Lead and Copper In Drinking Water. Nikki Belian August 9, 2017

Transcription

1 Lead and Copper In Drinking Water Nikki Belian August 9, 2017

2 Lead and Copper Rule Title 40, Code of Federal Regulations (CFR) 141 Subpart I Purpose of the lead and copper tap sampling rule (LCR) is to protect public health by minimizing lead (Pb) and copper (Cu) levels in drinking water. Lead and copper primarily are introduced to drinking water through corrosivity of plumbing materials which contain lead and copper. 2

3 Health Effects of Lead Children are highly susceptible Impaired mental development IQ deficits Shorter attention span Lowered birth weight Altered heme synthesis (carries oxygen in our blood) and Vitamin D metabolism Adults Increased blood pressure EPA set MCLG at zero MCLG: Maximum contaminant level goal: the level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety. 3

4 Health Effects of Copper Stomach and intestinal distress Complications of Wilson s Disease Damages the liver and nervous system Confusion delirium Abnormal posture of arms and legs Chronic exposure can cause liver disease in genetically predisposed individuals EPA set MCLG at 1.3 mg/l 4

5 Who Has to Sample? All community and non-transient non-community water systems are subject to LCR monitoring requirements. Lead and copper samples are the only drinking water compliance monitoring samples that are taken from interior sample taps: All samples must be one liter in volume taken from interior taps of consumption. Tap must stand motionless for at least six hours. Collected from the cold water tap of the kitchen or bathroom sink. Cannot be taken from a hose bib or point of entry (POE). 5

6 Lead and Copper Plans Lead and copper tap sampling plan is required to be completed and approved by the Department 30 days prior to sampling. Plans should be reviewed before sampling and updated if changes are necessary. All sites sampled must be on the plan in order to accept the results. Recommended to have 1.5 times more sample sites than required in order to increase sampling flexibility. Templates can be found on DEP s website _12.pdf 6

7 Page 1 Name, PWS ID, PWS Type PWS Size Small = E, F, G Medium = C, D Large = A, B Population, population interval look at chart Owner and contact information Chart in middle tells you population interval, how many sites to sample on standard monitoring and how many WQP sites to sample. Records review must complete at least one required sources of review (left column). 7

8 Page 2 Page 2 Identification of lead service lines must complete at least one required sources of review. Materials survey - must break down amount single family residences, multi-family residences, and buildings by info on the left. D. Total No. of Service Connections to Available Sampling sites can be a ratio or just the total number of sampling sites on page 3 E. Total No. of Service Connections in Distribution system should match No. of service connections provided to DEP 8

9 Page 3 Must fill in: Tier* Type of structure Location** Contact info Lead service line Plumbing material Field verified Sample or optional status Training of sampler/homeowner status *Tier information and codes for this page are listed on page 6 of the plan. **Hose bibs and POEs cannot be used as tap sampling site. If less than five sites then go back a 2 nd day and collect the rest of the sites. 9

10 Page 4 Water quality parameters: Need to list all POEs on left side. Need to list distribution sampling sites on right side. Distribution sites must come from bacteriological sampling plan. The amount of sites depends on the population interval on page 1. The target dates are not necessary since they change or are not needed at the time of the plan. Total sites at the bottom. 10

11 Page 5 A. Site Selection Criteria Need to explain why there are not Tier 1 sites or why they changed from the last monitoring period. (Systems always need to sample as many Tier 1 sites as possible, if they run out of Tier 1 sites then Tier 2 sites can be selected and so on.) If there are no Tier 1 sites they may put no Tier 1 sites used all Tier 2 sites. B. Lead Service Lines if they have lead service lines explain if they do not use at least 50% of the sites. Most places have no LSLs so they put N/A. C. WQP Sampling Plan If they do not use bact sampling plan sites, then explain why not. Most sites do, so they put N/A. 11

12 Page 6 Instructional page for completion of plan. Explains tiers, codes 12

13 Tiering Classification Community Water System Tier 1 sampling sites are single family structures: with copper pipes with lead solder installed after 1982 or contain lead pipes; and/or that are served by a lead service line. Note: When multiple-family residences (MFRs) comprise at least 20% of the structures served by a water system, the system may count them as Tier 1 sites. Tier 2 sampling sites consist of buildings, including MFRs: with copper pipes with lead solder installed after 1982 or contain lead pipes; and/or that are served by a lead service line. Non-Transient Noncommunity Tier 1 sampling sites consist of buildings: with copper pipes with lead solder installed after 1982 (but before the effective date of your State s lead ban) or contain lead pipes; and/or that are served by a lead service line. Tier 2 sampling sites consist of buildings with copper pipes with lead solder installed before Tier 3 Not applicable. Tier 3 sampling sites are single family structures w/ copper pipes having lead solder installed before

