Wildfire Response and Recovery Resources for the Water Sector

The Water Quality Control Division has resources available to assist your county, municipalities, communities, and water and wastewater systems through wildfire response and recovery processes. 

General resources

• CO - Post Fire Playbook: updated May 2025. 
• After the Flames: general community resource. 
• CoWARN: Use CoWARN if you need to, update your profile so you receive activations, and utilize the message board to discuss post-fire treatment issues, etc. 

Best practices to protect public health and comply with regulatory requirements

Communicate with the division if your water or wastewater system’s source water, collections system, treatment, or distribution system may be impacted by a wildfire. 

Non-emergency concerns for planning and response: 

• Drinking water - communicate with your compliance specialist. 
• Wastewater - communicate with the division’s Lead Wastewater Engineer - David Kurz  (303)692-6298.

Emergency concerns: 

• Immediate challenges with treatment, distribution, and collections, call the department’s 24-hour Incident Report Line - 1-877-518-5608
• Drinking water - Please consult the Pressure Loss Response Guidance for additional information on pressure loss/outages. 
• If any portion of your distribution system was burned by the fire, please consult the WQCD acute team regarding flushing, sampling, and potential advisories. Contact Lead Drinking Water Engineer, Chelsea Cotton, chelsea.cotton@state.co.us, and the acute team email inbox, cdphe.wqacutes@state.co.us 
• If any portion of your distribution system loses pressure for any reason, such as wildfire impacts to infrastructure, power outage or intentional shutdown due to evacuation, please call the department’s 24-hour Incident Report Line - 1-877-518-5608.
• If you are a surface water system and have filtration concerns, including but not limited to, if you are unable to meet your microbial removal or are getting close to exceeding your turbidity limits, following a wildfire, please call your compliance specialist. If you are calling outside of normal business hours please call the Incident Report Line. 

Best management practices for immediate response: 

Communicate the following information to the incident management team: locations of critical infrastructure, special considerations or hazards such as high-voltage power, chlorinators, source water protection areas.  If you don’t have a direct line of communication with the incident management team, please reach out to our 24-hour report line and the department emergency management team will assist you with getting the correct point of contact. 

• Evacuation 
• Pay attention to all emergency alerts, instructions, and evacuate immediately if asked by authorities.
• Turn off air conditioning or air circulation systems.
• Detach any electrical garage doors.
• Have an N-95 or other type of respirator available, if possible, to limit exposure to smoke and other toxic fumes.
• Re-entry
• Consult with the local incident management team before any utility personnel re-enter the facility. 
• Minimize the risk of inhaling dust particles by wetting debris.
• If returning from evacuation, remember that dangers could still exist for personnel such as hot spots, charred and fallen trees, downed power lines, smoldering and falling debris, sinkholes, mud, and landslides, etc.
• Resources
• EPA’s Incident Action Checklist 
• Tier 1 public notice instructions - Use for boil or bottled water advisory once you receive the advisory for the division.
• National Environmental Health Association - WILDFIRE RESPONSE Guide for Environmental Public Health Professionals

Best management practices for long-term recovery:  

• Purdue University - Addressing Contamination of Drinking Water Distribution Systems from Volatile Organic Compounds (VOCs) After Wildfires
• Center for Disease Control - Private Wells after a Wildfire
• Boulder County Health Department - Fire Recovery Resources for Private Wells and Septic 

➽ Kyra Gregory Drinking Water Training Specialist 

➽ Chelsea Cotton, P.E. Lead Drinking Water Engineer

Program Manager Message: A reminder about The Significance of Deficiencies!

Hello everyone, 

In the Winter 2009 Aquatalk issue, we ran a Program Manager message about significant deficiencies. This was in the aftermath of the 2008 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. Water utilities and the Safe Drinking Water Program have worked together since 2009 to correct thousands of significant deficiencies across the state. But we thought it would be a good time to rerun this article (with a few updates) as a reminder of how important it is to address significant deficiencies and avoid complacency despite our strong recent track record. We have had situations of reported illnesses likely associated with drinking water problems, but the exact combination of epidemiological evidence needed to confirm a waterborne disease outbreak did not materialize. 

