Monitoring Plans: Develop and Maintain this Crucial Document

What is a monitoring plan?

The monitoring plan is an important tool for your system that helps you capture an accurate inventory of your system and communicate that inventory to the division. The division then uses this information to develop your monitoring schedule and your compliance requirements. All public water systems are required to have a monitoring plan per regulation 11. The plan is required to be current, complete, and any new changes need to be reflected in your monitoring plan within 30 calendar days after the change is effective. During a sanitary survey, the inspector will ask to see your monitoring plan; they will confirm that the monitoring plan reflects the on-site review of your system.  

The monitoring plan includes:

• System contact information.
• Inventory of facilities.
• Process flow diagrams detailing treatment and entry point sampling. 
• Source, treatment and distribution details.
• Maps of your distribution system detailing sample locations.
• Individual rules sampling/monitoring plans (e.g. nitrate rule).

Our colleagues in the field services section have cited the following monitoring plan issues most commonly during sanitary surveys:

• Changes in treatment or distribution not reflected in the monitoring plan - thus missing from division records. 
• Lack of process flow diagram or a diagram that does not accurately capture compliance sampling locations - Entry Point, Raw Water Tap etc.  
• Lack of a map of the distribution system detailing sampling locations for Revised Total Coliform Rule, and Disinfection Byproduct Rule. Please note that these sample sites may be managed in the drinking water portal. But, the division recommends that you also have a map detailing where to find these sample sites in your distribution system. 
• RTCR sites that are not representative of the entire distribution system - missing zones or branches in distribution.

How do I create or update my monitoring plan?

The division has created an online tool to help you update your monitoring plan, we call it the monitoring plan wizard. This tool will help you to generate and update your monitoring plan. It is a google form that you fill out based on the sections that you need to generate or update for your system. You then receive an email with a pre-populated google document for the section(s) that you selected. You then download the pre-populated sections as a word document or a similar file. You will fill out any information that is lacking, review the pre-populated information to ensure that it is correct, and then submit the plan to the division. The best way to submit is through the drinking water portal. Paper forms are available if you choose not to use the wizard. 

If it has been some years since you have updated your monitoring plan it may be beneficial to create a new monitoring plan. To do this you will need to take the following steps: 

1. Evaluate what sections of the plan are required for your system. On the division’s monitoring plan website there is the below chart that details the monitoring plan requirements based on the type of system you have. If you are unsure as to your system type you can look at your drinking water monitoring schedule under system details. 
2. Now you will go to the monitoring plan wizard and select the sections that are required for your system. 
3. The division will send you a Monitoring Plan template that is filled in with the information we have on file for your system. Note: The google doc link that is sent in the email will be automatically deleted after 10 days. We recommend that you make a copy or download the template as a Microsoft Word document to avoid losing work.
4. Review the generated monitoring plan. Be sure to update any pertinent information and describe the changes you are making. This will help your compliance specialist as they review your submitted plan.  
5. Submit the new monitoring plan through the drinking water portal. 

Why would I need to update my monitoring plan?

There are several changes to a system that could result in a change to your monitoring plan. The below list details some but not all of these possible changes. Please note: Systems must contact their compliance specialist before making system changes. Changes in infrastructure (construction) or treatment often require design approval:

• Change to operator or administrative contact 
• Change in population
• New customers added to the system
• New sources or sources going off-line
• Sample sites must be reviewed and updated to account for system changes 

Why diagrams and maps?

There are several mechanisms for generating these often missed items for your monitoring plan. The process flow diagram is a section of the Monitoring Plan that folks often have questions about. The diagram is a way for you to accurately capture your system’s treatment inventory. It is also a good way to conceptualize your facility when training new employees, working to solve issues, or identifying potential improvements. This diagram will begin with your water source(s), go through treatment, and then into the distribution system. The diagram needs to include identification of compliance sampling locations. For groundwater plants this would include raw water tap and entry point tap. For surface water or groundwater under the direct influence of surface water systems this would include raw water sample, CFE turbidity sample, microbial inactivation sample, and entry point sample sites. The diagram can be hand drawn or from a visio drawing or other means to show the process.

The distribution system map is a useful tool to ensure that your RTCR and DBP plans meet regulatory requirements. Specifically, the RTCR sites need to represent your entire distribution system including any branches and segmentation of different zones. The DPB sample site(s) need to be located at the longest representative residence time of drinking water in your distribution system. Often, systems use chlorine residuals to determine these sample sites, where the chlorine residual is lowest in the distribution system. Using a map can also help you identify the points farthest from your treatment in distribution. The map can be taken from google maps, google earth, any maps of your distribution system you may have and can scan. Simple programs like Microsoft paint, word processors, and PowerPoint generators can be used to generate sample site locations. 

