J.18_Action_Level_Exceedance_Copper,_08162018.pdf

4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe/wqcd John W. Hickenlooper, Governor | Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer

August 16, 2018

LAURIE YEAGER

SHADOW MOUNTAIN VILLAGE - PWSID CO0125709

2150 CENTRE AVE BLDG E

FORT COLLINS CO 80526

Copper Action Level Exceedance January 1, 2018 – June 30, 2018

According to the Colorado Department of Public Health and Environment (“Department”) records, SHADOW MOUNTAIN VILLAGE (“Supplier”) submitted lead and copper test results for the above-referenced monitoring period. The following 90th percentile values were calculated from the test results:

• Lead 90th Percentile: 0.0006 mg/L (Sample Size = 10)

• Copper 90th Percentile: 2.1 mg/L (Sample Size = 10)

Within 30 days of being notified of the results, the Supplier must provide the individual lead tap water monitoring results to the consumers at the sample sites from which samples were collected, Section 11.26(2)(g) of the Colorado Primary Drinking Water Regulations (“Regulation 11”), 5 CCR 1002-11.

The results of the 90th percentile calculations indicate that the Supplier has exceeded the 1.3 mg/L copper Action Level for the specified monitoring period. As a result of the action level exceedance (ALE), pursuant to Section 11.26 of Regulation 11, please be advised of the following requirements:

LEAD AND COPPER TAP MONITORING

The Supplier must conduct lead and copper monitoring on a six-month sampling frequency (Section 11.26(2)(d)(v)).

a. The Supplier must collect 10 samples every six months for lead and copper. The next collection period is July 1, 2018 to December 31, 2018.

b. A copy of the Supplier’s monitoring schedule is available online at www.wqcdcompliance.com/schedules. Please note that all of the compliance requirements are indicated on the Supplier’s monitoring schedule.

c. No later than the 10th of the month following the end of each monitoring period, the Supplier must submit all of its lead and copper tap sample results to the Department.

WATER QUALITY PARAMETER MONITORING

No later than June 30, 2018, the Supplier must conduct the following water quality parameter (WQP) monitoring according to Attachment A (Section 11.26(4)(d) and Section 11.1(6)(a)):

Dedicated to protecting and improving the health and environment of the people of Colorado http://www.wqcdcompliance.com/schedules

SHADOW MOUNTAIN VILLAGE - CO0125709 August 16, 2018 Action Level Exceedance Page 2

a. At 1 tap sample site(s), collect 2 samples for each applicable water quality parameter from each sample site. Monitoring must be conducted on separate days.

b. At each entry point, collect 2 samples for each applicable water quality parameter. Monitoring must be conducted on separate days.

c. No later than the 10th of the month following the end of each monitoring period, the Supplier must submit all of its WQP sample results to the Department.

d. If the required water quality parameter monitoring was not completed on or before June 30, 2018, the Supplier is in violation and must conduct the required sampling to return to compliance.

LEAD AND COPPER SOURCE WATER MONITORING

No later than December 31, 2018, the Supplier must monitor the source water for lead and copper and indicate if source water treatment is required (Section 11.26(5)(b)). Specifically, the Supplier must:

a. Collect one lead and copper sample from each entry point.

b. Submit a written source water treatment recommendation to the Department.

OPTIMAL CORROSION CONTROL TREATMENT

No later than December 31, 2018, the Supplier must submit an optimal corrosion control treatment recommendation (OCCT) (Section 11.26(3)(c)):

a. In order to demonstrate a complete optimal corrosion control treatment recommendation, the Supplier must, at a minimum, provide the information required in Appendix K of the Design Criteria for Potable Water Systems (https://www.colorado.gov/pacific/cdphe/wq-design-criteria-policy-stakeholder).

Pursuant to Section 11.4(1)(b)(iii), a professional engineer is required for community water systems submitting an OCCT recommendation. Also, it is strongly encouraged to utilize the EPA’s Optimal Corrosion Control Treatment Evaluation Technical Recommendations and complete any applicable sections of the EPA’s Excel-based OCCT Evaluation Templates available at:

https://www.epa.gov/dwreginfo/optimal-corrosion-control-treatment-evaluation-technical-recommendations.

