Developed by RCAP/AWWA and funded by the USEPA

Developed by RCAP/AWWA and funded by the USEPA
Controlling Lead and Copper in Drinking Water Your name and contact info Be sure to type in your name and organization. Your name and contact info Developed by RCAP/AWWA and funded by the USEPA

Acknowledgement: EPA National Priority Area 1: Training and Technical Assistance for Small Public Water Systems to Achieve and Maintain Compliance with the SDWA, EPA Grant – X RCAP developed this presentation under an EPA contract. Jeff Oxenford, RCAP Training and Technical Services Specialist, led the development. Any questions, comments, or corrections to the module contact Jeff at (720) or

Assistance Partnership
Western RCAP Rural Community Assistance Corporation (916) Midwest RCAP Midwest Assistance Program (952) Southern RCAP Community Resource Group (479) Northeast RCAP RCAP Solutions (800) Great Lakes RCAP WSOS Community Action Commission (800) Southeast RCAP Southeast Rural Community Assistance Project (866) Rural Community Assistance Partnership Practical solutions for improving rural communities First, a word about RCAP. RCAP is a non-profit organization providing training and technical assistance to rural communities & tribes on drinking water, wastewater, and solid waste issues. We have approximately 160 field staff, including certified operators and professional engineers. Our staff members have expertise in drinking water and wastewater treatment & operations, utility financing, management, & general administration. We work in all 50 states, plus five U.S. territories. We are comprised of 6 regional offices & one national office. RCAP is funded by federal grants (USDA, HHS, EPA) and state grants. RCAP National Office 1701 K St. NW, Suite 700 Washington, DC (800) | Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Purpose/Rationale This material will:
Advise you of the requirements for addressing lead and copper in drinking water (specifically at small water systems) Inform you of potential future standards recommended by the National Drinking Water Advisory Council (NDWAC) regarding lead and copper in drinking water Explain how to be more effective in your efforts to protect public health Provide an overview of requirements that address lead and copper in drinking water – specifically at small water systems Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Learning Objectives At the end of this course you should be able to:
Apply the regulatory requirements of the Lead and Copper Rule to your system Calculate the 90th concentration Summarize factors that will impact the release of lead and copper Take action to protect consumers from lead and copper At the completion of this lesson, participants should have the ability to: Apply the regulatory requirements of the Lead and Copper Rule to your system Calculate the 90th concentration Summarize factors that will impact the release of lead and copper Take action to protect consumers from lead and copper Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Agenda 0:00 – 0:05 – Introduction 0:06 – 0:46 – Regulations
0:47 – 1:12 – Lead and copper basics 1:13 – 1:23 – Conducting an inventory 1:24 – 1:44 – Monitoring requirements 1:45 – 2:00 – Treatment requirements 2:01 – 2:06 – Public notification requirements 2:07 – 2:22 – Lead service line replacement 2:23 – 2:27 – Summary Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Pre-test: Controlling Lead and Copper in Drinking Water
The pre-test will be handed out Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Module One: Regulations
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Module One Learning Objectives
At the end of this module you should be able to… Summarize the purpose of the 1991 Lead and Copper Rule (LCR) Name the types of utilities that are subject to LCR requirements Demonstrate how to calculate the “90th percentile” for your system Describe additional requirements that may be triggered as a result of an Action Level (AL) exceedance Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Why address lead? Young children and infants tend to absorb more lead than the average adult. Impaired mental development IQ deficits Shorter attention spans Low birth weight Adults - Increased blood pressure EPA set the MCLG at zero. Young children, those 6 years and younger, are at particular risk for lead exposure because they have frequent hand-to-mouth activity and absorb lead more easily than do adults. Children’s nervous systems are still undergoing development and so they’re more susceptible to the effects of toxic agents including lead. Lead is also harmful to the developing fetuses of pregnant women. No safe blood lead level in children has been determined. Lead can affect almost every organ and system in your body. The most sensitive is the central nervous system (brain), particularly in children. Lead can also be harmful to adults. The degree of harm from lead exposure depends on a number of factors including the frequency, duration, and dose of the exposure(s) and individual susceptibility factors (e.g., age, previous exposure history, nutrition, and health). In addition, the degree of harm depends on one’s total exposure to lead from all sources in the environment - air, soil, dust, food, and water. MCLG – Maximum contaminant level goal. This is a non-enforceable health goal.

