Transcript Lead and Copper Rule Short

Lead and Copper Rule:
Short-Term Revisions and
Clarifications
Jim Moore
VDH – Office of Drinking Water
Training Objectives
1.
2.
3.
4.
Present a brief history of EPA lead and copper
regulations
Summarize basic elements of the original LCR
and LCRMR
Summarize the changes and clarifications
contained in the new Short Term Revisions
Rule
Present and discuss some lead and copper
monitoring examples and resulting required
actions
2
LCR Short-Term Revisions
Rule Making History
The Lead and Copper Rule: Short Term Revisions and Clarifications (LCR
STR) is the fourth EPA Rule dealing with lead and copper in drinking water
•
The Lead Contamination Control Act was promulgated in 1988
•
The original Lead and Copper Rule (LCR) was promulgated on June 7,
1991
•
The Lead and Copper Rule Minor Revisions (LCRMR) were promulgated
on January 12, 2000
•
The Lead and Copper Rule: Short Term Revisions and Clarifications
(LCR STR) were promulgated on October 10, 2007
•
EPA is not done – work on a Lead and Copper Rule: Long Term Revision is
underway
3
LCR Short-Term Revisions
Rule Making History
All of these Lead
and Copper Rules
apply to :
• Community
and,
• Non transient non
community
waterworks
4
Original LCR
Overview
•
First published on June 7, 1991
•
Established MCLGs for lead and copper
•
Established Action Levels in lieu of MCL’s
MCLG
Lead
Copper
0 mg/L
1.3 mg/L
Action Level
0.015 mg/L
1.3 mg/L
•
90th percentile sample result is compared to AL
•
ALE is a trigger and is not a violation
•
ALE requires waterworks to initiate various treatment
techniques and additional monitoring activities
5
Lead and Copper Rule
Overview
CWS or NTNCWS Collects Lead
and Copper Tap Samples
90th Percentile
Is at or Below
Both Action Levels
Conduct
periodic lead
and copper
tap
monitoring
90th Percentile
Exceeds the Lead
Action Level (15 μg/L)
Begin LSLR
replacement
if LSL are
present
Conduct
public
education
Begin CCT
steps
includes
WQP
monitoring
90th Percentile
Exceeds the Copper
Action Level (1.3 mg/L)
Conduct
source
water
monitoring
(Install SOWT,
if needed)
Conduct
periodic lead
and copper
tap
monitoring
6
Lead and Copper Rule
Review of Lead and Copper Tap
Monitoring Requirements
7
Review of Monitoring Requirements
Site Selection – Community Systems
• Prior to sampling each waterworks must submit a materials survey
and sample site selection justification
• LCR requires that samples be collected from the highest risk locations
• Three sampling site tiers: Tier 1, Tier 2, and Tier 3
• Tier 1 sample sites are considered high risk sites
• Tier 1 sampling pool consists of single family structures* that:
• Contain copper pipes with lead solder installed between 1983
and 1986 (date of Virginia’s lead solder ban) or;
• Contain lead pipes and/or;
• Are served by a lead service line
* May include multiple-family residences in sampling pool when
they comprise at least 20 percent of structures served
8
Review of Monitoring Requirements
Site Selection – Community Systems
• Tier 2 sampling pool consists of buildings including multiple
family residences that:
Contain copper pipes with lead solder installed between 1983 and 1986
(date of Virginia’s lead solder ban) or;
• Contain lead pipes and/or;
• Are served by a lead service line
•
• Tier 3 sampling pool consists of single family structures that:
• Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if
insufficient number of tiered sampling sites are available
9
Review of Monitoring Requirements
Site Selection – NTNC Systems
Two sampling site tiers: Tier 1 and Tier 2.
•
Tier 1 sampling pool consists of sample sites that:
•
•
•
•
Contain copper pipes with lead solder installed between
1983 and 1986 (Virginia’s lead solder ban) or;
Contain lead pipes and/or;
Are served by a lead service line
Tier 2 sampling pool consists of sample sites that:
•
Contain copper pipes with lead solder installed before 1983.
