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General Information | Emergency Planning | Resource Shortage | Operators | Drinking Water (Conducting Sampling, Labs, Backflow Prevention) | Wastewater & Stormwater | Swimming Pools |Other Water Operations


This page will be updated as new questions and information become available

Table of Contents

General Information | Emergency Planning | Resource Shortage | Operators | Drinking Water (Conducting Sampling, Labs, Backflow Prevention) | Wastewater & Stormwater | Swimming Pools | Other Water Operations

General Information

  1. Where can I go for up-to-date information about COVID-19 and water?

The state has a new webpage that is continuously updated with new information, press releases, executive orders, public orders and other important information. EPA has a new COVID-19 page and the Center for Disease Control also has a webpage with information. This FAQ summarizes some of this information.

  1. What should water-personnel know about the Governor’s recent executive orders?

The Governor regularly issues new executive orders to slow the spread of COVID-19. Currently, working from home is permitted and encouraged where possible. Critical workplaces are exempt from the orders and include public water and wastewater work. For more information about executive and public health orders, please see the main department COVID-19 webpage. When traveling for work, it is recommended you have a workplace badge or a general letter from your organization that demonstrates you are a staff member working for the water-industry and so are exempt from the Governor’s order. The EPA has provided a general letter template that state, localities, and water utilities can use to provide documentation to essential workers.

  1. What resources are available to help water and wastewater systems think through how to respond to and be prepared for this pandemic?

The EPA developed an Incident Action Checklist related to the COVID-19 pandemic which has a number of useful resources linked within. The Water Quality Control Division in the state health department is also working to develop training to support utilities and operators during the pandemic.

  1. Is drinking tap water safe?

The World Health Organization has stated that the “presence of the COVID-19 virus has not been detected in drinking-water supplies and based on current evidence the risk to water supplies is low.” EPA’s drinking water regulations require treatment at public water systems to remove or kill pathogens including viruses. The Colorado Department of Public Health and Environment is working with water treatment systems so that they continue to follow these regulations. If a system violates drinking water regulations, the system is required to release public notice to all its customers. It’s important for the public to be connected so that they are notified.

  1. Can COVID-19 be transmitted through wastewater?

According to the Centers for Disease Control and Prevention (CDC), “coronaviruses are susceptible to the same disinfection conditions in community and healthcare settings as other viruses, so current disinfection conditions in wastewater treatment facilities are expected to be sufficient. This includes conditions for practices such as oxidation with hypochlorite (i.e., chlorine bleach) and peracetic acid, as well as inactivation using UV irradiation.”  This means that it is important to keep up with routine maintenance, especially when it includes disinfection. You can find the CDC’s page on COVID-19 and municipal water here.

  1. Is drinking water or wastewater being tested for COVID-19?

Common disinfection treatment techniques are expected to be effective for COVID-19. Drinking water treatment involves multiple barriers and treatment to prevent germs in drinking water. Wastewater treatment involves multiple treatment processes including disinfection before discharge of treated wastewater. Individuals with COVID-19 shed viral fragments into raw wastewater. Researchers have developed a method to test for viral fragments (i.e., not live virus) and some wastewater treatment districts are beginning to pilot analyzing periodic samples of wastewater influent to provide insights into trends of COVID-19 prevalence in the community leading to the wastewater treatment facility. Not all utilities are doing this testing and the studies are only in their beginning phases , but if found viable, the idea could potentially  be used on a larger scale.

  1. I heard that state or federal grants or loans may be available to help entities facing challenges with COVID-19. Will any money be available to water/wastewater utilities

The Water Quality Control Division is not aware of any COVID-19 funding for utilities at this time. As soon as we learn of anything, we will notify stakeholders. We recommend that utilities interested in pursuing grants document their costs associated with COVID-19 impacts, including tracking people's time spent on specific COVID-19 activities, documenting the activities, saving receipts for anything purchased, loss of revenue. This may help with cost recovery, but such requirements have not been defined.  

Emergency Planning

  1. Are public utilities expected to uphold the routine maintenance of system facilities during an emergency?

The Department of Homeland Security declared water, wastewater systems and other utility operations as “essential critical infrastructure workers” during the COVID-19 response. This means that water and wastewater systems have a special responsibility to continue normal operations as modified to account for CDC workforce and customer protection guidance.  For more information on the definition of essential critical infrastructure workers, visit the Department of Homeland Security webpage.

Additionally, in the EPA’s COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program memo, EPA states that “Public water systems have a heightened responsibility to protect public health because unsafe drinking water can lead to serious illness and access to clean water for drinking and handwashing is critical during the COVID-19 pandemic.” Water system operators should continue normal operations and maintenance of their facilities.

