Lead and Copper Rule 10/21/2016. How long does it take water to leave the stomach after consumption? LCR

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1 How long does it take water to leave the stomach after consumption? Lead and Copper Rule OCTOBER 2016 NJWA ANNUAL CONFERENCE A. 10 seconds B. one minute C. five minutes D. 30 minutes E. 1 hour LCR Lead & Copper Tap Monitoring: 40 CFR Water Quality Parameter Monitoring: 40 CFR Lead & Copper Source Water Monitoring: 40 CFR Public Education: 40 CFR Corrosion Control Treatment: 40 CFR Source Water Treatment: 40 CFR Lead Service Line Replacement: 40 CFR Analytical Methods: 40 CFR Reporting: 40 CFR Recordkeeping: 40 CFR LCR Revisions In 2000, EPA published minor revisions to reduce monitoring and reporting burdens, and legal challenges to the 1991 rule. In 2004, EPA made minor revisions to reinstate text that was unintentionally dropped from the rule during previous revisions. In 2007, EPA made short term revisions to enhance implementation in the areas of monitoring, treatment, customer awareness, public education and lead service line replacement. In the news LEAD What is next in NJ? Components of the LCR are handled by both the Bureau of Safe Drinking Water and Bureau of Water System Engineering. Recently developed a Lead Team Kristin Hansen Kat Burkhard Jordana Nokes Kristen Ridarick Shaza Rizvi Leronda Aviles Gwen Derricotte Michelle Taormino Daylan Ware Tina Starr In addition Linda Bonnette is assisting with laboratories and lead in schools New Lead Website at 1

2 What is next in NJ? NJDEP is performing a self assessment of the LCR implementation. Previously: Evaluations of Corrosion Control Treatment Recommendations (CCTR) and issuing more detailed approval/denial letters. Follow-up Water Quality Parameter monitoring required following the installation of CCT. LCR Update August 19, 2016 Letter sent to all Community and Nontransient Noncommunity Water Systems. Contains: General Information Monitoring and Sampling Plans Sampling Technical Resources Corrosion Control Treatment Lead Service Line Replacement Lead and Copper Compliance Lead in Schools What is next in NJ? Addressed CCT inventory for all public water systems. Updating existing Permitting forms. Revising Pb and Cu Action Level Exceedance NONCs. Compliance will now be run on all LCR requirements. Violations are being issued. Licensed Operator Responsibilities N.J.A.C. 7:10A-1.12 Duties, records and reports 2. Each licensed operator shall: i. Properly operate and maintain the system, including, but not limited to, the following duties, as applicable: (1) Monitor chemical feed and other system components; (2) Monitor effectiveness of treatment; (3) Develop a preventive maintenance plan consistent with the schedule specified in the O&M procedures; (4) Read meters and gauges, making adjustments as needed; (5) Make all process control and/or system component integrity decisions; (6) Assist the system owner in resolving any problems complying with applicable regulations and permits; (7) Collect or oversee the collection of samples in accordance with O&M procedures; (8) Store chemicals in locked areas with proper safety equipment; (9) Inform the system owner of any technical or equipment needs of the system; (10) Assess the efficiency of system components (such as pumps and valves); and (11) Respond in a timely manner to customer complaints; ii. Schedule routine inspections and preventive maintenance tasks which will be undertaken to preserve the physical integrity of the system; iii. Establish and implement a routine recordkeeping system designed to incorporate all O&M procedures that relate to the system; iv. Develop a protocol for the system designed to ensure that each employee associated with the system is acquainted with his or her particular responsibilities and obligations, including the protocol to be followed in the event of an emergency within the system or an intervening factor which mandates deviation from routine O&M procedures; and v. Ensure that health and safety measures related to the O&M procedures are followed by the licensee, employees and agents of the system so as to protect human health, safety, welfare, and the environment. NJDEP Guidance and Forms New: Lead and Copper Sampling Plan Guidance Water Quality Parameter Sampling Plan Guidance Lead and Copper Sampling Pool Certification (BWSE 14) Lead and Copper Sample Site Certification (BWSE 15) Noncompliance Lead and Copper Tap Monitoring Form (BWSE 16) Optimal Water Quality Control Parameter Recommendation Form (BWSE-LC03) WQP Monitoring Report Form for Approved Party Water Sampling Analysis Form for Construction Permits and Temporary Approvals (BWSE- PA-101) Lead and Copper Approved Analytical Methods and Reporting Requirements Fact Sheet NJDEP Guidance and Forms Revised: Lead and Copper Sample Site Change Form (VBSDW 56) Public Education Certification Form (BSDW 55) Reminder: Lead and Copper Sampling Suspension Form (BWSE-LC01) CCT installation Certification Form (BWSE-LC02) Consumer Notice of Lead Tap Water Monitoring Results (BSDW 54) Lead Consumer Notice Templates 2

