Groundwater Resources - Westwater Hydrology Blog

Dewatering from Colorado Businesses Requires Discharge Permits

In June of 2020, the Colorado Department of Public Health and Environment (CDPHE) revised their rules for construction dewatering and also for long-term dewatering for non-residential facilities. Every non-residential facility in the state that has a sump pump or drains to control groundwater seepage and discharges the produced water to gutters or stormwater drains must now have a dewatering permit, regardless of the amount of water produced or the water’s chemical makeup. Depending on Site conditions, there may be alternatives to these permits.

The water’s clear, what’s the deal?

In some areas, fuel or chemical spills may contaminate groundwater that seeps into buildings and CDPHE wants to prevent these contaminants from entering streams. More commonly, however, as groundwater flows through the subsurface, minerals in the aquifer can dissolve and leach metals such as selenium or arsenic, salts, or radioactive elements such as uranium, into the groundwater. Normally these mineral constituents would slowly seep into streams and become diluted to concentrations that are harmless to downstream water users, and the fish and wildlife.

With the Front Range’s many unlined irrigation canals, and irrigated lawns where there were once arid grasslands, the natural groundwater system has changed and the water table has risen to near-surface conditions in many places. To prevent basement flooding or foundation damage, buildings may need dewatering pumps that may produce a few gallons here and there, or may pump thousands of gallons daily. When all of these discharges across the Metro Area add up, large quantities of groundwater are being discharged to storm sewers that drain to streams. In order to decrease the drinking water treatment burden for downstream communities, help prevent salt buildup in farmland soils, and protect fish and other aquatic life in creeks and rivers, CDPHE has created a permitting system to limit the amount of potentially toxic constituents flowing into local rivers and creeks.

Depending on the groundwater quality, one of two discharge permitting tracks will be followed if the discharged water will flow back to streams. These are referred to as either the “easy permit” or “hard permit.” If the water is relatively free of impurities, then the “easy permit” only requires limited sampling, a permit application, and a year of minimal monthly monitoring. If the groundwater contains higher concentrations of metals or other constituents, the “hard permit” is needed and sampling is much more involved and expensive, regular monitoring and reporting are required, and a treatment system may be needed for the discharged water.

Fortunately, depending on the geologic conditions, water quality, and volume discharged, there may be alternatives to either of these permits and commercial facility owners may be able to circumvent the CDPHE permitting requirements. Westwater Hydrology LLC will be glad to provide a confidential assessment of your dewatering system and work to find the most cost-effective way to handle building dewatering discharges.

PFAS Bill in Colorado Legislature

State of Colorado House Bill 20-1119 in Legislature

HB20-1119, State Government Regulation of Perfluoroalkyl and Polyfluoroalkyl Substances was introduced to the Colorado legislature January 15. As introduced, HB20-1119 has four sections; several amendments have also been offered:

Section 1 of the bill addresses when PFAS may be used for firefighting foam system testing both in general and in certain aircraft hangars.
Section 2 grants CDPHE the power to adopt and enforce standards and regulations that require public drinking water systems to sample drinking water supply sources and finished drinking water for PFAS.
Section 3 clarifies that the Colorado Water Quality Control Commission may set standards related to PFAS in surface- and groundwater and may require wastewater systems to collect PFAS data relevant to the commission setting PFAS standards.
Section 4 requires the CDPHE Solid and Hazardous Waste Commission to promulgate rules for a certificate of registration for any facility or fire department that possesses PFAS-containing foams, and for standards for capture and disposal of PFAS in firefighting agents or firefighting equipment.
Proposed amendments would include levy a fee on wholesale petroleum storage activities to establish an enterprise fund that would be administered by a Governor-appointed board. Other amendments would provide for an AFFF take-back program, water sampling, and waive liability for entities such as local governments and wastewater treatment plants. Other amendments being introduced include developing numeric surface- and groundwater standards by 2025, creating a registry of entities possessing PFAS-containing firefighting foams, and exempting domestic wastewater treatment plants from certain requirements.

