New Monitoring Schedule Website

The Drinking Water Compliance Assurance Section (DWCAS) is updating how Monitoring Schedules are displayed. Monitoring Schedules communicate water system’s sampling and reporting requirements, as well as additional compliance requirements. DWCAS recognizes that this is a significant change. Which is why the rollout of this change will be implemented in phases. Please share this article with others who may not have received it.

The new schedules come with added features (listed below) that will be beneficial to many users. The reasons for the change are complex: First, the current system has been in place since 2012, and is intertwined with our aging data system. Second, with our data system potentially nearing its end-of-life, and to ensure continuity with any potential future changes, we are transitioning to a new adaptable platform. Lastly, the new system will allow us to make updates faster, increase accessibility, and offer an interactive display. 

The new schedules are now available, along with the current system, at our drinking water monitoring schedule website.

Before diving into the features this new system has to offer, we encourage water systems to refer to our new Drinking Water Schedules Information and Guide or overview video. 

As a part of the update, the new schedules system allows for interactive tables. The tables within the monitoring schedule can be filtered by water system, operator, facility, analyte, monitoring period, frequency, and compliance schedule type. This means, associated contacts can filter to view all systems they are linked to. This will be helpful for contract operators managing multiple systems.

After using the filters, water systems are able to create a specific link that can be bookmarked or saved for future use. For more information about creating your own unique link, please refer to our Drinking Water Schedules Information and Guide. Using the link will automatically filter the report. The new system retains the ability for PDF downloads. For more information about downloading the report, please refer to our Drinking Water Schedules Information and Guide. The new system also allows for individual table exports for offline access. This feature will be helpful for large public water systems with requirements across numerous facilities. 

DWCAS recently made updates to the AIMS (Am I Missing Something) Tool. This update now shows all satisfied sampling schedules. The satisfied schedules section in the monitoring schedules links directly to the AIMS tool without extra filtering (this link is also available in SWIFT). This process is also more consistent as it uses the same system we use internally for determining compliance. Next, compliance schedules are linked to the website for systems to easily get to the relevant information and form. The new platform is better aligned with Colorado’s digital accessibility requirements (CDPHE digital accessibility).

Anticipated Questions:
Q: Why is this happening?
A: Our data system is nearing its end-of-life. Updating now positions us for continuous service regardless of the future data system. In addition, this will help us better meet accessibility requirements established by State law.

Q: How do I use the new system?
A: It is available at the same website. A detailed Monitoring Schedules Help Guide and overview video have been created to help users. It also includes steps for downloading as a PDF and exporting tables.

Q: How will I know that samples have been received in the new system?
A: Schedules in the new system contain a direct link to the recently updated AIMS Tool, providing confirmation of satisfied monitoring requirements. This has the following improvements:

• Fully aligned with how compliance is determined internally.
• Includes monthly schedules, so all analytes and frequencies are in one location.
• Shows the number of samples received (instead of just stating the schedule was satisfied).

Q: Will the data still be updated weekly?
A: Yes, there is no change to the data update frequency. The updated schedules and AIMs tool will be available every Thursday morning.

Q: When is this happening?
A: We are targeting a complete implementation of the new Monitoring Schedule platform in Winter 2025. However, to ease the transition to the new system, from now through January 2026, both monitoring schedules are available online. 

Q: I am having issues accessing my schedules. How can I fix this?
A: The monitoring schedules do not require a Google account to view. If you run into an issue, then your browser might not be up-to-date or a Google account might be tied to your browser. To fix this, you can try updating your browser, try a different browser (Chrome, Edge, Firefox, and Safari are all supported), or open a new window using Private or Incognito Mode (this will remove any saved login information). In the new Private window or Incognito Mode window, then try accessing the monitoring schedules.

Please do not hesitate to contact us during this transition for assistance. Thank you all for your commitment to Colorado’s drinking water and for your continued support as we update the Monitoring Schedule system. 

➽ Phillip Stanwood; Data, Records, and Reporting Unit Manager 

EPA PFAS Rule Update: What Colorado Water Systems Need to Know

The division is closely monitoring recent developments from the EPA regarding its 2024 drinking water PFAS Rule. While the EPA has signaled potential changes to the regulation, the official rulemaking timeline remains unchanged, with Colorado’s adoption scheduled for August 11, 2025. The division is committed to maintaining clarity for water systems and intends to highlight this federal uncertainty in its Statement of Basis and Purpose that is part of the rulemaking. The division is committed to communicating with water systems when federal action occurs and proposing revisions to Colorado’s PFAS rule to align with federal requirements before the Water Quality Control Commission.

