Water Quality

Polyphosphates are legally permitted additives that are widely used to aid processing or to improve eating quality of many foods, particularly meat and fish products. Phosphates are also used in making baking powder and cola drinks, and great quantities are used in fertilizers and detergents. Phosphates are present normally in all living things and are an essential component of our diet. A phosphate is a salt of phosphoric acid; when a number of simple phosphate units are linked to form a more complex structure, this is known as a polyphosphate. The phosphates used in foods may be simple phosphates, pyrophosphates containing two phosphate units, tripolyphosphates containing three units, or polyphosphates containing more than three phosphate units. Source: Food and Agriculture Organization of the United Nations

Ortho Polyphosphates are a blend of phosphate salts in their singular “ortho” form and chains of phosphate ions in the “poly” form. SeaQuest is a brand of Ortho Polyphosphate manufactured by Aqua Smart and is a blend of phosphate salts in these two forms. Ortho Polyphosphates are commonly used as corrosion inhibitors and have been used in the United States since the 1980s. For more information please see the following link to the article entitled: “Ortho Polyphosphate Corrosion Inhibitors”, published in the September 2006 issue of Government Engineering Journal. See Attachment 1.

Most polyphosphates added to food are broken down into single phosphate units in the stomach when the food is eaten; indeed, many are converted to single units in the food before it is eaten, for example, in chill storage or during cooking. Thus it is clear that most phosphates added to food are nutritionally equivalent to the phosphates naturally present in food. Nevertheless it is possible for essential food components to be harmful if taken in excess, and international medical authorities have recommended that the daily consumption of all phosphates should not exceed a certain level. It is believed that the amounts presently being eaten by the typical consumer are well below this limit. Some countries do have limits on the amount that can be added and exporters must bear this in mind. Source: Food and Agriculture Organization of the United Nations

The District is bound by regulations established by the Colorado Department of Public Health and Environment (CDPHE). All public water systems must have an approved plan for all water treatment, including the specific procedures and products to be used. The CDPHE approved the District’s Corrosion Control Plan with the specific use of the SeaQuest brand Ortho Polyphosphate. See Attachment 2.
The District cannot waiver from the approved plan unless or until an alternative plan has been approved by all applicable agencies. In order to ensure consumer safety for specific products, the District must rely on certifications issued by organizations charged with the responsibility of establishing, researching and enforcing public health standards. Such organizations include, but are not necessarily limited, to the Environmental Protection Agency (EPA), the CDPHE and the National Sanitation Foundation (NSF).
Article 8 of the Primary Drinking Water Regulations issued by the Water Quality Control Commission of the CDPHE requires that all chemicals which come into contact with the potable water systems served to the public be certified under the NSF/ANSI Standard 60. The Primary Drinking Water Regulations can be reviewed on the CDPHE web site at the following link: www.cdphe.state.co.us/regulations/wqccregs/100301primarydrinkingwaternew.pdf

NSF certifies products and writes standards for food, water and consumer goods.  As an independent, not-for-profit organization, NSF offers programs and services to support legislators and regulators, to increase the awareness and knowledge of public health by professional associations, and to help raise the bar when it comes to safety, health and quality for industry. NSF Regulatory Affairs provides regulators with copies of NSF standards, information on facility registrations and product certification programs, answers to code questions, and product listing verifications to ensure that regulated products meet national standards or other prescribed requirements.  NSF is accredited by ANSI, IAS, and OSHA in the US and the Standards Council of Canada (SCC) in Canada. These accreditations attest to the competency of services provided by NSF and compliance with established national and international standards for third-party certification.  The NSF can be contacted at www.nsf.org, or by phone at 1-800-673-6275.  Product Certification Contact: Cheryl Luptowski, ext. 5075.  Source:NSF

NSF/ANSI Standard 60, first adopted by the NSF Board of Trustees on October 7, 1988, covers corrosion and scale control chemicals; pH adjustment, softening, precipitation, and sequestering chemicals; coagulation and flocculation chemicals; well-drilling products; disinfection and oxidation chemicals; and miscellaneous and specialty chemicals for treatment of drinking water. The standard addresses the health effects and implications of treatment chemicals and related impurities. Both the treatment chemical and the related impurities are considered contaminants for evaluation purposes. The two principal questions addressed are:

1. Is the chemical safe at the maximum dose, and
2. Are impurities below the maximum acceptable levels?

Source: NSF

Yes, SeaQuest Liquid Ortho Polyphosphate, the chemical used by the District, meets this standard up to a maximum concentration of 28 mg/L. This standard is relied upon by the CDPHE as well as the American Water Works Association (AWWA). See Attachment 3.

The concentration of SeaQuest Liquid introduced to the District’s water supply is approximately 0.5 milligrams per liter (mg/L). This is 56 times LESS than the established NSF/ANSI limit for safe consumption. As previously mentioned, SeaQuest Liquid meets the NSF/ANSI Standard 60 for safe consumption in concentrations up to 28 mg/L.

Yes, the product has been tested and approved by the NSF. In addition, the product is approved by the United States Department of Agriculture (USDA) for potable water systems used in official establishments operating under the Federal Meat, Poultry, Shell Egg Grading, and Egg Products Inspection programs. See Attachment 4. While the approvals above were issued by State and Federal Agencies charged with oversight of public health, we are aware of an additional study performed by Rush Labs in 1998 which found that the product was not toxic to several species of aquatic life when exposed to extremely high concentrations of 500 to 1,000 mg/L, for periods ranging from 48 to 96 hours. See Attachment 5.

Yes, SeaQuest is a proprietary and trademarked product produced in a controlled environment. The primary elements of the product are phosphate salts mined in the United States. Specifications for the product including its constituents are attached. See Attachment 6.