HB20-1119 is currently scheduled to be heard by the House Energy & Environment Committee on Monday March 9, 2020. There will likely be significant changes to the bill as it moves through the legislative process.

Colorado PFAS Surface- and Groundwater Standard Development Underway

This post is part of Westwater Hydrology’s efforts to help inform the public on local developments regarding per- and polyfluoroalkyl substances (PFAS). More about PFAS can be found at the links at the bottom of this post and on Westwater’s PFAS webpage which includes a downloadable PFAS Fact Sheet with an overview of the topic.

Colorado’s PFAS Standard Development

The Colorado Department of Public Health and Environment (CDPHE) is developing PFAS “Narrative Standards” (Colorado Standards) to set limits for five PFAS compounds (PFOA, PFOS, PFNA, PFHxS, and PFBS) in surface- and groundwater. As part of the development of these standards, three PFAS Work Group meetings will be held by the CDPHE Water Quality Control Division (WQCD). The first was held on September 17, 2019 and the draft Colorado Standard was released on November 12. This post summarizes the status of the Colorado Standards development as of the second PFAS Narrative Policy Work Group Meeting held on Tuesday Nov. 19, 2019. The third meeting will be held on February 11, 2020 and a draft standard provided to the WQCD on March 2 for finalization on May 11, 2020. The following bullet points summarize the Draft Narrative Standards; further detail is provided below for those just getting up to speed on the PFAS standards.

According to the CDPHE, the Colorado Standard will:

Employ the use of “Narrative Standards” for surface- and groundwater under WQCD Regulations 31 and 41, respectively; this will expedite the Standard development relative to a potentially years-long process of adding PFAS numeric standards to the Regulations,
Group PFAS compounds according to health effects and translated toxicity levels:
1. Developmental toxins: Sets limits for PFOS + PFOA + PFNA + four identified parent compounds = 70 parts-per-trillion (ppt),
2. Endocrine toxins: Sets limit for PFHxS = 700 ppt (no parent compounds identified),
3. Renal toxins: Sets limit for PFBS = 400,000 ppt (no parent compounds identified),
Set minimum analytical requirements (detection level, specific PFAS compound list, lab certification) until draft EPA PFAS Method 8327 is validated and finalized,
Make recommendations regarding sampling and analysis procedures,
Apply to effluent discharge and other discharge permits,
Be used in cleanup actions and for protection of groundwater and drinking water sources.

Now for the Details…

Using the “Narrative Standard” Approach – CDPHE is taking an expedited approach to be responsive to public concern about this class of compounds. The use of “Narrative Standards” is an administrative tool allowing CDPHE to set standards based on the narrative portions of the regulations requiring surface- and groundwater to be “free from” pollutants not specifically listed in the tables found in the respective surface- and groundwater regulations. The standard will not apply to drinking water but will provide for monitoring and source investigation considering the presence of PFAS constituents in drinking water sources.

Grouping by Health Effects and Toxicity, Inclusion of Parent Compounds – CDPHE proposes grouping and setting limits for PFAS compounds based on their developmental, endocrine, and renal toxicity levels. Additionally, CDPHE translated the narrative standards using results from federally-derived consensus findings on the toxicity of the compounds PFOA, PFOS, PFNA, PFHxS, and PFBS to develop the Colorado Standard. CDPHE is also taking the novel approach of including four polyfluorinated compounds that are “oxidizable precursors” or “parent compounds” to the five compounds. While there may be many more parent compounds, CDPHE is only considering those that are included on the analytical list for EPA’s proposed draft laboratory method, EPA SW-846 Method 8327* (Method 8327).