Copper Exposure to copper can cause stomach and intestinal distress, liver and kidney damage, and complications of Wilson’s disease. EPA set an MCLG of mg/L Copper standards address long-term chronic risks. These can include liver and kidney damage, gastrointestillal distress, and complication of Wilson’s disease in genetically predisposed people. Wilson’s disease is a rare genetic disorder in which copper accumulates in tissues; this manifests as neurological or psychiatric symptoms and liver disease. It is treated with medication that reduces copper absorption or removes the excess copper from the body, but occasionally a liver transplant is required.[1]

Rules that impact lead Reduction of lead in materials
The Lead Ban (1986) The Reduction of Lead in Drinking Water Act (2011) Standards and Monitoring Requirements The Safe Drinking Water Act (1974) The Lead Contamination Control Act (LCCA) (1988) The Lead and Copper Rule (1991, revised 2000, 2007) A variety of rules have impacted lead in drinking water. Rules have addressed getting lead out of materials as well standards accompanied by monitoring and control strategies.

Lead Regulations – In materials
1986 – Required use of “lead free” pipe, solder, and flux 0.2% lead in flux/solder - “lead free” 50% prior to 1986 <8% lead for pipes and pipe fixtures 1998 – Banned fixtures that were not “lead free” 2011 – Redefined lead free as 0.25% These dates are important to note when investigating lead contamination. Note that many states and municipalities, began banning lead as early as the 1950’s ’s. Lead pipes were not banned nationally until 1986. In 1986 the Lead Ban took effect. This provision of the SDWA requires the use of “lead-free” pipe, solder, and flux in the installation or repair of any public water system or any plumbing in a residential or non-residential facility connected to a public water system. Solders and flux are considered to be lead-free when they contain less than 0.2 percent lead. Before this ban took effect on June 19, 1986, solders, used to join water pipes, typically contained about 50 percent lead. Pipes and pipe fittings are considered “lead-free” under the Lead Ban when they contain less than 8 percent lead. Plumbing fixtures that are not “lead-free” were banned from sale after August 6, Plumbing fixtures are subject to the National Sanitation Foundation International standard 61. In 2011 Congress passed the Reduction of Lead in Drinking Water Act (RLDWA) revising the definition of lead free by lowering the maximum lead content of the wetted surfaces of plumbing products (such as pipes, pipe fittings, plumbing fittings and fixtures) from 8% to a weighted average of 0.25%, establishing a statutory method for the calculation of lead content and eliminating the requirement that lead free products be in compliance with voluntary standards established in accordance with SDWA 1417(e) for leaching of lead from new plumbing fittings and fixtures.

Lead Regulations – Standards and monitoring requirements
1974 – MCL mg/L SDWA Lead Contamination Control Act Lead monitoring and reporting requirements for all schools (not enforceable) Lead and Copper Rule (LCR) Action levels mg/L lead, 1.3 mg/L Cu CWS and NTNCWS Minor revisions 2000, 2007 2017? – Long-term revisions to the LCR Lead was first regulated in the original Safe Drinking Water Act in The standard of mg/l was based on the 1962 Public Health Services standards. The 1988 Lead Contamination Control Act or (LCCA). The purpose of the LCCA is to reduce lead exposure and the health risks associated with it by reducing lead levels in drinking water at schools and child care centers. The LCCA created lead monitoring and reporting requirements for all schools, and required the replacement of drinking water coolers that contained excessive levels of lead. The testing provisions are not enforceable. As a results, states have the option to voluntarily enforce the provisions of the Act (or alternate provisions) through their own authority. The 1991 Lead and Copper Rule or (LCR). requires public water suppliers to monitor for lead in drinking water and to provide treatment for corrosive water if lead or copper is found at concentrations exceeding an action level of mg/l (15 ppb) or copper 1.3. mg/L. The action level is different from an MCL action. If the action level is exceeded action must be taken. Actions may include investigation, recommendation of treatment, installation of treatment, checking of source water, removal of lead containing plumbing, and public education EPA strongly recommends that schools test their facilities for lead. However, unless a school owns its public water system, testing for lead and copper within the school is not specifically required. Transient non-community systems are not included because the concern is with chronic, toxicity. The next proposed revision of the lead Rule is expected in 2017.

LCR (1991) Maximum Contaminant Level Goals (MCLG)
Lead – 0 µg/L Copper – 1.3 mg/L Action level based on the 90th percentile Lead µg/L Copper mg/L Requires optimized corrosion control rather than a Maximum Contaminant Level (MCL) In 1991, the LCR rule was promulgated. There were minor revision to this rule in 2000 and The LCR addresses corrosion of lead and copper in drinking water primarily from service lines and household plumbing. Important to note that the maximum contaminant level goal (MCLG) was set at zero, meaning there is no safe level for lead.

