Simple Fixes - chlorine addition points and hydropneumatic tanks

In Colorado there are approximately 2,100 public water systems ranging from a small gas station with a drinking water well up to Denver Water serving 1.4 million residents. Nearly 1,600 of those 2,100 public water systems serve 500 or less people. Many times, those very small systems consist of a simple groundwater well, hydropneumatic pressure tank (pressure tank), and a small distribution system. Oftentimes the distribution system at the smallest systems is only one building. Other than hand-pumped wells at campgrounds (which operate under a special rule), the remainder of public water systems must continuously chlorinate their source water and provide a chlorine residual throughout distribution greater than 0.2 mg/L. 

For some water systems, the appropriate location for the chemical injection point can be a point of confusion. This confusion may be exacerbated by the fact that the Colorado Division of Water Resources rules for well drillers has traditionally defined the scope of the water well supply system as being part of the well driller’s responsibility. Typically this is up to and including the pressure tank if installed. The definition from the well driller’s rule is as follows:

 5.2.56 “Water well supply system” includes all components of a groundwater well, pump, drop pipe, pitless adapters or units, other pumping equipment, storage tanks or cisterns, and piping and connections between the well and its point of discharge from the pressure tank, if such a tank is installed. 

Based on the above definition, a well driller may install a water well, pressure switch, and a pressure tank. Then, when a system becomes a public water system, it must add chlorine feed. Typical installation of chlorine feed involves linking the feed pump to an existing pressure switch that turns on both the well pump as well as the chlorine injection pump. In some cases, we have discovered that a public water system has installed their chlorine injection point at a location after the hydropneumatic pressure tank. 

The main issue with having the injection point after the pressure tank, but the chlorine feed pump linked to the well pump is that the pressure tank can discharge water to the distribution system even when the well pump isn’t running. This means that raw water (unchlorinated well water) would be fed to distribution without a chlorine residual, which may not be safe.  Per Sections 11.11 and 11.8 of the Colorado Primary Drinking Water Regulations (Regulation 11), water must be continuously chlorinated at the entry point. Therefore, whenever our field inspectors discover a situation where the pressure tank may be located in the potentially unsafe configuration, the issue is cited as a significant deficiency in the inspection findings and must be repaired.  

Fixes to the improper chlorine feed point:

Solution #1: Move the injection point:

Many public water systems choose to simply relocate their chemical injection location to a location prior to the pressure tank. This change will solve the significant deficiency of having unchlorinated water enter the distribution system. A typical schematic after correction is as follows:

*image courtesy of University of Georgia Extension

In the above example, please note that a carbon filter may remove all the chlorine residual, which is not allowed in Colorado because a 0.2 mg/L chlorine level must be maintained throughout the distribution system. Also, the chlorine metering pump can continue to be linked to the well pump on a pressure switch. 

Some water systems and water professionals have expressed concerns about the chlorine feed degrading the rubber bladder in the pressure tank and have indicated they prefer to keep the chlorine feed location after the pressure tank. If that is the case, then solution #2 may be a better option.

Solution #2: Install a flow switch to inject chlorine when there is flow

A second solution is to leave the chlorine injection point after the pressure tank and install a flow switch so that the chlorine feed pump is activated when flow is detected rather than when the well pump is turned on. A typical installation of a proportional flow meter or flow switch can be seen in our pre-accepted groundwater disinfection design document and is in the following schematic:

Typically, flow switches can be purchased from a variety of locations including usabluebook, amazon, grainger, omega, and more. The department strongly recommends small water districts employ personnel who have experience working with and installing such components if they choose to configure their system to work with a flow switch and it has been previously plumbed to use a pressure switch. Certified plumbers may also have the expertise necessary to perform the system upgrades.  While we do not require design approval to convert from a pressure switch to a flow switch, the department is happy to provide technical assistance if there are questions about the installation.

Coming Down the Pipe - Policy Updates

2021 Storage Tank and Cross Connection-Control Policy Updates 

In August 2020, the Water Quality Control Commission updated the Colorado Primary Drinking Water Regulations (Regulation 11). While there were a few minor changes to several rules, there were significant changes to the Storage Tank Rule (Section 11.28) and to the Backflow Prevention and Cross-Connection Control Rule (Section 11.39). 

During the stakeholder work for the August 2020 rulemaking, the department acknowledged that several key policies would need to be updated as a result of a successful rulemaking effort. Also, the department acknowledged that additional work on guidance documents like the annual backflow report template and the periodic tank inspection checklist needed to be completed.