Developmental Toxins: (PFOA, PFOS, and PFNA): Developmental toxicity is related primarily to effects to a developing fetus or a breast-fed child. PFAS compounds shown to exhibit developmental toxicity include PFOS and PFOA; PFNA has been added to this pair based on the ATSDR’s 2018 report showing a similar minimal risk levels (MRLs) for developmental toxicity as PFOS and PFOA. CDPHE is following EPA’s lead setting the Standard at 70 ppt level for the sum of these three compounds. Additionally, parent compounds reported in the Method 8327 list are NEtFOSAA, NMeFOSAA, PFOSA/FOSA which can be oxidized in the environment to PFOS, and the parent compound 8:2 FTS which can be oxidized to PFOA. The Standard conservatively assumes all of the parent compound mass will be oxidized and uses a formula based on concentration and molecular weights.
Endocrine Toxins (PFHxS): Endocrine toxicity is related to interference with hormones necessary for endocrine functions of a number of internal organs. The compound PFHxS has been shown to exhibit endocrine toxicity and has a MRL ten times that of PFOS and PFOA; thus the PFHxS Standard is set at 700 ppt. No parent compounds are currently identified for PFHxS.
Renal Toxins (PFBS): Renal toxicity is related to kidney damage. The compound PFBS has been shown to exhibit renal toxicity. The 400,000 ppt level was based on a Provisional Peer-Reviewed Toxicity Value primarily derived for use in EPA’s Superfund Program from a review of the relevant scientific literature using EPA methods, data sources, and guidance. The value of 400,000 ppt was selected for PFBS based on the EPA Regional Screening Level in tap water for PFBS. No parent compounds are currently identified for PFBS.

Minimum Analytical Requirements – Currently there are limited commercially-available analytical methods for PFAS in surface- and groundwater and wastewater. CDPHE appears to rely on the EPA’s draft analytical Method 8327*, however this method has not been finalized yet. The most common PFAS analytical methods for non-drinking water matrices are proprietary modified versions of the drinking water analytical Method 537, referred to as “modified method 537.” The EPA is in the process of developing and validating analytical

methods for PFAS in surface- and groundwater, wastewater, soil, etc. and has proposed draft Method 8327*. Until the EPA develops and validates a method for non-drinking water matrices, the Colorado Standard will allow analysis by modified 537 methods and ASTM method D7979 providing the methods adhere to Department of Defense quality standards (DoD, QSM 5.1 or later, table B-15). The Colorado Standard also requires a list of 25 PFAS compounds to be reported and quantified to minimum reporting levels of 8 ppt for most compounds and 20 ppt for several others. The Colorado Standard’s required reporting levels of 8 ppt are higher than regulatory or guidance levels set or proposed by some states for select PFAS compounds.

Sampling and Analysis Considerations – The Colorado Standard recognizes that care should be taken during sample collection and analysis to avoid using materials that contain PFAS compounds, such as Teflon™ tubing or sampling tools, containers, or other materials made of polytetrafluoroethylene (PTFE). Quality control sample collection is also mentioned, however details are not available yet.

Effluent Discharge Permits – The Colorado Standard will apply to some industrial dischargers, publicly-operated treatment works (POTWs) with industrial pre-treatment programs, other POTWs with significant sources of PFAS, and some dewatering permits. Industrial sources, wastewater treatment plants and some dewatering activities will require initial monitoring. Continued monitoring and source investigation may be required if PFAS is present, and based on proximity to drinking water sources. Effluent limits will apply to only to PFOA, PFOS, PFNA, PFHxS, and PFBS. The standard also makes provision for applicability to Colorado’s list of impaired waters.

Use in Groundwater Cleanup Actions – The draft Colorado Standard currently has a placeholder for this topic. At the meeting CDPHE staff stated that PFAS has been detected at about 16 RCRA hazardous waste sites in Colorado and that at most of these sites PFAS has not migrated offsite. Parties sampling their groundwater for PFAS will not be responsible for cleanup unless they are the ones who released the PFAS materials to the environment.