  1. Are laboratories considered “essential services” right now?

Yes. Both the department and EPA, per the EPA’s COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program memo, “expect laboratories performing analysis for water systems to continue to provide timely analysis of samples and results.” Certified laboratories should immediately contact the department at 303.692.3556 if issues arise that prevent the laboratory from conducting analyses of drinking water samples.

  1. We have heard that some systems in Colorado and other states have gone to a "sequestered" operations mode for staff. Is this true/allowable?

Yes, this is true. We are aware that some systems in Colorado and other states are sequestering staff, or isolating staff, at their facilities in various ways or durations. Many systems are also increasing remote operations. These approaches are acceptable and encouraged as long as compliance can be maintained. We have sequestration resources available on our main COVID-19 and water resources webpage in the Continuity of Operations Toolbox section, under the Emergency and Continuity of Operations Plans drop down.

Need an example?  Des Moines Water Works in Iowa sequestered 21 operators (out of a total staff of about 60) to operate their 3 plants in the Des Moines metro area. They work 12 hour shifts, 7 days a week. Some are scheduled to work 2 weeks at a time, others are scheduled on different rotations. They have set up camper trailers for the operators so they can get some rest and relaxation during their off-shift. Here is an article about it: https://iowacapitaldispatch.com/2020/03/19/des-moines-water-works-plant-operators-to-be-sequestered-in-campers/

  1. What kinds of operational impacts should we expect from a pandemic situation? What can we do to be prepared?

All public water systems should plan for continuity of operations during a pandemic or any other type of emergency (e.g., flooding or forest fires). The EPA developed an Incident Action Checklist related to the COVIV-19 pandemic which has a number of useful resources linked within. During a severe pandemic, the most serious expected challenge for public water systems would be absenteeism from employees who are sick, who are taking care of others, or who must stay home for other reasons. Planning for staffing shortages — both at your plant and at businesses you rely on — is one of the most critical things you can do to ensure continuity of operations.

  1. Can the state help with public and risk communication in the event of a boil water order or large spill?

During an emergency such as a spill or specific event at a utility (e.g., line break, sewer overflow, flood), we still expect utilities to manage the public information function for their district. This may include issuing emergency boil water advisories that require  24-hour public notice (i.e., tier 1 public notice) to all of a system’s customers. The department will always provide assistance with drafting and reviewing the required public notice. We have an easy-to-use public notice generator available at www.colorado.gov/pacific/cdphe/pnrule (use the “Create public notice” link). Additionally, in addition to direct delivery requirements, press releases and other social media outlets (e.g., Facebook, Next Door, etc.) have been an effective way to reach consumers in a relatively short amount of time. If you are unable to meet the direct delivery requirements (e.g., due to accessibility issues), please contact the department immediately at 1-877-518-5608.

For sanitary sewer overflows, the district should implement methods to cleanup and mitigate the sewer overflow that are standard for sewage overflows (e.g., collect ponded sewage, disinfect area, restrict public access). For example, disinfection with chlorine should remove or inactivate the virus that causes COVID-19. The CDC has indicated wastewater treatment plant operations should ensure workers follow routine practices to prevent exposure to wastewater. These include using engineering and administrative controls, safe work practices, and personal protection equipment (PPE) normally required for work tasks when handling untreated wastewater. No additional COVID-19–specific protections are recommended for employees involved in wastewater management operations, including those at wastewater treatment facilities. More information is available at: www.cdc.gov/coronavirus/2019-ncov/php/water.html and www.wef.org/coronavirus.

For public information officers working districts, we highly recommend coordinating with your local public health agency public information officers. The department is continually updating website resources regarding health issues related to COVID-19. This information can be found online at www.colorado.gov/pacific/cdphe/2019-novel-coronavirus.

  1. What adjustments are we allowed to make to keep our workers safe?

Employee safety is always a high priority. If you are unable to maintain your treatment or collect your required samples (for either drinking water or wastewater) due to staff safety concerns, please notify the department immediately. We can help you to try and maintain compliance. However, violations will still need to be issued and public notice implemented, as required. The department has created guidelines for worker and customer protection in essential industries that can be found here.

  1. Can essential water/wastewater treatment personnel be prioritized for COVID-19 testing or screening? Some utilities would like to "quarantine" healthy individuals at their treatment plants to assure that drinking water and sewage treatment facilities can function during this crisis.

You can find the current testing criteria here as well as information on if, and how, the state will prioritize tests. On May 26, 2020, the state issued an updated testing strategy. Colorado can now test:

This information on this COVID-19 testing webpage changes frequently so we encourage you to look often at this webpage, and the state COVID-19 homepage. Currently, these criteria do not allow for testing apparently healthy workers to confirm they do not have COVID-19.

All employees should be screened using this form and protocols. Everyone should be advised to avoid touching their eyes, noses and mouths and to cough or sneeze into a kleenex or into the bend of the elbow.