Yes. SeaQuest is distributed to 32 countries and at least 37 states within the United States. In Colorado, SeaQuest is used by at least 9 public water systems. These water systems include the Town of Poncha Springs, Parker Water and Sanitation District, Steamboat Springs Metropolitan District No. 2, Glacier View Meadows Water District, Indian Hills Water District, Evergreen Water District, Town of Lake City, Red Rocks Valley Estates and the District.

A Corrosion Control Plan (CCP) is a monitoring and treatment plan developed specifically for addressing elevated lead and copper levels within a public water system. The CCP is developed by the public water provider and then reviewed and approved by the CDPHE. The process for developing the CCP is outlined in Article 8 of the Colorado Primary Drinking Water Regulations promulgated by the Water Quality Control Commission of the CDPHE and is available online at: http://www.cdphe.state.co.us/regulations/wqccregs/100301primarydrinkingwaternew.pdf

A water system which experiences lead and copper exceedences as a result of routine water quality monitoring must develop a treatment technique for corrosion control (a/k/a CCP) as specified by the CDPHE under Article 8 of the Colorado Primary Drinking Water Regulations.

In 2007, routine water quality monitoring tests indicated that copper levels in the District’s water system exceeded the permissible copper action level of 1.3 mg/L at three different test locations. In response, the District, in conjunction with the CDPHE, developed a CCP to address these elevated levels. See Attachment 7.

The District is required to perform lead and copper tests twice a year (every 6 months). Article 8 of the Colorado Primary Drinking Water Regulations requires systems serving between 501 and 3,300 people to sample 20 sites. Once the District’s test results show reduced levels of lead and copper for 2 consecutive 6-month monitoring periods, the number of test sites can be reduced to 10.

No change to the CCP can be made without prior written approval of the CDPHE. Article 8 of the Colorado Primary Drinking Water Regulations requires a water provider under a CCP to notify the CDPHE, in writing, of any long term change in treatment. The CDPHE then reviews the notification and is required to approve it prior to any implementation of a new treatment plan under the CCP. The CDPHE may require the water provider to conduct additional monitoring or take alternative actions prior to implementing any approved change. Further, Article 8 prescribes that the CCP can be modified by the CDPHE, water provider or other interested party upon presentation, in writing, of an explanation of why the modification is appropriate and provision of supporting documentation evidencing the same. The CDPHE may modify the CCP in writing upon notification to the water provider setting forth the new treatment requirements, planning the basis for its decision and providing an implementation schedule for the same.

A CCP can be discontinued only upon demonstration to the CDPHE that the water system meets the testing requirements established by the CDPHE.

If a water provider fails to implement its CCP, this constitutes a violation of the Colorado Primary Drinking Water Regulations and the water provider may be subject to enforcement orders, civil or criminal actions and penalties as a result of the failure to comply.

Section 8.6 of the Colorado Primary Drinking Water Regulations prescribes permissible methods for corrosion control treatments. These include one or a combination of the following: 1) alkalinity and pH adjustment; 2) calcium hardness adjustment; and 3) the addition of a phosphate or silicate based corrosion inhibitor at the concentration sufficient to maintain an effective residual concentration in all test samples.

SeaQuest Liquid was chosen by the District’s staff in March 2008. Use of the product has continued for the following reasons:
1. Safe for consumption by the public. The product is approved for use by the CDPHE and meets the NSF/ANSI Standard 60.
2. Safe for handling by District Staff. The product requires no extraordinary safety precautions for safe handling, unlike many other products approved for use in administering a CCP.
3. The product is relatively simple to use. Introduction at the water source is metered and introduced to the water at the source according to the parameters of the CCP.
4. Minimal capital investment. The product requires minimal modification to the District’s infrastructure.
5. Low ongoing operating costs.  The District spends approximately $1,500 per year for the product.

Yes. There are several brands and manufacturers of ortho polyphosphate.

Article 1 of the Colorado Primary Drinking Water Regulations defines a Public Water System as including any collection, treatment, storage and distribution facilities under the control of the operator and used primarily in connection with the system. The definition also includes those facilities not under the control of the water provider, such as service lines within private residences.

The District is responsible for water quality from the source of the water to the tap in each individual home. While the District did not install the plumbing in individual homes, the District is responsible for maintaining water quality in accordance with the guidelines prescribed by the CDPHE. As you are probably aware, many homes have copper plumbing, which is joined at the fittings using lead solder. The lead concentration in solder has changed over the years, and older homes are typically at greater higher risk for increased levels of lead. The District’s distribution system contains some brass parts which is the industry standard. However, brass does contain elements of copper which contributes to the overall concentration of copper in the system.

The following table illustrates the copper results from 2009 through the first half of 2011: Copper/Lead Results Table

Yes, your water can be tested for the presence of these elements. If you would like your water tested for these elements by the District, the District charges $60 per test to cover the administrative time and processing fees. The timing for such testing is subject to the availability of the District’s staff and is processed on a first come, first served basis. Alternatively, property owners may obtain test results from a third party lab at their own expense. Contact information for these labs is as follows: Colorado Analytical Lab: 303-659-2313 or Evergreen Analytical Lab: 303-425-6021

There are a variety of water filtration companies which provide water filtration systems for individual homes. Interested customers may contact these companies to inquire into a system that best suits their home and needs. Customers are encouraged to analyze their individual needs and desires for such filtration systems. It should be noted that not all in-home filtration systems are 100% effective due to elements occurring organically and inorganically being present within faucets which are located after the filtration system. The District does not endorse any particular brand of filter, but reverse osmosis filters are capable of filtering Ortho Polyphosphate.