The Safe Drinking Water Program periodically conducts sanitary surveys at all public water systems in Colorado. During the survey, we review source(s), treatment, distribution system, finished water storage, pumps and controls, monitoring and reporting data, system management and operation, and operator certification

compliance. The Safe Drinking Water Program believes that the benefits of conducting sanitary surveys include providing compliance and technical assistance, communicating with water systems to better clarify current and upcoming regulations, and conducting a detailed review of all the elements listed above to help ensure that the water system is able to provide safe drinking water to its customers.

After the survey is complete, a sanitary survey report letter is sent to the water system. The sanitary survey letter will notify you if your system has any significant deficiencies. Significant deficiencies are conditions or practices at a water system that may result in the production of finished water that represents an unacceptable health risk to the public. Occasionally, we find situations that represent an imminent, acute health threat to public health. These instances require the immediate attention of both the water system and the state.

However, more typically, the sanitary survey letter will include a specific time frame for the water system to correct the significant deficiency or contact us regarding its plan to correct the significant deficiency. This follow-up is required in the Colorado Primary Drinking Water Regulations. Due to the public health risk that significant deficiencies represent, it is imperative that public water systems correct significant deficiencies and that the Safe Drinking Water Program verifies that these issues are addressed. Section 11.38(3) of the regulations requires a public water system to respond in writing to significant deficiencies and violations from Sanitary Survey reports no later than 45 days after receiving the report. The response must indicate what actions the system will take to address the significant deficiencies and violations noted in the survey letter and include a proposed schedule for completing those actions.

Therefore, I encourage you to locate your last sanitary survey letter from us and review it to see if any significant deficiencies were noted. If there were significant deficiencies, are you sure that they were corrected? I recommend verifying that the deficiencies were corrected and contacting the person who conducted the sanitary survey, if necessary. If the deficiencies have not been corrected, then I recommend contacting the person who conducted the survey and developing a plan to correct the deficiencies. When the deficiencies are corrected, please provide documentation of the correction, including photos, by uploading them to the Drinking Water portal. This will confirm that the deficiency is resolved. 

By working together to identify and correct significant deficiencies, the Safe Drinking Water Program and public water systems can help ensure that the public always receives safe drinking water.

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

Acute Health Risks - Can it happen to you?

The below article is a re-run and update from an article published in the 2007 Summer Aqua Talk newsletter. Since then, the water sector has navigated many acute and emergency situations in partnership with the WQCD. We value your continued partnership and vigilance as you protect the public health and environment for our communities. 

We could all learn a little something from the Boy Scouts, especially when it comes to acute health risks in drinking water systems. Acute health risks that must be reported can be caused by events such as:

• Acute total coliform maximum contaminant level violations (when fecal or E. Coli is present);
• Failure to collect repeat samples after a fecal or E. Coli positive sample;
• Failure to test for fecal or E. Coli in a total coliform positive repeat sample;
• Nitrate, nitrite or total nitrate nitrite maximum contaminant level violations;
• Failure to take nitrate or nitrite confirmation sample within 24 hours after receipt of the first sample showing exceedance of the maximum contaminant level;
• Surface water treatment rule violations, such as not using a filter cartridge, not feeding coagulant, or a single exceedance of the maximum allowable turbidity limit or failure to maintain chlorine level entering the distribution system; etc).
• Suspected waterborne disease outbreak;
• Situations such as depressurization of a distribution system due to a line break or loss of power;
• Uncontrolled cross connections that contaminate the water supply;
• A treatment or supply emergency (for example, failure or significant interruption of key water treatment processes, a natural disaster that disrupts water supply, chemical spill or unexpected loading of pathogens);
• Tampering or vandalism that could have contaminated the water supply

Preparing for these situations can save lives, not to mention save you time and money. To help you keep your cool in a stressful situation, consider preparation measures such as:

• Plan: Gather necessary forms and phone numbers, including the 24-Hour incident reporting hotline (877) 518-5608. 
• Be familiar with the Public Notice wizard to create public notice templates and think through possible acute situations.
• Designate people responsible for specific activities, make sure your Operator Delegation Plan is up to date.
• Practice with benchtop exercises/drills. Use this coaching request form to request a  Local Assistance Unit benchtop exercise for your facility.

If your system has experienced tampering or suspected tampering, including a cyber attack, you are required to notify the Colorado Department of Public Health and Environment immediately. For details, see section 11.2(1) of the Colorado Primary Drinking Water Regulations and visit the Drinking Water Security Response Toolbox. Report physical and cyber security incidents to the WQCD Tampering Threat and Incident Report Form. 