Use representative sites throughout distribution system if
insufficient number of tiered sampling sites are available
10
Review of Monitoring Requirements
Sample Site Selection
The LCR STR clarifies that an acceptable sampling location
should be a tap that is “normally” used for human
consumption:
• Typically cold water kitchen or bathroom sinks
• Drinking fountains and water coolers in schools or other
buildings
• Do not sample from outside hose bibs or utility sinks
11
Review of Monitoring Requirements
Sample Collection Method
•
•
First-draw samples
•
Minimum 6-hour standing time
•
One-liter volume
System or residents can collect
12
Review of Monitoring Requirements
Minimum Number of Tap Samples
System Population
Number of Sampling
Sites (Initial / Routine
Monitoring)
Number of Sampling
Sites ( Reduced
Monitoring)
>100,000
100
50
10,001 to 100,00
60
30
3,301 to 10,000
40
20
501 to 3,300
20
10
101 to 500
10
5
≤100
5
5
13
Review of Monitoring Requirements
Lead and Copper Tap Monitoring
•
Initial monitoring includes two 6-month periods
(January – June and July – December)
•
After the two 6-months of initial monitoring w/ results
below both AL’s, monitoring can be reduced to once per
year at the reduced number of sites
•
After three years of monitoring w/ results below both
AL’s, monitoring can be reduced to once per three
calendar years
•
Waterworks in reduced monitoring must collect all
samples during the months of June - September
14
Review of Monitoring Requirements
Collecting Samples and Calculating Compliance
• All valid sample results will be included in the 90th percentile
calculation:
• Sample must meet the selection criteria (tier and category)
• Sample must be collected within the compliance monitoring period (June –
September for reduced monitoring)
• Some samples are not included in the 90th percentile calculation:
• Customer-requested sample - unless meet site selection criteria
• Samples collected outside compliance monitoring period
• 90th percentile concentrations will be calculated even if less than
the minimum number of samples are submitted
• This is also monitoring violation
• A NOV will be issued
15
Review of Monitoring Requirements
Collecting Samples and Calculating Compliance cont.
•
Define a valid sample:
• First-draw – minimum of 6 hours standing time
• 1-liter in volume
• Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink, drinking fountain)
•
Waterworks can collect samples or review collection information
before analysis – if something is not right do not have the sample tested
•
States can only invalidate a sample if:
• Improper sample analysis, or
• Site selection criteria not met, or
• Sample container was damaged in transit, or
• Sample subjected to tampering
16
Review of Monitoring Requirements
Management of Aerators during Sample Collection
•
Encourage homeowners to regularly clean
aerators
•
Do not remove/clean prior to or during
sampling as this could fail to identify
typical lead contributions
•
DCLS sampling instructions have been
modified
17
Lead and Copper Rule
Review of 90th
Percentile Calculations
18
Review of 90th Percentile Calculations
More than 5 Samples
•
Step 1: Place lead or copper results in ascending order.
•
Step 2: Assign each sample a number, 1 for lowest value.
•
Step 3: Multiply the total number of samples by 0.9.
Example: 20 samples x 0.9 = 18th sample.
•
Step 4: Compare 90th percentile level
to AL (in above example, 18th sample)
19
Review of 90th Percentile Calculations
More than 5 Samples Example
Assume 10 samples are collected with lead and copper
results as follows:
Site A:
Site B:
Site C:
Site D:
Site E:
Site F:
Site G:
Site H:
Site I:
Site J:
0.005 mg/L
0.015 mg/L
0.005 mg/L
0.014 mg/L
0.014 mg/L What is the 90th Percentile Value?
0.005 mg/L
0.040 mg/L
0.014 mg/L
0.014 mg/L
0.005 mg/L
20
Review of 90th Percentile Calculations
More than 5 Samples Example
Step 1: Order results from lowest to highest:
1.
2.
3.
4.
5.