Actions for Lead Exceedance
Water quality parameter monitoring Corrosion Control Treatment Source water monitoring Public education Lead service line replacement Public education must be conducted within 60 days after the end of the monitoring period in which the action level is exceeded. State may allow an extension. Replace 7% of LSLR per year. Must inventory water system. Difficult to know how much lead service lines are in the ground.

Lead and Copper Rule 1991 Overview
* Includes systems serving ≤ 50,000 people and (b)(3) systems ** Includes non-(b)(3) systems serving > 50,000 people, irrespective of their 90th percentile levels; (b)(2) systems must collect WQPs. Conduct periodic lead and copper tap monitoring 90th Percentile Exceeds the Lead Action Level (15 μg/L) Exceeds the Copper Action Level (1.3 mg/L) Is at or Below Both Action Levels* CWS or NTNCWS Collects Lead and Copper Tap Samples Begin LSLR replace 7% of LSLs per year Begin CCT steps includes WQP monitoring ** Conduct public education due within 60 days Conduct source water monitoring (Install SOWT, if needed) LSLR – Lead service line replacement CCT – Corrosion control treatment WQP – water quality parameter monitoring SOWT – Source water treatment The Lead and Copper Rule applies to community water systems and non-transient non-community water systems. Systems with 90th percentile lead and copper tap levels that are at are below the action level are required to conduct periodic monitoring only. All large systems are required to have optimized corrosion control or demonstrate that they have minimal levels of corrosion in the distribution system based on lead and copper source and tap water samples in accordance with §141.81(b)(3) of the regulation. Non-(b)(3) large systems must install CCT, regardless of whether they have an ALE. (b)(2) systems (i.e., had CCT in place prior to 12/7/92) must conduct WQP monitoring. If the a system exceeds the lead AL, then it must conduct public education within 60 days after the end of the monitoring period, begin CCT steps which includes WQP monitoring, conduct source water monitoring and install source water treatment if needed, begin lead service line replacement and a rate of 7% of lead service lines per year and conduct periodic lead and copper tap monitoring.

Activity- EPA Quick Reference Guide
Monitoring – What type systems is the rule applicable to? For public education – Is public education required when copper action level is exceeded? Source water – How frequently must a ground system monitor? Corrosion control treatment – When must a small system conduct a CCT study. Moderators – Hand out the EPA Quick Reference Guide: Applicable to All CWSs and NTNCWSs. PE -Systems that exceed the Pb AL (not required if only the Cu AL is exceeded). Ground water PWSs monitor once during 3-year compliance periods; surface water PWSs monitor annually. If State requires study for small or medium systems, it must be completed within 18 months

Potential future standards
NDWAC recommendation - Development of a household action level Potentially lowering of the action level Requiring lead service line replacement The National Drinking Water Advisory Council (NDWAC) has made a series of recommendations to EPA for future regulation of lead. While these are only recommendations, they do serve as a starting point for the next round of regulatory negotiations. Household action level – The concept is the level at which a consumer take action if lead is found in their tap. EPA is rumored to be working on developing this guidance number. It is expected to be higher than the 90th percentile. There has been discussion of lowering the AL and it is very likely that a new action level will be promulgate with the next revision of the standard. There has also been discussion of requiring lead service line replacement. RCAP is being proactive by participating in the Lead Service Line Replacement Collaborative which is looking a voluntary programs to address service line replacement.

To calculate the 90th percentile:
Rank the samples according to their lead or copper concentrations Find the “sample” that: 90% of all samples have a lower concentration 10% of all samples have a higher concentration Sample # Lead (mg/L) 1 0.004 2 0.005 3 4 0.006 5 6 7 0.009 8 0.010 9 0.011 10 0.017 Stress a unique concept of the lead and copper rule is an action level based on the 90th percentile. This means that to be in compliance 90% of the households will need to be below this action level. 10% can be above.

Activity: Determining the 90th Percentile
Your instructor will distribute handouts for this activity INSTRUCTOR NOTE: Please see the document (in two formats – WORD and PDF -- to be used as necessary) entitled, “90th percentile – Lead and Copper Exercise” Note – When doing this activity – For 90th percentile values that are not whole numbers, EPA allows either rounding or interpolation. States can specify either approach. Using Rounding: EPA’s policy is to: 1. Round down to the nearest whole number if your decimal is 0.4 or lower. 2. Round up to the nearest whole number if your decimal is 0.5 or higher. Using Interpolation: To determine the 90th percentile level, using interpolation, you would: 1. Subtract the difference between the two samples between which your 90th percentile falls. In this example you subtract the 10th sample result of mg/L from the 11th sample result of mg/L, for a difference of mg/L. 2. Multiply the difference of mg/L by 0.8 because the 90th percentile level is 0.8 higher than the 10th sample result: x 0.8 = mg/L (or when rounded to the number of significant figures). 3. Add to the lower of the two sample results, in this example to the 10th sample result of mg/L: = mg/L. Colorado has a calculator for the interpolation method -