As a first step in these updates, the department identified minor changes in four policy documents to reflect the updates to the regulation. The department considers these changes relatively minor and is seeking stakeholder feedback on the changes. Once the policy changes are finalized, the department intends to launch a second stakeholder process to update the guidance. 

There are four key policy documents that must be updated to reflect the new language in Regulation 11. These were established policies the department published after the 2015 Regulation 11 rulemaking, but given the Regulation 11 updates in 2020, there were items that needed updating and clarifying. Please check our engagement page for more specific details on the minor modifications to these 4 policies:

Policy 7: Backflow Prevention and Cross Connection Control Policy

Policy 10: Sanitary Defect Policy (section about storage tanks only)

Policy 12: Storage Tank Rule Alternative Inspection Schedule Policy

Policy 15: Storage Tank Rule Inspection Methods Qualified Personnel Policy

➽Tyson Ingels| tyson.ingels@state.co.us

Program Manager Message

Looking Ahead to the 2020s

A few months ago, we republished an Aqua Talk article I authored in late 2009 entitled “Perspectives on a New Decade.” It looked back on what happened in the 2000s and attempted to look forward to what might happen in the 2010s. Then, in December we published an article titled “Perspectives on the 2010s” reviewing what actually happened in the 2010s. Now let’s  look forward to the 2020s. I know this is coming out a year late, but considering what happened in 2020, that worked out for the best as no one could have predicted the start to this decade that we actually experienced. 

In the 2020s we will not take our eye off the ball in terms of focusing on preventing waterborne disease outbreaks. We intend to continue vigorous implementation of our rules regarding disinfection waivers, storage tanks, backflow prevention and cross connection control, disinfectant residual in distribution, hand pumps, and water haulers. We hope to see a continued positive track record of no waterborne disease outbreaks and only rare E. coli violations in drinking water. However, new challenges will arise on this front as well. Pathogens present in biofilms have recently been shown to cause most of the serious health problems and health care costs related to waterborne disease in the United States. As EPA reviews the suite of Microbial/Disinfection Byproducts Rules in the early to mid-2020s, they will be considering these pathogens like Legionella and also more disinfection byproducts and different health endpoints, such as fetal development.

The 2020s will involve continued focus on lead and PFAS. EPA just finalized the Lead and Copper Rule Revisions (LCRR). The new administration is going to review this rule, and once it is truly finalized, Colorado will have two years to adopt the federal rule. Adopting this rule will involve a thorough stakeholder process, and of course our final rule must be at least as stringent as the federal rule. However, once the rule is final it will take years of effort to fully implement the rule, especially for systems with lead service lines. The revised rule will include efforts to sample at schools and daycares, and we will be able to provide some support in that area using a federal grant program. 

EPA also finalized their regulatory determination for PFAS compounds and indicated that they will move forward with MCLs for PFOA and PFOS. Again, the new administration may revise this approach. Additionally, many more PFAS compounds must be included in the fifth Unregulated Contaminant Monitoring Rule (UCMR5) sampling efforts under federal law. Fortunately, the sampling that we have done proactively in the late 2010s shows that we likely do not have a large number of water systems with high PFAS levels, but only about half of the community systems have been sampled so far.

As climate change continues to impact Colorado’s water supplies and the temperature of state waters, we could also see more harmful algae blooms and the threat of cyanotoxins being present in drinking water sources and possibly tap water. We have good programs in place to try to address underlying nutrient pollution and monitor for blooms, but these programs are not comprehensive so we are at some risk.

During the 2020s, we also intend to develop a regulatory framework including regulations, policies and guidance to assist water systems in planning and implementing direct potable reuse if needed. Direct potable reuse can help Colorado move forward with our State Water Plan. The framework for direct potable reuse is intended to have flexibility and ensure safe drinking water and help with public support. But we also intend to prevent communities without adequate technical, managerial, and financial capacity from undertaking such a serious effort.

While drinking water in Colorado is safer today than ever before, the world is not necessarily safer. In 2020 we saw considerably more vandalism and cyberattacks against drinking water infrastructure than normal. I hope that trend does not continue, but unfortunately I believe that this will be an added pressure on all of us for the foreseeable future.

It will take resources for water systems to continue their track record of improving water quality and for the Safe Drinking Water Program to enhance our services in support of those efforts. I am hopeful the recently increased federal funding will continue and be increased further to help us with implementing the expected new LCRR and PFAS rules plus help us support security needs.