  1. When a COVID-19 vaccine becomes available, can essential water/wastewater treatment personnel be prioritized for vaccination?

The state does not have any information available yet on who would be prioritized for vaccination, once a vaccine becomes available.

Resource Shortage

  1. What can we do if we experience labor shortages?

It is good for organizations to have a formal labor shortage plan detailing how they will remain in operation if a substantial portion of the workforce is unavailable. These plans should include procedures for augmenting staff as needed due to incapacitation or loss of available workforce. Also, mutual aid may be available through CoWARN, so it is important to make sure you are a member. Please see the Water Information Sharing and Analysis Center’s Business Continuity Planning for Water Utilities guidance document for more information on continuity planning.

  1. What do we do if we experience chemical shortages?        

If we become aware of specific shortages or issues commonly facing water and wastewater systems, we will keep both the COWARN network and this fact sheet updated.

During all kinds of resource shortages, whether of supplies or labor, utilities should utilize the CoWARN network. CoWARN is an organization that facilitates mutual aid and resource sharing between water and wastewater utilities, and it is free to join. Once a utility has signed the mutual aid agreement and becomes a member, they can “activate CoWARN” which will send out an email to all 162 CoWARN members with a request for help. Members will then respond if they are able to offer assistance. Often it is easy, quick, and inexpensive to get equipment and personnel help from a neighboring utility.

  1. Can a supplier substitute substituting Calcium Hypochlorite for Sodium Hypochlorite to maintain chlorine residuals in the drinking water. Does the supplier need approval? And does the Solution need to be NSF 60 certified?

The Water Quality Control Division would generally allow a water system to utilize calcium hypochlorite in place of sodium hypochlorite bleach on a temporary basis without approval. We would ask for an email informing us of the practice. Also, that is assuming that no new feed equipment was being installed (like a calcium hypochlorite tablet feeder) but rather that a batch of concentrated chlorine solution was being mixed manually to feed the existing chemical pumps. If brand new equipment is being installed, we ask that the entity work with our engineering group (email CDPHE.WQEngReview@state.co.us) for a quick review. While we would prefer that all calcium hypochlorite is approved for potable water use and meets ANSI/NSF 60 standards, we would allow for pool chlorine tablets to be used provided they consist of only calcium hypochlorite and no additional additives or chemicals.

Operators

  1. Are operator certification exams remote? What about Training Units?

At this point, there is not an option to take operator certification exams remotely. The Water and Wastewater Facilities Operators Certification Board and its contractors are exploring options in the future but there are no immediate plans to change the way tests are delivered. As updates develop, information will be posted soon to the board's website. You can also visit PSI’s website as they regularly update this webpage with information about exams.

Operators are still able to meet their training unit requirements through online webinars or online courses. You can learn more about these online courses through this summary.

  1. I am an operator and want to help other systems in need. What do I need to know and how can I let systems know I’m available to assist?

As long as a system has an Operator Response in Charge certified at the appropriate level in Colorado, then non-certified operators and out-of-state operators can work for a system under the direction of the Operator Response in Charge. This requires a written operating plan that covers the delegation of operator duties.

Individual operators can sign up to the CoWARN to learn which systems are in need of help and can offer assistance if available. Here’s how it works:

Drinking Water

  1. Can the virus spread through drinking water?

According to the CDC, “the virus that causes COVID-19 has not been detected in drinking water. Conventional water treatment methods that use filtration and disinfection, such as those in most municipal drinking water systems, should remove or inactivate the virus that causes COVID-19.”

  1. I cannot find Clorox bleach to disinfect my water. Are there other bleach products I can use for drinking water disinfection?

Yes, there are many bleach products that are safe for the disinfection of drinking water.  The department has an informational sheet about which bleach water systems can use. An excerpt from the document is as follows: water systems may use any regular bleach product provided it meets the following:

  1. I am a public drinking water system and want to make sure my contact information is up-to-date. How do I do that? What if I have to make a contact change?


All public drinking water systems can easily check to see if their contact information is up-to-date. Current contact information is available on each system’s monitoring schedule. If the contact information is no longer accurate, systems should complete a contact update using the monitoring plan wizard (select “01 Contacts” under the Individual Templates section) or use the paper update form. Once complete, upload the document to the drinking water portal or fax the form to 303-758-1398 ((the division receives faxed forms electronically using a secure platform). If you have questions, contact your system’s drinking water compliance specialist.

Conducting Sampling

  1. With everything going on with COVID, is monitoring under the Unregulated Contaminant Monitoring Rule (UCMR4) still required?

While a majority of the required sampling for most systems occurs at the entry point, some monitoring is required at sources and in the distribution system. The UCMR4 program has some flexibility for rescheduling sampling for situations such as this COVID-19 pandemic. Please note that most systems have been able to collect their UCMR4 samples by using alternative locations or by gaining access to facilities closed under the Stay at Home order to collect their samples. To request a change in your schedule:

If you need to find an alternative laboratory, please see the list of EPA-approved UCMR4 laboratories.