3 NJDEP Guidance and Forms Under Development: Lead and Copper Sampling Plan Template Water Quality Parameter Sampling Plan Template Materials Evaluation Form Public Education Requirement Fact Sheet Lead Service Line Replacement Fact Sheet Reduced Sampling Site Selection Guidance EPA: Guidance and Memorandums EPA periodically issues memorandums which clarify drinking water policies and regulations. These policy memos have been collected into a water supply guidance (WSG) manual which is made available to states and public water systems to assist in implementation of the Safe Drinking Water Act. EPA: Guidance and Memorandums Lead and Copper Rule Clarification of Requirements for Collecting Samples and Calculating Compliance memo November 23, 2004 What samples are used to calculate the 90 th percentile? What should utilities do with sample results from customer requested sampling programs? How to calculate compliance if the minimum number of samples are not collected? Grounds a sample may be invalidated. EPA: Guidance and Memorandums November 3, 2015 Due to the unique characteristics of each PWS it is critical that public water systems, in conjunction with their primacy agencies and, if necessary, outside technical consultants, evaluate and address potential impacts resulting from treatment and/or source water changes. EPA: Guidance and Memorandums February 29, 2016 Clarification of Recommended Tap Sampling Procedures for Purposes of the Lead and Copper Rule Removal and cleaning of aerators Pre-stagnation flushing Bottle configuration wide mouth bottles EPA: Guidance and Memorandums EPA: Optimal Corrosion Control Treatment Evaluation Technical Recommendations for Primacy Agencies and Public Water Systems March

4 What Size System under the Lead and Copper Rule? Size Category Population Served* Large > 50,000 Medium 3,301 50,000 Small < 3,300 * Transient populations served are not factored in to the population served Large Water Systems (serving >50,000) 2015 requested Water Quality Parameter (WQP) data. Evaluated WQP data and requested WQP monitoring plans. Due to the NJDEP by February 10, WQP monitoring began July 1, Most systems are on follow-up WQP monitoring. Large Water Systems July 2016 required the submittal of Lead and Copper Sampling Plan, Sampling Pool Certification Form and Sample Site Certification Form. All were due by September. A few have requested an extension. All large systems placed back onto standard lead and copper monitoring beginning January 1, Small and Medium Systems Will be requesting Lead and Copper Sampling Plans, WQP Sampling Plans (if applicable), Sample Site and Sampling Poll Certification Forms. For any system that exceeds the lead and/or copper action level. For any system changing CCT, a related treatment and/or source. As other concerns arise. Small and Medium Systems Then as follows: Have CCT and have had an ALE within the past 6 years Have CCT and have an ALE >6 years Have CCT and no ALE All other systems *Schools with CCT 4

5 Upcoming training For public water systems with CCT and have had an ALE. Information provided at these sessions will review what is required to be included in the Lead and Copper and Water Quality Parameter Sampling Plans. November 29 and 30, New Jersey Department of Environmental Protection, Main Building, Public Hearing Room, 401 E. State Street, Trenton. 8:30 AM 12:15 PM To register to attend one of the sessions call Tina Starr or Jordana Nokes at (609) Registration closes November 21, Due to limited space availability, only one representative from each public water system will initially be registered. If seats are still available after registration closes, you may request to send additional attendees. Lead in Schools and Child Cares Lead in schools Newark NJ Board of Education Rule NJDEP providing technical guidance All NJ public Schools required to sample by July Must have a sampling plan and QAPP. Based on EPA s 3Ts Lead in Schools Guidance Document; however, there are some significant differences. What city was the first distributor of lead? A. Paris B. Rome C. Cairo D. Athens E. Derbyshire Lead and Copper Sampling - Quick Points Water systems are not required to sample a person s home for lead and/or copper per request, unless the system has exceeded the lead action level. Public Education is required to provide information to customers on how they can have their water tested. If a water system elects to conduct sampling per a customers request, the sample result must be submitted for compliance if it is the correct tier and is collected during the monitoring period. Site Tier designation must be submitted for each sample site. Requiring the submittal of the Sample Site and Sampling Pool Certification Forms. Do not sign if you are not 100% sure the sample sites meet the criteria. Sampling Plan Content General water system information. Specific information: Materials evaluation of the distribution system Primary and alternate sample sites and the sample site tier designation Distribution tap monitoring requirements/schedule Sampling protocols and customer certification Sample invalidation procedures Compliance determination Action Plans for: Action Level exceedance Monitoring and Reporting violation Lead Consumer Notice Sampling Plan Content The system shall update the plan as needed based on any change within the water system, such as, but not limited to, water main replacements, treatment change, lead service line replacement, etc