Even with all these expected challenges ahead and those that we cannot anticipate as well, I am not losing sight of the fact that, as mentioned before, our tap water is safer than ever and that is something to celebrate and be proud of. We launched a Culture of Health, and I believe it is catching on. We will continue our partnership with water systems, EPA, local health departments and operators to foster a Culture of Health throughout the community of water suppliers. With a Culture of Health firmly entrenched in all of us, we will be ready to face challenges and succeed! I cannot predict what the drinking water world will look like in 2030, but hope we have some fun this decade on that journey!  

➽Ron Falco, Drinking Water Program Manager

Indroducing the new Aqua Man: Aqua Answers

Aqua Man recently retired but fear not, your questions about all things water can now be directed to the new Aqua Talk feature “Aqua Answers.” This new title is intended to serve as a respectful, gender neutral name to reflect the diverse water professionals and champions in Colorado. 

Dear Aqua Answers,

I heard recently that operators now need to report storage tank rule violations to the state, and not wait for the sanitary surveys that take place every few years. Is that right?

Respectfully,
Hope N. De'Fecte'

Dear Hope,

Yes. That is correct. However, that requirement is not new. Revisions to the storage tank rule were proposed as a result of our recent work with stakeholders prior to the August 2020 rulemaking before the Water Quality Control Commission. During that process, everyone agreed that within the storage tank rule, we should reference back to an existing requirement in the regulations that covers reporting violations. Section 11.35(2)(c) of the Colorado Primary Drinking Water Regulations (Regulation 11) already required that suppliers report all violations within 48 hours, unless a different timing is specified in the regulations. This means that violations of the storage tank rule were already required to be reported within 48 hours. It was agreed to reference back to this requirement in the storage tank rule. The purpose of this change was to add clarity and help avoid finding out about a violation until a sanitary survey that takes place a couple of years later, which makes the timing of public notice more awkward and more challenging for the public.

Hope, as I am sure you know, we are working with water systems across Colorado and at all levels to institute a Culture of Health. The Culture of Health needs to be adopted at the state level, but even more importantly by all the people working that design, operate, manage and own public drinking water systems. We all need to work together to help make sure that drinking water is always safe, and that if there is an issue we will let people know. So, yes it is important to make sure that storage tanks are free from defects to keep drinking water safe. But it is also important to work with us at the health department to implement all the drinking water rules and report violations to us in accordance with the regulations. Thank you so much for your question!

Sincerely,
Aqua Answers

Assistance Grants Successes

Meadow Mountain Water Supply 

The calendar year 2020 wasn’t all bad, especially for drinking water systems that received funding under the assistance grants program. With support from division staff, this program provides funding up to $25,000 to public drinking water systems that need help addressing a water quality challenge. 

One system that received funding from this program, Meadow Mountain Water Supply, installed corrosion control treatment to ensure their drinking water is in compliance with the lead and copper rule and that all the water distributed to their customers is safe. As a small system serving 80 residents, the project expense was a challenge for the system. With assistance grant funding, Meadow Mountain installed a soda ash system to prevent the water from leaching lead out of homeowners’ indoor piping. According to Rachel Barkworth, the administrative contact for the system, “We were delighted to be recommended for the assistance grant program as we are a very small community system and have a lot of financial challenges. The grant came at just the right time to assist us in accomplishing our goals to maintain compliance. The grant process itself, although requiring a lot of information, was clear and easy to follow once approved. Division staff was especially helpful in navigating this process.”

Town of Dolores

The Town of Dolores also used assistance grant funding to address challenges with disinfection contact time. After a visit, the division recommended that the Town of Dolores move their entry point residual disinfectant monitoring location to allow the system to more accurately calculate their contact time and meet the requirements for surface water disinfection. Assistance grant funding paid for approximately 50% of the total project cost and greatly helped the system complete this necessary work during a stressful year. 

This program begins coordination efforts with division staff in August of each year. If you believe your system would be a good fit for this type of project, please contact Kaitlyn Beekman at kaitlyn.beekman@state.co.us. 

➽Kaitlyn Beekman, Communications & Special Projects Unit

Operator Certification Exams: Is Remote Proctoring Right for You?

Beginning January 12, 2021, Colorado’s operator certification exam administrator, PSI, began offering the option of remotely proctored examinations. This option allows approved exam candidates to take their certification tests from their home computers. However, before signing up for a remotely proctored exam, candidates need to make sure they have the right equipment, the right environment, and are able to comply with all security and professional  requirements. 