  1. What can drinking water systems do when faced with challenges accessing needed sample sites? Are we still expected to follow our regular sampling schedules during an emergency?

During an emergency, we still expect utilities to take drinking water samples, such as chlorine and bacteria samples, from the required sampling locations. To not sample appropriately could create another health risk to the public. It is a good idea to identify alternative locations now so that you would be ready to use them in an emergency.

The department realizes that accessibility during an emergency may be limited, however public health still needs to be protected.

For total coliform sampling, systems may have to collect samples from outside spigots, hydrants, etc. to avoid going into people's homes. We highly encourage systems to review their current total coliform sample siting plan to make sure it is up-to-date and includes readily accessible sampling sites that are representative of distribution system water quality. Please contact your compliance specialist and we can help you with updating your plan. Colorado utilities shared their total coliform rule sampling plans.

For disinfection byproduct sampling, many of our regulated systems are on reduced monitoring (i.e., annual monitoring). Please visit your online monitoring schedule at www.wqcdcompliance.com/schedules. We highly encourage systems to collect their disinfection byproduct samples early in the monitoring period. This allows ample time to both collect and analyze the samples. If you have accessibility issues, please contact the department. We will work with your system to identify other possible monitoring sites that meet the regulatory requirements (e.g., are within five sample sites of the original location).  

For lead and copper monitoring, approximately 75% of our public water systems are on annual monitoring (i.e., required to sample for lead and copper June through September). Again, we highly encourage systems to collect their samples early in the monitoring period. If a sample site is unavailable, you may collect a sample at another site in your sampling pool (that meets the tiering requirements). Please contact your compliance specialist if you need assistance with identifying additional sample sites.

Please be aware that the department is not waiving any drinking water regulatory requirements because we must ensure public health is protected through their drinking water. All monitoring and reporting requirements still apply and any violations will continue to be issued. It is important that the public be made aware of drinking water problems via the public notice rule as required by both the federal Safe Drinking Water Act and Colorado Primary Drinking Water Regulations.

If there are any accessibility issues with any of your treatment or distribution system samples, please contact your system’s drinking water compliance specialist or contact us at 303.692.3556.  

  1. Can public drinking water systems choose to collect all of their TOTAL COLIFORM samples from outside locations in order to prevent community spread and as part of social distancing measures?

Yes. If a system chooses to collect total coliform samples from outside locations, such as a hose bib, the department recommends that the supplier take the necessary precautions to ensure that the sample tap is properly cleaned and disinfected with bleach or alcohol before the sample is collected. Please be advised that the department will not invalidate positive total coliform or E. coli results just because the samples were collected at outdoor locations.

If the outdoor sample location is not from a previously specified sample location identified within their total coliform sample siting plan, the supplier must update its total coliform sample siting plan and make sure that the new site is representative of distribution system water quality. Systems can easily add their total coliform sample sites using the portal. If you have any questions, please contact your drinking water compliance specialist.

  1. Can public drinking water systems choose to collect their DISINFECTION BYPRODUCTS samples from outside or alternative locations in order to prevent community spread and as part of social distancing measures?

Yes. If a supplier chooses to collect disinfection byproducts from an outside or alternative location the supplier must ensure that the sample site is representative of high TTHM and/or HAA5 concentrations in accordance with Regulation 11. However, if a normal sample location is not available, suppliers are allowed to collect a sample from a location with similar water quality and in close proximity to the original site. All sample site changes must be submitted to the Department. Systems can easily report sample site changes using the portal. If a system is unable to collect a sample from an area that represents high TTHM and/or HAA5 concentration, it is possible that a violation will have occured. If you have any questions, please contact your drinking water compliance specialist.  

  1. Can public drinking water systems choose to collect their TOTAL COLIFORM samples from a site more than once a month to meet the number of required samples and to prevent community spread and as part of social distancing measures?

Yes, as long as the proposed sampling site is representative of water quality in the distribution system and is clearly identified in the system’s total coliform sample siting plan.

The department recommends the following:

Required Minimum Number of Total Coliform Samples (per Monitoring Period)

Recommended Number of Routine Total Coliform Sites  (Excluding Repeat Monitoring Locations)

1 to 30 samples

At least one sample site per number of samples required. For example, a system that is required to collect 9 total coliform samples should have at least 9 sample sites.

40 to 50 samples

At least 30 sample sites

60 or more samples

Half the number of sample sites as samples required. For example, a system that is required to collect 240 samples should have at least 120 sample sites.

Any deviation from the table will require a department approved alternative total coliform sample siting plan. For any questions, please contact your drinking water compliance specialist.

