Inspection Year 26 is Here!

The Field Services Section (FSS) wrapped up Inspection Year 2025 (IY25), completing 496 sanitary surveys and four (4) Level 2 assessments/sanitary surveys. We would like to extend a big “Thank You” to all the water suppliers and operators for all their help in making IY25 a success! 

After one inspection year ends, another starts, and the new Inspection Year 2026 (IY26) started on October 1, 2025 and will end on September 30, 2026. A total of 555 sanitary surveys are planned for IY26. The list of suppliers included in the IY26 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 will be reaching out to you to schedule the survey anytime during the IY26 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 (L2SS) 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 and the great work by our operators, we had only four (4) L2SS occur in IY25, and typically we experience under five (5) of these events a year. Compared to other states that do not require a minimum disinfection concentration in the distribution system, this number is very low. 

Field Services recommends that suppliers take advantage of the free sanitary survey preparation course from the Local Assistance Unit. 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

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

Record of Approved Waterworks and Sanitary Survey Significant Deficiencies

The Field Services Section (FSS) just wrapped up the 2024 inspection year (IY24) in September 2024 and the new IY25 inspection year started in October 2024! We appreciate all the assistance from public water systems in completing 497 sanitary surveys in 2024. In this article we will discuss one of the most frequently cited significant deficiencies from IY24: T119 Proper treatment operation of surface water or groundwater under the direct influence (GWUDI) systems. 

Many suppliers of surface water or groundwater under the direct influence (GWUDI) have participated in the Disinfection Outreach and Verification Effort (DOVE) led by the Engineering Section. DOVE reviews typically include a detailed  assessment of the disinfection process and thorough documentation of all other unit processes at all active surface water treatment plants. The two end results of the DOVE review are 1) a facility-specific Monthly Operating Report (MOR)  and 2) a Record of Approved Waterworks (RAW). The RAW is issued by the Engineering Section and it covers all the supplier’s approved treatment and storage facilities and water sources. To find you facility's RAW please visit this website and type in your PWSID or the name of your facility. 

The RAW includes conditions of approval specific to the treatment plant that are evaluated during the sanitary survey. These conditions of approval are important operational requirements specific to each facility that are in place to ensure the production of safe drinking water and protection of public health. All suppliers are encouraged to be familiar with their RAW; especially the “conditions of approval” for each facility. 

Frequently seen RAW conditions of approval that are evaluated during the sanitary surveys include but are not limited to:

1. For suppliers reporting the log inactivation ratio achieved in their MOR:
• Clearwell levels and flow rate must be measured and recorded at least as often as each disinfectant residual monitoring event as defined in Section 11.8(3)(c) of Regulation 11. The records of clearwell volume and flow rate are subject to Division review during sanitary surveys.
• Water temperature and pH must be measured and recorded as often as necessary given source water quality conditions but at least as often as once every week. These records are subject to Division review during sanitary surveys.
2. For suppliers reporting the lowest daily chlorine residual value in their MOR:
• The minimum contact time volume must be measured and recorded at least as often as each disinfectant residual monitoring event as defined in Section 11.8(3)(c) of Regulation 11. The records of contact time volume is subject to Department review during sanitary surveys.
• Tank level sensors typically are required to be verified at least annually to ensure measurements are calibrated and accurate. Records of level sensor measurement confirmation must be kept and  are subject to review during sanitary surveys.
3. Any contact tank bypass valves (if present) must be confirmed as being operationally closed at least once per year by appropriately actuating the valve. If the bypass is operated at any time, the supplier must notify the Division prior to use. Records of bypass valve annual actuating and maintenance must be maintained and are subject to Division review during sanitary surveys. A common method for verifying valve closure and valve actuator integrity is to count, and keep a record of the number of actuator turns from open to closed and verify that the number of turns counted is correct for the valve type and size.
4. Suppliers using alternative filtration technology must continuously meet the design, performance, and operation and maintenance requirements established in Sections 4.3.9.6 – 4.3.9.8 of the Design Criteria and in the Department’s Acceptance letter for the specific filtration technology/vendor. 

