Comments from the Colorado Safe Drinking Water Program regarding the U.S.EPA Finished Drinking Water Storage Facility Inspection and Cleaning Public Meeting

– October 15, 2014

As we discussed during our presentation portion of the webinar , Colorado is moving forward with a proposed rulemaking regarding storage tank operations and maintenance, including periodic and comprehensive storage tank inspections. We believe that having a specific, yet flexible, regulatory requirement on this topic is more proactive and more transparent, as opposed to relying on the sanitary survey process. Sanitary surveys do not include a thorough inspection of all tanks including tank entry and cleaning. Also, problems detected during sanitary surveys are by

defin ition already problems so that the public has already experienced some higher degree of contamination risk to their water supply. We believe that a proactive approach that includes thorough inspections and cleaning when needed would be
better. Also, we bel ieve that if the regulatory agency expects water systems to properly maintain storage tanks, then it is more transparent for that expectation to be clearly spelled out in a regulation as opposed to relying on the sanitary survey process. We do have experie nce with water system operators actually asking for us to cite violations or significant deficiencies to support their efforts to obtain funding

from decision

- makers for needed activities at their water system.

C olorado also wishes to make an additional s tatement about risk management within drinking water distribution systems. W e believe that a multiple barrier approach is essential to protecting public health within distribution systems. That being said, a sing le federal regulation focusing only on stora ge tanks may give the mistaken impression that tanks are the highest risk area or other known distribution system failure points like line breaks and cross connections are somehow less pressing. We believe that a comprehensive approach to water quality wit hin distribution systems is warranted at all public water systems. A comprehensive approach would dovetail well with the concepts of the Revised Total Coliform Rule.

W hile the Alamosa and Gideon waterborne disease outbreaks were linked to finished

water storage tank defects, it is also possible that a robust chorine residual c ould

have prevented those outbreaks or reduced their exten t and consequences. We believe that one of the real lessons from Alamosa is that it probably did not take very

much animal waste to cause that outbreak. Cross connections, line breaks and other distribution system defects not associated with finished water storage tanks also provide contamination pathways that cause disease outbreaks. T he federal Center for

Disease Control and Prevent ion report s hundreds of probable drinking water outbreaks

from cross connections.Since these multiple threats have equal importance and distribution systems need to be protected holistically, Colorado is moving forward with a combined rulemaking approach requiring the following for public water systems :

• Finished water storage tanks must be free from defects.

• Develop and implement maintenance plans for finished water storage tank s including periodic and comprehensive inspections , with cleaning as needed.

• Robust cross connection control.

• Maintain a chlorine residual of 0.2 mg/L throughout distribution . This is

based on Colorado’s total coliform rule sampling data over the past 21⁄2

years , which shows 300 percent higher numbers of E. coli positives i n samples with chlorine residuals below 0.2 mg/L compared to samples with a higher residual

.

We developed these proposed regulations with considerable stakeholder input. We believe that we can implement these rules primarily as modifications and

clarification s of our current practice s and accomplish this without additional funding

or full time employees ( FTE ) for the state program. Any federal effort to develop regulations about storage tanks need s to be flexible and consider implementation

activi ties and funding levels.

We believe that this is the best direction for Colorado to take in implementing the
recommendations from our Alamosa disease outbreak investigation report to mitigat e

waterborne disease outbreak risks within drinking water distri bution systems.