  1. Can public drinking water systems collect all of their total coliform samples on the same day or collect all of the samples during the first week of the month?

The drinking water regulations require that public water systems collect their total coliform samples at regular time intervals throughout the month. The purpose of this requirement is to assess the safety of the drinking water throughout the monitoring period. Only groundwater systems that serve less than or equal to (<) 4,900 people are allowed to collect all of their samples on a single day. In Colorado, approximately 85% of our regulated systems are only required to collect one total coliform sample per month (since they serve less than or equal to (<) 1,000 people). We always recommend that these smaller systems sample early in the month and follow their total coliform sample siting plan.

For larger systems that are required to sample at routine intervals, the department requires that systems collect samples in accordance with their total coliform sample siting plan. These systems can still collect samples early in the sampling interval - for example on the 24th of the month instead of the 30th of the month for a fourth week sample interval.

Population Served Range (people)

Recommended Sampling Intervals

1,001 – 4,900

Sample twice a month at regular intervals, unless the system is a groundwater system that serves less than or equal to (<) 4,900 people

4,901 – 12,900

Sample twice a month at regular intervals

12,901 – 17,200

Sample three times a month at regular intervals

17,201 – 25,000

Sample four times a month at regular intervals

25,001 or more

Samples collected at regular intervals throughout the month

  1. Can public drinking water systems choose to collect all of their LEAD AND COPPER samples from outside locations in order to prevent community spread and as part of social distancing measures?

No. Lead and Copper samples taps are required to be collected a “FIRST-DRAW TAP SAMPLE” which means a lead and copper tap sample that is collected, without flushing the tap, where the water has stood motionless in the plumbing system for at least six hours. Residential samples must be collected from the cold water kitchen sink or bathroom sink tap. Samples collected at nonresidential buildings must be collected at an interior tap from which water is typically drawn for human consumption.

If the supplier does not have access to the highest risk tier sites as specified in their monitoring schedule they need to document the situation through the Unavailable High Risk Sites form. The department recommends that the supplier attempt to collect samples throughout the full monitoring period whenever possible. If a supplier is not able to collect samples at the required number of highest risk tiered sites by the end of the monitoring period it is possible that a violation will have occured. If you have any questions, please contact your drinking water compliance specialist.

  1. What do I do if 1) a homeowner will not let my water staff in the house to collect the lead and copper samples or 2) will not collect the lead and copper samples on behalf of my system?

As Lead and Copper Rule sampling is often a homeowner-based sampling program, you should reach out to your volunteer homeowners now to confirm whether they plan to continue their participation or not. There does not need to be in-person contact between residents collecting samples and those dropping off sample bottles/picking up samples. Suppliers could explain to its volunteers that bottles can be left outside their residences on a specific day so that the volunteer can collect samples the next morning. This may reassure your homeowners that contact with your staff will be minimal. Suppliers could communicate that you are taking safety measures to prevent the spread of COVID-19, including that staff are; washing their hands often, disinfecting the outside of the sample bottles when dropping them off, and emphasize that you are using porch drop-off and pick-up for collection. Suppliers should provide the homeowners with a phone number where they can reach staff should they have questions - this will minimize any face-to-face contact.  

If your staff usually collects the lead and copper samples in people’s homes, you have two options when a homeowner is unwilling to participate. First, you could try to find an alternative sampling location that meets the tiering requirements where the homeowner is willing to participate. Or, you could provide the homeowners with sampling instructions, sampling bottles, and allow them to collect the lead and copper samples on your behalf. Please be aware that if you allow homeowners to collect the samples, you cannot challenge the results based on sampling error. Therefore, make sure the homeowners have been properly trained on how to collect the samples. Again, this can be done via email or over the phone.

  1. For public drinking water systems, what if the water system is a restaurant or business and it is closed for the entire month? Will it receive drinking water violations for not sampling?

If you are only closed for a portion of a month (or monitoring period), you must still collect your required samples for that month/period. We always encourage systems to sample early to account for any unforeseen circumstances, such as what we are experiencing now with COVID-19. Failure to complete your required drinking water monitoring will result in violations.  

However, if you are closed for the entire month (or monitoring period), you are not required to collect your drinking water samples for that month/period. For example, if you are closed for the entire month of April, you would not be required to collect your total coliform samples since the system was not serving water to the public for the entire month. If this is your situation, please notify your drinking water compliance specialist no later than the end of the month/monitoring period.

Labs

  1. What do I do if I need more lab support or if my drinking water lab is not accepting samples because they have closed in response to COVID-19?

There are five ways you can look for lab support (based on EPA’s Water Laboratory Alliance guidance document). It is important to assure your public that your drinking water is meeting all of the regulatory standards, especially in this time of emergency. You can also contact your compliance specialist.