Module Two: Lead and Copper Basics

Module Two Learning Objectives
At the end of this module, you should be able to: Name the two forms of lead that may be present in drinking water Discuss factors that can impact lead concentrations in drinking water Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Sources of Lead Rarely from source water or distribution mains
Service lines Lead service lines, on either side of the meter Goosenecks or pigtails Customer plumbing Solder Plumbing fixtures New lead free standards are emerging to reduce lead levels. Existing materials are grandfathered in, but are addressed by compliance monitoring.

Ownership of System Components
Area in red is often the concern of the utility. Point out the goosenecks and pigtail. Systems without lead service lines may still have these. The ownership (utility or homeowner) of the service line and position of the meter varies between systems. Customers/ or utilities may own the service line to the main, to the curb, to the meter, up to entering the home. Meters can be in a pit near the curb or inside the home. Good place to ask a question of the audience – Who owns the complete service line, only to the meter, to curb stop, or nothing past the main.

There are two forms of lead: Dissolved lead Particulate lead
Lead can be present in two forms – Dissolved lead is typically derived from the dissolution of lead from the surfaces of lead pipe, lead solder, and brass elements. Particulate lead results from the sloughing off and transport of lead particles. For example if a lead scale breaks off. Particles can be trapped in aerators and can beak down over time into small particles (passing through the aerator).

Factors that impact dissolved lead concentrations
Water quality parameters pH, alkalinity, dissolved inorganic carbon, hardness Chlorine residual levels, Presence of corrosion inhibitors Materials Other conditions Temperature, Flow velocity, Electrical current A variety of factors can impact dissolved lead concentrations pH – Lower pH leads to more corrosion Alkalinity – Low alkalinity – more corrosion Dissolved organic carbon and hardness – Low levels typically mean more corrosion. Changes in these level can also be a factor is lead release Corrosion inhibitors can reduce corrosion Chlorine residual levels – recent research indicates that if chlorine residual drops lead can be released. Chlorine residuals may increase copper corrosion Materials – Lead service lines, lead solder, or lead in fixtures can impact this . Temperature – Higher temperatures can increase corrosion rate Flow velocity – typically has more impact on particulate lead Electrical current – grounding of electrical wires to plumbing can increase corrosion.

Factors that impact particulate lead concentrations
Operations practices that can impact lead levels Physical disturbances Repairing a main break Meter repair Hydraulic changes Flushing Valve/ hydrant testing Particulate lead can be a major cause of extremely high lead levels. It occurs when something disrupts the scale on the pipe. Scales can also contain iron, manganese, or other hydroxides. These have an affinity for lead. Utility operations can also impact scales, like disruption following a main break. Some people have even postulate that working on the road can cause scales to break off. Hydraulic changes like flushing or valve operation can disrupt scales.

Factors that can impact both dissolved and particulate concentrations
Change in source water Changes in water chemistry Change in pH Change in chlorine residual levels The issue in Flint, MI started with a change in water sources (different pH, different water chemistry, no corrosion inhibitor). The very high levels that were reported were mostly due to particulate lead, scales coming off the pipe. Distribution systems don’t like change. Any change can disrupt the water quality. Once scales get disrupted, more lead will dissolve.

Discussion What would happen to lead levels if:
Seasonally switch between a surface water source and a ground water Bring a new well into service Repair a water main Replace the service line between the main and meter Good opportunity for a small group discussion – Groups can address each question, or can assign one problem to a table and report back to the group. Changing between water sources can impact your corrosion rates. Scales can break off, dissolution rates can change. Bringing on a new well from the same aquifer mot likely would have minimal impact – but if from a different aquifer? Problems can occur when disrupting service lines when repairing a main. Lead can be disrupted. Between the main and meter is what’s considered a partial service line replacement. If a lead service line remains between the meter and home lead can be disrupted. Replacing the full service line doesn’t mean the problems are over. Home plumbing needs to be flushed. Also, lead can leach from in home plumbing.

