Leah A. Guzman Environmental Program Specialist

Drinking Water Program Alaska Department of Environmental Conservation

Sustained Compliance for Public Water Systems,Chapter 2

Lead and Copper Issues – An Overview

September 29, 2011Anchorage, Alaska

Presented by

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PRESENTATION OUTLINE

Public Health Risks

Overview of the Lead and Copper Rule (LCR)

Sampling Protocols

Corrosion Control Treatment (CCT) Process

Getting Back To Compliance

Guidance and References

Summary

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Health Risks of Lead and Copper

Corrosion is the degradation of metal.

Lead – May cause delays in physical or mental development in infants and children; kidney problems and high blood pressure among adults.

Copper – May cause gastrointestinal (GI) distress from short-term exposure; kidney or liver damage from long-term exposure.

Lead and Copper come from corrosion of household plumbing system or erosion of natural deposits.

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Overview of the LCR40 CFR 141

EPA published LCR June 7, 1991. Revisions were made between 2000-2006. Final short-term revision to LCR was public-noticed on Oct 10, 2007.

Purpose: Protect public health by minimizing lead (Pb)

and copper (Cu) levels in drinking water, primarily by reducing water corrosivity.

Action Level: 0.015 mg/L (Pb) and 1.3 mg/L (Cu)

Applicability: CWS and NTNCWs

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Overview of the LCR

Public Water System (PWS)* is a water system that serves regularly at least 25 persons daily, at least 60 days of

the year, or has at least 15 service connections.

PWS is either Community (CWS) or Non-Community (NCWS) water system.

CFR 141.2*NOTE: These are public water systems that must comply with federal

regulations.

Overview of the LCRRegulatory Distinctions Among Water Systems

Public Water System

Non-Community Water System

(NCWS)

Non-Transient Non-Community Water

System

Transient Non-Community Water

System

Community Water System (CWS)

LCR does

not apply

to TNCWs

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Overview of the LCRPublic Water Systems in Alaska

LC

R?

YES NO

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Overview of the LCR

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Overview of the LCR, cont’d

Overview of the LCR, cont’d

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Overview of the LCR, cont’d

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Overview of the LCR, cont’d

Monitoring Provisions

First-draw samples at taps/distribution (homes/buildings)

Number of Samples - Population-based (system size)

Monitoring FrequencyInitial/Standard: every 6 monthsReduced: annually, every 3 years

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Overview of the LCR, cont’d

Action Levels and Consumer Notification

• EFFECTIVE IN 2008• Public water system owners or operators

should notify consumers from sites sampled of individual Lead tap results

• CWS consumers need to be educated about lead in their drinking water through annual CCRs

(CWS + NTNCWS)

(CWS )

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Consumer Notification40 CFR 141.85(d)

CWS + NTNCWS

CWS

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Lead and Copper Sampling Protocols

Planning is important!

What needs to be done (Sampling Plan)?When and where to sample?What forms to fill out?Who should we send the sample to?

Monitoring Summary as one of the Planning Tools

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1.What to sample for & where to sample

2. Sample Frequency

3. Date of last sample

4. Date next sample is due

5. Definitions and explanations

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6. DEC contact information

Monitoring Summary as one of the Planning Tools

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Lead and Copper Sampling PlanSite Selection

• Distribution materials evaluation (pipes & fixtures; residential or commercial)

• Accessibility

• Activity / Inactivity

• First-draw samples – water remains motionless for 6 to 8 hours

• Do not include sites with Point-of-use (POU) or Point-of-Entry (POE) treatment devices

• Consistent locations provide results that can be compared over time

• Newly replaced pipes or fixtures may influence analytical results

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Lead and Copper Sampling PlanSite Selection, cont’d

Community Water Systems (CWS)

Tier 1 – considered high risk sites. Single Family Residences (SFRs)

Contain copper pipes with lead solder installed after 1982 (but before State’s lead ban) or;

Contain lead pipes and/or; Are served by a lead service line

Tier 2 – Buildings (BLDGs) including MFRs that contain copper pipes w/ lead solder (installed after 1982) or contain lead pipes or lead service lines.

