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, 2011 Anchorage, Alaska Presented by

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 2

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

4

Overview of the LCR 40 CFR 141 EPA publishedLCR June 7, Revisions were made between Final short-term revision to LCR was public-noticed on Oct 10, EPA published LCR June 7, Revisions were made between Final short-term revision to LCR was public-noticed on Oct 10, Purpose: Protect public health by minimizing lead (Pb) and copper (Cu) levels in drinking water, primarily by reducing water corrosivity. Action Level: mg/L (Pb) and 1.3 mg/L (Cu) Applicability: CWS and NTNCWs 5

Overview of the LCR Public Water System (PWS)* 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 CFR *NOTE: These are public water systems that must comply with federal regulations. 6

Overview of the LCR Regulatory 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) L C R d o e s n o t a p p l y t o T N C W s

8 Overview of the LCR Public Water Systems in Alaska L C R? YES NO

Overview of the LCR 9

Overview of the LCR, cont’d 10

Overview of the LCR, cont’d 11

Overview of the LCR, cont’d 12

Overview of the LCR, cont’d Monitoring Provisions Monitoring Provisions First-draw samples at taps/distribution (homes/buildings) Number of Samples - Population-based (system size) Monitoring Frequency Initial/Standard: every 6 months Reduced: annually, every 3 years 13

Overview of the LCR, cont’d Action Levels and Consumer Notification Action Levels and Consumer Notification 14 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 )

Consumer Notification 40 CFR (d) 15 CWS + NTNCWS CWS

16

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? 17

Monitoring Summary as one of the Planning Tools 18 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

19 6. DEC contact information Monitoring Summary as one of the Planning Tools

20

21 Lead and Copper Sampling Plan Site 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

22 Lead and Copper Sampling Plan Site Selection, cont’d Community Water Systems (CWS) Tier 1 – considered high risk sites. Single Family Residences (SFRs) Contain copper pipes with lead solder installed Contain copper pipes with lead solder installed after 1982 (but before State’s lead ban) or; after 1982 (but before State’s lead ban) or; Contain lead pipes and/or; Contain lead pipes and/or; Are served by a lead service line 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 1982 or prior years. 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.

23 Lead and Copper Sampling Plan Site 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)

24 Lead and Copper Sampling Plan Site Selection, cont’d Special Cases Non-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.

25 Lead and Copper Sampling Plan Site 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 units ion exchangers reverse osmosis units adsorber 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 Emphasize flushing and use cold water tap Flushing procedures Flushing procedures Describe how 6-hour no-flow time will be met Describe how 6-hour no-flow time will be met Note if residents will collect samples Note if residents will collect samples 26

27

Pre-collection Preparations  Supplies Sample bottles Sample bottles Packing materials Packing materials Paper towels Paper towels Labels, Forms, and Pens Labels, Forms, and Pens Watch Watch Other items as needed 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 28

29 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 30

Lead and Copper First-Draw Sampling Words of Caution 31 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 NAME as 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 32

Partially Completed Forms 33 the lab

First-Draw Lead/Copper Sampling 34

LCR – Sample Invalidation 40 CFR (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 35

LCR – Sample Invalidation 40 CFR (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 36

Reporting  Ensure that time and money are not wasted: Recheck forms & labels for accuracy & completeness Recheck forms & labels for accuracy & completeness Label on bottle Label on bottle  Labs are required to report results directly to DEC  PWSs are responsible to ensure that DEC receives results 37

38 Example of DEC Lead & Copper Monitoring Summary Report

Sampling: Key Points 1. Develop Sampling Plan 2. Plan, coordinate, and sample early 3. Use reminder & scheduling tools 4. Keep water motionless 6-8 hrs prior to sampling (no toilet flushing) 5. Complete forms accurately 6. Know that your job is important! 7. Drinking Water is important! 39

Lead and Copper Rule 90 th 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 = 18 th sample.* Step 4: Compare 90 th percentile level to AL (in above example, 18 th sample). to AL (in above example, 18 th sample). Review of 90 th Percentile Calculations More than 5 Samples * When more than minimum number of samples are collected, may need rounding or interpolation to determine 90 th percentile sample

Review of 90 th Percentile Calculations More than 5 Samples: Example Question Assume 10 samples are collected with lead 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

Review of 90 th Percentile Calculations More than 5 Samples: Example Answer Step 1: Order results from lowest to highest: 1. Site A: Site E: Site C: Site H: Site F: Site I: Site J: Site B: Site D: 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 mg/L) Step 3: Compare to lead action level  No Exceedance

Review of 90 th Percentile Calculations 5 Samples Step 1: Place results in ascending order. Step 2: Average 4 th and 5 th highest sample results. Step 3: Compare 90 th percentile level to action level.

Review of 90 th Percentile Calculations 5 Samples: Example Question Site A: mg/L Site B: mg/L Site C: mg/L What is the 90th Percentile Value? Site D: mg/L Site E: mg/L Assume 5 samples are collected with lead results as follows:

Review of 90 th Percentile Calculations 5 Samples: Example Answer Step 1:Order results from lowest to highest: 1. Site A: mg/L 2. Site D: mg/L 3. Site E: mg/L 4. Site B: mg/L 5. Site C: mg/L Step 2: Average 4th & 5th samples highest samples to get 90th percentile value = mg/L mg/L mg/L = mg/L 2 Step 3: Compare average to lead action level  Step 3: Compare average to lead action level  Exceedance

Review of 90 th 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 90 th percentile level. Assume 3 lead samples: mg/L, mg/L, and mg/L. 90 th percentile = mg/L

48

49 What happens when the action level is exceeded?

50 What happens when the action level is exceeded?

51 What happens when the action level is exceeded?

52

53

 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: My contact information: Leah A. Guzman Phone: Phone 54 Additional Information

REFERENCES Lead and Copper Rule : US EPA (May 10, 2011) - Current Regulation (40 CFR ) & Quick Reference Guides Lead and Copper Rule in Alaska Drinking Water Regulations, Adopted by Reference – Alaska Administrative Code, Article 1 (18 AAC (a)(12) and Article 5 (18 AAC – 18 AAC ) EPA Aerator Memorandum: aerators_ pdf aerators_ pdf aerators_ pdf Lead and Copper Rule: Public Education & Consumer Notification (NTNC) Public-Education-Consumer-Notification-Requirements-for-Non-Transient-Non- Community-Water-Systems.pdf Public-Education-Consumer-Notification-Requirements-for-Non-Transient-Non- Community-Water-Systems.pdf Lead and Copper Sampling Procedures (DEC Website) 55

In Summary… 56 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

“An ounce of prevention is worth a pound of cure.” - Benjamin Franklin 57

Photo courtesy of water source Alaska image 58