• For bag and cartridge filtration systems, this includes the requirements to not exceed the maximum specified pressure differential and keep a record of daily routine pressure differential readings and filter change outs and these records will be reviewed during the sanitary survey. Specific spare parts may also be required to be on hand and will be checked during the sanitary survey. 
• For membrane systems, suppliers must maintain an operation and maintenance manual for the filtration system. All integrity tests and Clean In Place (CIP) procedures must follow manufacturers prescribed procedures. The supplier must also keep records of the following operational parameters and the records will be reviewed during the sanitary survey:
• Integrity test date, results (pass or fail), and initials of person performing the test
• Clean in place dates with clean water permeability and integrity test results.
• Filter maintenance and fiber repair results
• Filter replacement date and reason for replacement.

Please review your RAW and make sure you are aware of the requirements established by any conditions of approval and keeping the required records. The RAW conditions of approval and site-specific records will be reviewed during the sanitary survey and if there is an issue, a T119 Significant Deficiency may be issued. According to Regulation 11, Section 11.3(72), a significant deficiency means: any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public served by the water system. Significant deficiencies must be addressed in writing within 45 days after the sanitary survey letter and any significant deficiencies that remain unresolved after 120 days or past an department approved schedule will be referred to compliance for a type 45-violation that requires Tier 2 public notice (30 day public notice with health effects language). 

Please check the conditions of approval in your RAW to protect public health and avoid significant deficiencies during your next sanitary survey. If you have any questions regarding your RAW, please contact the Engineering Section. If you would like additional assistance on technical issues or sanitary survey preparation, please sign up for individualized coaching here.  For any questions or concerns about sanitary surveys 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

➽ Andrew Rice, PE, Engineering Section

Storage Tank Rule Guidance and Checklist Updates Underway

In 2020, the division worked with stakeholders to develop the updated Storage Tank Rule regulation and Policies DW-010, DW-012 and DW-015 that accompany the regulation updates. The Commission approved all proposed modifications in August 2020 and the regulation updates were effective on October 1, 2020. The Storage Tank Rule (Regulation 11, Section 28) protects public health and public water systems from potential contamination associated with unprotected storage tanks within the public water system’s drinking water distribution system. 

The Field Services Section is actively working on finalizing the Storage Tank Guidance and the periodic and comprehensive inspection checklists to reflect the 2020 Storage Tank Rule updates. The updates to the checklist will incorporate feedback inspectors have received from operators in the field during sanitary surveys. We hope that the updated checklist will be a clear, concise and useful tool for operators when conducting the periodic and comprehensive inspections that are key in ensuring safe drinking water.   

The goal for publishing the updated Storage Tank Rule guidance and checklists on our website is December 2024. If you have questions regarding implementation of the Storage Tank Rule, please email the Field Services Section at cdphe_wqcd_fss_questions@state.co.us. The department, operators and the supplier share the same goal – “Always Safe Drinking Water”.  

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

Storage Tank Roofs - Issues with Metal and Corrugated Metal Roofs

Since Colorado’s storage tank rule went into effect in 2016 we have published many articles on different aspects of finished water storage tanks. Today we would like to focus on another important potential avenue of contamination, corrugated and metal storage tank roofs. 

In recent inspections for systems that have tanks with sheet metal and corrugated metal roofs, the water quality control division (division) has seen an increase in issues with seals between the roof of the tank, and the tank walls, vents, and access hatches. Corrugated tank roofs are of particular concern due to the gaps created by their corrugated ridges. Below are some of our most important lessons learned about metal and corrugated tank roofs.

Corrugated Tank Roofs Can be Difficult to Seal

The voids created between the ridges of a corrugated roof and the walls of a tank can be difficult to effectively seal and may be a desirable shelter for rodents and other small animals. It is also much more challenging to correctly seal roof penetrations for things like tank vents in a corrugated roof. If your system has a preexisting tank with a corrugated roof the division recommends more frequent periodic inspections of these tanks with a particular focus on the seals around the corrugated materials. 

Figure 1 - Improper seal between two corrugated panels

Figure 2 & 3 - Gaps left between corrugated roof and tank walls that can allow rodents and bugs to enter the tank, creating a public health risk.

Figure 4 - Light is visible from the interior of a tank around a vent in a corrugated roof showing that it is improperly sealed.

Figure 5 - Improper seal around a tank hatch.

Expanding Foam is not an Effective Method to Seal Gaps in Tank Openings

Figure 6 - Foam used to seal the interior of a tank.