Site A:
Site C:
Site F:
Site J:
Site D:
0.005
0.005
0.005
0.005
0.014
6. Site E:
7. Site H:
8. Site I:
9. Site B:
10. Site G:
0.014
0.014
0.014
0.015
0.040
Step 2: Multiply number of samples by 0.9 to determine
which represents 90th percentile level
10 x 0.9 = 9th sample (or 0.015 mg/L)
Step 3: Compare to lead action level  No Exceedance
21
Review of 90th Percentile Calculations
More than 5 Samples Example
•
Suppose when you multiply the number of samples the
result is not a whole number
•
As an example consider a sample set that contains 24
lead and copper samples
•
Example: 24 samples x 0.9 = 21.6th sample result
•
In this situation you can use rounding (round the 21.6 up
to 22 and compare the 22nd highest sample result to the
Action Level
As an alternative method you can use interpolation
•
22
Review of 90th Percentile Calculations
5 Samples Example
•
Step 1: Place results in ascending
order.
•
Step 2: Average 4th and 5th
highest sample results.
•
Step 3: Compare 90th percentile
level to action level.
23
Review of 90th Percentile Calculations
5 Samples Example
Assume 5 samples are collected with lead and copper
results as follows:
Site A: 0.009 mg/L
Site B: 0.011 mg/L
Site C: 0.020 mg/L What is the 90th Percentile Value?
Site D: 0.009 mg/L
Site E: 0.010 mg/L
24
Review of 90th Percentile Calculations
5 Samples Example
Step 1: Order results from lowest to highest:
1.
2.
3.
4.
5.
Site A:
Site D:
Site E:
Site B:
Site C:
0.009 mg/L
0.009 mg/L
0.010 mg/L
0.011 mg/L
0.020 mg/L
Step 2: Average 4th & 5th samples highest samples to get 90th
percentile value = 0.016 mg/L
0.011 mg/L + 0.020 mg/L = 0.0155 mg/L
2
Step 3: Compare average to lead action level  Exceedance
25
Review of 90th Percentile Calculations
Fewer than 5 Samples
•
•
•
Procedure has changed under LCR STR.
Some systems may collect < five samples.
Sample with highest result is 90th percentile level.
Assume 3 lead samples: 0.020 mg/L, 0.008 mg/L, and 0.005 mg/L
90th percentile = 0.020 mg/L
•
No M/R violation.
26
Lead and Copper Rule:
Short-Term Revisions and Clarifications
27
LCR Short Term Revisions
Major Changes
Monitoring Revisions
1.
•
•
•
2.
3.
4.
5.
6.
Minimum Number of Samples Required
Definitions for Compliance and Monitoring Periods
Reduced Monitoring Criteria
Consumer Notice of Lead Tap Results
Consumer Confidence Report Mandatory Language
Notification of Treatment and Source Changes
Public Education Changes
Reevaluation of Tested Out Lead Service Lines
28
LCR Short Term Revisions
Compliance Dates
•
LCR STR was published on October 10, 2007 and has
an effective date of December 10, 2007
•
For States that “Adopt by Reference” the rule
compliance date is 180 days after promulgation - or by
April 8, 2008
•
For State’s with a formal adoption process the rule
compliance date is two years after the effective date
- or by December 10, 2009 - Virginia is in this category
•
States can request up to an additional two years
extension – or by December 10, 2011
29
LCR Short Term Revisions
Compliance Dates
•
As noted above, Virginia technically has until
December 10, 2009 to implement this new rule
•
However, as we have done with other EPA
rules, ODW will proceed with implementation
during the interim period of formal adoption
•
Implementation will begin with samples
collected this summer
30
Minimum Number of
Samples Required
Systems affected
• Small systems serving 100 or fewer people with less
than five taps used for human consumption
(primarily non-transient, non-community water
systems – NTNCWS)
􀀶
Regulatory revision
• Retain the 5 sample minimum, but also allow
States discretion to reduce monitoring to one
sample per tap used for human consumption
where there are fewer than 5 such taps
31
Minimum Number of
Samples Required
•
For systems taking fewer than 5 samples, the
highest single sample lead and copper values
are used to determine if the system meets the
Action Levels
•
The ODW is adopting the < 5 sample provision
for very small waterworks
32
Minimum Number of
Samples Required
If a waterworks chooses this option to collect fewer
than five samples, the ODW must ensure that:
•
The LCR Monitoring Plan is revised to indicate the number of
samples to be collected and the specific sample locations