  1. What is the state doing to address potential lab support shortage?

To help alleviate laboratories’ capacity in the state, the state lab is relaxing reciprocity criteria for other out of state labs that may be interested in performing testing in Colorado. We are offering certification via reciprocity and will waive the onsite visit as long as they are certified by their state or other certifying authority such as, Region VIII or TNI.

The laboratories seeking reciprocity are required to submit an application, supporting documents (i.e., certificates, scope of accreditation) and certification fee. The application and fee structure are available online at https://www.colorado.gov/cdphe/dwlabs.

In addition, the state laboratory offers a courier service that transports samples from predetermined locations to the state lab. This service is free for all public water systems.

Backflow Prevention

  1. Are public drinking water systems expected to meet backflow prevention and cross-connection control compliance ratios such as the survey ratio, assembly testing ratio, and method inspection ratio even if challenges are presented accessing assemblies?

Yes. Please be aware that the department is not waiving any backflow prevention and cross-connection control (BPCCC) drinking water regulatory requirements because we must ensure public health is protected through their drinking water. All BPCCC implementation and reporting requirements still apply and any violations will continue to be issued. It is important that the public be made aware of drinking water problems via the public notice rule as required by both the federal Safe Drinking Water Act and Colorado Primary Drinking Water Regulations. If there are any compliance issues with any of your compliance ratios please contact us at cdphe_wqcd_fss_questions@state.co.us. If a supplier becomes aware of a backflow contamination event into its distribution system, please contact the department immediately at 1-877-518-5608. The executive order and the more detailed public health order broadly reference water and wastewater infrastructure as critical infrastructure that needs to be maintained. Certified testers and public water systems should continue to work with the public to ensure that backflow prevention assemblies and methods are being tested and inspected at least annually.

  1. What can public drinking water systems do if backflow prevention assembly installations or repairs are delayed due to challenges accessing the assemblies?

If a cross-connection cannot be controlled within 120 days of being identified, a supplier can submit to the department a 120-day cross-connection control extension application. If a failed assembly cannot be repaired within 60 days of the supplier being notified, a supplier can submit to the department a 60 day assembly repair extension application. Please provide an anticipated resolution date in the application. If a supplier fears that the drinking water system may be at risk, the supplier could evaluate if a suspension of service is an appropriate option in order to better protect public health.

Currently, Reg 11 requires 90% of all assemblies and methods be tested/inspected in 2020 and there is not a provision for the department to approve an alternative schedule. We are currently trying to update the regulation to allow for the 0.80 ratio for 2020 but it needs to be approved by the Water Quality Control Commission (hearing date: Aug. 10, 2020). If the system does not reach that level, then a treatment technique violation would occur.

Executive Orders D2020-012, 031, 051, and 088 gave directives regarding disconnection of service due to inability to pay. Executive order D2020-031 clarified that, "this directive does not cover disconnections necessary for safety purposes." Executive Order D2020-088 signed May 29, 2020 expired 15 days after issuance.

        Note that:

  1. Can a certified cross-connection control technician with an expired certification continue to test backflow prevention assemblies?

No. Regulation 11, section 11.39(1)(h) states that if a certification has expired, the certification is not valid. The department acknowledges that the American Backflow Prevention Association (ABPA) is offering an extension to certifications and will accept tests performed by certified testers holding ABPA certifications in accordance with the ABPA extensions. The department also acknowledges that the American Society of Sanitary Engineers (ASSE) is offering an extension to certifications and will accept tests performed by certified testers holding ASSE certifications in accordance with the ASSE extensions. According to their website, ASSE is “extending the expiration date for all certifications expiring between 1/1/2020 and 6/30/2020. The new expiration date is 7/31/2020. ASSE is also giving a 6-month grace period for you to complete a recertification class and exam.”The department recommends that certified testers continue to work with the ABPA or ASSE to obtain recertification or additional information regarding their certification.

Wastewater and Stormwater

  1. Should wastewater workers be doing anything differently to keep themselves safe on the job, like wearing masks?

According to the CDC and Occupational Safety and Health Administration (OSHA), there is no evidence that wastewater workers need to take additional precautions. Workers should follow routine practices to prevent exposure to wastewater, including using the engineering and administrative controls, safe work practices, and personal protective equipment normally required for work tasks when handling untreated wastewater. Also review CDC’s basic hygiene precautions and wearing the recommended personal protective equipment, which does include wearing a protective face mask or splash-proof face shield. We continuously evaluate any new CDC guidance and determine if it’s guidance we should follow at the state. If you are in need of personal protection equipment, we are encouraging entities join CoWARN and ask for assistance from other utility members. If that is not adequate, requests can be made through the particular county representatives who are connected with the State Emergency Operations Center.

  1. How should dischargers complete their Discharge Monitoring Reports (DMRs) if staff are unable to sample or if they cannot get results back from the laboratory?