It is not uncommon to see expanding foam used to seal gaps in corrugated tanks because it can easily fill large gaps. The use of this foam can lead to potential public health risks and sanitary defects. Foam used in exterior gaps can degrade rapidly due to weather and may be used by small animals as nesting material. Foam that is used as a sealant on the interior of tanks may deteriorate and flake off into the water posing a contamination risk itself over time. Condensation collecting on the foam can leach contaminants and then drip into the drinking water.

Metal Tank Roofs Can be Challenging to Inspect

We have seen tanks with metal roofs where it isn’t possible to examine the interface between the walls of the tanks and the metal roof without an interior inspection. A dislocation or break in the gasket material or a warpage or dislocation of the metal panels could allow the entrance of contaminants such as plants, insects, birds, and small animals into the tank. A brief walk around a tank is not effective in finding potential openings. An extendable mirror can be helpful for looking at tough to see locations around all storage tanks.

Drinking Water Design Criteria for Tanks

The division has outlined the requirements for tank roofs in the design criteria. This section of the criteria is currency undergoing a stakeholder update process. If you are interested in receiving updates on this process or getting involved you can find more information on our Drinking Water Design Criteria webpage. 

New or modified storage tanks being submitted to the Department for approval must meet the design criteria. Also, the Department intends to update the design criteria to clarify that we will not approve tanks moving forward with corrugated metal roofing. However, during a sanitary survey an inspector will not issue a significant deficiency solely based on your existing tank not meeting the current design requirements unless there is a condition identified during the sanitary survey that is a potential threat to public health (examples include unprotected openings to tanks, missing/damaged screens, unsealed/un-gasketed hatches, improperly sealed tank roofs, etc.).

Figure 7 - Excerpt from the current Design Criteria for Potable Water Systems (2022 Edition)

Identification of Sanitary Defects and Risks to Public Health

If a supplier finds an animal or other concerning debris in an improperly sealed storage tank please contact the division’s emergency line at 1-877-518-5608 as soon as possible but within 24 hours of discovery. The drinking water acute team will consult with you on next steps.

If suppliers identify a sanitary defect, it must be documented upon discovery. Also, a corrective action schedule in accordance with the Storage Tank Plan must be developed to fix it as soon as possible. Take photographs before and after making repairs. By doing so, suppliers can avoid a violation for not correctly implementing the storage tank rule.

Sanitary defects that are discovered during sanitary surveys may be cited as significant deficiencies or possibly even as a Tier 2 (treatment technique) violation of the storage tank rule for permitting a known sanitary defect. The risk of violations is especially present for defects that should be ‘obvious’ to anyone performing a periodic tank inspection.

Additionally, if suppliers do not follow the corrective action schedule that they developed, they will also be in violation of the storage tank rule. Avoid violations of the storage tank rule by proactively identifying sanitary defects and then documenting that the supplier is following a corrective action schedule to fix them.

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

Questions from Q&A Session during CRWA Annual Conference

The Water Quality Control Division Field Services Section participated in the Colorado Rural Water Conference on March 18th during the WQCD round table discussions and received really great questions and feedback from operators attending the session. We wanted to share some of the questions related to Backflow Prevention and Cross Connection Control and Storage Tanks for those operators that were not participating in the conference. 

Backflow Prevention and Cross Connection Control Rule (BPCCC)

BPCCC Resources 

• Frequently asked questions
• Updated Backflow Guidance Document
• CDPHE Backflow Prevention and Cross Connection Website(opens in new window)

1. Under the new Backflow Rule updates, do I still have 15 months to get 100% of all my devices tested every year?

This question relates to the untested 2-year rule in the 2023 updated regulation as opposed to the 90-day rule from the old BPCCC regulation. With the 2023 regulation update, the “90 day rule” is gone. Under the updated rule, the supplier must achieve a backflow prevention annual compliance ratio of greater than or equal to (≥) 0.90 and with that remaining 0.10, the supplier must ensure that no backflow prevention assembly is present for more than two consecutive calendar years without being tested, service being suspended to the customer, or the cross-connection being removed.

2. What happens if a device fails a test and tests good 7 days later? What if the device fails and is fixed and passes on the same day?

This is a great question and the backflow policy DW007 helps answer this. An assembly that fails testing and is repaired and receives a passing test will be reported in the combined compliance ratio (Report lines 8-10) AND as an uncontrolled cross connection that has been controlled (Report Line 7.A) in the annual report. A violation does not occur for a failed assembly unless the assembly is not repaired within the required timeline. If an assembly fails but is repaired and passes a test on the same calendar day, the supplier may exclude reporting the assembly as having failed in the annual report and only count it in the compliance ratio (Report Lines 8-10) in the annual report. 

