Midwest RCAP Midwest Assistance Program (952) Southern RCAP Community Resource Group (479)

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1 Controlling Lead and Copper in Drinking Water Chad Ham, Fayetteville Public Works Commission Your name and contact info Developed by RCAP/AWWA and funded by the USEPA Acknowledgement: EPA National Priority Area 1: Training and Technical Assistance for Small Public Water Systems to Achieve and Maintain Compliance with the SDWA, EPA Grant X Rural Community Assistance Partnership Practical solutions for improving rural communities Western RCAP Rural Community Assistance Corporation (916) Midwest RCAP Midwest Assistance Program (952) Southern RCAP Community Resource Group (479) Northeast RCAP RCAP Solutions (800) Great Lakes RCAP WSOS Community Action Commission (800) RCAP National Office 1701 K St. NW, Suite 700 Washington, DC (800) info@rcap.org Southeast RCAP Southeast Rural Community Assistance Project (866)

2 Purpose/Rationale This material will: Advise you of the requirements for addressing lead and copper in drinking water (specifically at small water systems) Inform you of potential future standards recommended by the National Drinking Water Advisory Council (NDWAC) regarding lead and copper in drinking water Explain how to be more effective in your efforts to protect public health 4 Learning Objectives At the end of this course you should be able to: Apply the regulatory requirements of the Lead and Copper Rule to your system Calculate the 90 th percentile concentration Summarize factors that will impact the release of lead and copper Take action to protect consumers from lead and copper 5 Agenda Introduction Regulations Lead and copper basics Conducting an inventory Monitoring requirements Treatment requirements Public notification requirements Lead service line replacement

3 Module One: Regulations Why address lead? Young children and infants tend to absorb more lead than the average adult. Impaired mental development IQ deficits Shorter attention spans Low birth weight Harmful to developing fetuses Adults Also harmful to adults Copper Long term chronic health risks Liver & Kidney damage Stomach and intestinal distress Complications of Wilson s disease

4 Rules that impact lead Reduction of lead in materials The Lead Ban (1986) The Reduction of Lead in Drinking Water Act (2011) Standards and Monitoring Requirements The Safe Drinking Water Act (1974) The Lead Contamination Control Act (LCCA) (1988) The Lead and Copper Rule (1991, revised 2000, 2007) Lead Regulations In materials 1986 Required use of lead free pipe, solder, and flux (December 1985 in NC) 0.2% lead in flux/solder lead free 50% prior to 1986 <8% lead for pipes and pipe fixtures 1998 Banned fixtures that were not lead free 2011 Redefined lead free as 0.25%, established method for calculation of lead content Lead Regulations Standards and monitoring requirements 1974 MCL mg/l SDWA 1988 Lead Contamination Control Act Lead monitoring and reporting requirements for all schools (not enforceable) 1991 Lead and Copper Rule (LCR) Action levels Community Water Systems Non Transient Non Community Water Systems Minor revisions 2000, ? Long term revisions to the LCR

5 LCR (1991) Maximum Contaminant Level Goals (MCLG) Lead 0 mg/l Copper 1.3 mg/l Action level based on the 90th percentile Lead mg/l Copper 1.3 mg/l Requires optimized corrosion control rather than a Maximum Contaminant Level (MCL) Lead and Copper Rule Overview CWS or NTNCWS Collects Lead and Copper Tap Samples 90th Percentile Is at or Below Both Action Levels* 90th Percentile Exceeds the Lead Action Level (15 μg/l) 90th Percentile Exceeds the Copper Action Level (1.3 mg/l) Conduct periodic lead and copper tap monitoring Begin LSLR replace 7% of LSLs per year Conduct public education due within 60 days Begin CCT steps includes WQP monitoring ** Conduct source water monitoring (Install SOWT, if needed) Conduct periodic lead and copper tap monitoring * Includes systems serving 50,000 people and (b)(3) systems ** Includes non (b)(3) systems serving > 50,000 people, irrespective of their 90 th percentile levels; (b)(2) systems must collect WQPs. Activity EPA Quick Reference Guide Monitoring Provisions Consumer Notification Public Education Source Water Monitoring Corrosion Control Treatment Lead Service Line Replacement

6 Potential future standards NDWAC recommendation Development of a household action level Potentially lowering of the action level Requiring lead service line replacement Module Two: Lead and Copper Basics Rarely from source water or distribution mains Service lines Lead service lines, on either side of the meter Goosenecks or pigtails Customer plumbing Solder Plumbing fixtures Sources of Lead

7 Ownership of System Components Forms of lead There are two forms of lead: Dissolved lead Particulate lead Factors that impact dissolved lead concentrations Water quality parameters ph, alkalinity, dissolved inorganic carbon, hardness Chlorine residual levels, Presence of corrosion inhibitors Materials Other conditions Temperature, Electrical current

8 Factors that impact particulate lead concentrations Operations practices that can impact lead levels Physical disturbances Repairing a main break Meter repair Hydraulic changes Flushing Valve/hydrant testing Factors that can impact both dissolved and particulate concentrations Change in source water Changes in water chemistry Change in ph Change in chlorine residual levels What would happen to lead levels if: 1. Seasonally switch between a surface water source and a ground water 2. Bring a new well into service 3. Repair a water main Discussion 4. Replace the service line between the main and meter

9 Module Three: Conducting an Inventory Conducting an inventory Installation records Codes, regulations Main renewal records Observations during construction Observation during meter replacement Customer reporting