*Note Regarding Analytical Method 8327: In its current form draft Method 8327 has reporting levels that are about 10 times higher than many commercially-available modified 537 methods. The DoD’s Environmental Data Quality Workgroup considers Method 8327 only useful as a screening-level analytical method “that should not be used for the collection of definitive data” needed for project decision making. Additionally, the Colorado Standard requires reporting limits at 8 ppt for PFOA, PFOS, PFNA, PFHxS, and PFBS, and 20 ppt for the parent compounds included in the standard, NEtFOSAA, NMeFOSAA, PFOSA/FOSA and 8:2 FTS. Method 8327 has “suggested lower limits of quantitation and calibration ranges” of 10 ppt for PFOA, PFOS, PFNA, and PFBS and 40 ppt for PFHxS. Method 8327 quantitation limits are thus higher than the required reporting levels set forth in the Colorado Standard. The Colorado Standard also lists the PFAS compound “Gen-X,” developed as a “safer” replacement compound for PFOA, however Gen-X is not included in the Method 8327 compound list.

More information can be found at:

CDPHE PFAS Narrative Policy Work Group

EPA PFAS Homepage

CDPHE Perfluorinated Compounds Resources Webpage

ITRC PFAS fact sheets

December 9, 2019

Disconnecting Our Water Use from Economic and Population Growth

When we talk about water in the West, there are three myths we hear so often they have become accepted by many as truth. The first myth is that, as population grows and the economy expands, we will soon run out of water; economic growth will come to a screeching halt, and a parched, dust-bowl apocalypse will be upon us. The second myth is that we can only forestall imminent water shortage and the accompanying economic collapse by building bigger reservoirs and longer aqueducts, drilling deeper for groundwater, drying up farmland, and diverting more distant rivers. The third myth is that “whisky’s for drinking and water’s for fighting over.” This is the headline-grabbing narrative that Western water supply is a zero-sum game in which stakeholders with legions of attorneys are pitted against each other and for every winner, a loser will lie vanquished in the dust.

Denver’s Total Water Use has Declined 20% Since 2002

In 2016 Denver Water CEO Jim Lochhead was interviewed in Denver’s 5280 Magazine about the $380 million Gross Reservoir Expansion Project, meant to secure additional water supplies for the Front Range. The article follows the standard narrative of how precarious Denver’s water supply is, that Denver Water almost ran out of water during the drought of 2002 and ends dramatically by stating, “the Gross Reservoir expansion will help ease drought concerns—at least for now.” However, buried in the article’s narrative of urgency and pending shortage is the nugget: “Denver residents have managed to reduce water consumption by more than 20 percent in the last 15 years, even with a 15 percent increase in population.”

So let that sink in for a moment: since 2002 Denver’s total water use fell by 20% despite a 15% population increase and an economy accelerating at an amazing pace. If you ponder this it seems pretty impressive and it’s easy to think there are either high-technology tools, like “smart water meters,” or draconian water cutbacks behind this conservation miracle. In truth the water savings were accomplished with a combination of public education and fairly low-tech conservation measures encouraged by rebates for low-flush toilets and appliances or installing higher efficiency landscaping and irrigation systems – the “low hanging fruit” of water efficiency. These tools are only scratching the surface of what we can do if we put our minds to it.

That water use in Denver has declined so much was news to me. Since 2002, only a couple of residents in my Western ‘burbs neighborhood have ripped out their lawn and gone full xeriscape, people still water their grass and smell like they bathe regularly. More likely there have been some bathroom remodels like mine where a water-guzzling toilet was replaced by a newer, more efficient model. But I haven’t noticed any fake lawns or signs of other radically decreased water use. And yet Denver is using one-fifth less water despite our growth.

Decoupling Resource Use from Economic and Population Growth

This trend of decreasing water use while population and the economy grow, referred to as “decoupling,” is happening all around the country and in agriculture as well as the cities. For example, California agricultural water use has declined by 40% since the 1980s while the amount of irrigated land has increased overall. Put simply, economic and population growth do not require fixed amounts of water per dollar of output, or per person.

So how much further can we go before water savings impinge on our quality of life and become an inconvenience? The water savings above are only a start; in the Denver Water service area, households receiving efficiency rebates are likely still in the minority. The implications of greater participation in conservation programs, non-potable water reuse, and especially landscaping more suitably for our semi-arid climate, could result in significant water use savings and prepare us for the next drought.