Module Three: Conducting an Inventory

Module Three Learning Objectives
At the end of this module, you should be able to: Name information sources you can use to inventory the materials used in your system Identify ways to tell whether or not a pipe is made of lead We will focus on using conversion factors, specifically those found on the formula/ conversion tables (ABC or state specific). Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Conducting an inventory
Installation records Codes, regulations Main renewal records Observations during construction Observation during meter replacement Customer reporting It will take some investigation to determine what line materials were used in your system. If you have installation records of service lines, great. But in most cases these don’t exist or are incomplete. By analyzing codes and practices you can get a rough idea of what’s going on. By being aware of lead service lines, gooseneck, etc. you can being making observations during construction, meter replacement, etc. Example state requirement (CO) Suppliers must complete a materials evaluation to identify lead, copper and galvanized steel materials in the distribution system. The following sources of information should be utilized in performing the materials evaluation: ● Plumbing Codes; ● Plumbing Permits; ● Distribution Maps and Drawings; ● Inspection and Maintenance Records; ● Meter Installation Records; ● Capital Improvement and Master Plans; ● Standard Operating Procedures; ● Operation and Maintenance Manuals; ● Permit Files; ● Existing Water Quality Data; ● Interviews with Senior Personnel, Building Inspectors, and Retirees; and Community Survey.

Pictures of lead service lines.

Ways to tell if pipe is lead
Scratch test Grey or color like a penny? Easy to scratch? Lead swabs Shape Magnet (will stick to steel, not lead) Some utilities have been using the lead swabs available at stores like Home Depot. The comment I heard was that they are afraid that galvanized lines were so thin that a scratch can break the pipe. Demonstration It would be great if you could have an example lead service line to try the scratch test or magnet. Also have a galvanized line and copper line. You could also show the video from Cincinnati waterworks, I heard that the original picture used by the media for a lead service line was actually a dirty copper line.

Question Who has lead service lines? Have you conducted an inventory?
What are the ages of homes in your system? Full group question Use questions to probe if folks really know if they have lead service lines or not. What are the oldest homes in their system?

Module Four: Monitoring Requirements

Module Four Learning Objectives
At the end of this module, you should be able to: Discuss how to properly select sampling sites for a Community Water System as well as for a Non-Transient, Non-Community Water System Monitor your system as prescribed by Standard Monitoring and Reduced Monitoring requirements Follow procedures required to properly collect and manage lead and copper tap samples Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Monitoring Requirements
Sampling sites – with highest potential levels Frequency – Set by regulation – Reduced monitoring possible Procedures – First-draw, try to observe the highest concentrations These requirements will be discussed in the following slides

Site selection CWS Three tier criteria to identify home with the highest risk Tier 1 Single family If lead service lines (50% of the sites) Copper pipe and lead solder after 1982 (and before lead ban 87/88) Tier 2 - Building/multi-family Tier 3 – Lead solder before 1983 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 after 1982 or contain lead pipes and/or; Are served by lead service line. Although typically a Tier 1 sampling pool is comprised of single family homes, when multiple-family residences comprise at least 20 percent of the structures served by the water system, the system may include these types of structures in its sampling pool. Tier 2 - Without a sufficient number of Tier 1 sites should select Tier 2 sites to complete the sampling pool. The Tier 2 sampling pool consists of buildings including multiple family residences that: Contain copper pipes with lead solder installed after 1982 or contain lead pipes; and/or, A CWS with insufficient tier 1, tier 2, and tier 3 sampling sites must complete its sampling pool with representative sites throughout the distribution system. A representative site is a site in which the plumbing materials at that site is commonly found at other sites served by the water system

NTCNWS 2 tier criteria Tier 1 Tier 2 Lead service lines or
Copper pipe and lead solder after 1982 (and before lead ban 87/88) Tier 2 Lead solder before 1983 Site Selection for Non Transient Non community Water Systems Tier 3 is not applicable Similar to a CWS… Systems without a sufficient number of Tier 1 sites should select Tier 2 sites to complete the sampling pool. A NTNCWS with insufficient tier 1 and tier 2 sampling sites must complete its sampling pool with representative sites throughout the distribution system.

Minimum number of sites
Systems without enough tiered sites must use representative sites Must identify sites in your monitoring plan Best to have more sites than the minimum required Best to have more sites than the minimum required – Since customers are asked to take samples you may want to have greater than the minimum number of sites submitting samples. That way you always remain in compliance.

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 Water systems must collect at least one lead and copper tap sample from the number of sites listed in the table corresponding to the system’s population and monitoring frequency. Reduced monitoring sites must follow tiering requirements. For example, if a system has 100 sites, of which 75 are Tier 1 and 25 are Tier 2, it must collect all 50 reduced sites from Tier 1 sites if they are available. Otherwise, rule does not specify which sites should be chosen for reduced monitoring (e.g., ones with highest lead results). However, the States may specify sampling locations when a system is on reduced monitoring. The minimum number of samples requirement in the LCR-Short term Revisions affect small systems serving 100 or fewer people with less than five taps for human consumption (primarily NTNCWSs). The regulatory revision retains the 5 sample minimum and clarifies that multiple samples may need to be collected from the same location on different days. Also allow States discretion to reduce monitoring to one sample per tap for human consumption where there are fewer than 5 such taps. However, since this new provision is not more stringent States do not have to adopt this new provision. For systems taking fewer than 5 samples, the highest concentration is compared against the action levels to determine compliance with AL.