14 Homeowner Education 14

15 Proper Sampling Procedure LCR defines a proper sample as a first draw sample 1 liter in volume Taken after water has been standing in plumbing for at least six hours From an interior tap typically used for consumption - cold water kitchen or bathroom sink tap in residences. [40 CFR (b)(2)] There is no outer limit on standing time To ensure sampling is conducted properly, the LCR requires that samples be collected by the system or by *residents if they have been properly instructed by the water system. *As added insurance that the system gives proper instructions, the rule does not allow water systems to challenge sample results based on alleged homeowner errors in sample collection. [40 CFR (b)(2)] 15

16 Additional Sampling Procedures Removal and cleaning of aerators EPA recommends that homeowners regularly remove and clean aerators as a general practice Water systems should not recommend removing and cleaning aerators prior to sampling Pre-Stagnation Flushing Flushing removes water that may have been in contact with the lead service line for extended periods, which is when lead typically leaches into the water EPA recommends that sampling instructions do not contain prestagnation flushing step Bottle Configuration EPA recommends wide-mouth bottles be used Allow for a higher flow rate which is representative of a the flow that a consumer may use to fill up a glass of water 16

17 Avoiding Sampling Collection Problems Utility may wish to do the sampling itself or review the sample collection information before sending it to the lab. If the utility chooses to use residents to perform the sampling, it should provide clear instructions and a thorough chain-of-custody form for residents to fill out when the sample is taken. This will allow the laboratory or utility to eliminate improperly collected samples prior to the actual analysis. For example, if a sample bottle is only half full, then it should not be analyzed by the laboratory. Likewise, if the documentation accompanying the sample indicates that it was taken from an outside tap, the sample should not be analyzed. Systems may need to make arrangements to collect replacement samples for samples that are not analyzed by the laboratory. 17

18 Invalidating Samples Regulations allow the state to invalidate a lead or copper tap sample only if it can document that at least one of the following conditions has occurred: Laboratory establishes that improper sample analysis caused erroneous results; State determines that the sample was taken from a site that *did not meet the site selection criteria; Sample container was damaged in transit; or There is substantial reason to believe that the sample was subject to tampering. [40 CFR (f)(1)] *A site that is not part of the compliance sampling pool or that has been altered in such a way that it no longer meets the criteria of a high-risk site (e.g., new plumbing or the addition of a water softener). 18

19 Population Intervals (Standard) Population Served Population Interval L & C Sites WQP Sites > 100,000 A ,001 to 100,000 B ,001 to 50,000 C ,301 to 10,000 D to 3,300 E to 500 F 10 1 Less than 101 G 5 1 Standard Monitoring is every 6 months = January June and July December 19

20 Standard Monitoring Standard Monitoring is Biannual January June and July December New systems begin monitoring on standard monitoring. Systems that add a new source (new well) or a new treatment will be placed on standard monitoring for two consecutive 6 month periods. Systems that exceed the 90 th percentile action level for lead or copper will be placed on standard monitoring. 20

21 Population Intervals (Reduced) Reduced Monitoring Annual = June September every year Triennial = June September on Standard Monitoring Framework (SMF) 21

22 Reduced Monitoring Annual If a system has two consecutive 6 months of results below the action level, they will be reduced to annual. Triennial If a system has three consecutive years of annual results below the action level, they will be reduced to triennial. If a system was on triennial and was placed on standard (biannual) monitoring after a new source or treatment, they will return to triennial after two consecutive 6 months of results below the action level. 22

23 Standard Monitoring Framework Type Population Sampling Date Community > 3, , 2014, 2017 Community <3, , 2015, 2018 NTNC Any 2013, 2016, 2019 SMF consists of a 9 year compliance cycle made up of 3 year compliance periods depending on the size and type of the system. Some systems are still off of their compliance cycle for lead and copper. We are working to adjust their schedules to get them on SMF. 23

24 What samples are used to calculate the 90 th percentile? Systems must develop a targeted sampling pool, focused on those sites with the greatest risk of lead leaching. All compliance samples used to determine the 90 th percentile must come from that sampling pool. All sample results from a system s sampling pool during the monitoring period must be included in the 90th percentile calculation, even if this includes more samples than the required minimum number needed for compliance. [40 CFR (e)] For example, if a system sends out sample kits to 150 households to ensure that it will have a sufficient number of samples to meet its required 100 samples for compliance, and the system receives sample results from 140 households, it would use the results of the 140 samples in calculating the 90th percentile. 24