Roadblocks to Conservation

Despite plenty of off-the-shelf technology and knowledge of how to save water, the main impediments to conservation seem to come from institutional inertia and habits of perception. While there is more cooperation among water users these days many, particularly in the media, still subscribe to the mentality summed up by the third Western water theme of conflict over a scarce resource. Suspicion about who will get any conserved water if there’s not a specified user designated to receive that saved water is an issue to be dealt with. Our Western water rights framework, the Prior Appropriation System has a “use it or lose it” provision that requires maximum consumption of a decreed water right even if the water isn’t needed. Indeed, there are places in the South Platte River Basin where water management methods have been so successful that aquifers have risen to the point that fields are waterlogged and structures have been damaged. And in some circles an attitude exists that conservation of our shared resource, especially if mandated by the government, is anathema to free market economics and the “American Way,” as if highly subsidized water projects to irrigate low-value crops are consistent with capitalist supply and demand theory.

We Can Do It!

After high school I worked offshore on oil rigs in the Gulf of Mexico. One evening my crew kicked back in safety netting slung under the Ocean Viking, an offshore platform rising a hundred feet from the waves. Four years earlier this 3,000-ton semi-submersible drilling platform oil had been in the North Sea where it struck first oil off the coast of Norway. After watching a graceful school of manta rays glide below us my gaze rose to the horizon where another half dozen similar rigs were busy punching three-mile deep holes in the seafloor for oil. The thought that this hulk of steel had been towed thousands of miles across the Atlantic to Norway and back again to the Gulf of Mexico instilled in me the belief that, when motivated, we humans can do the most amazing things. We’ve got the technology to save water, preserve our quality of life, and prevent degrading the environment more. Surely we can meet our growing needs with the water we have.

November 20, 2019

This post is an updated version of an article that originally appeared in the May 2017 Colorado Environmental Management Society Newsletter. No part of this article may be reproduced without attribution to the author. Please feel free to link to this post.

Is My Water Safe to Drink? PFAS Detections Raise Concern

When new acquaintances learn I’m an environmental consultant specializing in water they frequently ask, “Is my water safe to drink?” For almost three decades my stock answer has been that if they are on a public water system there is little worry except for tiny concentrations of disinfection byproducts (DBPs) that form due to interaction of chlorine with natural carbon in the water. We accept this one-in-a-million cancer risk from DBPs as a trade-off to losing one in four young children to dysentery or other water-borne diseases. If you don’t like the chlorine taste, I’d say, get a countertop water filter or simply fill a pitcher with water and let it sit overnight, allowing a few parts per billion DBPs and any residual chlorine to off-gas to the air.

I’m no longer so sure of myself. I thought the public water supply was safe, that we’d dealt with toxic chemicals in public distribution systems years ago. Environmental remediation of groundwater was my profession but I seldom worked on sites with contaminants directly entering public water supplies. I thought situations such as the case of Woburn Massachusetts, portrayed in the 1998 movie A Civil Action, had been cleaned up or were the rare exception to the rule. Organic compounds, heavy metals, and a host of other contaminants are tested by our water providers and the results made public. Compliance with the Safe Drinking Water Act (SDWA) is required and utilities face consequences if they exceed the Maximum Contaminant Levels (MCLs) for contaminants in drinking water. Yet PFAS sample results have yet to appear on the annual water quality reports some large water suppliers, such as Denver Water, provide.

The notion that in 2019, millions of Americans could be served toxic concentrations of chemicals by public water systems has been a jolt to my world view.

PFAS in the Environment

Here in Colorado, at least three aquifers are known to be tainted with per- and polyfluorinated substances (PFAS), a family of synthetic chemicals called “forever chemicals” because they are difficult to treat, don’t easily break down in the environment, and stay in our bodies for years. The combination of PFAS toxicity, environmental persistence, and mobility allow PFAS to migrate for miles in groundwater from source to a water well. This class of chemicals is also used in a wide variety of products we use daily, ranging from dental floss to non-stick skillets, raincoats, and fast food wrappers. In particular, large quantities of PFAS have entered the environment as fire-fighting foams used for petroleum fires. PFAS has also been found in landfill leachate and in wastewater treatment plant effluent discharging to rivers and streams. While many products containing PFAS have been phased out there are still many common items we use daily that expose us to these chemicals.

