Non-Community Water System Inspection, Recordkeeping and Compliance Device

State: CO Type: Model Practice Year: 2011

Tri-County Health Department (TCHD) serves three counties: Adams, Arapahoe, and Douglas in Colorado. Water is received from large public water systems, small groundwater systems, and private, residential wells. In 2009, TCHD received water quality complaints at local campgrounds and restaurants using small groundwater systems to deliver drinking water. Upon investigation, TCHD identified the need to provide local assistance and guidance to these small systems in order to prevent a community health problem from appearing and to encourage the operators to comply with the Safe Drinking Water Act (SDWA) National Primary Drinking Water Regulation (40 CFR Part 141). In 2010, TCHD contracted with the Colorado Department of Public Health and Environment (CDPHE) to conduct sanitary surveys (inspections) of both transient and non-transient, non-community water systems. These systems are typically located in rural areas and may be in operation infrequently throughout the year with many of them only operating during the summer months. In the TCHD area, there are approximately 90 non-community water systems which need to be inspected on a three-year cycle. This cycle results in about 30 systems inspected each summer. By looking at common deficiencies found by CDPHE at non-community water systems, TCHD identified that paperwork deficiencies were the most common violation. Having proper monitoring plans and recordkeeping techniques not only allows the water system operator to consistently follow proper techniques, but during a health investigation, good recordkeeping can quickly identify if any potential health risks exist and can prevent water system contamination or failure. Since 2010 was the first year for TCHD to assume this program, staff wanted to be successful and, at the same time, improve the paperwork and recordkeeping at the non-community water systems.  
In preparation for the first sanitary survey season, TCHD created a non-community water system inspection, recordkeeping and compliance toolkit (the toolkit) containing the system’s well permit and other well log information, templates for the required written plans (general monitoring, coliform sampling plan, nitrate/nitrite sampling plan, emergency response plan, cross-connection control plan, operations and maintenance guide, source water protection guide), a sample system site plan, a location for storing a copy of the operator’s license, information on training grants, monitoring schedule, and a location for lab results as well as a location for correspondence with regulators . TCHD staff inspectors took the toolkit with them on their sanitary surveys. This toolkit was used as a tool to help the water systems organize their current records and use the templates when written plans were missing. In addition, the toolkit served as a reminder to the inspector of all of the paperwork that should be available for inspection. As TCHD’s contact with the non-community water system community increased, the operators that operated more than one system began to use the templates for their other water systems. To locate the toolkit effortlessly when stored on a bookshelf, the toolkit was placed in hot pink binder which was easily recognizable as the location of paperwork and records."
Agency Community RolesTCHD was the lead in bringing this toolkit to the small water system community. TCHD inspectors compiled the toolkit in binders which included the templates and other resources. For instance, TCHD inspectors found well permits on the Division of Natural Resources for each water system and included these in the toolkit binder. Once compiled, TCHD inspectors brought a toolkit binder to each inspection and offered it to the operator. The inspector also carried additional binders in the event an operator wanted more than one.ImplementationTo achieve the goal of consistency, Tri-County Health Department (TCHD) offered the toolkit to all 25 inspected systems, to operators and owners upon request, and to all new public water systems. To achieve reliability, the systems with written plans were offered the toolkit. The written plans were placed in the appropriate section of the toolkit. This provided the inspector, owner, and operator an easy way to keep all records in one place on-site in an appropriate order allowing inspections to go more smoothly. To achieve Objective 1, educate and encourage on-site recordkeeping, TCHD located all Colorado Department of Public Health and Environment (CDPHE) templates and prepared templates for any unavailable items. These were printed and placed in a three-ring binder with labeled dividers for each template or record-keeping section. Additional toolkits were printed and prepared and made available upon request to operators and owners of multiple public water systems. Finally, any new public water systems were offered the toolkit upon completion of the final plan review for their system. To achieve Objective 2, provide a memory tool for inspectors, training on the use of the toolkit was provided to the inspectors. Additionally, the Water Program Lead interviewed each inspector after the initial three uses of the toolkit to determine if changes were needed to improve the usability of the toolkit as a memory aid. To achieve Objective 3, easing regulatory compliance, if the operator was found to have incomplete written plans as required by the Colorado Primary Drinking Water Regulations, then the inspector completed the templates with the operator on-site and during the inspection. The operator and owner were asked to send a copy of the written plans to CDPHE no later than December 31, 2010 thereby attaining compliance. TCHD also received a copy of all written plans. TCHD inspectors asked operators if they needed additional compliance assistance with this task. If so, the inspector faxed a copy of the completed plan to CDPHE to gain compliance. All systems achieved compliance with the written plan requirements of the regulations. Both of the goals including consistency and reliability were accomplished immediately during the inspection. The inspection season was May through December 2010. The timeframe for Objective 1 was to prepare and deliver the toolkits to each of the 25 inspected public water systems no later than September 30, 2010. Additional toolkits were made available within 10 business days upon request from operators or owners of multiple public water systems. Any interested new public water systems interested in the toolkit was given it upon completion of the final plan review for their system. The timeframe for Objective 2 was to train inspectors on using the toolkit prior to the start of the inspection season in May 2010. Each inspector was interviewed after each of the initial three uses of the toolkit during an inspection. The toolkit was adapted, if appropriate, to better serve both the system and the inspector. At the end of the inspection and follow-up season, a hotwash was held to obtain feedback on the toolkit and to identify and incorporate changes to the toolkit for the next inspection season. The timeframe for Objective 3 was to immediately complete templates for written plans found to be in noncompliance. These plans were sent to CDPHE no later than December 31, 2010 in order to attain compliance.