A permittee that temporarily can not collect or analyze samples as required by their permit should still submit the required DMRs. The DMR should be completed to the best of your ability and include the required information described below at the time of DMR submittal.

  1. What happens when self-inspection and other practice based permit requirements can’t be followed because of staff absenteeism or quarantine measures related to COVID-19?

If a facility violates their permit effluent limits, which includes practice based effluent limits like self inspection requirements, because it is following COVID-19 safe practices the facility may be able to claim upset per the permit. The stormwater permits and other Colorado Discharge Permit System permits define upset as - an exceptional incident in which there is unintentional and temporary noncompliance with permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or improper operation in accordance with 40 CFR 122.41(n) and Regulation 61.2(114). Refer to the upset provisions in Part II of your permit for more information.

It is important to document when the facility evoked this condition and when it ended so it is clearly communicated why there may be a lapse or reduced frequency of inspection oversight.  Also, document the actions that were taken, or will be taken, to minimize the period and potential impact of noncompliance, such as implementing temporary stabilization for disturbed areas prior to shutting down a project.

41. For submittals that are required to be mailed with an original signature, will the division accept electronic or scanned signatures during the COVID-19 outbreak?

Some Colorado Discharge Permit System permits and division forms require submittals to include an original signature.  

Until the governor's Safer at Home executive order expires, the division will accept a scanned hand-signed signature or a digital signature (as described below). You can email the submission to our records center at cdphe.wqrecordscenter@state.co.us. Please do not send us a paper copy. We will provide at least 30 days notice before we end this measure and will start requiring original signatures again. The division may extend or modify this process upon expiration of the Safer at Home executive order in alignment with any new state guidance, please refer to this FAQ upon that occurring for any new guidance from the division.

In the email submission, you MUST include the permit or authorization number (if applicable) and the name of the document ("permit application", etc.) in the subject line. In the body of the email, please tell us if you have or have not sent us a paper copy. For documents for which directions were to provide documents to a specific person in the division (e.g., inspection responses), be sure to address the email to both that person and cdphe.wqrecordscenter@state.co.us . Please include any needed cover forms, like the Narrative Conditions Report Form, the Chemical Evaluation Request Form, or a permit modification application.

These digital signature and email submission instructions do not apply to permit applications submitted through the CEOS system or electronic discharge monitoring report submittals (NetDMR). Continue to follow the current process for electronic submittals for those systems.

Acceptable digital signatures include signatures that can be tied back to a computer login, drawn (on a digital tablet, phone or with a PC) signatures, and images of your real signature.  Digital signatures that will not be accepted are typed in signatures of any kind. Please see the examples below

Acceptable Signatures

Computer login verified:

Drawn:

Photographed:

Not Accepted

Typed or electronic  

         Joe Smith  Or  

  1. Do I still have to follow stormwater construction compliance if I have to shut down or delay my project?

Yes please be proactive in how you can maintain compliance with your stormwater construction permit during these challenges. Projects that have to delay or shut down should have temporary stabilization or final stabilization of disturbed soils and stockpiles whenever possible. Temporary stabilization methods may include but are not limited to, tarps, soil tackifier, and hydroseed. If temporary or final stabilization is not possible, the projects should focus available resources on strengthening perimeter sediment controls and outfall controls measures (inlet protections, modified pond structures, etc.) and ensure that these critical control measures are in good operating condition to protect receiving waters prior to delay or shut down.

  1. We have a portable handwashing station for all construction site personnel to regularly wash their hands. What are the proper procedures and requirements for draining the handwashing stations?

The water from the handwashing station must be managed so it does not runoff off the site or into groundwater, even if the soap is biodegradable. The handwashing water can be drained on-site into contained areas such as a lined pit or approved concrete washout area. The amount of water being drained on-site needs to be small enough so that it completely evaporates instead of soaking into the ground (water soaked into the ground can potentially go into groundwater). The handwashing water can also be drained into enclosed equipment such as a bucket with a lid or IBC Tote and then it should be dumped into the sanitary sewer.

Employees and workers need to be trained on how to use the handwashing station, the importance of washing hands, and that they are educated on how the water should be properly disposed of. If the construction site has a permit under the Colorado Discharge Permit System (CDPS) for Stormwater Discharges Associated with Construction Activities the stormwater management plan should discuss the handwashing water as a potential pollutant source. The stormwater management plan must also include design specifications that contain information on the handwashing station and how the water will be drained to meet good engineering hydrologic and pollution control; including as applicable drawings, dimensions, installation information, materials, implementation processes, inspection plan, and maintenance requirements. The site map must be updated to include the location of the handwashing station.