•
All sample taps used for human consumption are sampled
•
The owner is aware that the single highest sample result will be
compared to the Action Levels
•
This sampling plan is approved in writing prior to the sampling event
33
Definitions of Compliance and
Monitoring Periods
Systems affected:
• All systems when they exceed an action level
Regulatory Revision:
• Clarify definitions for monitoring period and
compliance period
•
For waterworks in reduced monitoring the end of the
monitoring period is typically September 30 (samples
must be collected during June through September)
whereas the compliance period would end
December 31
34
Definitions of Compliance and
Monitoring Periods
•
Timing of actions required after an AL
exceedance is not clearly defined for
waterworks in reduced monitoring – i.e. is
compliance calculated from the end of the
monitoring period or from the end of the
compliance period
•
LCR STR revisions clarify that systems are
deemed to be exceeding the AL as of the end of
the monitoring period (i.e. September 30)
35
Definitions of Compliance and
Monitoring Periods
•
LCR STR revises the various timeframes from end of
monitoring period for actions trigger by AL
exceedance:
•
Example – Waterworks corrosion control treatment
recommendation is required within 6 months following
the end of the monitoring period (September 30, 2007) or
by March 30, 2008
•
Example – Waterworks Public Education is required
within 60 days following the end of the monitoring
period (September 30, 2007) or by November 30, 2007
36
Deadlines Are Critical
From the end of the monitoring period –
September 30
•
•
•
•
10 days to report LCR monitoring results
60 days to complete public education
3 months to certify consumer notification
6 months for corrosion control treatment
recommendations
37
Three Year Compliance Cycle for
Systems on Triennial Monitoring
•
Samples must be collected during a four month
period every 3 calendar years (typically June –
September)
•
Systems on triennial monitoring can not spread
sampling out over a three-year period (samples
must be collected in the same year)
•
System can not exceed 3 years between sampling
events – calendar years
38
LCR STR Monitoring Revisions
Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)
•
•
•
Triennial monitoring must occur once every 3-year compliance period
Monitoring period is June – Sept. of same calendar year
Cannot exceed 3 years between sampling events (see example)
2009
June–September
June–September
Monitoring period
Monitoring period
2010
2011
Three-year compliance period
2012
2013
2014
Three-year compliance period
39
STR Monitoring Revisions
Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)
The LCR STR clarify that:
•
Annual reduced lead and copper tap
monitoring starts the next year after 2nd
6-month period
If 2nd 6-month is:
Annual Monitoring Begins
January – June
June 1 of next year
July - December
40
Criteria for
Reduced Monitoring
Systems Affected:
• All systems exceeding the lead action level
Rule Revision:
• Systems on reduced monitoring for lead and copper
that are currently exceeding the lead Action Level (but
meeting WQP’s) will need to go back on standard 6month tap monitoring schedule
•
Limits reduced monitoring to those systems
meeting optimal water quality parameters and
the lead Action Level
41
Reduced Monitoring Example
•
WQP’s that define optimal corrosion control treatment
have been established for a large waterworks in
triennial reduced monitoring
•
Monitoring results indicate that the waterworks meets
the established WQP’s during all 6 month compliance
periods
•
Monitoring results indicate a 90th percentile lead
concentration of 18 ppb which exceeds the 15 ppb
Action Level
42
Reduced Monitoring Example
•
Under current LCR language, this waterworks is
eligible to remain in triennial reduced monitoring
•
The LCR STR Rule clarifies that any waterworks can
only become eligible for, or be allowed to remain in
reduced monitoring if the 90th percentile lead
concentration is below the lead Action Level
•
Under the LCR STR Rule this large waterworks would
be required to return to initial monitoring (6 month
frequency at the initial number of samples)
43
Let’s Take a Break !!