Resources: 

• CDPHE - Regulating per- and polyfluoroalkyl substances (PFAS) in drinking water
• CDPHE - PFAS mapping (includes PFAS in treated drinking water map and data) 
• CDPHE - PFAS Grant program

EPA’s Announced Changes

In May 2025, the EPA announced that it may significantly revise the 2024 PFAS Rule. Proposed changes include:

• Removing and reconsidering regulations for four PFAS compounds: PFNA, PFHxS, HFPO-DA (GenX), and PFBS.
• Retaining Maximum Contaminant Levels (MCLs) and monitoring requirements for PFOA and PFOS only.
• Eliminating the Hazard Index concept and its associated MCL for PFAS mixtures.
• Extending the compliance deadline for PFOA and PFOS MCLs from 2029 to 2031.

These changes are planned to occur via a revised PFAS Rule proposal in Fall 2025, and anticipated finalization in Spring 2026.

It’s important to note that, so far, EPA’s announcement has not indicated changes to the requirements for initial monitoring of six PFAS compounds by the April 2027 compliance deadline.

Colorado’s Approach

Colorado is moving forward with adopting the PFAS rule this summer to retain full Safe Drinking Water Act primacy. This ensures that the division, not EPA, will continue to oversee PFAS compliance, monitoring, and enforcement across Colorado systems.

To account for the evolving federal landscape, the division has included a “federal flexibility provision” in its rule language. This provision allows for the automatic extension or stay of any deadlines or requirements altered by the final federal PFAS Rule, minimizing disruption for water systems.

Why Primacy Matters

Colorado’s decision to adopt the rule in 2025 avoids a primacy extension agreement with EPA. Under such an agreement, EPA would have authority over PFAS compliance while the state catches up. This would fragment regulatory oversight, complicate compliance for Colorado’s water systems, and limit our decision-making authority during this period. We believe that the division can provide the best decisions for water systems and their customers in Colorado.

The division’s experience with the Lead and Copper Rule Revisions (LCRR) demonstrated the benefit of timely rule adoption. Being one of the few states to implement LCRR on schedule allowed the division to retain control and better support systems through technical and operational challenges. The same advantages apply here.

Operational Implications for Water Systems

Drinking water data across Colorado shows that PFOA and PFOS are the primary PFAS compounds detected in public water supplies in Colorado. The removal of other compounds from the federal rule should not change which systems require PFAS treatment in Colorado. However, there may be impacts to treatment plant design and operation, which the division will work to consider during rule implementation.

In the meantime, systems are encouraged to stay engaged and continue monitoring for PFAS to meet initial monitoring requirements. The division will provide ongoing updates and technical assistance throughout this evolving process.

Stay Informed

The division is committed to supporting Colorado’s water systems during this transition. As the revised federal rule develops, Colorado will adapt, but always with the goal of maintaining clarity, consistency, and strong public health protections.

➽ Haley Orahood, Regulatory Development and Implementation Specialist

Small Victories - Our Culture of Health in Action!

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

Newly Regulated Water System

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

Broken Well Casing

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

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

➽ Drinking Water Compliance Team

Mobile Home Park Drinking Water Regulations

In a recent AquaTalk article, the following quiz question was proposed for readers:

If a mobile home park does not have a well or treatment system, but bills customers for water, what regulations apply?

1. The plumbing code alone
2. The plumbing code and the new Mobile Home Park Water Quality Act
3. The plumbing code, the new Mobile Home Park Water Quality Act, DOLA’s Mobile Home Park Oversight program, and Regulation 11 within the distribution system.
4. None of the above are fully correct; it’s complicated!

It is complicated! All of the above (and more) may apply, but the answer is 4 because it depends on some important variables that must be evaluated on a case by case basis. Hopefully after reading this, the statutory and regulatory frameworks that apply to mobile home park water quality regulations will be more clear. 

DOLA’s Mobile Home Park Oversight Program

The Department of Local Affairs (DOLA), Division of Housing’s Mobile Home Park Oversight Program (MHPOP) implements the Mobile Home Park Act. The program also conducts outreach, education and maintains an annual mobile home park registration system. DOLA has all of the applicable laws, rules, and policies located on their MHP rules website.

What is a mobile home park? MHPOP’s definition of MHPs is on their website. To summarize, a "mobile home park" is a parcel of land that accommodates five or more mobile homes. And the park operates for the monetary benefit of the land owner. Homes must be "designed for long-term residential occupancy". This language clarifies the difference between mobile home parks and recreational vehicle (RV) parks. Refer to MHPOP’s definition to understand the nuances between housing communities. To add, if a mobile home park does not have 5 or more manufactured homes, it is not considered a mobile home park. 