3. How do I handle if a place closes and is no longer in use but they had a backflow device?

If it was in use at any time during the year it must be included in the annual report. The supplier can suspend service to the location to remove the cross connection concern for future years while the business is not occupied or using water.

4. Can PWSs have their operators certified as backflow testers? What are the pros/cons?

There are no Colorado state limitations on whether an operator can also be the certified backflow tester. Some utilities administer their backflow program where the operators perform device testing. Other utilities consider it to be a conflict of interest. Each water system can work with their management and legal team to decide the best path for their water system. Some pros to having operators test backflow devices may include having some level of control over the timing of when the assembly is tested, immediate test results, and prioritized testing. However some of the “Cons” of having operators test devices are potential conflicts of interest, it’s another certification to test and maintain.

5. How do I become a certified backflow tester?

Regulation 11 allows for two certification organizations; ASSE and ABPA. They are national organizations with testing/certifications in Colorado. Just google ASSE or ABPA backflow tester and it will bring up testing, schools and how to sign up.

6. Yard hydrants - I installed one with a “Y” adapter with a hose attached to one end with a HBVB installed. Is this ok?

When not in use, the hydrant can be shut down with the non-used side of the “Y” left open to allow for the yard hydrant’s weep hole to work correctly. As long as the non-used side of the “Y” has no hose attached this should be acceptable.

7. Do I have to use your forms?

No, suppliers can develop their own forms as long as they meet the Regulatory requirements and include all the required information.

8. Can I use GIS to track my methods/assemblies?

WQCD does not mandate how suppliers track their methods/assemblies. As long as all required information needed in completing the annual report and maintaining a backflow program are achieved we see no issue with using GIS. One area of concern when using locational software to track assemblies/methods is that one location may have multiple assemblies/methods (isolation versus containment or multiple service connections).

Storage Tank Rule

Storage Tank Rule Resources 

• CDPHE Storage Tank Rule Website
• Storage Tank Guidance Handbook 
• Inspection summary instructions(opens in new window)

1. Overflows - do I need a flap and a screen or are screens banned? Are you going to issue me a significant deficiency during my next sanitary survey for this? 

This highlights the difference between a significant deficiency associated with Sanitary Surveys and changes in the design criteria for designs submitted to the Engineering Section. New or modified water facilities must meet the design criteria, but the Field Services Section does not issue significant deficiencies if an existing tank does not meet the current design requirements unless there is a condition that is a potential threat to public health (flap valve is stuck open, screen is torn or missing). During a sanitary survey, tank overflows with flap valves or screens are fine as long as they are in good operating condition (flap valve functions, seats completely, flap valve is not propped open/submerged; screens are non-corrodible 12-16 Mesh and intact).

2. Do I have to use 24-Mesh non corrodible screen - I can’t find it.

Screens may not have openings that exceed 0.07 inches (typically 12 or 16 mesh) and have to be non-corrodible.

3. Can I use actual plastic window screen to screen my vents, overflows, etc?

Plastic window screen can be easily damaged/torn by rodents and should not be used. Non-corrodible metal screen should be used.

4. My tank is 20 years old and does not meet the current design criteria. Are you going to cite me for a significant deficiency or violation during my next sanitary survey?

New or modified water facilities must meet the design criteria, but your inspector will not issue a significant deficiency if your existing tank does not meet the current design requirements unless there is a condition that is a potential threat to public health (examples include unprotected openings to tanks, missing/damaged screens, unsealed/un-gasketed hatches, etc.).

5. Does the Storage Tank Rule apply to all my tanks?

The storage tank rule applies to finished water storage tank(s). “FINISHED WATER” or “FINISHED DRINKING WATER” means water that is supplied to the distribution system of a public water system and intended for distribution and human consumption without further treatment, including disinfection contact time, except treatment as necessary to maintain water quality in the distribution system (e.g., booster disinfection, addition of corrosion control chemicals). If you need help determining if a tank is considered to be part of the treatment system or part of the distribution system, please email us at: cdphe_wqcd_fss_questions@state.co.us

6. What should I do to maintain my Contact Time tanks that are not part of the distribution system?

We recommend that you consider following the Storage Tank Rule guidelines for Contact Time (CT) tanks to avoid a potential risk to public health but it is not a requirement. Your inspector will be looking at all tanks including the contact time tanks during your next sanitary survey and any potential risks to public health (example: unprotected openings, missing/damaged screens, unprotected overflows, sediment buildup) will be cited as significant deficiencies.