44
Consumer Notification
Systems Affected:
• All systems (Community and NTNC) – even if both
lead and copper Action Levels are met
Rule Revision:
• Waterworks must provide notification of the lead and
copper sampling results to the occupants at each site
that was tested in the LCR tap monitoring program
within 30 days of receipt of results
•
This 30 day time period begins on the date the
waterworks receives the lead and copper results
notification letter from the ODW
45
Consumer Notification
•
In addition to the lead and copper sample results,
waterworks must also provide:





•
Health effects language
Actions residents can take to reduce exposure to lead in
drinking water
Utility contact information
Maximum contaminant level goal (MCLG)
Action Level Definition
The Consumer Notification is required following each
lead and copper monitoring event – regardless of the
results
46
Consumer Notification
•
Delivery Mechanisms – Direct mail or another method
approved by the State
• NTNC systems could post the results on a bulletin board in the
facility
• Small waterworks could provide notification by hand delivery
• Must provide notice to the occupants of the building
that was tested – even if those residents do not receive
water bills
􀀶
47
Consumer Notification
Reporting requirements:
•
Within 3 months from end of monitoring period, the
waterworks must submit a copy of notification that
was provided and must certify that all notification
requirements have been met
•
Consumer Notification templates are provided in the
handout material
􀀶
48
New Violation
LCR STR Rule adds an additional violation for
failure to meet the lead consumer notification
requirements
• Note that is part of the Public Education portion
of the rule but is a separate violation
• This is a M/R violation and not a TT violation like
failure to meet the PE requirements following a
lead Action Level exceedance
•
49
Consumer Confidence
Report (CCR) Revisions
Systems Affected:
• All systems – even if results are “not detected” for lead and copper
Rule Revision:
• All CCR’s must include mandatory language concerning lead in
drinking water. The mandatory language includes:
• Health effects on children
• Flushing recommendation of 15 to 30 seconds
• Waterworks can write its own educational statement in consultation
with the ODW Field Office
• This new language must be in included in all CCR’s beginning
with the 2008 CCR’s (to be delivered by June 2009)
50
Consumer Confidence
Report (CCR) Revisions
•
Must include following mandatory language. Any
modifications must be approved by ODW.
If present, elevated levels of lead can cause serious health problems, especially
for pregnant women and young children. Lead in drinking water is primarily
from materials and components associated with service lines and home
plumbing. [Name of Utility] is responsible for providing high quality drinking
water, but cannot control the variety of materials used in plumbing
components. When your water has been sitting for several hours, you can
minimize the potential for lead exposure by flushing your tap for 15 to 30
seconds or until it becomes cold or reaches a steady temperature before using
water for drinking or cooking. If you are concerned about lead in your water,
you may wish to have your water tested. Information on lead in drinking
water, testing methods, and steps you can take to minimize exposure is
available from the safe Drinking Water Hotline or at
http://www.epa.gov/safewater/lead.
51
Notification & Approval for
Long-term Treatment Changes
Systems affected
• All systems on reduced lead and copper tap monitoring
making a long-term treatment change
Rule Revision
• Requires waterworks owners to notify the State in
writing and obtain approval prior to implementing a
long-term change in water treatment
•
Notification timeframe for systems – at a time
specified by the State, or if none specified, then as
early as possible prior to the long-term change
52
Notification & Approval for
Long-term Treatment Changes
•
Examples of long-term treatment changes:
•
•
•
•
Changing disinfectants such as chlorine to chloramines
Changing primary coagulants such as alum to ferric chloride
Changing corrosion inhibitor chemicals such as
orthophosphate to a blended phosphate
Making a change in dose of an existing chemical if the
waterworks is planning a long-term change to its finished
water pH or inhibitor residual concentration
53
Notification & Approval for
Long-term Treatment Changes
•
Additional examples of long-term treatment changes:
•
Installation of a major unit process such as membrane
filtration, ozonation, enhanced coagulation
•
Other treatments or processes that can greatly affect the pH,
oxidation-reduction potential, or alkalinity
54
Notification & Approval for
Long-term Treatment Changes
•
Waterworks Regulations 12 VAC 5-590-190 Permits - require
waterworks owners to obtain a Construction Permit for any
changes in treatment or the addition of a new water source
•
ODW’s approval as required by the LCR STR, implies an
assessment as to whether treatment changes may have an adverse
impact on corrosion and/or result in elevated lead levels in the
distribution system
•
ODW may require the waterworks to conduct:
• A new OCCT study prior to the treatment change
• Additional lead and copper monitoring to assess any impacts
55
Notification & Approval for
Long-term Treatment Changes
•
Potential impacts on corrosion or elevated lead levels
should be addressed during the Preliminary
Engineering Conference or as part of the Preliminary
