that were identified through the program.  

Who can benefit from the training?

All drinking water systems. Do you have a small system and aren’t required to report annual losses but still interested in water loss? No problem, small systems can benefit from the water loss program and are encouraged to register. Water loss best management practices can help all systems save water, money, prepare for water supply shortages, and prepare for future climate impacts. All systems will learn to take the appropriate steps toward effective water loss control management. 

How much is it? And where do I register for the program?

The program and materials are offered at no cost and are available to all eligible drinking water staff. See the below resources to learn more about the program

• Video interviewing participants about their experience
• CWCB Water Talk Podcast - CWLI staff discusses the program
• Register here for the program

Interested in helping to improve water loss control and management? Join the CWLI Committee!

The Colorado Water Loss Control & Management Committee was formally established in December 2023 by the Colorado Water Conservation Board. The committee's objective is to improve water loss control and management by planning water loss strategies, trade technical information, inform water loss policy discussions, train and educate water utilities on water loss, and support water loss goals of the Colorado Water Conservation Board. You can find more information at the Colorado Water Loss Control & Management Committee  website.  

➽ Angela Green Garcia, Drinking Water Training Specialist

➽ Kevin Reidy, DNR, Senior Water Efficiency Specialist 

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