6 Materials Evaluation Objective: Identify a pool of targeted sampling sites that meet the tier criteria for lead and copper sampling. The water system must identify if the following categories of piping and plumbing materials are present in the distribution system: Lead from piping, solder, caulking, interior lining of distribution mains and home plumbing Copper from piping, service lines and home plumbing Galvanized piping, service lines, and home plumbing Ferrous piping material such as cast iron and steel Designation of Sample Sites Population Served* Minimum Number of Standard Sites Minimum Number of Reduced Sites Recommended Minimum Number of Sites in Sampling Pool > 100, , , ,301 10, , *Population served only accounts for residential and non-transient population Lead and Copper Rule Sample Sites Lead and Copper Rule Sample Sites Tier 1 Tier 2 Tier 3 Other Community Water Systems Single-Family Structures: Served by a lead service line; and/or Contain copper pipes with lead solder installed after 1982 or contain lead pipes. *When multiple-family residences comprise at least 20% of the structures served by a water system, the system may include these types of structures in its sampling pool. Buildings, including multiple-family residents: Are served by a lead service line: and/or Contain copper pipes with lead solder installed after 1982 or contain lead pipes. Single family structures that contain copper pipes with lead solder installed before 1983 Structures with other plumbing materials If a water system contains lead service lines, at least 50 percent of the sampling sites should be those served by a lead service line. If a water system has no lead service lines, but it does have lead goosenecks, the system should at least collect 50 percent of tap water samples at the sites with goosenecks. Samples may not be taken from taps that have point of use or point of entry treatment devices designed to remove inorganic contaminants. Do not sample a location not in use or has not been used for a significant period of time. (The sample can not be invalidated.) Do not sample from outside hose spigots Lead and Copper Rule Sample Sites Tier 1 Non-Transient Non-Community Buildings: Served by a lead service line; and/or Contain copper pipes with lead solder installed after 1982 or contain lead pipes. Tier 2 Buildings that contain copper pipes with lead solder installed before 1983 Other Structures with other plumbing materials Designation of Sample Sites Sampling plan shall include the following: Standard lead and copper sites. Sites used for reduced lead and copper monitoring or protocol for how the reduced sites will be selected from the standard pool. Alternate sites. Tier designation for all sites. Sample Site Certification Form (BWSE-15) for each designated standard/routine and alternate site. Protocol if a sampling site no longer meets the tier requirements or if the customer refuses to participate. Documentation of a sample site no longer included in the water system s sampling pool (BWSE-56)

7 Sample Site Change No longer willing to participate in sampling No longer meets tier criteria *Lead and Copper Sample Site Change Form (BWSE-56) is required to be submitted within 10 days following the end of the monitoring periods for any sample change from the previous monitoring period Monitoring Schedule Situations and protocols when the water system may collect additional lead and copper samples. Does the water system distributes more sample bottles than the required number of sites. The system cannot dilute the 90 th percentile value with lower tier sample sites. If a sample site result is greater than the action level, will a confirmation sample be collected. If a customer requests the water system to sample their home for lead and copper Sampling Procedure Sampling procedures if the water system collects the lead and copper samples. Protocol used to reach out to the customers to solicit their participation. Copy of the instructions provided to the customers if the customers are collecting the samples. If the water system is a non-transient non-community and operates 24 hours (i.e. a hospital), outline procedures to ensure the water stands motionless in the area of the tap for a minimum of 6 hours. Sample Invalidation A sample may be invalidated if it meets any of the following conditions: The laboratory establishes that improper sample analysis caused erroneous results The State determines that the sample was taken from a site that did not meet the site selection criteria The sample container was damaged in transit There is substantial reason to believe that the sample was subject to tampering Action Level Exceedance The sampling plan shall include the following: Notification to NJDEP and bulk purchasers WQP Monitoring (initial, follow-up or optimal) Source water monitoring Public Education (for Lead Action Level only) Implementation of Corrosion Control Treatment Steps Implementation of Source Water Treatment Steps Return to Standard lead and copper tap monitoring, if currently on reduced Lead Service Line Replacement Templates Public Education Lead Consumer Notice Customer Sample Instructions Do not instruct them to remove and/or clean aerators. Do not recommend flushing. Recommend asking: POU or POE treatment Interior plumbing changes Replaced service line. 41 7