Engineering Report review process
•
Each situation must be evaluated on a case-by-case
basis
•
Additional monitoring requirements will be determined
on a case by case basis
56
Notification & Approval for
Addition of New Sources
Systems affected
• All systems on reduced lead and copper tap monitoring
adding a new water source
Rule Revision
• Requires waterworks owners to notify the State in
writing and obtain approval prior to adding a new
source of water
•
Notification timeframe for systems to provide written
documentation – at a time specified by the State, or if
none specified, then as early as possible prior to
adding a new water source
57
Notification & Approval for
Addition of New Sources
•
Notification and approval are not required every year
if source is used seasonally
•
ODW will deal with new sources on a case-by-case
basis in the same manner as adding a new treatment
process or making a long-term change in treatment
58
Public Education
Revisions
Public Education Revisions
Systems affected
• All systems exceeding lead AL
Rule Revision
• LCR STR Rule makes significant changes in the
message content, delivery requirements, and the
timing of when waterworks must complete
required Public Education activities
60
Public Education Revisions
Written Materials
• PE written materials (Community and NTNC) include:
• Introduction/information statement - this is mandatory
language and can not be altered
• New health effects language that provides greater specificity
on lead health effects – i.e., lower IQ impacts in children - this
is mandatory language and can not be altered
• Sources of lead
• Steps to take to reduce exposure to lead in drinking water Flushing recommendations can be tailored to the system’s
specific situation
• What happened and what is being done
• Sources of additional information – this mandatory language
and can not be altered
61
Public Education Revisions
Written Materials
Required content for community waterworks only:
•
Tell consumers how to get their water tested
•
Discuss lead in plumbing components and the
difference between low lead and lead free
62
Public Education Revisions
Written Materials
“Special” Community Waterworks may:
• Limit the Public Education written materials by eliminating the language
telling customers how to get their water tested and the discussion of
plumbing components
• Limit the Public Education deliver to the delivery requirements for
NTNC waterworks
If the waterworks is a facility such as a prison, hospital, boarding
school where the population served is not capable of, or is prevented from,
making improvements to plumbing or installing POU treatment devices, and
The waterworks provides water as a part of the cost of services and
does not separately charge for water consumption
63
Public Education Revisions
Delivery Requirements – Written Materials
Community Waterworks
• Deliver written materials (pamphlets, brochures, etc.) to all bill paying
customers
• Deliver written materials to facilities and organizations that are served by
the waterworks that are most likely to be visited regularly by pregnant
women and children
• Local Heath Departments
• Public and private schools and preschools
• WIC and Head Start programs
• Public and private hospitals
• Pediatricians, Gynecologists and Midwives
• Family Planning Clinics
• Local welfare agencies
• Within 60 days of the end of the monitoring period
64
Public Education Revisions
Delivery Requirements – LHD Contact
Community Waterworks
• Are required to make contact with the Local Health
Department in person or by telephone - this is addition
to sending the PE written materials. The LHD contact
must be made even if the LHD is not served by the
waterworks
• Request assistance from the LHD in notifying specific
organizations that serve “at-risk” customers such as
licensed day care centers, public and private
preschools, obstetricians-gynecologists, and midwives
65
Public Education Revisions
Delivery Requirements – LDH Contact
Community Waterworks
• If the LDH provides a list, all organizations must be
contacted and provided with the written material:
• For large waterworks serving > 3,300 persons all
organizations must be contacted even if the
organization is not served by the waterworks
• For waterworks serving 3,300 or fewer persons all
organizations must be contacted that are served by
the waterworks
66
Public Education Revisions
Delivery Requirements – Additional Activities

Implement additional Public Education activities from the
following list:
Waterworks serving > 3,300 persons must implement at least 3
Waterworks serving ≤ 3,300 persons must implement at least 1









Public Service Announcements
Paid advertisements
Public area information displays
E-mails to customers
Public meetings
Household deliveries
Targeted individual customer contacts
Direct material distribution to all multi-family homes or institutions
Other methods approved by the state
67
Public Education Revisions
Delivery Requirements – Billing Cycle Notification
Community Waterworks
• Provide information about lead in drinking water on or in each customer
water bill with each billing cycle
• This notification must be done at least quarterly
• If water bills are not sent at least quarterly a separate mailing is
required
[Insert name of water system] found high levels of lead in drinking water in some
homes. Lead can cause serious health problems. For more information please call
[insert name of water system] or visit [insert your web site here].