Monitoring schedules Standard monitoring: Reduced monitoring
Conducted at 6-month intervals from January-June or July-December Reduced monitoring Can be annual, triennial, or 9-year monitoring schedules. Must take sample for 4 consecutive months Time of normal operation when highest likely lead levels Reduced monitoring Allowed if 90th percentile levels for two consecutive 6-months are: Lead < mg/L Copper < 0.65 mg/L • System goes directly to triennial monitoring • State approval not required Monitoring Waivers: Materials Criteria • Applies to distribution system, service lines, drinking water supply plumbing, including within homes/buildings served • Lead criteria: • No plastic pipes w/ lead plasticizers or plastic service lines w/ lead plasticizers, • No LSLs, lead pipes, lead soldered pipe joints, leaded brass or bronze fittings and fixtures (unless meet lead-leaching std) • Copper criteria: no copper pipes or service lines Monitoring Waivers: Monitoring Criteria • Must have completed one 6-month round of monitoring since meeting materials criteria • 90th percentile levels must be: Lead < mg/L • Must continue to monitor once every 9 years • Recertification every 9 years, with monitoring results • Renewed automatically if system still meets criteria

Procedures for sampling
First-draw 6-hour standing time One-liter volume System or residents can collect Samples are taken from kitchen/bathroom taps Sample Collection Method Lead and copper in drinking water is primarily due to the corrosion of distribution and household plumbing materials; therefore, tap water samples are collected at kitchen or bathroom sink taps of residences and other buildings vs. entry points to the distribution system. The Short Term Revisions clarify that sampling “sites’’ refer to “taps that can be used for human consumption,’’ such as kitchen and bathroom taps as opposed to outlets such as hose bibs or taps at utility sinks. All lead and copper tap samples must be first-draw -- the water should have stood (not been used) for at least six hours prior to collecting the one-liter sample. For the 1991 rule, the minimum 6-hour stagnation time was a compromise between ease of sample collection and waiting for equilibrium solubility. A first-draw sample from a nonresidential building should be collected at an interior tap used for consumption. NTNCWSs or “special CWSs” (such as a prison or nursing home that do not have enough inside taps where the water stands unused for at least six hours, can request approval from the State to use inside taps that are the most likely to have remained unused for the longest period of time. If samples are collected by residents, then instructions should be provided and a chain of custody maintained.

Issues and recent recommendations
No water softeners or POU/POE Aerators – Leave on Use wide mouth sample bottles (encourages higher flow rates) No pre-stagnant flushing Aerators Although aerators are not intended to remove inorganic contaminants, aerators may trap particulate matter within the faucet. The 2006 memo states that while EPA recommends homeowners regularly clean their aerators to remove particulate matter, EPA does not recommend removing or cleaning aerators prior to or during the collection of tap samples for determining 90th percentile for lead. If customers are only encouraged to remove and clean aerators prior to sampling for lead, the customer may fail to take additional actions needed to reduce exposure to lead in drinking water. If results (with an aerator) is > AL, EPA recommends another sample be collected (without an aerator or with a clean aerator) to determine whether particulate matter is a lead source. Both results must be used in 90th percentile calculations. The first sample cannot be invalidated based on the presence of lead-bearing matter in the aerator Prestagnation flushing may potentially lower the lead levels as compared to when it is not practiced. WSG 197 Date Signed: February 29, 2016 Flushing removes water that may have been in contact with the lead service line for extended periods, which is when lead typically leaches into drinking water. Therefore, EPA recommends that sampling instructions not contain a pre-stagnation flushing step. Bottle Configuration: EPA recommends that wide-mouth bottles be used to collect Lead and Copper compliance samples. It has become apparent that wide-mouth bottles offer advantages over narrow-necked bottles because wide-mouth bottles allow for a higher flow rate during sample collection which is more representative of the flow that a consumer may use to fill up a glass of water.

States may invalidate a sample if
Improper sample analysis Site selection criteria not met Sample container damaged Sample subjected to tampering It’s difficult to invalidate a sample States may invalidate samples, but in light of Flint, it will be very difficult to invalidate a sample.