1. Please note that a recommendation for no treatment or a treatment selection without any justification is not adequate and may result in a treatment technique violation requiring public notification.

b. If the Department requests additional information or water quality parameter monitoring samples to aid in its review of the proposed corrosion control treatment, the Supplier shall respond to Department with the information. Failure to respond to a Department’s request will be considered an inadequate optimal corrosion control treatment recommendation and may result in a treatment technique violation requiring tier 2 public notification to all customers.

c. If the Department is unable to designate the Supplier’s optimal corrosion control treatment due to lack of information or variability in system operating conditions within twelve (12) months from the end of the first monitoring period with an action level exceedance, the Department may require the Supplier to perform corrosion control studies and submit a complete study report within eighteen (18) months (Section 11.26(3)(c)(ii)(B)).

https://www.colorado.gov/pacific/cdphe/wq-design-criteria-policy-stakeholder https://www.epa.gov/dwreginfo/optimal-corrosion-control-treatment-evaluation-technical-recommendations https://www.epa.gov/dwreginfo/optimal-corrosion-control-treatment-evaluation-technical-recommendations

Action Level Exceedance Page 3

LEAD SERVICE LINE REPLACEMENT

If the Supplier exceeds the lead action level after installing optimal corrosion control treatment, the Supplier may be required to replace lead service lines if present (Section 11.26(6)).

Additional Lead and Copper Resources Colorado Department of Public Health and Environment’s Lead and Copper website:

www.colorado.gov/cdphe/lcr.

EPA’s Lead and Copper website: www.epa.gov/dwreginfo/lead-and-copper-rule.

Please submit data, documents, reports, forms, and replies to the Department:

• Electronically – via the Drinking Water Portal (preferred) o First-time users must create an account. The Portal is located at wqcdcompliance.com/login.

• Fax or Mail o Fax: 303.758.1398 o Colorado Department of Public Health and Environment

Water Quality Control Division / WQCD-B2-CAS 4300 Cherry Creek Drive South Denver, Colorado 80246-1530

This does not constitute an Enforcement Order and is not subject to appeal. The Department may pursue formal enforcement action with penalties concerning the above, including issuing the Supplier an Enforcement Order or amending a current order.

If there are any questions regarding the contents of this letter and/or requirements for the Supplier, please contact Amy Schultz by phone at 303-691-4927 or by email at amy.schultz@state.co.us.

ec:

LAURIE YEAGER - AC

TOM MCCLELLAND - OPERATOR

BRENE BELEW-LADUE - PUBLIC HEALTH DIRECTOR - GRAND COUNTY PUBLIC HEALTH

LAURA SCHEENING, RN - COMMUNICABLE DISEASE - GRAND COUNTY PUBLIC HEALTH

File: CO0125709, GRAND COUNTY, NON-TRANSIENT, NON-COMMUNITY – GROUNDWATER http://www.colorado.gov/cdphe/lcr http://www.epa.gov/dwreginfo/lead-and-copper-rule https://wqcdcompliance.com/login mailto:amy.schultz@state.co.us

Action Level Exceedance Page 4

Attachment A: Water Quality Parameter Monitoring

As a result of the action level exceedance, the Supplier must comply with the water quality parameter (WQP) requirements specified in Section 11.26(4). In addition to parameters specified in Section 11.26(4), the Department is requiring additional water quality data as specified below, pursuant to Section 11.1(6)(a) to aid the Department’s review of optimal corrosion control treatment and/or a treatment recommendation. The Supplier must monitor for all WQPs below at representative locations within the distribution system and at each entry point within the monitoring period that the lead or copper action level is exceeded. The Supplier is required to conduct the following:

• WQP Tap Samples: All WQP samples must be representative of water quality throughout the distribution system, taking into account the number of individuals served, different sources of water, different treatment methods employed and seasonal variability. Please note that the WQP tap samples are not required to be collected at the Supplier’s lead and copper tap sampling sites.

• WQP Entry Point Samples: At each entry point, collect the required monitoring for each applicable water quality parameter.

The Supplier must monitor the following WQPs at both the entry point and tap sampling locations:

• pH (field test within 15 minutes of collection)

• Water temperature (field test within 15 minutes of collection)

• Alkalinity

• Calcium (as mg/L CaCO3)

• Conductivity or Total Dissolved Solids

• Silica (only if an inhibitor containing silica is used)

• Orthophosphate (mg/L as P)* (required even if an inhibitor containing phosphate is not used)

• Total phosphorus (mg/L as P)

• Chloride

• Sulfate

• Iron

• Manganese

* Note, if an orthophosphate concentration is given in units of “mg/L as PO4” or “mg/L as orthophosphate,” the value must be divided by 3 to convert to “mg/L as P”