8 LCR Action Level Exceedance Remember an Action Level Exceedance is not a violation. Failure to comply with the corrective actions may result in a treatment technique violation. Following an ALE a water system must: Conduct source water monitoring Conduct WQP monitoring Submit a CCT Recommendation Submit a SWT Recommendation Conduct Public Education (Lead ALE only) Replace lead service lines (if CCT is installed and Lead ALE) Source Water Monitoring Within 6 months after the end of the monitoring period. Samples should be collected from each entry point to the distribution system. Source Water Treatment (SWT) may be required if results indicated elevated levels from the source. Source Water Treatment Water Quality Parameter Monitoring SWT recommendation required to be submitted within 180 days after the end of the monitoring period. After approval, treatment required to be installed within 24 months. Treatment option include ion exchange, reverse osmosis, lime softening, or coagulation and filtration. This is rarely the case as most sources of lead and copper are in the distribution system. Objectives Determine water corrosivity. Identify appropriate corrosion control treatment. Determine whether corrosion control treatment is being properly maintained. Schedule Types Initial Follow-Up Optimal True or False? Aerators should be removed from taps when collecting a WQP sample in the distribution system. Sample Collection & Analysis Certified Laboratory or by Person Acceptable to the State 8

9 Person Acceptable to the State When is Initial WQP Monitoring Required? Licensed Operator or someone trained by a Licensed Operator Use analytical methods in 40 CFR (k)(1) Conduct proper calibrations and maintain records of all QAQC tasks Submit results on the Excel Generic WQP Analysis Spreadsheet via to watersupply@dep.nj.gov Within 6 months of the beginning of the monitoring period in which the lead and/or copper action level was exceeded. January June July December June November Systems that have already started follow-up or optimized monitoring don t trigger back to initial monitoring even if exceed an action level. Initial Parameters & Frequency ph Alkalinity Calcium Conductivity Temperature *Orthophosphate *Silica 2 sets of samples at each Point of Entry and Distribution Tap. Each set must be collected on different days and should account for seasonal variability. Required # of distribution taps is based on population. 40 CFR (a)(2) Corrosion Control Treatment (CCT) Recommendation Submit recommendation within 6 months from end of monitoring period. June 30 th, December 31 st, or March 30 th Recommend 1 or more of the following: Alkalinity adjustment ph adjustment Calcium hardness adjustment Phosphate/silicate based corrosion inhibitor CCT Recommendation Approved Install approved CCT process within 24 months Required to obtain proper approvals/permits from administrative authority. Within 30 days of installation submit: Construction Completion Certification OR CCT Installation Certification Form CCT No longer approving just to maintain existing treatment. Can cease Pb/Cu monitoring while implementing CCT Steps. If CCT steps were stopped due to system returning to compliance (2 consecutive 6-months met AL) - must complete CCT steps from where previously left off if system exceeds the AL again. 9

10 When is Follow-Up WQP Monitoring Required? 2 consecutive 6-month monitoring periods immediately following installation of CCT Begins January 1 st or July 1 st, whichever is sooner. Lead and Copper tap monitoring also required during these 2 consecutive 6-month monitoring periods. Follow-Up Parameters & Frequency POINT OF ENTRY Biweekly ph Alkalinity Orthophosphate Silica Dosage rate of chemical DISTRIBUTION TAPS Required # of distribution taps is based on population. 40 CFR (a)(2) 2 sets of samples collected on different days (should account for seasonal variability). ph *Orthophosphate Alkalinity *Silica *Calcium Setting Optimal WQP Values Submit recommended optimal WQP values within 30 days of completing follow-up monitoring. Recommend for each WQP at each POE and distribution system. Division will only be setting minimums. When is Optimal WQP Monitoring Required? Each 6-month monitoring period after Division sets Optimal WQP Values. Beginning January 1 st or July 1 st, whichever is sooner. All systems, regardless of size, will be required to conduct this monitoring for all monitoring periods in which the system is in operation. Optimal Parameters & Frequency Systems Eligible for Reduced Optimal WQP Monitoring POINT OF ENTRY Biweekly ph Alkalinity Orthophosphate Silica Dosage Rate of Chemical DISTRIBUTION TAPS Required # of distribution taps is based on population. 40 CFR (a)(2) 2 sets of samples collected on different days (should account for seasonal variability). ph Silica Orthophosphate Alkalinity Calcium Maintain Optimal WQP Values for 2 consecutive 6-months. Reduce # of distribution taps [40 CFR (a)(2)]. Maintain Optimal WQP Values for 3 consecutive years (6 consecutive 6- months). Sample at reduced # of distribution taps annually. Maintain Optimal WQP Values for 3 consecutive annual monitoring periods. Sample at reduced # of distribution taps triennially. 10