Mobile Home Park Water Quality Act

The Colorado Department of Public Health and Environment’s Water Quality Control Division implements the Mobile Home Park Water Quality Act (Act). This Act applies to all mobile home parks that meet the MHPOP definition. This Act was signed into law by Governor Polis in June 2023. This law establishes a water quality testing program for mobile home parks. The following occurs under the law:

• Mobile home parks are prioritized for testing based on criteria in the law.
• Site-specific testing plans are created for each mobile home park.
• The department’s contractor, Terracon, completes water quality testing.
• The analysis is completed at certified laboratories.
• All test results are submitted to the department.
• The department has 10 days to notify the mobile home park owner of test results. The wholesaler also receives a copy of the notice.
• Test results are posted online in English and Spanish.
• Mobile home park owners must provide residents with a notice of test results within five days.
• If a water quality issue is identified, the department will typically require the mobile home park to complete additional testing. Remediation or temporary measures necessary to address acute health risks may be required.

The purpose of the Act is to conduct water quality testing at all mobile home parks over a four year period. The law considers resident concerns about water quality. The Act also requires the department to create an Action Plan. The Action Plan will provide an overview of findings and offer longer term recommendations to improve water quality in parks across Colorado. 

In February, we posted an informative AquaTalk article about the new Mobile Home Park Water Quality Act.

Colorado Primary Drinking Water Regulations - Regulation 11

The Colorado Department of Public Health and Environment’s Water Quality Control Division implements Regulation 11. This Regulation is applicable to public water systems (PWS). A PWS is defined as:

• A system that provides the public water for human consumption through pipes or other constructed conveyances; 
• Has at least fifteen service connections; and/or
• Regularly serves an average of at least 25 individuals daily at least 60 days per year; and
• Includes either a source or treatment, or receives all of its water from a public water system and sells water to its customers.

Some mobile home parks treat their own water source, but a majority of mobile home parks in the state are connected to existing public water systems. Parks that get water from a public water system and bill customers for water based on usage are selling water. Any water billing structure that fluctuates based on water usage is considered selling. This includes submetering and splitting a bill amongst users. If water charges are included in rent, the mobile home park is not considered selling. Any mobile home park with 25 or more residents or 15 service connections that sells water is a public water system and subject to Regulation 11.

If a mobile home park meets the definition of a public water system but receives all of its water from another public water system, it is still required to monitor water quality in the distribution system (disinfection, disinfection byproducts, lead and copper, total coliform bacteria). The mobile home park must also comply with operator certification and backflow prevention requirements, storage tank inspections/maintenance requirements, recordkeeping requirements, and perform public notifications. The Department also performs sanitary surveys on a 3-5 year frequency.

Water and Wastewater Facility Operators Certification Requirements - Regulation 100

The Colorado Department of Public Health and Environment’s Water Quality Control Division and the Water and Wastewater Facility Operators Certification Board implement Regulation 100. Regulation 100 is applicable to the mobile home parks that meet the PWS definition. Regulation 100 ensures that people who operate water and wastewater facilities are properly trained and certified. If a mobile home park receives all of its water from another public water system, it is still required to have a certified operator for its distribution system.

Plumbing Code

Another critical requirement is the plumbing code. The State Plumbing Board licenses, registers, and regulates plumbers, apprentices, and plumbing contractors. Information is available at The Department of Regulatory Agencies' plumbing website. The Colorado Plumbing Rules and Regulations are an adoption of the International Plumbing Code and International Residential Code 2021 edition. These regulations and plumbing codes are applicable to mobile home parks. The terms Manufactured Home and Manufactured Housing is used throughout the plumbing code to refer to mobile home parks.

Hypothetical Examples

What rules and regulations apply to a mobile home park that has 13 mobile homes, 28 residents, is connected to a public water system and bills customers for water based on usage?

• DOLA’s Mobile Home Park Oversight Program
• CDPHE’s Mobile Home Park Water Quality Act
• Regulation 11
• Regulation 100
• Plumbing Code

What rules and regulations apply to a mobile home park that has 50 mobile homes, 100 residents, is connected to a public water system and includes water in resident’s rent without fluctuation based on usage.

• DOLA’s Mobile Home Park Oversight Program
• CDPHE’s Mobile Home Park Water Quality Act
• Plumbing Code

The number of mobile homes in the mobile home park, number of residents or service connections, and billing structure are important variables when identifying applicable rules and regulations. 