Resources

• Division’s monitoring plan website 
• Monitoring plan wizard 
• Monitoring plan wizard videos
• Drinking water portal 

➽ Kyra Gregory, Drinking Water Training Specialist

Asset Management - the Key to a System's Capacity

The Water Quality Control Division’s Local Assistance Unit is charged with assisting Colorado’s public water systems with building their capacity to provide safe drinking water to their communities now and into the future. Capacity can be defined  as the amount that something can hold or produce, whether it is applied to people, things or systems. In a public water system (PWS), capacity is an indicator of the overall health of a system. A PWS’s capacity is assessed using 3 criteria: Technical, Managerial, and Financial or T-M-F. Just 3 little letters, sounds simple, right?  

Don’t let the  simplicity of those letters fool you, they are powerful. The key to a successful and healthy water system is T-M-F capacity. Every part of a water system can be classified under one (or more) of these criteria areas. So, it makes sense that understanding your system's capacity is essential to running a successful water system. In fact, when applying for funding an in depth capacity assessment may be required, depending on the funding source.  Beyond funding however, it is a tool that helps you manage and assess your system’s needs both short and long term.  

How can you determine your system's capacity?  

CDPHE’s TMF capacity worksheet tool can assist you. This worksheet offers a condensed, quick-tool version of the more robust TMF assessment done when applying for funding. By completing each question you will generate an estimate of your capacity percentage for each criteria area TM & F.  Using this percentage you can determine which areas are in good shape and which areas require more focus. Good TMF capacity is often tied to good asset management.  Understanding your system as a whole is critical to short- and long-term planning. Assets are everything your system is composed of from the physical infrastructure, pipes, meters, tubing, valves, etc. to the people that work in your system. Asset management is a cumulative inventory of your system as a whole that allows you to critically assess each piece, its lifetime, cost, and to generate a prioritized needs assessment. There are a variety of tools available for developing your asset management plan:

• Asset inventory is a big part of asset management and the EPA’s Taking Stock of Your Water System: A Simple Asset Inventory for Very Small Drinking Water Systems is an easy to follow tool that will help you begin developing your asset inventory. 
• Asset Management: A Handbook for Small Water Systems offers a step by step guide to building a full asset management plan. A robust asset management plan facilitates high capacity and high capacity is directly tied to a systems success.  

Need assistance with asset management or capacity development?

The Colorado Department of Public Health (CDPHE) Water Quality Control Division (WQCD) has capacity coaching available for free through the Local Assistance Unit (LAU). A PWS can request assistance by filling out the Coaching Assistance Form. Please welcome the newest member of our capacity development team Angela Green Garcia. Angela will be focusing on asset management and financial readiness.  

➽ Angela Green Garcia - Drinking Water Training Specialist

Coaches Classroom: New CoWARN website!

Colorado's Water/Wastewater Agency Response Network (CoWARN) is a free mutual aid network in which water and wastewater providers offer and receive assistance during emergency events. CoWARN has launched a new website! 

Required Action for CoWARN Members

If you are a current CoWARN member please reset your passwords through the new website to maintain your CoWARN membership. To reset your password please click on this link. If you encounter any issues with your password reset, please use this form to ask for assistance. Due to a high volume of assistance requests it may take 3-5 business days before the CoWARN administrator is able to get in touch and help resolve your issue. Thank you for your patience! 

After you reset your password please take the following action: 

1. Log in using your new password. You will be automatically redirected to the home page.
2. Locate the round red profile button in the top right corner of the page. Click on it to access your profile.
3. On your profile page, you can update your personal information and add your utility. 
4. Once you have made any necessary changes and added your utility, you will be able to access the new website functions.

New Website Functionality

This new website offers new functions:

Member managed activation: CoWARN members can now activate the CoWARN Network for emergency resource requests from their website profile. This feature enables emergency requests to be sent to the membership via email and text communications. Once assistance is received, it allows the Requestor to provide an update to the rest of the membership and close out the request.

Message board: CoWARN members now have access to a free message board where they can share lessons learned, discuss best management practices, and troubleshoot issues related to utility emergency management.

Events page: CoWARN often partners with state and federal agencies to put on emergency preparedness training events for water and wastewater providers. All events offered by CoWARN will be advertised on the events webpage. 

How to become a CoWARN member?

If you are interested in becoming a CoWARN member please go to the join CoWARN website, fill out and submit a mutual aid agreement, and fill out the contact information of the individual creating the CoWARN profile. You will be able to add additional contact information after your profile has been created. 

Thank you for all that you do to protect public health and the environment in Colorado! 

➽ Kyra Gregory Drinking Water Training Specialist and CoWARN Administrator

Aqua Answers - How do I keep everything straight?

Dear Aqua Answers,

As an operator, there’s a lot going on. How do I keep everything straight?

Thanks,

Stacie Indeno

Dear Stacie,

Public water systems need to meet many drinking water regulatory requirements to protect public health. This includes monitoring and reporting. Keeping track of all this information may be overwhelming for operators, owners, and administrators. As a result, we have developed several assistive tools that can help avoid an unnecessary violation. These include the following: 

Monitoring Schedules: 

Your online monitoring schedule is the first and best place to start. This document identifies your system’s testing requirements and deadlines. 