25 Does LCR Allow Confirmation Samples? Utility may choose to take a confirmation sample to verify high or low concentration. Where confirmation samples are taken, the results of the original and confirmation sample must be used in calculating the 90th percentile. LCR does not allow substitution of results with confirmation samples, nor does it allow the averaging of initial and confirmation samples as a single sampling result. 25

26 Reporting Requirements 1. Lead and copper tap sample results: a) Due the 10 th of the month following the month of sampling or the 10 th of the month following the end of the monitoring period, whichever is sooner b) 2. Consumer notification: a) Participants must be notified of individual lead tap sample results within 30 days after the system learns of the results regardless if the result was above the AL. b) Include lead results for tap that was tested, explanation of health effects of lead, steps to reduce exposure to lead, contact info for utility. c) default.htm 3. Certification of notification: a) DEP Form (16), PWS Certification of Notification of Lead and Copper Tap Sample Results must be submitted to the Department no later than three months following the end of the monitoring period. 26

27 Determining Compliance Compliance is based on the 90 th percentile. Each result is assigned a number: Lowest concentration is number 1. Highest concentration is equal to the total number of samples taken. Total number of samples is multiplied by 0.9. Numbered sample yielded by the calculation is the 90 th percentile. 27

28 Example Asphalt Acres MHP collects 30 samples: 30 x 0.9 = th sample s result on the list is the 90 th percentile. If a system collects 5 samples: Average the 4 th and 5 th results to get 90 th percentile. 28

29 Individual Exceedance If one or more sites exceed the AL, but the 90 th percentile did not exceed, then they have an individual exceedance. Each site must be notified (Consumer Notification), but Public Education is not necessary. 29

30 Action Level Lead Action Level (AL) is exceeded if the 90 th percentile is greater than mg/l mg/l = parts per million (ppm) ppm = 15 parts per billion (ppb) 15 ppb = 15 ug/l (micrograms per liter) Watch the units on lead results. They are reported in ppm on the lab reports, but in ppb on CCRs. Copper Action Level is exceeded if the 90 th percentile is greater than 1.3 mg/l. 1.3 ppm (Copper isn t converted) 30

31 AL Exceedances - Copper Copper If the 90 th percentile is above 1.3 mg/l the system must do the following: Notify individuals at the sites that exceeded. Return to standard monitoring (biannual full amount of samples per plan). Collect water quality parameters during the same monitoring period they exceeded, but if that period has passed then during the next monitoring period. Desktop study (usually done by FRWA) Treatment Recommendation Letter 31

32 Action Level Exceedances - Lead Lead If the 90 th percentile is above mg/l the system must do the following: Public Education must be sent to ALL customers of the water system, not just the participants. Return to standard monitoring (biannual full amount of samples per plan). Must complete both sets before the 12 month anniversary of the set that exceeded. Collect Water Quality Parameters during the same monitoring period in which system exceeded, but if that period has passed then during the next monitoring period. (2 sets, 4 weeks apart) Desktop study (usually done by FRWA) Treatment Recommendation Letter 32

33 Public Education All consumers of the water system must be notified via Public Education if the system exceeded the Lead Action Level. Public education materials must be provided to customers within 60 days after the end of the monitoring period. (Templates) Public education must continue at least once every 12 months subsequent to exceeding the lead action level so long as the lead action level continues to be exceeded. All written public education materials must be submitted to the Department prior to delivery. Complete and submit DEP Form (17), Lead Public Education Program Report for PWSs within 70 days after the end of the monitoring period. Annual/Triennial samples would be due by December 9 th since monitoring period ends September 30 th. 33

34 Public Education Notice Requirements Must include the elements in printed materials in the same order and exactly as written in the rule, as outlined below: Opening statement Health effects language, sources of further information Sources of lead Steps to reduce lead exposure Any known reason for elevated lead levels and steps system is taking to reduce lead levels Contact information 34

35 Water Quality Parameters WQPs ph Temperature Conductivity Calcium Alkalinity Lead (inorganic) and copper (secondary) Silica and orthophosphate must also be tested, if used in daily treatment. 35

36 WQPs WQP monitoring is designed to Assist each system develop optimal corrosion control treatment. Help them determine whether treatment is properly operated and maintained. Per rule, initial WQP monitoring is required for all large systems (> 50,000) but only for small or medium systems if they exceed an AL. 36