How PFAS Affects Us

PFAS compounds mimic the fatty acids in our bodies and bind to proteins. They have been found in polar bear blood, detected in 95% of US schoolchildren, and are likely present in your body and mine. PFAS have been linked to kidney, testicular, bladder, and lung cancer, as well as reproductive, cardiovascular and developmental toxicity, and immune system suppression. Because PFAS compounds become part of our tissue, they stay in our system for years after consumption and can accumulate to more than 100 times the concentration originally consumed. Due to the accumulation in our bodies, the EPA has set a non-enforceable “Health Advisory Limit” (HAL) of 70 parts-per-trillion (ppt) for the sum of the two compounds PFOS and PFOA.

PFAS Environmental Distribution

In Colorado, over 100,000 residents of the Fountain Valley near Colorado Springs and in Denver Metro Area’s South Adams County recently learned their municipal drinking water for years contained untreated PFAS concentrations greater than the EPA HALs. In the idyllic foothills of Boulder County domestic well owners near two fire stations where fire-fighting foams were used or stored years ago may have also been exposed to PFAS in groundwater pumped by their private wells. Nationwide PFAS compounds have been discovered in many water systems, however we have no idea how long these contaminants have been in the drinking water because sampling for PFAS only became widespread in about 2015, when the EPA required large water systems to sample for six PFAS compounds. And with thousands of compounds in this class of contaminants, what’s been detected is likely the tip of the iceberg.

As analytical labs have expanded their capabilities and lowered their detection limits, more compounds are being detected. In groundwater that I sampled in December 2018 from Fountain, Colorado, there were 11 different PFAS compounds detected out of the 17 compounds analyzed. When more extensive suites of PFAS compounds are reported by labs, it’s likely that more compounds will be detected in the groundwater there and elsewhere, and the responsible parties will eventually require a plan for environmental remediation.

Environmental Remediation

PFAS environmental remediation is in its infancy. Once upon a time groundwater cleanup was limited to “pump and treat” remediation: pumping contaminated water out of the aquifer, filtering, and then reinjecting the water back into the aquifer. One groundwater cleanup expert compared pump and treat methods to “trying to get soap out of a sponge.” Several decades ago groundwater remediation was revolutionized by “in-situ” cleanup methods – stimulating natural microbes to degrade toxins, or injecting chemicals into an aquifer that break down contaminants in the groundwater. With PFAS, there are no available in-situ treatment methods that have been developed and we are years away from any. We’re back to pump and treat.

The good news is that domestic well owners with PFAS contaminated groundwater can use certain “point of use” home filters that are readily available and easy to install. These are also available for municipal water users.

Regulation

Our public health infrastructure and regulatory institutions are struggling to catch up with this emerging family of contaminants. The EPA has yet to set an enforceable MCL for any PFAS compounds. Without an enforceable standard, responsible parties have been reluctant to pursue PFAS environmental remediation without clear cleanup goals or a regulatory requirement. In the vacuum of federal leadership, many states are setting their own HALs, MCLs, or other cleanup levels for the two main chemicals, PFOS, PFOA, and a hodgepodge of other PFAS compounds. However, there is little consensus on “safe” PFAS drinking water concentrations and some states have established regulatory levels that are less than half the EPA’s HALs. Colorado has recently begun the process of setting standards for surface- and groundwater but limits will not be set until spring of 2020 at the earliest.

This scattershot regulatory environment will create confusion, and likely suspicion, if the EPA eventually sets an MCL at a level higher than many state levels, no matter how sound the supporting science is. Added to this a recent study by the Centers for Disease Control that recommended “safe” concentrations about one tenth of the EPA HALs and the picture becomes even more clouded.