System Requirements for Remotely Proctored Exams

Your computer set-up must include the following:

• Web camera
• Speakers 
• Microphone
• Stable broadband internet connection

PSI provides a compatibility check on its scheduling website. This online tool will check the audio/video features of your computer (the one you plan to use for the exam) as well as verify that your internet browser, platform and connection speed are sufficient. You should use the online compatibility tool only when you are in the location where you will be testing. Please note, you will be required to verify your system’s functionality again immediately before beginning your exam. If you have any questions about your compatibility check, you may contact PSI’s remote proctoring technical support team at 844-267-1017.

Environment Requirements

The room where you are testing must be a secure testing environment:

• You will be asked to scan the room from which you are testing prior to launching your exam. You will need to use your web camera. Electronic devices and recording devices, including cell phones, pagers, cameras (other than your web camera), etc. are not permitted in the testing environment.
• If there are notes, drinks, a box of tissues or any such items on your desk, you will be asked to remove them prior to beginning the exam.

Security Requirements

• You must present a valid, unexpired identification in order to take your test. Military IDs are not accepted.
• You may connect with PSI Remote Proctors for testing up to 15 minutes prior to your scheduled start time provided your exam is ready to launch. Your launch button will be enabled when your exam is fully prepared for delivery.
• No conversing or any other form of communication is permitted once your exam has been released. You will want to make sure no one enters the room while your test is in progress.
• If you need assistance during your exam, you should initiate a chat with the online test administrator using the exam chat tool.
• You may not exit the camera view or use your cell phone or other electronic devices during the examination.
• Your hands must be visible to the camera at all times. Talking or mouthing words while testing is prohibited.
• You are prohibited from reproducing, communicating or transmitting any test content in any form for any purpose. Copying or communicating content is a violation of PSI security policy. Either one may result in the disqualification of examination results, may lead to legal action and will be reported to the Colorado Department of Public Health and Environment.
• The only electronic or recording device allowed in the testing environment is your testing machine.

Professional Requirements

• PSI requires all employees and exam takers to conduct themselves in a professional and courteous manner at all times. Exhibiting abusive behavior towards a proctor via chat will be reported to the Colorado Department of Public Health and Environment and may result in criminal prosecution.

Remotely proctored exams add one more layer of flexibility for the Colorado Certified Water Professionals Program. In some cases, where individual operators do not have the equipment and/or environment necessary to take advantage of remotely proctored exams, employers may be able to provide both the equipment and the secure testing space. Otherwise, if you are not fully equipped and prepared for a remotely proctored exam, save yourself a lot of frustration by scheduling your exam at a PSI test center.

➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison

Facility Operator Certification: Stakeholder Input

The Facility Operators Certification Program recognizes the value and importance of stakeholder involvement in any initiative to improve the program. However, depending on the issue, the program may invite input in a variety of ways. In May 2017, the Water and Wastewater Facility Operators Certification Board (board) conducted a customer satisfaction survey. The survey was sent to nearly 10,000 individuals. Eight hundred and ninety one (891) responses came back to the board, approximately 70% from certified operators. Based on the feedback, the board took action to improve operator services with minimal increase in costs to operators. The Colorado Certified Water Professionals (CCWP) Portal is a direct result of feedback from the survey.

In 2019, following the board’s adoption of a new mandatory regulatory training requirement, a stakeholder group was formed to develop guidance for the new requirement. Interested individuals met in person and by phone to draft the guidance document and present it to the board for approval. The board adopted the guidance on June 25, 2019.

The board expects the division to seek stakeholder input whenever substantive revisions to Regulation 100 or board policies are proposed by the division. This allows the division to consider other perspectives and potentially modify its proposal prior to the board’s formal hearing process. If stakeholder suggestions to the division do not result in changes to the proposed revisions, stakeholders can still present their views about the revisions to the board through the formal hearing process.

In addition, the board sets aside time at each of its meetings for public comment. We encourage you to attend a board meeting, which can be done virtually now.

There is a difference between a survey and a stakeholder work group. There is a difference between a stakeholder work group and an opportunity for stakeholder comment on proposed document revisions. The division’s stakeholder process invites stakeholders to speak to a different audience than the board’s formal hearings. A board or division-initiated invitation for feedback limits comments to the issue at hand, while the invitation for public comment at board meetings gives stakeholders an open-ended opportunity to raise any concern with the board at any time.

Through all these processes, stakeholders have a say in program improvements. Stakeholder perspectives and ideas are invaluable to the board and to the certification program. Let’s keep on working together, and listening to each other, to continually improve the operator certification program.

➽ Nancy Horan, Facility and Operator Outreach and Certification Board Liaison