37 When to Sample WQPs After an action level exceedance: At each point of entry (POE) and the number of distribution sites required on the Lead and Copper Tap Sampling Plan. Twice about four weeks apart during the monitoring period in which they exceeded (or as close to it as possible). 37

38 WQPs Update In July 2017 an was sent to all small and medium drinking water systems with corrosion control treatment within the Central District, stating that they will no longer be required to collect and submit point of entry WQPs. The rule does not require WQPs to be taken by small and medium drinking water systems. In accordance with 40 Code of Federal Regulations (CFR) Part , small/medium water systems are only required to collect WQPs if they exceed the lead or copper action level. 38

39 Desktop Study Action required after a system exceeds AL. FRWA inputs WQP results into a spreadsheet based tool known as the RTW Model for Corrosion Control and Process Chemistry. Precipitation Potential (key item to be in desired range): If low = corrosive (leaching lead and copper) If high = scale forming (building up calcium) In range = neutral 39

40 Treatment Recommendation Desktop used to make treatment recommendation. System submits letter recommending treatment/what type or no treatment. If no treatment need to explain why they believe AL exceeded and want to wait for results of both sets of six month monitoring. State can reply with agreement of treatment or no treatment. If no treatment recommended then must be below AL for 2 sets of six month sampling to reduce sampling. 40

41 AL Exceedances Once a system completes all steps required after an AL and both sets of results from the biannual monitoring are below the AL, the system may return to reduced monitoring (either annual or triennial - based on the results). If the system does not have results below the AL for two consecutive six month monitoring periods, or the system installs treatment, then they will remain on biannual sampling until two consecutive six month monitoring periods are below the AL. 41

42 Corrosion Control Study Within 12 months of AL exceedance, system must be deemed optimized or notified to conduct a corrosion control study as in 40 CFR (c). Deemed optimized for small/medium systems means two sets of six month monitoring below AL. 42

43 Good Practices Make sure your lead and copper plans are up to date, check them for accuracy well before the monitoring period to avoid problems during sampling. Collect number of samples in accordance with your plan, if you are on reduced, collected ½ the number of samples. Sample early in the monitoring period. If something happens (samples are damaged, lost, etc.) and more samples need to be collected, you can do so within the monitoring period. If you foresee a problem, call your DEP office to discuss options. If you have a 90 th percentile action level, contact your DEP office to notify them and get started on the follow up steps. 43

44 Missed Monitoring If Lead and Copper Tap Sampling monitoring is missed: The system will be placed on biannual monitoring and will be asked to collect the first set immediately The number of samples required will be the number of samples required on standard monitoring Population Served Population Interval L & C Sites > 100,000 A ,001 to 100,000 B 60 10,001 to 50,000 C 60 3,301 to 10,000 D to 3,300 E to 500 F 10 Less than 101 G 5 44

45 Missed Monitoring If Lead and Copper Tap Sampling monitoring is missed: A Public Notice (PN) must be issued by mail or other direct delivery to each customer receiving a bill and to other service connections to which water is delivered by the PWS; and by publication in a daily newspaper of general circulation. Posting is required until the system has the results of the make-up samples, but no less than 7 days. Within 10 days of issuing the PN, the system needs to send the Department a copy of the certification of delivery (COD) completed with the dates and methods the PN was issued. 45

46 Missed Monitoring examples The results of the Lead and Copper tap sampling will determine the frequency of the monitoring after a missed sampling event. For example: System A : Was sampling triennially, missed monitoring, and exceeded the Lead Action Level during at least one of the two consecutive 6-month sampling periods after the initial missed monitoring. System A would stay on biannual monitoring until two consecutive 6-month periods of results with the 90 th percentile below the action level. 46

47 Missed Monitoring examples The results of the Lead and Copper tap sampling will determine the frequency of the monitoring after a missed sampling event. For example: System B: Was sampling triennially, missed monitoring, and did not exceed the Lead Action Level for two consecutive 6-month sampling periods after the initial missed monitoring. System B would begin annual sampling during June - September the following year 47

48 Missed Monitoring examples The results of the Lead and Copper tap sampling will determine the frequency of the monitoring after a missed sampling event. For example: System C: Was sampling triennially, missed monitoring, and the 90 th percentile for two consecutive 6-month sampling periods was at or below.005 mg/l for lead and.65 mg/l for copper System C would begin triennial sampling during June - September on their Standard Monitoring Framework year 48

49 Questions? 49

50 Contact Department of Environmental Protection Central District Jill Farris, Environmental Consultant