7. When are you going to make me do the Storage Tank Rule for my Contact Time Tanks?

The Division does not have any current plans to re-open the Storage Tank Rule however, the tanks must still be maintained and will be inspected during sanitary surveys.

We hope sharing these questions and answers from the Colorado Rural Water Association helps all operators. If you have any questions please feel free to reach out to us at: cdphe_wqcd_fss_questions@state.co.us.

➽ Tom Valenta Field Services Section Work Group Lead, Unit 3 

➽ Heather Young Field Services Section Manager

Monitoring Plans: Develop and Maintain this Crucial Document

What is a monitoring plan?

The monitoring plan is an important tool for your system that helps you capture an accurate inventory of your system and communicate that inventory to the division. The division then uses this information to develop your monitoring schedule and your compliance requirements. All public water systems are required to have a monitoring plan per regulation 11. The plan is required to be current, complete, and any new changes need to be reflected in your monitoring plan within 30 calendar days after the change is effective. During a sanitary survey, the inspector will ask to see your monitoring plan; they will confirm that the monitoring plan reflects the on-site review of your system.  

The monitoring plan includes:

• System contact information.
• Inventory of facilities.
• Process flow diagrams detailing treatment and entry point sampling. 
• Source, treatment and distribution details.
• Maps of your distribution system detailing sample locations.
• Individual rules sampling/monitoring plans (e.g. nitrate rule).

Our colleagues in the field services section have cited the following monitoring plan issues most commonly during sanitary surveys:

• Changes in treatment or distribution not reflected in the monitoring plan - thus missing from division records. 
• Lack of process flow diagram or a diagram that does not accurately capture compliance sampling locations - Entry Point, Raw Water Tap etc.  
• Lack of a map of the distribution system detailing sampling locations for Revised Total Coliform Rule, and Disinfection Byproduct Rule. Please note that these sample sites may be managed in the drinking water portal. But, the division recommends that you also have a map detailing where to find these sample sites in your distribution system. 
• RTCR sites that are not representative of the entire distribution system - missing zones or branches in distribution.

How do I create or update my monitoring plan?

The division has created an online tool to help you update your monitoring plan, we call it the monitoring plan wizard. This tool will help you to generate and update your monitoring plan. It is a google form that you fill out based on the sections that you need to generate or update for your system. You then receive an email with a pre-populated google document for the section(s) that you selected. You then download the pre-populated sections as a word document or a similar file. You will fill out any information that is lacking, review the pre-populated information to ensure that it is correct, and then submit the plan to the division. The best way to submit is through the drinking water portal. Paper forms are available if you choose not to use the wizard. 

If it has been some years since you have updated your monitoring plan it may be beneficial to create a new monitoring plan. To do this you will need to take the following steps: 

1. Evaluate what sections of the plan are required for your system. On the division’s monitoring plan website there is the below chart that details the monitoring plan requirements based on the type of system you have. If you are unsure as to your system type you can look at your drinking water monitoring schedule under system details. 
2. Now you will go to the monitoring plan wizard and select the sections that are required for your system. 
3. The division will send you a Monitoring Plan template that is filled in with the information we have on file for your system. Note: The google doc link that is sent in the email will be automatically deleted after 10 days. We recommend that you make a copy or download the template as a Microsoft Word document to avoid losing work.
4. Review the generated monitoring plan. Be sure to update any pertinent information and describe the changes you are making. This will help your compliance specialist as they review your submitted plan.  
5. Submit the new monitoring plan through the drinking water portal. 

Why would I need to update my monitoring plan?

There are several changes to a system that could result in a change to your monitoring plan. The below list details some but not all of these possible changes. Please note: Systems must contact their compliance specialist before making system changes. Changes in infrastructure (construction) or treatment often require design approval:

• Change to operator or administrative contact 
• Change in population
• New customers added to the system
• New sources or sources going off-line
• Sample sites must be reviewed and updated to account for system changes 

Why diagrams and maps?