➽ Ian Ferguson, Drinking Water Compliance Specialist

Public Health Success in Partnership

Palmer Lake Mobile Home Ranch and The Town of Monument Partner to Provide Drinking Water

Town of Monument, CO

Palmer Lake Mobile Home Ranch successfully closed out their long-standing enforcement order after many hurdles and plot twists. This is a story of collaboration between water systems and with Department staff. Palmer Lake Mobile Home Ranch is a mobile home community in El Paso County that serves approximately 250 people. 

In 2014 to 2018, Palmer Lake Mobile Home Ranch was struggling to maintain compliance with a variety of regulatory requirements. As a result, in 2018, the Department issued an Enforcement Order due to the system's failure to comply with The Colorado Primary Drinking Water Regulations (Regulation 11) and The Water and Wastewater Facility Operators Certification Requirements (Regulation 100).  The purpose of the Order was to provide deadlines and oversight to keep Palmer Lake Mobile Home Ranch on track toward returning to compliance and maintaining long-term compliance with Regulation 11 and Regulation 100.

Later in 2018, water samples collected from a proposed well indicated elevated concentrations of combined radium -226 and -228 and resulted in violations of the maximum contaminant level (MCL). Radionuclides such as these can occur naturally in water sources as a result of the erosion of natural deposits. While they are not an acute health risk for short-term consumption, there are chronic risks including a higher risk of developing cancer if water with elevated radium levels is consumed over a long period of time. Even though Palmer Lake Mobile Home Ranch had resolved all but one of the prior violations, the Department issued an amendment to their Order to bring the new MCL violations into the corrective action oversight provided by the Order.

The owner of Palmer Lake Mobile Home Ranch expressed frustration at the complexity of this new MCL violation but continued to work with their contract Professional Engineer and the Department to explore affordable solutions. Even though this water system serves full-time residents, as a private, for-profit business, the owners could not qualify for funding assistance (grants or low interest loans) from local, state or federal agencies. Collaborative communication between the Department, the system, and contract engineers was dedicated to designing a solution that would effectively reduce the concentration of combined radium in the water. Several ideas were considered, but only a few were realistically going to ensure future compliance. The system decided to install treatment to remove radium, but complications developed throughout the process: the financial burden of the total cost of the project was becoming an increasing concern, and they were not allowed to discharge the removed radium as a waste stream which eliminated some treatment options. The remaining treatment option added extra cost beyond the treatment installation and operation/maintenance. They would need to use a treatment that captured the removed radium in a resin instead of discharging it in a waste stream. This would require obtaining a hazardous waste handler permit for the Palmer Lake Mobile Home Ranch itself, and they would also pay indefinitely for a specially permitted waste hauler service to remove the resin on a regular frequency. 

In 2022, a new partner entered the conversation. The Town of Monument informed the Department of plans to construct a water line that was going to run along the property edge of Palmer Lake Mobile Home Ranch as part of a new storage tank construction project. Given the complications that Palmer Lake Mobile Home Ranch was experiencing with installing treatment for their own water supply, they were enthusiastic about this new development. When the Department received confirmation from the Town of Monument that they were willing to provide a connection to Palmer Lake Mobile Home Ranch, as well as confirmation from Palmer Lake Mobile Home Ranch that they would accept the connection and disconnect their wells, the Department readily agreed to the change of plans.

Despite having exhausted significant effort and resources toward implementing solutions for an improved water system and treatment for combined radium, ultimately, Palmer Lake Mobile Home Ranch decided that the best way to return to compliance was to tie in with the Town of Monument. In December 2023, the connection was completed and the wells were disconnected. Palmer Lake Mobile Home Ranch is now classified as a consecutive system receiving finished drinking water from another regulated water system, and the water being distributed to its residents is now in compliance with Regulation 11. 

While Palmer Lake Mobile Home Ranch demonstrated admirable determination in attempting to independently return the water system to compliance with all regulations, ultimately, success was found in partnership, as expressed in these testimonials from Palmer Lake Mobile Home Ranch and The Town of Monument. This highlights the important lesson in weighing perseverance against the path of least resistance: sometimes the simplest option is the best option. The Department is committed to a culture of health that prioritizes safe drinking water for all consumers and works hard to facilitate success stories such as these.

It is also important to take into consideration how existing regulations now apply to Palmer Lake Mobile Home Ranch moving forward. Consecutive water systems are still required to comply with Regulations 11 and 100, there are just differences in the applicability of certain rules. Additionally, the new water quality testing program under the Mobile Home Park Water Quality Act will begin this year. This program is designed to address community member concerns, identify water quality issues, and remediate water quality issues at parks throughout Colorado.

Did you know that Colorado has hundreds of small mobile home parks that receive finished drinking water from a regulated water system? 