Other samples Customer requested samples should not be included in the 90th percentile calc. (states are still requiring these to be reported) Sampling not required at schools or public buildings (but recommended) Over the years, EPA has issued memoranda relating to the monitoring, sampling, and calculation of the 90th percentile. In a 2004 memo, EPA clarified elements of the lead and copper rule associated with the collection and management of lead and copper samples and the calculation of the lead 90th percentile for compliance. In this memo EPA addressed 7 aspects of the requirements for collecting samples and calculating compliance: All sample results from a system’s sampling pool during the monitoring period must be included in the 90th percentile calculation (even if this includes more samples than the required minimum number needed for compliance). A system sends out kits to 150 homes to ensure that it will get the required 100 samples at least. The system received sample results for 140 households, the system would have to use all 140 samples in calculating the 90th percentile. In terms of confirmation samples, the original and confirmation sample must also be used to calculate the 90th percentile. Customer-requested samples that are not collected as part of the system’s regular compliance sampling pool may or may not meet the sample site criteria. Including results from samples that do not meet the criteria could inappropriately reduce the 90th percentile value. Therefore, customer-requested samples should not be used to calculate the 90th percentile, except in cases where the system is able to determine that the site selection criteria for compliance sampling are satisfied. Even though customer-requested samples are not used for the 90th percentile calculation, the sample results must still be provided to the State. A sample cannot be invalidated as a result of: Alleged homeowner error in sample collection Excessive stagnation periods

Activity - Monitoring Your instructor will distribute handouts for this activity Develop an activity – true and false about monitoring – have students work in a team to answer questions – Leverage FAQs INSTRUCTOR NOTE: Please see the two documents entitled, “Lead and Copper Sampling Activity” and “Lead and Copper Sampling Activity – Distance” and distribute to participants.

Module Five: Treatment Requirements - Optimal Corrosion Control Treatment (OCCT)

Module Five Learning Objectives
At the end of this module, you should be able to: Explain why a small or medium system would decide to apply Optimal Corrosion Control Treatment (OCCT) techniques Summarize the purpose of Water Quality Parameter (WQP) Monitoring for small and medium systems Water quality Parameter Monitoring may be required for small and medium systems that exceed the lead or copper action level Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Optimal corrosion control treatment (OCCT)
Chemical treatment designed to reduce the corrosivity of water Raising pH to make water less acidic Adding buffering to make water more stable Adding corrosion inhibitors to create a barrier to inhibit metals release OCCT required for large system Required for small/medium systems only if the action level is exceeded Corrosion control is chemical treatment that is designed to reduce the corrosivity of water. The major optimal corrosion control treatment (OCCT) techniques are: pH and/or Alkalinity Adjustment. And an Inhibitor Addition (for example ortho phosphate or silicate based inhibitors) For small/med systems, the action level for lead is a trigger for optimal corrosion control as part of the treatment technique. It is based on treatment feasibility; NOT on a health threshold. Large systems are required to optimize corrosion control regardless of their 90th percentile lead concentration, unless the difference between the 90th percentile and the highest source water lead concentration is <0.005 mg/L.

Water Quality Parameter Monitoring
Required when < 50,000 that exceed AL > 50,000 regardless of 90th percentile* *(b)(3) systems not subject to CCT requirements (b)(3) system = 90th percentile lead - highest source water < mg/L for 2 consec. 6 mos. WQP monitoring is required for all large systems and small and medium systems that exceed the lead or copper action level. Unlike lead and copper tap samples, WQP samples should be taken from taps that are fully flushed. Samples collected at entry points to the distribution system must be collected at locations representative of each source of water after treatment. If a system draws water from more than one source, the sources are combined before distribution, and samples are not collected at the entry point to the distribution system, the system must collect samples at sites in the distribution system where the water is representative of all sources being used.

WQP Monitoring - Parameters
Typical Water Quality Parameters pH1 Orthophosphate2 Alkalinity Silica3 Calcium Temperature1 Conductivity 1 Measured on-site. 2 Applies when a phosphate-containing inhibitor is used. 3 Applies when a silicate-containing inhibitor is used. Typical water quality parameters include pH, alkalinity, calcium, conductivity, and temperature. Orthophosphate is monitored when a phosphate-containing corrosion inhibitor is used. Silica is monitored when a silicate-containing inhibitor is used. A State may specify additional water quality parameters, so it is best for systems to check with the State regarding specific requirements.

Purpose of WQP monitoring
To assist in determining water corrosivity To identify appropriate corrosion control treatment To determine whether corrosion control treatment is being properly maintained

Corrosion Control Treatment Steps
Study/treatment recommendation by system State treatment determination Treatment installation Follow-up Pb/Cu tap & WQP monitoring State-specified operating parameters There’s a lot of considerations associated with corrosion control treatment. Beyond what we can do in this module.