11 Compliance Determinations State Designated Optimal WQP Values How Often is Level Compliance Determined? Each 6-month compliance period January June July December 3 Step Process Calculation of Daily Values Determine duration of excursion Determine if Treatment Technique Violation Step 1: Calculation of Daily Values *Days in which no samples were collected on, the daily value is the most recent result taken at that location, even if the result is from a previous monitoring period. Monitoring Frequency More than Daily Daily Biweekly Semi- Annually Annually/Trie nnially Daily Value Calculation Average all results measured for each parameter at each sampling location Result of each daily sample for each parameter at each sampling location Result of the biweekly sample for each parameter at each sampling location* Result of the semi-annual sample for each parameter at each sampling location* Result of the annual/triennial sample for each parameter at each sampling location* Step 2: Determine Duration of Excursion Consider unresolved excursions from a previous monitoring period 1. Count the 1 st day with a result below the minimum value set by the State 2. Stop counting days when a sample result from the same location and for the same parameter is equal to or greater than the minimum value set by the State 3. Repeat 1 and 2 above every time a result is below the minimum value set by the State during the 6-month period being evaluated Excursion Any daily value for a parameter that is below the minimum value set by the State. Step 3: Determine Treatment Technique Violation Cannot be outside the set Optimal WQP Values for more than a total of nine days at: A specific sampling point or combination of sampling points OR For a specific WQP or combination of WQPs Please note Water systems should make arrangements with the labs regarding notification to the system if the result is less than the minimum value so treatment adjustments can be done and repeat samples can be taken

12 Example 1: Point of Entry Sample Date ph Orthophosphate January January January February February March March April April May May June June Sample ph Date February May May Orthophospha te Point of Entry: 3 days out of compliance Example 1: Distribution Tap Sample Date ph February May Sample Date p H February February Orthophosph ate Orthophosph ate Distribution Tap: 2 days out of compliance Example 1: Point of Entry & Distribution Tap Excursions Date of Excursion Point of Entry Distribution Tap February 13 February 14 May 22 May 23 4 Excursions for this 6-month monitoring period Example 2: Multiple Distribution Taps A sample collected at one location cannot be used to demonstrate compliance at a different sampling site Sample Date Distribution Distribution Tap 2 Tap 1 February May May No sample collected May No sample collected Example 3: Unresolved Excursion Consider unresolved excursions from a previous monitoring period Sample Date Distribution Distribution Tap 2 Tap 1 February May May No sample collected May No sample collected July November Following a Treatment Technique Violation Report violation to NJ DEP within 48 hours Deliver public notice (Tier 2) Include discussion of violation in CCR Return to standard (every 6-months) WQP tap monitoring AND lead and copper tap monitoring 12

13 Which famous person died from lead poisoning? A. Einstein B. Cleopatra C. Caesar D. Beethoven E. Marc Antony Lead Public Education Required 60 days from the end of the monitoring period. BWSE must review and approve all PE materials. Remember additional outreach activities are required. Repeat written PE every 12 months as long as the system exceeds the lead AL. Press releases required twice every 12 months. Quarterly water bill statement. Schools and childcares must provide PE to all parents/legal guardians. Submit a PE Certification quarterly. 40 CFR There are 6 main elements to the public education a system must include: Informational Statement Health Effects of Lead Sources of Lead Steps to Reduce Exposure What Happened and What s Being Done More Information (more mandatory language) Water Bill Statement [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)]. Implement at least 3 of the following activities: Public service announcements Paid advertisements Public area informational displays s to customers Public meetings Household deliveries Targeted individual customer contact Direct material distribution to all multi-family homes and institutions Other methods approved by the state Lead Service Line Replacement Required if system incurs a lead ALE and has CCT or SWT. 7% annually. The first year of LSLR begins on the first day following the end of the monitoring period. NJDEP will be developing tracking for LSL replacement. All water systems should start working on their LSL inventory. Develop mechanisms to track LSL replacement. Document during water main breaks Notifications by homeowners Survey during lead and copper sampling 13

14 Long-term Revisions to LCR LCR Working Group National Drinking Water Advisory Council EPA will have to propose a rule. Will be open for public comment. Resources EPA s Lead and Copper Rule Monitoring and Reporting Guidance for Public Water Systems EPA s How to Determine Compliance with Optimal Water Quality Parameters as Revised by the Lead and Copper Rule Minor Revisions EPA February 29, 2016 Memo: NJDEP Lead in Drinking Water webpage: 79 Are you banging you head yet? Questions? Contact Information Lead Team watersupply@dep.nj.gov Kristin Hansen Kristin.Hansen@dep.nj.gov Pintrest.com 14