10 Ways to tell if pipe is lead Scratch test Grey? Easy to scratch? Lead swabs Shape Magnet (will stick to steel, not lead) Review NC s Materials Inventory Form NC Forms located at Module Four: Monitoring Requirements

11 Monitoring Requirements Sampling sites with highest potential levels Frequency Set by regulation Reduced monitoring possible Procedures First draw, try to observe the highest concentrations Site Selection CWS Three tier criteria to identify highest risk Tier 1 Single family built between 1/83 and 12/85 Lead service lines or copper pipe and lead solder Tier 2 Building/multi family built between 1/83 and 12/85 Lead service lines or copper pipe and lead solder Tier 3 Single family with copper pipe and lead solder built before 1983 Site Selection NTNCWS 2 tier criteria Tier 1 Structures with lead service lines or Copper pipe and lead solder built between January 1983 and December 1985 Tier 2 Lead solder before

12 Site Selection Summary Must identify sites in your monitoring plan Use Tier 1 if available Best to have more sites than the minimum required Systems without enough tiered sites must use representative sites Review NC Sample Poole Spreadsheet NC now requires this information to be entered into their online database Contact your region or the Lead & Copper Rule Manager for info Minimum Number of Tap Samples System Population Number of Sampling Sites (on Routine Monitoring) Number of Sampling Sites (on Reduced Monitoring) >100, ,001 to 100, ,301 to 10, to 3, to

13 Monitoring schedules Standard monitoring: Conducted at 6 month intervals from January June and July December Reduced monitoring Can be annual or triennial monitoring schedules. Must sample in 4 consecutive month period with highest likely lead levels (June September) Procedures for sampling First draw 6 hour standing time One liter volume System or residents can collect Samples are taken from cold water at kitchen/bathroom taps 38 Issues and recent recommendations No water softeners or POU/POE Aerators Leave on Use wide mouth sample bottles (encourages higher flow rates) No pre stagnant flushing

14 States may invalidate a sample if Improper sample analysis Site selection criteria not met Sample container damaged Sample subjected to tampering It s difficult to invalidate a sample Other samples Customer requested samples should be included in the 90 th percentile calculation if its collected during the specified monitoring period and it s a Tier 1 site. All samples must be reported to the state Sampling not required at schools or public buildings (but recommended) Determining the 90 th Percentile 1. Arrange results in order from lowest to highest. 2. Rank each result: 1 = lowest result through highest result (i.e. 54) 3. Multiply the number of total results by 0.9 = 90th percentile rank th percentile = the sample result corresponding to the result. 5. Interpolate if 90 th percentile is a decimal

15 Reporting Requirements All lead results must be reported to state through online system (LDS) Submit Lead and Copper Report no later than 10 days following the end of the monitoring period Module Five: Treatment Requirements - Optimal Corrosion Control Treatment (OCCT) Optimal Corrosion Control Treatment (OCCT) Chemical treatment designed to reduce the corrosivity of water Raising ph to make water less acidic Adding buffering to make water more stable Adding corrosion inhibitors to create a barrier to inhibit metals release OCCT & Study required for all large systems Small/medium systems No OCCT, only have to get below the Action Levels. No study, complete NC Form 141c

16 Water Quality Parameter Monitoring Required when < 50,000 that exceed AL > 50,000 regardless of 90th percentile Purpose of WQP monitoring To assist in determining water corrosivity To identify appropriate corrosion control treatment To determine whether corrosion control treatment is being properly maintained WQP Monitoring Parameters Typical Water Quality Parameters ph 1 Orthophosphate 2 Alkalinity Silica 3 Calcium Temperature 1 Conductivity 1 Measured on site. 2 Applies when a phosphate containing inhibitor is used. 3 Applies when a silicate containing inhibitor is used

17 Corrosion Control Treatment Steps Study/treatment recommendation by system State treatment determination Treatment installation Follow up Pb/Cu tap & WQP monitoring State specified operating parameters Determining The Best Corrosion Control Treatment Consult with your primacy agency Obtain recommendations of chemical suppliers Check with other water systems Don t experiment on the whole system Consider advantages and disadvantages of storing, handling and feeding various chemicals Module Six: Public Notification Requirements

18 Without an action level exceedance Notify consumers of lead tap results Consumer Confidence Reports Lead Consumer Notice Impacts all CWSs and NTNCWSs Requirements (varies by state) Provide notice of lead tap water monitoring results Regardless of whether sample exceeds lead AL To all served by sampling site not just the person who pays the bills (i.e. renters) As soon as practical but within 30 days after receiving results By mail or other State approved methods Consumers tips for reducing lead exposure Flushing Stagnant water Clean aerators Get your water tested Filters

19 Module Seven: Lead Service Line Replacement Lead service lines do they need to be replaced Only required if AL is exceeded Full replacement main to inside the home Partial replacement the main to the meter Disturbance on the main or service line can cause increased lead levels Summary The primary source of lead are service lines, solder, and plumbing fixtures. Some of which are not under direct control of the utility. The utilities responsibilities are: Monitoring Controlling the corrosivity of the water Public education and outreach Operation practices to minimize lead Programs to get the lead out

20 You are not required, but recommended to: Have a program to replace lead service lines Have a program to help customers monitor their tap water Sample schools and other public buildings AWWA EPA Lead and Copper Rule Quick Reference Guide: Rural Community Assistance Partnership (RCAP): NC Public Water Supply Section Resources THANKS FOR ATTENDING! CHAD HAM CHAD.HAM@FAYPWC.COM