QUIZ: If a mobile home park does not have a well or treatment system, but bills customers for water, what regulations apply? Choose the correct answer:

1. The plumbing code alone
2. The plumbing code and the new Mobile Home Park Water Quality Act
3. The plumbing code, the new Mobile Home Park Water Quality Act, DOLA’s Mobile Home Park Oversight program, and Regulation 11 within the distribution system
4. None of the above are fully correct; it’s complicated!

Look for the answer in a future AquaTalk article!

➽ Lauren Fracasso Compliance Specialist for South Unit

➽ Emily Clark Enforcement & Field Findings Compliance Lead

Safe Drinking Water Information Finder Tool

SWIFT Tool expands access to information about public water systems across Colorado

The department has created an online safe drinking water information finder (SWIFT) tool. The tool allows the public to access public drinking water records, system-specific results, and a summary of violations and/or sanitary survey findings along with contact information for public water systems across the state. The tool can be accessed on the department’s drinking water consumer information and data website. The tool expands transparency and access to publicly available information about public water systems across Colorado.

The data and information displayed by the tool are public information. The tool can be filtered by water system name, county, water type, and enforcement status. The tool allows the creation and sharing of individual links for any populated searches and allows the user to select various options per category. The user can download information by table. Tables can be downloaded by clicking the three dots on the upper right-hand corner of the table. Select “Export” and the preferred file format (e.g., Excel or Google Sheets). 

The tool integrates the department’s electronic record system and contains up-to-date information. For example:

• On the Public Water System table, there is a column labeled “PWS ID (Links to Records)”, if you click the link in the column, it will show all the public records related to the specific water system.
• On the Public Water System table, there is a column labeled “Enforcement”. If it shows “Open Order”, the system is currently under enforcement. If you click the link in the “Enforcement” column, it will take you to the enforcement-related records.
• On the Violations and the Inspection and Deficiencies tables, there is a column labeled “Resolved”. If it shows “Yes”, the violation and or finding has been resolved and if it shows “No”, it has not been resolved. If you believe the violation and or finding has been resolved please reach out to your compliance specialist or inspector to discuss the status further. 
• There are other record searches built into the tool, such as Reports and Notices, and Violation & Inspection Records. 

Please direct questions about the information provided on the tool to the assigned compliance specialist. 

Thank you for your partnership and commitment to making sure that Colorado’s water consumers are informed when it comes to their drinking water. 

➽ Jorge Delgado, Drinking Water Compliance Unit 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

Lead and Copper Rule Revisions and Service Line Inventories

On August 14, 2023, the Water Quality Control Commission adopted the Lead and Copper Rule Revisions into Regulation 11. The changes to Regulation 11 are effective as of October 15, 2023, but the Lead and Copper Rule Revisions have a delayed start date and won’t take effect until October 16, 2024. The Lead and Copper Rule Revisions are a comprehensive update to the EPA’s 1991 Lead and Copper Rule.

Prior to adoption the division conducted an extensive stakeholder process with 26 meetings that provided opportunities for public feedback about the proposed changes. Overall, the division gained stakeholder consensus on adopting the Lead and Copper Rule Revisions into Regulation 11 within two years after promulgation of the revisions, and many of the stakeholder comments related to clarity of the rule requirements. The division reorganized the structure of the Lead and Copper Rule Revisions and incorporated stakeholder comments into the draft rule, where possible, to increase readability and clarity.

The Lead and Copper Rule Revisions affect more than 1,050 community and non-transient, non-community public water systems in Colorado, serving nearly 6.5 million people. A key requirement due by October 16, 2024 is that all systems subject to the rule must complete an initial lead service line inventory to classify the material of each service line entering a building, regardless of ownership.

To aid systems, the division has made many resources available to systems. First, we have posted EPA and state guidance for systems on how to complete a lead service inventory and reporting forms to submit to the division once completed. Second, the division contracted with Corona Engineering and worked with stakeholders to develop an initial lead service line inventory development policy that details the expectations for completion of an inventory and clarifies many lingering issues that remained unanswered in EPA guidance. Some examples include: 

• When can galvanized pipe be considered non-lead versus galvanized requiring replacement?
• How does a system use predictive modeling to complete their inventory?
• When can a system indicate all service lines installed after 1959 are non-lead?

Third, we are contracting with WSP USA Inc to provide no-cost technical assistance to systems serving less than or equal to 15,000 people and allowing systems serving 7,500 or more people to apply for grants to assist with completing their service line inventory and service line replacement planning. This money cannot be used for physical replacement of lead service lines. Grants will be awarded on a first-come, first-serve basis to eligible applicants over several application periods. 