Tier 3 – SFRs that contain copper pipes w/ lead solder installed in 1982 or prior years.

Tier 1 - May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served.

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Lead and Copper Sampling PlanSite Selection, cont’d

Tier 1 – Buildings (BLDGs) that contain copper pipes with lead solders installed after 1982 (1983 & beyond but before the year the state bans the use of lead solders) or contain lead pipes; also buildings with lead service lines.

Tier 2 – Buildings (BLDGs) that contain copper pipes with lead solder installed before1983 (1982 and earlier years).

In 1986, the Congress banned the use of lead solders with > 0.2% lead

Non-Transient, Non-Community Water Systems (NTNCWS)

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Lead and Copper Sampling PlanSite Selection, cont’d

Special CasesNon-Tier residences or buildings – No lead or soldered copper pipes to meet tier sampling site requirements. Special-case residences and buildings still need to monitor for lead and copper.

Non-tier CWS or NTNCW should collect sampling pool from representative sites – plumbing used is common to other sites in the

distribution system served by the PWS.

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Lead and Copper Sampling PlanSite Selection, cont’d

Do not include sites with point-of-use (POU) or point-of-entry (POE) treatment devices for inorganic chemicals.

POU treatment control is the use of devices attached to water taps or in lines near water outlets such as:

filter unitsion exchangersreverse osmosis unitsadsorber cartridges

Developing A Lead and Copper Sampling Plan

Explain selection of sites Provide clear descriptions and names for

each site, and include alternative sites Sample procedures

Emphasize flushing and use cold water tap Flushing procedures Describe how 6-hour no-flow time will be met Note if residents will collect samples

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Pre-collection Preparations Supplies

Sample bottles Packing materials Paper towels Labels, Forms, and

Pens Watch Other items as

needed

Arrangements Lab hours Flights Coordinate with any

relevant contractors Courtesy reminders to

home or business owners – ensure access

Payments Other items as

situation warrants

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Sampling Protocols:Aerators/faucet screens

Lead and Copper First-Draw Sampling Reminders

Do NOT remove the aerator Flush cold water tap 6 hours of NO water activity

(6-8 hrs is optimal) Use 1-Liter bottle (1,000 ml) Fill bottle to neck with first

water from cold tap Do NOT overflow Label accurately

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Lead and Copper First-Draw Sampling Words of Caution

DO NOT OVERFLOW OR RINSE while filling up the bottle; you need to keep the liquid preservative in the bottle.

DO NOT USE THE PRESERVATIVE NAMEas the sample or analysis type. Indicate “lead and copper” for analysis or sample type on bottle labels and lab forms.

Keep Data Consistency

Lab Forms

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Partially Completed Forms

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the lab

the lab

First-Draw Lead/Copper Sampling

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LCR – Sample Invalidation40 CFR 141.86 (f)

(1) The State may invalidate a lead or copper tap water sample if at least one of the following conditions is met.

(i) Laboratory analysis error

(ii) The State determines sample was taken from an inappropriate site

(iii) The sample container was damaged in transit

(iv) There is substantial reason to believe that the sample was subject to tampering

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LCR – Sample Invalidation40 CFR 141.86 (f), cont’d

(2) The system must report the results of all samples to the State and all supporting documentation for samples the system believes should be invalidated

(3) To invalidate a sample under paragraph (f)(1) of this section, the decision and the rationale for the decision must be documented in writing

States may not invalidate a sample solely on the grounds that a follow-up sample result is higher or lower than that of the original sample

Reporting

Ensure that time and money are not wasted:

Recheck forms & labels for accuracy & completeness

Label on bottle

Labs are required to report results directly to DEC

PWSs are responsible to ensure that DEC receives results

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Example of DEC Lead & Copper Monitoring Summary Report

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Sampling: Key Points

1. Develop Sampling Plan2. Plan, coordinate, and sample early3. Use reminder & scheduling tools4. Keep water motionless 6-8 hrs prior to

sampling (no toilet flushing)5. Complete forms accurately6. Know that your job is important!7. Drinking Water is important!