There are several mechanisms for generating these often missed items for your monitoring plan. The process flow diagram is a section of the Monitoring Plan that folks often have questions about. The diagram is a way for you to accurately capture your system’s treatment inventory. It is also a good way to conceptualize your facility when training new employees, working to solve issues, or identifying potential improvements. This diagram will begin with your water source(s), go through treatment, and then into the distribution system. The diagram needs to include identification of compliance sampling locations. For groundwater plants this would include raw water tap and entry point tap. For surface water or groundwater under the direct influence of surface water systems this would include raw water sample, CFE turbidity sample, microbial inactivation sample, and entry point sample sites. The diagram can be hand drawn or from a visio drawing or other means to show the process.

The distribution system map is a useful tool to ensure that your RTCR and DBP plans meet regulatory requirements. Specifically, the RTCR sites need to represent your entire distribution system including any branches and segmentation of different zones. The DPB sample site(s) need to be located at the longest representative residence time of drinking water in your distribution system. Often, systems use chlorine residuals to determine these sample sites, where the chlorine residual is lowest in the distribution system. Using a map can also help you identify the points farthest from your treatment in distribution. The map can be taken from google maps, google earth, any maps of your distribution system you may have and can scan. Simple programs like Microsoft paint, word processors, and PowerPoint generators can be used to generate sample site locations. 

Resources

• Division’s monitoring plan website 
• Monitoring plan wizard 
• Monitoring plan wizard videos
• Drinking water portal 

➽ Kyra Gregory, Drinking Water Training Specialist

Wellhead Deficiencies

In this article, we continue our discussion of the Top 10 most frequently cited significant deficiencies and violations to raise awareness and help operators identify and correct issues before they become a potential health threat or citations in a sanitary survey. At #2 in the Top 10, source construction deficiencies (S030) were cited 9% of the time during sanitary surveys for the 2022 inspection year and 9% in the 2023 inspection year. Groundwater wells are the most common sources of drinking water used in Colorado (70% of public water systems use groundwater wells) and are perhaps one of the most overlooked parts of water systems. Wells can go unnoticed for years since they are often located away from most activities and may only be noticed when the flow of water is altered. The most commonly discovered significant deficiencies with wells are related to electrical conduits, gaskets, vents and vaults.

What are the minimum standards for a properly constructed well? In the “State of Colorado Design Criteria for Potable Water Systems” (Policy DW005), CDPHE actually primarily refers to the Colorado Division of Water Resources’ (DNR) latest edition of “2 CCR 402-2 Rules and Regulations for Water Well Construction, Pump Installation, Cistern Installation, and Monitoring and Observation Hole/Well Construction” (a.k.a. Colorado Well Driller Regulations). The purpose of these regulations is to ensure public health and the safety of groundwater resources. The regulation outlines minimum construction standards for all types of wells in all types of environments, and it defines minimum well height, screening, minimum distance from potential sources of contamination, grouting standards, pump installation and much more.

There are many variations to well heads, but the two primary ones that inspectors come across are the “split-cap” and the “well-cap” (see image below for reference). The “split-cap” has the discharge line, vent and electrical conduit all protruding from the wellhead. The well head is comprised of two metal plates with a rubber gasket in between. When installed, the two plates are compressed, the rubber gasket expands and creates a watertight seal. The “well-cap” has a pitless water connection (below frostline) and a designated female electrical connection, a set of gaskets and a built-in vent (which are typically screened).

*photo courtesy of Oregon State University https://wellwater.oregonstate.edu/well-water/wells/well-check-list

Well head

Well heads must be designed and constructed at the top of well casings to prevent the entry of contaminants into the well. The majority of the wells that the department inspects are located outdoors and are exposed to the elements. It is vital that the wells are constructed and maintained in a manner that will protect the raw water. Some common issues that inspectors observe are missing/damaged gaskets, missing bolts, broken or loose well caps (bolts are missing or not tightened), split-caps not seated on the well casing properly and a split-cap with a rope (used to hold the well pump in position or to assist in pulling the pump out) coming out of the well that is not properly sealed.

The split-cap well head was not properly sealed to the well casing. The supplier applied caulking between the split-cap and the well casing.

The bottom of the well head cap was broken and did not allow for a tight seal. A new well head was installed.