It’s important to note that with less than one year left to complete an initial lead service line inventory and recognizing the resources necessary to diligently complete an inventory, water systems may categorize service lines as “lead status unknown” when they cannot determine the material through an evidence-based approach. However, additional requirements, including customer outreach and planning, are triggered under the new rule if any service lines are listed as “lead status unknown.”

• Other key changes under the LCRR include, but are not limited to:
• Compliance with a new lead “trigger level” set at 10 parts per billion (ppb).
• Tap sampling requirements that target lead service lines.
• Testing water for lead in schools and childcare facilities.
• Strengthened corrosion control treatment, lead service line replacement, and public education requirements.

Please note that these key requirements (e.g., lead trigger level and sampling changes) may be revised under another new rule, the Lead and Copper Rule Improvements (LCRI). The EPA plans to finalize the LCRI by October 2024. The department is awaiting more information about the LCRI in late 2023 or early 2024. Therefore, the department will provide communication and resources related to these requirements once more is known about the LCRI.

Resources:

• LCRR guidance, FAQs, and forms are available on the department’s Lead and Copper Rule & Revisions webpage.
• Review the department’s initial service line inventory development policy.
• To request no-cost technical assistance (Systems ≤ 15,000), complete the online form.
• To apply for grant funding (Systems ≥ 7,500, visit the Water Quality Grants webpage.
• Visit the department's drinking water training and assistance website to register for upcoming Lead and Copper Rule courses (online and in-person options available) and other free training opportunities.

➽ Bryan Pilson Technical & Regulatory Implementation & Coordination Unit Manager

Aqua Answers - How do I keep everything straight?

Dear Aqua Answers,

As an operator, there’s a lot going on. How do I keep everything straight?

Thanks,

Stacie Indeno

Dear Stacie,

Public water systems need to meet many drinking water regulatory requirements to protect public health. This includes monitoring and reporting. Keeping track of all this information may be overwhelming for operators, owners, and administrators. As a result, we have developed several assistive tools that can help avoid an unnecessary violation. These include the following: 

Monitoring Schedules: 

Your online monitoring schedule is the first and best place to start. This document identifies your system’s testing requirements and deadlines. 

• You can find your system’s online monitoring schedule at the division's drinking water schedule website. You can then search by your system’s PWSID (COXXXXXXX) or “System Name”.
• Your monitoring schedule details your system’s information, including your Facility ID, Sample Point ID, and the monitoring collection period. 
• You should always have an up-to-date copy at all times. This could be an electronic copy or a paper copy kept in your compliance binder. 
• You should always use your monitoring schedule to fill out your chain-of-custody (COD) form. 
• Monitoring requirements are marked as “Sample Result(s) Received” and struck out on your monitoring schedule once they are submitted and processed (excluding total coliform sampling - please see the AIMs tool listed below). Please be aware that it may take us several days to process the data. If data is submitted incorrectly, we will not process the data. The requirement will then remain on the schedule. If there is an error, please contact your assigned drinking water compliance specialist.
• We update the monitoring schedules every Thursday. 

Am I Missing Something? (AIMS) Tool: 

You can use our brand new AIMs Tool to check total coliform sample and chlorine residual submissions. 

• The AIMS tool can identify missing samples or data errors for total coliform samples. If there is an issue with the sample result, the tool highlights the sample in red. The most common issues we see are that 1) the sample is missing or 2) the chlorine residual was not reported. 
• If you are a listed contact for many water systems (e.g., you are a contract operator), you can sort the tool by your name. This allows you to check all your water systems at a glance. 
• We have developed a User Guide: Am I Missing Something? (AIMS) Tool for tips and tricks on using this new tool. 

Reporting Guidance: 

• We always encourage systems to collect their required samples early in the collection period. Our motto is “Sample early and sample often!” 
• Fill out your COD form correctly. By law, we must process the data exactly as provided. If the result has missing or incorrect information, it will not be processed. This will result in a reporting violation. 
• All sample results must include the following information provided by the PWS: 
• PWS ID;
• Facility ID;
• Sample Point ID; and
• Collection Date.
• Except for hand pumps and disinfection waivered systems, all total coliform sample results must also include the measured chlorine residual and labeled as free or total. 
• Please do not add any extra information into the Facility ID or Sample Point ID sections. Adding additional information to these fields will result in a violation since we cannot process the sample result. If you must include more information, use the comment or address field. 
• It is always the water system’s ultimate responsibility to report by the deadline. Even if the lab is in error, we still have to issue the violation to the water system. 
• While not required, most labs submit the drinking water results on behalf of their customers. This is the easiest and preferred method for submitting sample results. 
• We highly encourage you to work with your lab and ensure that they are meeting the reporting deadlines. 
• If your lab is reporting your data, they must report the results to us as a CSV file. A CSV file helps report the data in a tabular format. You can still access these results under “My…Sample Results” in the drinking water portal.
• We have developed more guidance for properly reporting sample results, including: 
• Tips on accurately submitting sample result
• WQCD Guidance and Resources for Laboratories
• Timely reporting guidance document
• If you are submitting a COD for public notice requirements (e.g., Consumer Confidence Reports, public notice for violations, lead consumer notification, etc.): 
• Ensure a representative copy of the notice is included in your submittal. 
• Please be aware that you cannot certify that an activity was completed in the future. Only submit the COD and the representative notice copy after the required action is completed.