• Waterworks serving > 100,000 must post material on web site
68
Public Education Revisions
Delivery Requirements – Press Release
Community Waterworks
• Submit a press release to newspapers, television, and radio
stations
• The press release delivery requirement may be waived for a
waterworks serving 3,300 or fewer persons if the
waterworks delivers the written material to every
household served
• Within 60 days after the end of the monitoring period
69
Public Education Revisions
Delivery Requirements – Written Materials
NTNC Waterworks
•
Post informational posters containing the required
written materials in a public place or common area in
each building served by the waterworks and
•
Deliver written materials to each person served
•
Notification by electronic transmission may be
approved if it achieves at least the same coverage
•
Within 60 days following the end of the monitoring
period
70
Public Education Revisions
Repeat Delivery Requirements
Community waterworks must repeat every 12 months:
• Delivery of written materials to each billing customer
• Delivery of written materials to LHD, and facilities and
organizations that are most likely to be visited regularly by
pregnant women and children
• Implement the additional Public Education activities from the
approved list
Community waterworks must repeat twice every 12
months:
•
Press Release
For as long as the lead Action Level is exceeded
71
Public Education Revisions
Repeat Delivery Requirements
NTNC waterworks must repeat every 12 months
• Post informational posters containing the required written
materials in a public place or common area in each building
served by the waterworks - within 60 days following the end of
the monitoring period
and
• Deliver written materials to each person served - within 60 days
following the end of the monitoring period
For as long as the lead Action Level is exceeded
72
Public Education
Delivery Certification
Within 10 days after the end of the each period in which
the waterworks is required to perform Public Education:
• Send written documentation to the state certifying that
the waterworks written material met all of the content
requirements, and
• That all of the delivery requirements have been met
73
Re-evaluation of Tested-out
Lead Service Lines
Systems affected
• Systems required to implement the Lead Service Line Replacement
treatment technique
• Under current LCR language, waterworks can test each LSL prior to
replacement. If the lead result is below 15 ppb the LSL does not have to
be replaced but can be counted as being replaced
Rule Revision
• LSL’s that tested below 15 ppb would not be considered permanently
replaced and would have to be re-evaluated if system later re-exceeds
action level
• Re-evaluation could consist of either testing the line again or physical
replacement of the line because previous sample may no longer be
representative of the lead service line lead concentrations
74
Lead Service Line Replacement
• LSL replacement schedule is more explicit
• First year requires 7% replacement, begins
immediately at end of the monitoring period
• Still have all existing testing and notification
requirements
75
Lead Service Line Replacement
• To date no waterworks in Virginia have been
required to implement the LSL Replacement
treatment technique
76
Lead and Copper Tap Sample
Monitoring Example
77
Monitoring Example
•
Anytown is a community waterworks serving a
total population of 3800 persons. Anytown is
currently in triennial reduced monitoring
collecting lead and copper tap samples once
every three years
•
Based upon the 3800 population Anytown is
required to submit the results of 20 lead and
copper tap samples during the reduced
monitoring period
78
Monitoring Example
Minimum Number of Tap Samples
System Population
Number of Sampling
Sites (on Routine
Monitoring)
Number of Sampling
Sites (on Reduced
Monitoring)
>100,000
100
50
10,001 to 100,00
60
30
3,301 to 10,000
40
20
501 to 3,300
20
10
101 to 500
10
5
≤100
5
5
79
Monitoring Example – cont.