Objective 1: Educate the non-community water system operators and owners about needed paperwork and the value of keeping all records in one on-site location. Performance measure: Number of systems receiving and using toolkit: 28 In 2010, TCHD successfully conducted sanitary surveys at 25 locations. All 25 systems received the toolkit. The inspector and the water system operator reviewed each page of the toolkit binder. This review helped the operator understand all required materials and taught many the new Groundwater Rule. Upon questioning by the TCHD inspector, the water system representatives (i.e. owner and operator) commented that the toolkit was easy to follow. They also appreciated that the templates had been approved by CDPHE; therefore, they could use the toolkit to ensure continued compliance. In addition, TCHD also provided the toolkit to three additional systems that were not inspected, but whose operators had requested agency assistance. All 28 water systems that received the toolkit binder told inspectors they intended to use the toolkit. Even those systems with their own recordkeeping system indicated the desire to replace their system. For those systems that hired off-site operators, the off-site company kept their own recordkeeping system and used the TCHD toolkit binder to organize on-site records. Provide a memory tool for inspectors to use while reviewing paperwork during a sanitary survey (water system inspection). Performance measure: Interview inspectors and timeliness of sanitary survey completion The organized toolkits containing system-specific information gave TCHD confidence that the inspected systems were following consistent techniques for monitoring and maintaining their systems as well as locating their records. Since the paperwork requirements were in one location and could be viewed by both the system representative and the TCHD inspector at the same time, the sanitary survey took less time than originally projected. In addition, if items were missing, the inspector could easily identify the missing component and prepare a timely deadline for compliance. The ease of organizing and recalling all paperwork requirements as outlined in the toolkit allowed TCHD staff to complete the sanitary surveys almost one month prior to the contract deadline. Provide a tool to ease regulatory compliance. Performance measure: Follow-up tracking During the sanitary survey, the water systems that lacked a general monitoring plan or sampling plan needed for compliance were assisted in completing the templates on-site during the inspection. Once the template was completed, the TCHD inspector required the system to submit the newly completed plans to the Colorado Department of Public Health and Environment (CDPHE) to achieve compliance. All of the systems had completed plans at the end of the inspection; however, some of the systems were slow to submit their new plans to CDPHE. TCHD staff called, emailed, and visited with systems that had difficulty submitting plans. TCHD even offered to fax plans to CDPHE to achieve compliance. At this time, all systems have submitted plans or an agreed upon date to achieve compliance as recorded on follow-up tracking forms submitted to CDPHE by TCHD. Interviews with CDPHE staff indicate the toolkit has significantly improved compliance from previous years. They also state that many of the systems have come into compliance with the Groundwater Rule as an unintended result of the toolkit's inclusion of information on this new rule.
The stakeholders include TCHD non-community water system inspectors, TCHD restaurant inspectors, TCHD childcare inspectors, CDPHE Water Quality Control Division, non-community water system owners and non-community water system operators. TCHD began the non-community water system inspection program in 2010 due to a few significant incidences at several childcares and restaurants using wells for their water supply. TCHD staff has a commitment to continue the use of the Non-Community Water System Inspection, Recordkeeping, and Compliance Toolkit because it provides an easily-identifiable means of locating water system records in the event of an investigation of a disease outbreak, an emergency situation, and/or an inspection. Due to better compliance achievements, CDPHE staff also has a commitment to continue updating their templates and adding more templates as needed. Many owners hired operators to monitor and care for their drinking water systems. All paperwork was kept at the home office of the operator and not on-site. In these cases, the information about how the drinking water system operated was unavailable and the owner felt helpless when a violation event occurred. They are committed to the toolkit because it allows an easy way to keep a copy of all records on site. The operators also are committed to using the toolkit because they find it’s an easy way to locate all the necessary paperwork needed during an inspection and are having better compliance while using the toolkit. Better compliance means they are meeting their needs through meeting the needs of the regulator and the owner.The toolkit will be sustained over time by leveraging updates to CDPHE templates and by making the toolkit an electronic tool. An electronic toolkit can be shared with the systems and operators through email or via a downloadable format from the Internet. The electronic toolkit will reduce TCHD time in preparing the toolkits as well as TCHD supply costs in printing and binding the toolkit. A reduction in costs over time coupled with an increase in compliance will result in a long-term sustainable practice.