Mistakes and Errors: 

1. If you have made a reporting mistake, there are three main ways that you can address the error:
2. Work with your lab to have the data corrected and resubmitted. This is the preferred method and often the easiest for water systems. 
3. Submit a Sample Correction Form with all the correct information. This will help us identify and address the issue. 
4. Submit a copy of sample results with corrected information clearly provided. This is the least preferred option as we cannot readily determine what the issue is with the data.  

**Any corrections must be received by the applicable reporting deadline. If they are received after the deadline, your system will receive a reporting violation.** 

Sampling Reminders:

Sample results must be submitted no later than the first 10 calendar days following the end of the monitoring period. Generally, this is no later than the 10th of the month after the end of the monitoring period. 

• For example, you must collect a disinfection byproduct (DBP) sample every year. Thus, the monitoring period ends December 31st. Your results are due by January 10th.
• As an assistive effort, the department is sending reminder emails regarding potentially missing data around the 7th of every month. The best way to use these reminders is to submit your data early. That allows us sufficient time to process the data. If you received a reminder and your data was submitted early enough, there may be an error. Use the steps above to correct the issue.
• While not required, compliance specialists often send out additional reminders for other requirements. If you are receiving this help, take action! There may be something missing or incorrect.

Finally, if you are not receiving reminders, please make sure your contact information is correct. Your monitoring schedule lists your system’s Administrative Contact, Treatment Operator, Distribution Operator, and Owner. Remember, water systems are responsible to submit a contact update any time there is a contact change. This can be completed by either using the 1) monitoring plan wizard and checking the “01 Contacts” in the template or 2) using the contact update paper form. As always, if you have any questions or need additional assistance, please contact your assigned drinking water compliance specialist. 

Sincerely,

Aqua Answers

Upcoming Regulatory Changes for the 2020s

In January 2023 we published a recycled Aqua Talk article about upcoming drinking water regulatory changes that were expected in the 2000s. The article was recycled from our December 2000 newsletter. Back then the newsletter was called Tapping In.  In February 2023 we again published a recycled Aqua Talk article about upcoming drinking water regulatory changes. This time the article was the October 2008  Aqua Talk article entitled “New Rules in Challenging Times” about our then-recent adoption of the Long-Term 2 Enhanced Surface Water Treatment Rule, Stage 2 Disinfectants/Disinfection By-Products Rule, and the Groundwater Rule. These rules were significant and  together applied to all the public water systems in Colorado. In both the early and late 2000s the challenges faced in the U.S. were largely economic, and there were also security concerns. 

As we move forward in the 2020s, we again face tremendous challenges in our country and the water industry. The challenges are too numerous to fully elaborate, but many stem from the COVID-19 pandemic and related economic upheaval, including serious supply chain issues. We are also faced with more severe security threats than ever before. Colorado water utilities have been targeted with ransomware attacks and other physical security incidents have occurred as well.

On top of all this, as noted in the lead-in paragraph of the January 2023 recycled article, the 2020s promise to be a decade of substantial changes to the federal Safe Drinking Water Act. I believe that these will be the most significant and intense set of new and updated drinking water rules we have experienced since the early 2000s. In the early 2000s Colorado was well-positioned for a number of these rules because of the way we approached drinking water regulations over a long period of time, such as our disinfection and certain surface water treatment practices, combined with intense planning to get ahead of, or at least early starts on, the arsenic rule, radionuclides rule and groundwater rule. Now, in 2023, I believe that we are once again well-positioned to tackle a number of the challenges associated with the upcoming rules. We have instituted special projects since the late-2010s that will help us with preparations for the Lead and Copper Rule Revisions (LCRR) via the Lead Outreach and Verification Effort (LOVE) project, surface water treatment via the Disinfection Outreach and Verification Effort (DOVE) project, and extensive PFAS sampling. We also have a considerable influx of federal funding dollars via the Bipartisan Infrastructure Law (BIL) to help with the investments that water utilities will need to make in this decade. Additionally, we recently completed the development of a Direct Potable Reuse (DPR) Rule that will support Colorado’s water supply future. The table below summarizes all these new (DPR and LCRR are either completed or underway) and new rules in the 2020s. As of this writing, the EPA’s draft PFAS rule has not been published. The modest change to the Backflow Prevention and Cross Connection Control (BPCCC) Rule slated for August 2023 is not shown. 