Lead and Copper Rule

90th Percentile Calculations

Courtesy of EPA presentation on Short-term Revisions to LCR

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).

Review of 90th Percentile Calculations More than 5 Samples

* When more than minimum number of samples are collected, may need rounding or interpolation to determine 90th percentile sample

Review of 90th Percentile Calculations More than 5 Samples: Example Question

Assume 10 samples are collected with lead results as follows:

Site A: 0.005 mg/LSite B: 0.015 mg/LSite C: 0.005 mg/L Site D: 0.014 mg/LSite E: 0.014 mg/L What is the 90th Percentile Value?Site F: 0.005 mg/L Site G: 0.040 mg/LSite H: 0.014 mg/LSite I: 0.014 mg/LSite J: 0.005 mg/L

Review of 90th Percentile Calculations More than 5 Samples: Example Answer

Step 1: Order results from lowest to highest:1. Site A: 0.005 6. Site E: 0.0142. Site C: 0.005 7. Site H: 0.0143. Site F: 0.005 8. Site I: 0.0144. 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

Review of 90th Percentile Calculations 5 Samples

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.

Review of 90th Percentile Calculations 5 Samples: Example Question

Site A: 0.009 mg/LSite B: 0.011 mg/LSite C: 0.020 mg/L What is the 90th Percentile Value?Site D: 0.009 mg/LSite E: 0.010 mg/L

Assume 5 samples are collected with lead results as follows:

Review of 90th Percentile Calculations 5 Samples: Example Answer

Step 1: Order results from lowest to highest: 1. Site A: 0.009 mg/L2. Site D: 0.009 mg/L3. Site E: 0.010 mg/L4. Site B: 0.011 mg/L5. 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

Review of 90th Percentile Calculations Fewer than 5 Samples

Procedure has changed under LCR Short-Term Revision (LCRSTR). Some systems may collect < five samples.Sample with highest result is 90th percentile level.

Assume 3 lead samples: 0.020 mg/L, 0.008 mg/L, and 0.005 mg/L. 90th percentile = 0.020 mg/L

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What happens when the action level is exceeded?

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What happens when the action level is exceeded?

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What happens when the action level is exceeded?

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For local help, please contact your friendly DEC Environmental Program Specialists assigned in your area.

Additional help may also be available from your local Environmental Health Offices.

My contact information:Leah A. Guzman

Phone: 907-269-7518 PhoneLeah.Guzman@alaska.gov

Additional Information

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REFERENCESLead and Copper Rule : US EPA (May 10, 2011) - Current Regulation (40 CFR 141.80-91) & Quick Reference Guides

http://water.epa.gov/lawsregs/rulesregs/sdwa/lcr/index.cfmLead and Copper Rule in Alaska Drinking Water Regulations, Adopted by

Reference – Alaska Administrative Code, Article 1 (18 AAC 80.010(a)(12) and Article 5 (18 AAC 80.500 – 18 AAC 80.565) http://dec.alaska.gov/regulations/pdfs/18%20AAC%2080.pdf

EPA Aerator Memorandum: http://www.epa.gov/ogwdw/lcrmr/pdfs/memo_tapsamples-aerators_10202006.pdf

Lead and Copper Rule: Public Education & Consumer Notification (NTNC)http://water.epa.gov/lawsregs/rulesregs/sdwa/lcr/upload/Lead-and-Copper-Rule-Public-Education-Consumer-Notification-Requirements-for-Non-Transient-Non-Community-Water-Systems.pdfLead and Copper Sampling Procedures (DEC Website)http://dec.alaska.gov/eh/dw/publications/sample.html

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In Summary…Public Health Risks Associated with Lead and Copper

Lead and Copper Rule (LCR) Monitoring Provisions Action Levels Public Education and Consumer Notification

Sampling Protocols

Corrosion Control Treatment (CCT) Process

Getting Back To Compliance

Guidance and References

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“An ounce of prevention is worth a pound of cure.”

- Benjamin Franklin

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THANK YOU FOR YOUR ATTENTION

Photo courtesy of water source Alaska image