Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

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

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

Original LCR Overview MCLG Action Level First published on June 7, 1991 Established MCLGs for lead and copper Established Action Levels in lieu of MCL’s 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 MCLG Action Level Lead 0 mg/L 0.015 mg/L Copper 1.3 mg/L 1.3 mg/L 5

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 replacement if LSL are present Conduct public education Begin CCT steps includes WQP monitoring Conduct source water monitoring (Install SOWT, if needed) Conduct periodic lead and copper tap monitoring 6

Review of Lead and Copper Tap Monitoring Requirements Lead and Copper Rule Review of Lead and Copper Tap Monitoring Requirements 7

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 Virginia’s 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 8

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 Virginia’s 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 9

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 (Virginia’s 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 10

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 11

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

Review of Monitoring Requirements Minimum Number of Tap Samples System Population Number of Sampling Sites (Initial / Routine Monitoring) Number of Sampling Sites ( Reduced Monitoring) >100,000 100 50 10,001 to 100,00 60 30 3,301 to 10,000 40 20 501 to 3,300 10 101 to 500 5 ≤100 13

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 AL’s, monitoring can be reduced to once per year at the reduced number of sites After three years of monitoring w/ results below both AL’s, monitoring can be reduced to once per three calendar years Waterworks in reduced monitoring must collect all samples during the months of June - September

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 15

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 16

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 17

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

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) 19

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 20

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 21

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 22

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. 23

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 24

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 25

Review of 90th Percentile Calculations Fewer than 5 Samples Procedure has changed under LCR STR. Some systems may collect < 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 26

Lead and Copper Rule: Short-Term Revisions and Clarifications 27

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

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 State’s 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

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

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

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 < 5 sample provision for very small waterworks

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

Definitions of Compliance and Monitoring 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

Definitions of Compliance and Monitoring 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)

Definitions of Compliance and Monitoring 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

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

Three Year Compliance Cycle for Systems 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

(Three-Year Compliance Period) 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) 2009 2010 2011 June–September Monitoring period 2012 2013 2014 Three-year compliance period 39

Annual Monitoring Begins STR Monitoring Revisions Compliance 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 If 2nd 6-month is: Annual Monitoring Begins January – June June 1 of next year July - December 40

Criteria for Reduced 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 WQP’s) 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

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

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)

Let’s Take a Break !!

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

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

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 􀀶

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 􀀶

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

Consumer Confidence Report (CCR) Revisions Systems Affected: All systems – even if results are “not detected” for lead and copper Rule Revision: All CCR’s 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 CCR’s beginning with the 2008 CCR’s (to be delivered by June 2009)

Consumer Confidence Report (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/safewater/lead. 51

Notification & Approval for Long-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

Notification & Approval for Long-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

Notification & Approval for Long-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

Notification & Approval for Long-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 ODW’s 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

Notification & Approval for Long-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

Notification & Approval for Addition 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

Notification & Approval for Addition 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

Public Education Revisions

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

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 system’s specific situation What happened and what is being done Sources of additional information – this mandatory language and can not be altered

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

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

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

Public Education Revisions Delivery 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-gynecologists, and midwives

Public Education Revisions Delivery 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 > 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

Public Education Revisions Delivery Requirements – Additional Activities Implement additional Public Education activities from the following list: Waterworks serving > 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

Public Education Revisions Delivery 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 > 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].

Public Education Revisions Delivery 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

Public Education Revisions Delivery 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

Public Education Revisions Repeat 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

Public Education Revisions Repeat 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

Public Education Delivery 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

Re-evaluation of Tested-out Lead 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 LSL’s 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

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

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

Lead and Copper Tap Sample Monitoring Example

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

Monitoring Example Minimum Number of Tap Samples System Population Number of Sampling Sites (on Routine Monitoring) Number of Sampling Sites (on Reduced Monitoring) >100,000 100 50 10,001 to 100,00 60 30 3,301 to 10,000 40 20 501 to 3,300 10 101 to 500 5 ≤100 79

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

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

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

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

Monitoring Example – cont. Anytown 90th Percentile Calculation:

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

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

Monitoring Example #2 – cont. Let’s 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

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)

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

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

Questions and Discussion