Well Vents

Vents are an integral part of a well as they permit air to freely enter and exit the well. Vents need to be located at a minimum of one foot above ground level, be turned down and be covered with a non-corrodible screen. Screens may not have openings that exceed 0.07 inches (typically 12 or 16 mesh screen). 

The two most common issues observed with vents on wells are that they are broken or missing.

The well-cap has a built-in vent that was broken/corroded. The supplier replaced the broken screen with an acceptable mesh screen.

Electrical Conduit

According to the Colorado Well Driller Regulation, electrical connections are to meet the standards of the NFPA 70: National Electric Code (2014). Some common electrical conduit issues that are observed during sanitary surveys are where the electrical conduit has separated from the well head or the junction box which can typically occur due to the ground settling. Another common finding is missing or partially attached cover plates on electrical junction boxes. Split-cap wells can also have electrical wires penetrating the well top without a properly constructed conduit or a proper seal between the wire and the rubber gasket. All of these situations present a pathway for contaminants to enter the well, which pose a health risk and are significant deficiencies that will be cited during a sanitary survey.

The electrical conduit separated from the electrical junction box, creating an opening. The supplier installed a conduit sleeve to provide a watertight junction.

The electrical junction box was missing a screw. The supplier sealed the hole with caulk.

Split-cap well had the electrical wire enter from an unsealed port. The supplier sealed the gap with caulk.

Well Vaults

Although well vaults are not a common practice these days, the department still observes wells located in vaults. Placing a well in a vault was a common practice to protect the well from the elements. However, having a well in a vault can subject the well to flooding. If a well is located in a vault, the vault cover or lid must be watertight and the vault must either drain to daylight or have a sump. Evidence of water accumulating in the vault and potentially submerging the wellhead is a significant deficiency.

Well vault was subject to flooding. Supplier installed a sump pump.

Concrete Pads

Inspectors are frequently asked if concrete pads are required? The Colorado Well Driller Regulation along with the department do not recommend that wells have concrete pads with the exception of hand-pumped wells. Well pads were commonly installed if well depths were less than 100 feet or to keep vegetation down around the well head. However, the department has observed that concrete pads tend to attract animals that burrow underneath the pad creating a source of contamination. Concrete pads also tend to crack and shift, which can create a funnel effect and divert surface water to the well casing. Minor cracks can be repaired; however, the department recommends that a supplier remove their existing concrete pad if they notice animals burrowing or if the concrete pad begins to divert surface water to the well casing. Evidence of burrows under a concrete pad or severely damaged pads capable of channeling surface water to the well casing are significant deficiencies that would be cited during a sanitary survey.

Burrow located under the concrete pad, the burrow was filled in and will be monitored in the future.

Drainage and Slope

According to the Colorado Well Driller Regulation, well locations should incorporate proper positive drainage from the well casing. As a rule of thumb, the department has historically viewed positive drainage 20 feet in all directions from the well if possible. Wells should not be located in depressions as surface water can pool around the well casing and be a source of contamination. If a well is built on a slope, a berm is recommended uphill to divert runoff and surface water away from the well casing. 

Well was located in a depression that could allow for water to pool around the well casing. The supplier added pea gravel around the well head and created positive drainage away from the well casing.

For more information the department recommends that suppliers utilize DNR’s latest edition of “2 CCR 402-2 Rules and Regulations for Water Well Construction, Pump Installation, Cistern Installation, and Monitoring and Observation Hole/Well Construction” for proper well construction, maintenances and fixes. In addition, suppliers may email the Field Services team at cdphe_wqcd_fss_questions@state.co.us if they have any questions or concerns.

➽ Tom Valenta, CWP, Field Services Work Group Leader

EPA Requirement to Address Cybersecurity in Sanitary Surveys

The US EPA Office of Water issued a memorandum, “Addressing PWS Cybersecurity in Sanitary Surveys or an Alternate Process” on March 3, 2023 to all State Drinking Water Administrators requiring cybersecurity evaluations during each sanitary survey. The EPA definition of sanitary survey is “an onsite review of the water source, facilities, equipment, operation, and maintenance of a PWS for the purpose of evaluating the adequacy of such source, facilities, equipment, operation, and maintenance for producing and distributing safe drinking water.” In Colorado, CDPHE conducts sanitary surveys of all public water systems (PWS) every 3 years for community systems and every 5 years for non-community systems. Colorado has been engaged with the Association of State Drinking Water Administrators (ASDWA) over the last year and with EPA’s issuance of the Memo, we are reviewing the newly published requirements and the below information summarizes what we know so far.