  1. Do biosolids (treated sewage sludge) contain COVID-19 and can they be land applied safely?

Existing requirements and guidance help ensure that biosolids are processed, handled, and land-applied in a manner than minimizes the risk of exposure to pathogens, including viruses. We have no evidence that biosolids contain the infectious virus when requirements under 40 CFR part 503 are met for Class A biosolids. Generally, pathogens may exist when requirements are met under 40 CFR part 503 for Class B biosolids, which is why EPA’s site restrictions that allow time for pathogen degredation should be followed for harvesting crops and turf, for grazing of animals, and public contact. All requirements under 40 CFR Part 503 should continue to be met. Additionally, per CDC’s Guidance for Controlling Potential Risks to Workers Exposed to Class B Biosolids, employers should prevent work-related illness by providing proper personal protective equipment (PPE) and supporting other health and safety practices for persons hauling and land applying biosolids. While no additional COVID-19–specific protections are recommended for the land application of biosolids, consider checking for advisories from your local health department.

Swimming Pools

  1. Are swimming pools allowed open right now?

As of June 1, 2020, swimming pools can open at limited capacity and the Governor encourages people to have safe fun outdoors away from others. The department released recreation guidance for everyone to follow.

  1. Can COVID-19 spread through swimming pools? Is there anything we need to do to keep pool users and workers safe?

To protect public health, all public pools, hot tubs, spas and other similar facilities in Colorado should be closed per Public Health Orders 20-24 and 20-22. It’s important to adequately close pools and hot tubs to prevent Legionella and other bacterial growth. This includes:

For more recommendations on preventing illness and injuries at public aquatic facilities, visit

https://www.cdc.gov/mahc/index.html.

If you have a pool or hot tub at home, make sure you practice social distancing such as not having pool parties. According to the Centers for Disease Control and Prevention (CDC), “There is no evidence that COVID-19 can be spread to humans through the use of pools and hot tubs. Proper operation, maintenance, and disinfection (e.g., with chlorine and bromine) of pools and hot tubs should remove or inactivate the virus that causes COVID-19."

  1. How do you calculate bather load so we know what is half capacity for pools?

The CDC Model Aquatic Health Code (MAHC) is the most recent comprehensive guidance out there for pool design and operation. Section 4.1.2.3.5 of the MAHC provides guidelines for calculation of Theoretical Peak Occupancy based on surface area.

Note the Colorado pool regulations 5 CCR 1003-5 had a section 3.23 regarding calculation of bather load, however that section of the regulation was removed but it is still referenced in the document erroneously.

The Water Quality Control Division does not conduct pool inspections or pool design reviews but your local public health department might. Please contact your local health department to see if they have a pool program and to determine if they have specific requirements.

Other Water Operations

  1. Is maintaining septic systems or private wells considered critical in the Governor’s Stay at Home executive order?

Yes, the executive order, and the more detailed public health order, broadly reference water and wastewater infrastructure as critical infrastructure that needs to be maintained. It’s important that members of the public have access to safe and sanitary conditions. On-site wastewater treatment systems (aka septic systems) and private wells are permanent wastewater and drinking water infrastructure for many homes. A failing septic system or inoperative private well presents a public health and environmental threat, and repairs need to be performed by qualified professionals. Companies that pump, repair, or operate/maintain these systems and the manufacturers who provide the supplies needed to pump, repair, or operate/maintain these systems – are considered essential water and wastewater infrastructure.

  1. I am a campground that is considered a drinking water public system. Does the Safe at Home order mean that I cannot open my campground?

Campgrounds may open following the guidance issued by the department. For more information and guidance for campgrounds, visit the state department COVID-19 website.

  1. I work in the construction industry. Am I exempt from the executive orders?

Construction efforts may continue as long as social distancing requirements are followed. The state released COVID-19 guidance for the industry. The guidance must be followed to ensure all construction workers and members in their supply chain are protected. Make sure you check with your local jurisdiction in case there are more strict requirements.

If your job requires transporting workers, they should be screened using this form prior to transport and everyone should be advised to avoid touching their eyes, noses and mouths and to cough or sneeze into a kleenex or into the bend of the elbow. Social distancing within vehicles is also required (even if this means multiple trips to transport workers to site). Consider prioritizing PPE use for employees traveling in close proximity.

  1. Can COVID-19 spread in reclaimed water?

Reclaimed water, also called recycled water, is wastewater that is treated to a certain level to be reused for other purposes safely. For example, cities and counties may use reclaimed water to irrigate landscapes. Currently there are no single-family residential homeowners that irrigate their landscapes with reclaimed water. Businesses, apartments, parks and golf courses that use reclaimed water are required to have a sign notifying the public.

The risk of getting exposed to COVID-19 through reclaimed water is low. Treated municipal wastewater, the source of reclaimed water, is disinfected and has been proven to inactivate other viruses — viruses that are more resistant to disinfection methods than coronaviruses. To learn more, check out the division’s “Information on COVID-19 and Treated Wastewater and Reclaimed Water” document.