Determining The Best Corrosion Control Treatment
Consult with your primacy agency Obtain recommendations of chemical suppliers Check with industries, hospitals, clinics, and wastewater plants Check with other water systems Don’t experiment on the whole system Consider advantages and disadvantages of storing, handling and feeding various chemicals

Discussion Has anyone modified corrosion control practices

Module Six: Public Notification Requirements

Module Six Learning Objectives
At the end of this module, you should be able to: Comply with the Lead Consumer Notice requirements as mandated in the 1991 Lead and Copper Rule Communicate with consumers regarding effective strategies to reduce lead exposure Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Without an action level exceedance
Notify consumers of lead tap results Consumer Confidence Reports

Lead Consumer Notice Impacts all CWSs and NTNCWSs
Requirements (varies by state) Provide notice of lead tap water monitoring results Regardless of whether sample exceeds lead AL To all served by sampling site -- not just the person who pays the bills (i.e. renters) As soon as practical but within 30 days after receiving results By mail or other State-approved methods

Consumers tips for reducing lead exposure
Flushing – Stagnant water Clean aerators Get your water tested Filters You can engage consumers on how to reduce any potential exposure to lead by Flushing – let the water run before you drink. If there’s concern about wasting water, you can capture the water in a bucket and use for plant watering or washing. Aerators can trap particulates. Periodic cleaning is recommended. Water testing – consumers can go on their own to a private lab (make sure it’s a certified lab) or some utilities are offering this as a service (free or for a fee). Filters – Some filters do remove lead. Make sure they are NSF certified for lead remove and follow the maintenance schedule.

Module Seven: Lead Service Line Replacement

Module Seven Learning Objectives
At the end of this module, you should be able to: Explain the impacts to public health when considering lead service line replacements Describe the difference between a partial and a full service line replacement Suggest consumer alternatives to service line replacements Even full service line replacement can lead to elevated lead levels following replacements of the service line; an emerging issue is the impact of disturbance on the main and its potential for increasing lead levels. Partial replacement means that the service line is replaced from the main to the home’s meter. Full replacement means the service line is replaced from the main to the inside of the home Consumer alternatives to lead service line replacement might include aggressive in-home flushing and temporary use of water filters. Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Lead service lines – do they need to be replaced
Full replacement – From main to inside the home Partial replacement – From the main to the meter Disturbance on the main or service line Under current regulatory requirements, full lead service line replacement is not required. However, it is rapidly becoming the recommended best practice. Recognize that even full service line replacement can lead to elevated lead levels following replacements. Processes such as aggressive in-home flushing and temporary use of water filters should be considered. Partial LSLR means, replacing only the lead that is under the utilities control. While a plan to replace LSLs is required when a utility exceeds the action level, this practice is rapidly becoming not recommended as the disturbance on the remaining service line can cause elevated lead levels. Some utilities are contacting customers and giving them the option of having the service line replaced at the same time either at the home owners expense or utility’s expense. An emerging issues is the impact of disturbance on the main and its potential impact on lead levels.

Case Against Partial Replacement
Galvanic Series Referenced to Copper-Copper Sulfate Galvanic Corrosion from partial replacement Metal Volts Magnesium -1.6 to -1.75 Zinc -1.10 Aluminum -1.05 Carbon Steel -0.5 to -0.8 Cast/Ductile Iron -0.5 Lead Copper -0.2 Carbon, Graphite +0.3 Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Activity What action(s) will you take on returning to your utility?
Examples could include: Conduct a materials inventory Review sampling plan and sites selected Develop notices for consumers Develop an SOP for when lead service lines are disturbed Review treatment strategies Develop a strategy for replacing service lines In a small group discuss potential actions upon returning to your utility. Report back to the full group.

Summary The primary source of lead are service lines, solder, and plumbing fixtures. Some of which are not under direct control of the utility. The utilities responsibilities are: Monitoring Controlling the corrosivity of the water Public education and outreach Operation practices to minimize lead Programs to get the lead out

You are not required, but recommended to:
Have a program to replace lead service lines Have a program to help customers monitor their tap Sample schools and other public buildings

Resources AWWA: EPA Lead and Copper Rule Quick Reference Guide: 01N8P.txt Rural Community Assistance Partnership (RCAP): Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Post-test: Controlling Lead and Copper in Drinking Water
Post-test will be handed out Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Thanks for Attending! your name
Contact Info Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016

Developed by RCAP/AWWA and funded by the USEPA

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Developed by RCAP/AWWA and funded by the USEPA

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