What systems are impacted?  

From the March 2023 EPA memorandum, cybersecurity evaluations must be included in the sanitary surveys for all PWSs that use industrial control system technology as part of the operation of the water system. In the EPA guidance document, “Evaluating Cybersecurity During Public Water System Sanitary Surveys” it states that industrial control systems include not only Supervisory Control and Data Acquisition (SCADA) systems, but also Programmable Logic Controllers (PLCs). Colorado does have some small transient water systems that are limited to a basic well and chlorinator, but the vast majority of PWSs in Colorado have industrial control systems in place.

What is being required?

In a nutshell, Colorado will be required to include cybersecurity as part of the sanitary survey process for all PWSs with industrial control system capabilities or establish a program outside of the sanitary surveys that is no less stringent than federal regulations and involves identifying and addressing significant deficiencies in cybersecurity. EPA outlined three options for conducting the assessments:

1. PWS self assessments/third party assessments followed by a sanitary survey
2. State conducted assessments during the sanitary survey
3. An alternative program that meets the requirements. 

EPA recognizes that flexibility will be needed and states may choose one or more options to best meet their needs. For cybersecurity, EPA considers significant deficiencies to include the absence of a practice or control, or the presence of a vulnerability, that has a high risk of being exploited, either directly or indirectly, to compromise an operational technology used in the treatment or distribution of drinking water. The Colorado Primary Drinking Regulations (Regulation 11), Section 11.3(72) defines a significant deficiency as: any situation, practice, or condition in a public water system with respect to design, operation, maintenance, or administration, that the state determines may result in or have the potential to result in production of finished drinking water that poses an unacceptable risk to health and welfare of the public served by the water system. Water systems have to either fix significant deficiencies and violations no later than 120 days after the date of the inspection letter or request a corrective action plan (CAP). If the water system does not fix a significant deficiency by 120 days or an approved CAP schedule, a violation (type 45 violation) requiring Tier 2 public notice occurs. 

When is this taking effect?

EPA has stated that the memorandum was effective as of the date of publication, however, states will need time to build the capacity to implement the requirements. Colorado does not have the capacity to implement these requirements as part of the sanitary survey process during this current inspection year or the upcoming inspection year starting in October 2023. Colorado is evaluating the best path forward for our state at this time in coordination with CDPHE leadership, other states and ASDWA.

What can systems do in the meantime?

All PWSs with industrial control system capabilities should assess their cybersecurity programs with an established method if they have not already done so. EPA guidance recommends that self assessments be conducted with established methods such as those from the Department of Homeland Security (DHS), Cybersecurity and Infrastructure Security Agency (CISA), National Institute of Standards and Technology (NIST), the American Water Works Association (AWWA), International Organization for Standardization (ISO), or International Society of Automation/International Electrotechnical Commission (ISA/IEC). The PWS should implement measures recommended from any assessment to ensure continued production and distribution of safe drinking water. Depending on the approach CDPHE takes, the self assessment reports may be required to be submitted to the inspector prior to the sanitary survey in the future for determination of potential significant deficiencies. 

Additional resources can be found: 

• EPA water sector Cybersecurity website
• EPA’s Water Security Assessment Tool
• EPA's Water Sector Cybersecurity Evaluation Program where PWSs can coordinate with EPA on cyber security assessments 
• EPA’s cybersecurity training schedule
• CDPHE’s Water Security Toolbox
• CISA Cyber Threats to W/WW website
• CISA Free Cyber Hygiene Services (including assessments and evaluations) 
• DHSEM Cyber Services Roadmap

Colorado recognizes that PWSs are among the  targets of malicious cyber activity and is committed to partnering with water suppliers on this issue going forward. Many large utilities have robust cybersecurity programs in place. Many small to medium size systems will need to build cybersecurity capacity. If you have any questions or concerns as we determine the implementation path, we’d like to hear from you. Please contact either Heather Young at heather.young@state.co.us or Cameron Wilkins cameron.wilkins@state.co.us of the WQCD Field Services Section. For cybersecurity training resources, please contact Kyra Gregory at kyra.gregory@state.co.us.

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

➽ Cameron Wilkins, PE, Field Unit II Manager