•
Anytown collects 14 samples on July 3, 2009. Results are
submitted to the ODW Field Office on July 25, 2009 by
the laboratory
•
Anytown collects 10 additional samples on October 2,
2009. Results are submitted to the ODW Field Office on
October 10, 2009 by the laboratory
•
All samples were collected from sites that were included
in the initial LCR sampling plan that was approved by
the ODW
80
Monitoring Example – cont.
What actions will be taken by the ODW Field
Office??
•
There are only 14 valid lead and copper tap
sample results
•
The 10 samples collected on October 2, 2009 can
not be utilized as all reduced monitoring
samples must be collected during the months of
June through September
81
Monitoring Example – cont.
•
The ODW Field Office must calculate the 90th
percentile lead and copper concentrations using
the 14 samples that were collected in July 2009
•
The ODW Field Office must issue a monitoring
violation for failure to submit 20 lead and
copper sample results – only 14 valid results
were submitted
82
Monitoring Example – cont.
ODW Field Office will calculate the 90th percentiles
• Place the 14 samples in ascending order
•
Multiply the 14 samples by 0.9
14 x 0.9 = 12.6
•
Round the 12.6 value up to 13 – the 13th highest
sample results are compared to the Action Levels
83
Monitoring Example – cont.
Anytown 90th Percentile Calculation:
S ample
As cending
Collection
Lead
Date
S ample
Number
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
3-Jul-09
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Lead
Res ult
(ppb)
As cending
Copper
S ample
Number
Copper
Res ults
(mg/L)
< 5
< 5
< 5
< 5
< 5
< 5
< 5
6
7.3
8.6
9
13
14
25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
0.22
0.33
0.33
0.34
0.5
0.5
0.5
0.55
0.73
0.79
0.89
1
1.1
1.9
84
Monitoring Example – cont.
ODW Field Office will calculate the 90th percentiles
•
The 90th percentile lead concentration is 14 ppb
which is below the 15 ppb Action Level
•
The 90th percentile copper concentration is 1.1 mg/l
which is below the 1.3 mg/L Action Level
85
Monitoring Example – cont.
What actions are required by Anytown ??
•
Anytown must distribute public notification (the M/R
violation is a Tier III violation) within 12 months
•
Anytown must collect their next round of LCR tap
samples during the June through September 2010
monitoring period
•
Anytown must initiate the consumer notification
requirements – to be completed within 30 days of receipt
of the ODW lead and copper results notification letter
86
Monitoring Example #2 – cont.
Let’s Assume that the 90th percentile lead concentration for
Anytown was calculated to be 17 ppb.
What actions are required by Anytown ??
• Anytown must distribute public notification (the M/R
violation is a Tier III violation) within 12 months
•
Anytown must initiate the consumer notification
requirements – to be completed with 30 days of receipt
of the ODW lead and copper results notification letter
87
Monitoring Example #2 – cont.
•
•
•
The 17 ppb 90th percentile concentration has exceeded
the lead Action Level of 15 ppb
Anytown must submit an optimum corrosion control
treatment recommendation to the Field Office within 6
months of the end of the monitoring period or by March
31, 2010.
Anytown must conduct Water Quality Parameter
Monitoring within 6 months from the beginning of the
monitoring period or by November 30, 2009 (6 months
from June 1, 2009)
88
Monitoring Example #2 – cont.
•
Anytown must conduct source water monitoring for
lead within 6 months from the end of the monitoring period
or by March 30, 2010 (6 months from September 30,
2009)
•
Anytown must complete all of the Public Education
requirements within 60 days of the end of the
monitoring period or by November 30, 2009
•
Public Education must continue as long as Anytown
continues to exceed the lead Action Level
•
Lead Service Line Replacement is not required since
Anytown does not have any lead service lines
89
Monitoring Example #2 – cont.
•
•
Anytown is no longer eligible for reduced monitoring
Anytown should continue to monitor
•
•
•
•
•
Collect 40 lead and copper samples during January – June 2010
Will end the monitoring violation
If results are below the lead AL will end Public Education
If the AL continues to be exceeded corrosion control
treatment must be installed
Treatment must be installed within 24 months of ODW
notification, unless an OCCT study is required
90
Questions and Discussion
91