There is currently no coherent national approach to regulating PFAS. The EPA has begun research to establish threshold “reference doses” for PFOS, PFOA, and a handful of other specific compounds, with the stated intent of establishing MCLs for drinking water in the next few years. Meanwhile both of Colorado’s senators have cosponsored federal legislation that would designate all PFAS compounds hazardous substances under CERCLA (Superfund law). The future is uncertain with respect to how these compounds will be regulated and what constitutes a safe concentration in drinking water. It’s as if we’re back in 1980 and are just learning about benzene and TCE. We have a long way to go.

UPDATE 11/20/19 – The Colorado Department of Public Health and Environment is developing standards for PFAS in groundwater and surface-water. The new standards are expected in May of 2020. Additionally PFAS testing is being performed by large water providers.

October 30, 2019

This post is an updated version of an article that originally appeared in the Colorado Environmental Management Society April 2019 Newsletter. No part of this article may be reproduced without attribution to author. Please feel free to link to this post.

See: Horn, Andy, 2019. Is the Water Safe to Drink? Colorado Environmental Management Society Newsletter, April 2019.

Inadequate Oversight of Colorado’s Water Well Industry

A recent audit of Colorado’s Water Well Inspection Program raises concerns for domestic water well owners.

Unlike above-ground construction, once a well has been built inspection of the work that was done is difficult, if not impossible. Water well issues may go undetected until a problem arises or the well breaks down leaving the owner high and dry. Water well contractors (drillers and pump installers) are licensed in Colorado and their work sometimes inspected, however state oversight of the well drilling and pump installation industry has historically been understaffed and underfunded. The shoddy work of some contractors reached a point several years ago that prompted the industry trade group, the Colorado Water Well Contractors Association, to ask the state for improved state oversight of their industry. The CWWCA even hired a lobbyist in hopes of getting legislation passed to provide full funding for the well inspection program and improve contractor oversight. After lack of action in the legislature, the CWWCA eventually requested the state audit the well inspection program as a last resort. The state’s audit was completed in June 2019.

Key Audit Findings About Well Inspections in Colorado

Only half the number of inspectors mandated by statute have been in the field inspecting water wells during construction and testing,
In Fiscal Year 2018,the state’s three well inspectors only inspected 310 wells, or less than 8%, of about 4,000 wells constructed that year,
Colorado well inspectors only inspected 7% of the “high risk” wells constructed in 2018, while inspecting many more “low risk” wells,
Of the few wells inspected in 2018, over two thirds were never inspected during key phases of construction,
Water well inspections were sometimes obstructed, or prevented, by drillers or well owners, and the inspectors never notified their overseeing board that they were denied access,
The Division of Water Resources (DWR) does not monitor or enforce submittal of the work reports (well construction, pump installation, and well abandonment reports) required of contractors when well construction is complete, pumps are serviced or replaced, or wells abandoned,
The DWR does not use water well work reports to help monitor adherence to construction requirements.

Well Inspection Recommendations

To their credit, the Colorado Division of Water Resources agreed with the auditors’ recommendations to:

Require advance notice of key construction phases for all wells,
Prioritize inspection of high-risk wells and of key phases of construction, and
Use work reports to monitor compliance with construction requirements,
Improve financial controls over the Well Inspection Cash Fund.

While there are many reputable and highly competent water well contractors in Colorado the bad actors in the industry have cast doubt on all well contractors. There is currently a bill before the legislature to fully fund the inspection program using money from the recent Proposition DD. However, over decades, many tens of thousands of water wells have been installed but never inspected and could have problems that affect the water supplies many well owners rely on.

You can find the state’s Well Inspection Program Audit Report here: https://leg.colorado.gov/audi…/water-well-inspection-program

Considering Water Well Drilling or Maintenance?

If you are drilling a new well or having your water well serviced, Westwater can either hire and oversee a qualified contractor or work with your water well contractor to make sure all work is done properly and to the highest standards.

October 17, 2019