For more information about acute procedures, please check Drinking Water Policy DW-0001 Response to Acute Health Threats from Public Water Systems, the Pressure Loss and Main Break Guidance and the Drinking Water Emergency information website.

CoWarn, the statewide Water/Wastewater Agency Response Network (CoWARN) of utilities helping utilities to prepare for the next natural or human-caused emergency is also a resource to help public water systems.

By being prepared, water suppliers can effectively handle emergency situations and potential acute situations to protect public health. 

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

➽ Emily Clark, Drinking Water Enforcement Unit Manager

Legionella Bacteria and Drinking Water Disease Outbreaks

I attended the American Water Works Association’s (AWWA’s) Annual Conference and Exposition (ACE) in Denver, Colorado, earlier this year. There were some excellent sessions on a wide variety of topics. However, the session that stood out the most to me covered Legionnaires'  Disease and drinking water. Presenters include Dr. Mark Lechavellier, Dr. Chad Seidel, Sheldon Masters, and Julie Kennedy. The session covered some of the latest research into Legionella and drinking water, plus a case study regarding an outbreak in Grand Rapids, Minnesota, that occurred from 2023 to 2024.

Although there are over fifty Legionella species and about half can cause disease, Legionella pneumophila is the most important because it causes most Legionnaires' disease cases and occurs naturally in aquatic environments. The species can infect free-living Amoeba, where the amoeba can act as a host for Legionella. The 1989 drinking water Surface Water Treatment Rule (SWTR) set a treatment technique for Legionella and established a Maximum Contaminant Level Goal (MCLG) equal to zero. Groundwater systems have no such treatment technique requirements, but one-third of the outbreaks occur in groundwater systems. Partly due to better reporting and testing, Legionella cases rose 10-fold from 1990 to 2021. Legionnaires’ outbreaks often occur in buildings such as hotels, medical facilities, and offices. People catch Legionnaires’ disease by inhaling small droplets of water suspended in the air containing Legionella. Legionnaires’ disease does not spread from person to person.

Dr. Lechavallier reported on a Legionella occurrence study that involved water testing 57 utilities. Overall, 9,118 samples were collected, and 1.2% (109) were positive. Thirty-two percent of utilities had detections. A chlorine residual of at least 0.4 mg/L dramatically reduced the positive detection frequency. Dead-end water lines, low water usage, and tank sediment raised the risk of finding Legionella. Flushing can be effective in reducing Legionella levels. Optimum Corrosion Control Treatment (OCCT) reduces pipe corrosion, which reduces the habitat where Legionella can grow. The study concluded that while eliminating Legionella is impossible, testing and management are feasible. Communicating with commercial and industrial customers about Legionella can also be beneficial. 

Unfortunately, Grand Rapids, Minnesota, experienced a severe Legionella outbreak from 2023 to 2024. Grand Rapids has a population of 11,000 and uses groundwater from five wells. The community did not disinfect and had three storage tanks (0.5 million-gallons each) and 81 miles of distribution system. Increased disease incidence began in mid-2023, but water was not believed to be the cause at that time. Legionella were not found in the water system, but the bacteria were found in the water in buildings with Legionnaires’ Disease cases. Over the next year, there were 34 total cases with 30 people hospitalized and two fatalities. After a complete assessment and expert assistance, including Dr. Seidel, chloramination started in June 2024. There have been no Legionella cases in Grand Rapids since then. Considerable effort also involved working with building owners in the town. Generally, buildings that maintain and actively implement water quality management plans do not have outbreaks.

EPA is in the process of updating its rules addressing Microbial Pathogens/Disinfection Byproducts (M/DBPs). It will be a few years before the update is finalized, and these rules will still not apply to groundwater systems. The updated rules are likely to improve the treatment technique requirements for Legionella at surface water systems. While we believe that Colorado is well-positioned to implement improvements due to our rules covering disinfectant residual, storage tanks, and cross connection control (backflow prevention), the occurrence data in this study are concerning. Additionally, even with solid operations by water utilities, important work involving water quality management plans within buildings is not part of our oversight. We encourage utilities to learn more about Legionella and consider partnering with their commercial and industrial customers, especially health facilities like hospitals and nursing homes, to take steps that could reduce the likelihood of a Legionnaires’ Disease outbreak in Colorado.  

As always, thank you for keeping our drinking water safe.

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

➽ Co-Author Chelsea Cotton, P.E. Lead Drinking Water Engineer