Please note that states typically have two years, from the date of a final federal rule to adopt and implement it, with compliance dates usually starting soon thereafter. So, for the PFAS rules, states would have until Fall 2025 to adopt the rule. However, some rules have had “early implementation” requirements in the past. Each rule is unique. 

As you can see, this is quite a list. While utilities must comply with these rules, states must be able to adopt and adequately enforce the rules to maintain primary enforcement authority or “primacy”. To gain primacy for each rule, detailed “primacy packages” need to be prepared by the state and reviewed by EPA to gain approval. In talking with many of my colleagues across the U.S., many states have experienced such a degree of staff turnover in the last several years, that a number of states have no staff that have previously prepared a primacy package for EPA. But rest assured in Colorado, we still have many experienced staff that have conducted stakeholder engagement processes and prepared primacy packages. As always, we will be engaging stakeholders in developing these rules, a process well underway for LCRR, and also importantly identifying assistance, policy and training needs during those processes as well. 

We will strive to help water systems meet these rules and requirements as best as our funding and resources enable us to. But I urge you to learn about these new rules as soon as you can, so that you can best prepare your water system for the challenges that it may face in addressing them and keeping tap water safe for your customers. Thank you.

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

Drinking Water Sanitary Survey Follow Ups and Compliance - What you need to know

The Field Services Section (FSS) works with public water systems on sanitary survey inspections to ensure the production and distribution of safe drinking water. Just as water systems have inspections on a routine basis, our program also gets “inspected” by the Environmental Protection Agency (EPA) Region 8 to ensure that we meet federal requirements. Starting in 2021, EPA Region 8 conducted an audit of 86 sanitary surveys across 43 large community public water systems in Colorado. In September 2022, EPA Region 8 provided their final report. Overall, the report highlighted some of the WQCD sanitary survey processes as best practices such as public notice for field based violations, our online records system and our sanitary survey report quality. The report also  includes areas where we need to improve on sanitary survey follow ups. Going forward, we'll be working on those areas of improvement with a focus on the items below.

Type 45 Violations for Unresolved Significant Deficiencies:

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) occurs.

The EPA audit found that the WQCD was not consistently issuing 45-violations when necessary and must issue compliance advisories and treatment technique (type 45) violations in situations where a significant deficiency is overdue and unresolved. Please note that type 45 violations require Tier 2 public notice by the supplier within 30 days of receipt of the violation letter from the Compliance Assurance Section and every 90 days thereafter as long as the significant deficiency remains unresolved. Please avoid this situation and protect public health by fixing significant deficiencies. For significant deficiencies that need more time for engineering evaluations, financing and construction, a Department-approved CAP may be an option. 

Department-approved corrective action plans (CAPs):

For significant deficiencies and field violations that need more than 120 days to fix, the water system can request a Corrective Action Plan (CAP). The CAP request must include the actions the supplier will take to fix the significant deficiencies and/or violations and the schedule for completing the actions. Field Services then reviews the CAP proposal and, if appropriate, issues an approval letter. Any changes to the CAP or CAP schedule also need to be approved prior to the CAP expiring. If you are in compliance with your CAP, you may avoid the Type 45-violation with Tier 2 public notice. However, it is very important to know that community water systems still have to include any unresolved significant deficiencies and their approved CAP schedule in their annual Consumer Confidence Report.

CAP schedules are normally limited to a year unless special circumstances such as financing, engineering design and construction need additional time. Also, interim measures to protect public health may be required at any time during the CAP process. The EPA audit identified that extended timelines CDPHE allowed for unresolved significant deficiencies as a concern. As part of our follow up improvements, CAPs that are expired will no longer be repeatedly renewed. Please reach out to your inspector if you have any questions about CAPs. 

Thank you for all you do to protect your customers by resolving significant deficiencies and field violations. To see the compliance status for your water system, please look at your monitoring schedule available online at the division's monitoring schedule webpage. If you need help on technical issues or sanitary survey significant deficiencies and violations, please reach out to your inspector or 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

➽ Nicole Graziano, PE, Compliance Assurance Section Manager