• You can find your system’s online monitoring schedule at the division's drinking water schedule website. You can then search by your system’s PWSID (COXXXXXXX) or “System Name”.
• Your monitoring schedule details your system’s information, including your Facility ID, Sample Point ID, and the monitoring collection period. 
• You should always have an up-to-date copy at all times. This could be an electronic copy or a paper copy kept in your compliance binder. 
• You should always use your monitoring schedule to fill out your chain-of-custody (COD) form. 
• Monitoring requirements are marked as “Sample Result(s) Received” and struck out on your monitoring schedule once they are submitted and processed (excluding total coliform sampling - please see the AIMs tool listed below). Please be aware that it may take us several days to process the data. If data is submitted incorrectly, we will not process the data. The requirement will then remain on the schedule. If there is an error, please contact your assigned drinking water compliance specialist.
• We update the monitoring schedules every Thursday. 

Am I Missing Something? (AIMS) Tool: 

You can use our brand new AIMs Tool to check total coliform sample and chlorine residual submissions. 

• The AIMS tool can identify missing samples or data errors for total coliform samples. If there is an issue with the sample result, the tool highlights the sample in red. The most common issues we see are that 1) the sample is missing or 2) the chlorine residual was not reported. 
• If you are a listed contact for many water systems (e.g., you are a contract operator), you can sort the tool by your name. This allows you to check all your water systems at a glance. 
• We have developed a User Guide: Am I Missing Something? (AIMS) Tool for tips and tricks on using this new tool. 

Reporting Guidance: 

• We always encourage systems to collect their required samples early in the collection period. Our motto is “Sample early and sample often!” 
• Fill out your COD form correctly. By law, we must process the data exactly as provided. If the result has missing or incorrect information, it will not be processed. This will result in a reporting violation. 
• All sample results must include the following information provided by the PWS: 
• PWS ID;
• Facility ID;
• Sample Point ID; and
• Collection Date.
• Except for hand pumps and disinfection waivered systems, all total coliform sample results must also include the measured chlorine residual and labeled as free or total. 
• Please do not add any extra information into the Facility ID or Sample Point ID sections. Adding additional information to these fields will result in a violation since we cannot process the sample result. If you must include more information, use the comment or address field. 
• It is always the water system’s ultimate responsibility to report by the deadline. Even if the lab is in error, we still have to issue the violation to the water system. 
• While not required, most labs submit the drinking water results on behalf of their customers. This is the easiest and preferred method for submitting sample results. 
• We highly encourage you to work with your lab and ensure that they are meeting the reporting deadlines. 
• If your lab is reporting your data, they must report the results to us as a CSV file. A CSV file helps report the data in a tabular format. You can still access these results under “My…Sample Results” in the drinking water portal.
• We have developed more guidance for properly reporting sample results, including: 
• Tips on accurately submitting sample result
• WQCD Guidance and Resources for Laboratories
• Timely reporting guidance document
• If you are submitting a COD for public notice requirements (e.g., Consumer Confidence Reports, public notice for violations, lead consumer notification, etc.): 
• Ensure a representative copy of the notice is included in your submittal. 
• Please be aware that you cannot certify that an activity was completed in the future. Only submit the COD and the representative notice copy after the required action is completed.

Mistakes and Errors: 

1. If you have made a reporting mistake, there are three main ways that you can address the error:
2. Work with your lab to have the data corrected and resubmitted. This is the preferred method and often the easiest for water systems. 
3. Submit a Sample Correction Form with all the correct information. This will help us identify and address the issue. 
4. Submit a copy of sample results with corrected information clearly provided. This is the least preferred option as we cannot readily determine what the issue is with the data.  

**Any corrections must be received by the applicable reporting deadline. If they are received after the deadline, your system will receive a reporting violation.** 

Sampling Reminders:

Sample results must be submitted no later than the first 10 calendar days following the end of the monitoring period. Generally, this is no later than the 10th of the month after the end of the monitoring period. 

• For example, you must collect a disinfection byproduct (DBP) sample every year. Thus, the monitoring period ends December 31st. Your results are due by January 10th.
• As an assistive effort, the department is sending reminder emails regarding potentially missing data around the 7th of every month. The best way to use these reminders is to submit your data early. That allows us sufficient time to process the data. If you received a reminder and your data was submitted early enough, there may be an error. Use the steps above to correct the issue.
• While not required, compliance specialists often send out additional reminders for other requirements. If you are receiving this help, take action! There may be something missing or incorrect.

Finally, if you are not receiving reminders, please make sure your contact information is correct. Your monitoring schedule lists your system’s Administrative Contact, Treatment Operator, Distribution Operator, and Owner. Remember, water systems are responsible to submit a contact update any time there is a contact change. This can be completed by either using the 1) monitoring plan wizard and checking the “01 Contacts” in the template or 2) using the contact update paper form. As always, if you have any questions or need additional assistance, please contact your assigned drinking water compliance specialist. 

Sincerely,

Aqua Answers