Lead and Copper Rule: ShortTerm Revisions and Clarifications - PowerPoint PPT Presentation

1 / 91
About This Presentation
Title:

Lead and Copper Rule: ShortTerm Revisions and Clarifications

Description:

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 ... – PowerPoint PPT presentation

Number of Views:255
Avg rating:3.0/5.0
Slides: 92
Provided by: jimm210
Category:

less

Transcript and Presenter's Notes

Title: Lead and Copper Rule: ShortTerm Revisions and Clarifications


1
Lead and Copper RuleShort-Term
Revisions and Clarifications
  • Jim Moore
  • VDH Office of Drinking Water

2
Training Objectives
  • 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

3
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

4
LCR Short-Term Revisions Rule Making History
  • All of these Lead
  • and Copper Rules
  • apply to
  • Community
  • and,
  • Non transient non community waterworks

5
Original LCR Overview
  • First published on June 7, 1991
  • Established MCLGs for lead and copper
  • Established Action Levels in lieu of MCLs
  • 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

6
Lead and Copper RuleOverview
CWS or NTNCWS Collects Lead and Copper Tap
Samples
90th Percentile Exceeds the Lead Action Level
(15 µg/L)
90th Percentile Exceeds the Copper Action Level
(1.3 mg/L)
90th Percentile Is at or Below Both Action
Levels
7
Lead and Copper Rule
  • Review of Lead and Copper Tap Monitoring
    Requirements

8
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 Virginias 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

9
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 Virginias 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

10
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 (Virginias 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

11
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


12
Review of Monitoring Requirements Sample
Collection Method
  • First-draw samples
  • Minimum 6-hour standing time
  • One-liter volume
  • System or residents can collect

13
Review of Monitoring Requirements Minimum Number
of Tap Samples
14
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 ALs, monitoring can be
    reduced to once per year at the reduced number of
    sites
  • After three years of monitoring w/ results below
    both ALs, monitoring can be reduced to once per
    three calendar years
  • Waterworks in reduced monitoring must collect all
    samples during the months of June - September

15
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

16
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

17
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

18
Lead and Copper Rule
  • Review of 90th
  • Percentile Calculations

19
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)

20
Review of 90th Percentile Calculations More
than 5 Samples Example
Assume 10 samples are collected with lead and
copper results as follows
Site A 0.005 mg/L Site B 0.015 mg/L Site
C 0.005 mg/L Site D 0.014 mg/L Site E 0.014
mg/L What is the 90th Percentile Value? Site
F 0.005 mg/L Site G 0.040 mg/L Site
H 0.014 mg/L Site I 0.014 mg/L Site J 0.005
mg/L
21
Review of 90th Percentile Calculations More
than 5 Samples Example
Step 1 Order results from lowest to highest 1.
Site A 0.005 6. Site E 0.014 2. Site
C 0.005 7. Site H 0.014 3. Site
F 0.005 8. Site I 0.014 4. Site
J 0.005 9. Site B 0.015 5. Site
D 0.014 10. Site G 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
22
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

23
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.

24
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
25
Review of 90th Percentile Calculations 5
Samples Example
Step 1 Order results from lowest to highest
1. Site A 0.009 mg/L 2. Site D 0.009
mg/L 3. Site E 0.010 mg/L 4. Site B
0.011 mg/L 5. Site C 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
26
Review of 90th Percentile Calculations Fewer
than 5 Samples
  • Procedure has changed under LCR STR.
  • Some systems may collect lt five samples.
  • Sample with highest result is 90th percentile
    level.
  • No M/R violation.

Assume 3 lead samples 0.020 mg/L, 0.008 mg/L,
and 0.005 mg/L 90th percentile 0.020 mg/L
27
Lead and Copper Rule Short-Term Revisions and
Clarifications
28
LCR Short Term Revisions Major Changes
  • Monitoring Revisions
  • 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

29
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 States 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

30
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

31
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

32
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 lt 5 sample provision for
    very small waterworks

33
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

34
Definitions of Compliance andMonitoring 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

35
Definitions of Compliance andMonitoring 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)

36
Definitions of Compliance andMonitoring 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

37
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

38
Three Year Compliance Cycle forSystems 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

39
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)

40
STR Monitoring RevisionsCompliance 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

41
Criteria forReduced 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 WQPs) will need to go back on
    standard 6-month tap monitoring schedule
  • Limits reduced monitoring to those systems
  • meeting optimal water quality parameters and
  • the lead Action Level

42
Reduced Monitoring Example
  • WQPs 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 WQPs during all 6 month
    compliance periods
  • Monitoring results indicate a 90th percentile
    lead concentration of 18 ppb which exceeds the 15
    ppb Action Level

43
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)

44
Lets Take a Break !!
45
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

46
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

47
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
  • ??

48
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
  • ??

49
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

50
Consumer ConfidenceReport (CCR) Revisions
  • Systems Affected
  • All systems even if results are not detected
    for lead and copper
  • Rule Revision
  • All CCRs 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
    CCRs beginning with the 2008 CCRs (to be
    delivered by June 2009)

51
Consumer ConfidenceReport (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/sa
fewater/lead.
52
Notification Approval forLong-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

53
Notification Approval forLong-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

54
Notification Approval forLong-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

55
Notification Approval forLong-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
  • ODWs 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

56
Notification Approval forLong-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

57
Notification Approval forAddition 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

58
Notification Approval forAddition 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

59
Public Education Revisions
60
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

61
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 systems specific situation
  • What happened and what is being done
  • Sources of additional information this
    mandatory language and can not be altered

62
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

63
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

64
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

65
Public Education RevisionsDelivery
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-gynec
    ologists, and midwives

66
Public Education RevisionsDelivery
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 gt 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

67
Public Education RevisionsDelivery
Requirements Additional Activities
  • Implement additional Public Education activities
    from the following list
  • Waterworks serving gt 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

68
Public Education RevisionsDelivery
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
  • Waterworks serving gt 100,000 must post material
    on web site

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.
69
Public Education RevisionsDelivery
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

70
Public Education RevisionsDelivery
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

71
Public Education RevisionsRepeat 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

72
Public Education RevisionsRepeat 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

73
Public EducationDelivery 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

74
Re-evaluation of Tested-outLead 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
  • LSLs 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

75
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

76
Lead Service Line Replacement
  • To date no waterworks in Virginia have been
    required to implement the LSL Replacement
    treatment technique

77
Lead and Copper Tap SampleMonitoring Example
78
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

79
Monitoring Example Minimum Number of Tap Samples
80
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

81
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

82
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

83
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

84
Monitoring Example cont.
  • Anytown 90th Percentile Calculation

85
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

86
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

87
Monitoring Example 2 cont.
  • Lets 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

88
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)

89
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

90
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

91
Questions and Discussion
Write a Comment
User Comments (0)
About PowerShow.com