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

2. Training Objectives
Present a brief history of EPA lead and copper regulations
Summarize basic elements of the original LCR and LCRMR
Summarize the changes and clarifications contained in the new Short Term Revisions Rule
Present and discuss some lead and copper monitoring examples and resulting required actions

3. LCR Short-Term Revisions Rule Making History
The Lead and Copper Rule: Short Term Revisions and Clarifications (LCR
STR) is the fourth EPA Rule dealing with lead and copper in drinking water
The Lead Contamination Control Act was promulgated in 1988
The original Lead and Copper Rule (LCR) was promulgated on June 7, 1991
The Lead and Copper Rule Minor Revisions (LCRMR) were promulgated on January 12, 2000
The Lead and Copper Rule: Short Term Revisions and Clarifications (LCR STR) were promulgated on October 10, 2007
EPA is not done – work on a Lead and Copper Rule: Long Term Revision is underway

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

5. Original LCR Overview 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 mg/L mg/L
Copper mg/L mg/L 5

6. 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

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

8. Review of Monitoring Requirements Site Selection – Community Systems
Prior to sampling each waterworks must submit a materials survey
and sample site selection justification
LCR requires that samples be collected from the highest risk locations
Three sampling site tiers: Tier 1, Tier 2, and Tier 3
Tier 1 sample sites are considered high risk sites
Tier 1 sampling pool consists of single family structures* that:
Contain copper pipes with lead solder installed between 1983 and 1986 (date of 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

9. Review of Monitoring Requirements Site Selection – Community Systems
Tier 2 sampling pool consists of buildings including multiple family residences that:
Contain copper pipes with lead solder installed between 1983 and 1986 (date of 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

10. Review of Monitoring Requirements Site Selection – NTNC Systems
Two sampling site tiers: Tier 1 and Tier 2.
Tier 1 sampling pool consists of sample sites that:
Contain copper pipes with lead solder installed between 1983 and 1986 (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

11. Review of Monitoring Requirements Sample Site Selection
The LCR STR clarifies that an acceptable sampling location
should be a tap that is “normally” used for human
consumption:
Typically cold water kitchen or bathroom sinks
Drinking fountains and water coolers in schools or other buildings
Do not sample from outside hose bibs or utility sinks 11

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

13. 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

14. Review of Monitoring Requirements Lead and Copper Tap Monitoring
Initial monitoring includes two 6-month periods (January – June and July – December)
After the two 6-months of initial monitoring w/ results below both 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

15. Review of Monitoring Requirements Collecting Samples and Calculating Compliance
All valid sample results will be included in the 90th percentile calculation:
Sample must meet the selection criteria (tier and category)
Sample must be collected within the compliance monitoring period (June – September for reduced monitoring)
Some samples are not included in the 90th percentile calculation:
Customer-requested sample - unless meet site selection criteria
Samples collected outside compliance monitoring period
90th percentile concentrations will be calculated even if less than the minimum number of samples are submitted
This is also monitoring violation
A NOV will be issued 15

16. Review of Monitoring Requirements Collecting Samples and Calculating Compliance cont.
Define a valid sample:
First-draw – minimum of 6 hours standing time
1-liter in volume
Collected from an inside tap normally used for human consumption (kitchen or bathroom sink, drinking fountain)
Waterworks can collect samples or review collection information before analysis – if something is not right do not have the sample tested
States can only invalidate a sample if:
Improper sample analysis, or
Site selection criteria not met, or
Sample container was damaged in transit, or
Sample subjected to tampering 16

17. Review of Monitoring Requirements Management of Aerators during Sample Collection
Encourage homeowners to regularly clean aerators
Do not remove/clean prior to or during sampling as this could fail to identify typical lead contributions
DCLS sampling instructions have been modified 17

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

19. Review of 90th Percentile Calculations More than 5 Samples
Step 1: Place lead or copper results in ascending order.
Step 2: Assign each sample a number, 1 for lowest value.
Step 3: Multiply the total number of samples by 0.9.
Example: 20 samples x 0.9 = 18th sample.
Step 4: Compare 90th percentile level
to AL (in above example, 18th sample) 19

20. Review of 90th Percentile Calculations More than 5 Samples Example
Assume 10 samples are collected with lead and copper
results as follows:
Site A: mg/L
Site B: mg/L
Site C: mg/L
Site D: mg/L
Site E: mg/L What is the 90th Percentile Value?
Site F: mg/L
Site G: mg/L
Site H: mg/L
Site I: mg/L
Site J: mg/L 20

21. Review of 90th Percentile Calculations More than 5 Samples Example
Step 1: Order results from lowest to highest:
1. Site A: Site E: 0.014
2. Site C: Site H: 0.014
3. Site F: Site I: 0.014
4. Site J: Site B: 0.015
5. 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 21

22. Review of 90th Percentile Calculations More than 5 Samples Example
Suppose when you multiply the number of samples the result is not a whole number
As an example consider a sample set that contains 24 lead and copper samples
Example: 24 samples x 0.9 = 21.6th sample result
In this situation you can use rounding (round the 21.6 up to 22 and compare the 22nd highest sample result to the Action Level
As an alternative method you can use interpolation 22

23. Review of 90th Percentile Calculations 5 Samples Example
Step 1: Place results in ascending order.
Step 2: Average 4th and 5th highest sample results.
Step 3: Compare 90th percentile level to action level. 23

24. Review of 90th Percentile Calculations 5 Samples Example
Assume 5 samples are collected with lead and copper
results as follows:
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 24

25. Review of 90th Percentile Calculations 5 Samples Example
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
0.011 mg/L mg/L = mg/L 2
Step 3: Compare average to lead action level  Exceedance 25

26. 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: mg/L, mg/L, and mg/L
90th percentile = mg/L 26

27. Lead and Copper Rule: Short-Term Revisions and Clarifications27

28. LCR Short Term Revisions Major Changes
Monitoring Revisions
Minimum Number of Samples Required
Definitions for Compliance and Monitoring Periods
Reduced Monitoring Criteria
Consumer Notice of Lead Tap Results
Consumer Confidence Report Mandatory Language
Notification of Treatment and Source Changes
Public Education Changes
Reevaluation of Tested Out Lead Service Lines

29. LCR Short Term Revisions Compliance Dates
LCR STR was published on October 10, 2007 and has an effective date of December 10, 2007
For States that “Adopt by Reference” the rule compliance date is 180 days after promulgation - or by April 8, 2008
For State’s with a formal adoption process the rule compliance date is two years after the effective date or by December 10, Virginia is in this category
States can request up to an additional two years extension – or by December 10, 2011

30. LCR Short Term Revisions Compliance Dates
As noted above, Virginia technically has until December 10, 2009 to implement this new rule
However, as we have done with other EPA rules, ODW will proceed with implementation during the interim period of formal adoption
Implementation will begin with samples collected this summer

31. Minimum Number of Samples Required
Systems affected
Small systems serving 100 or fewer people with less than five taps used for human consumption (primarily non-transient, non-community water systems – NTNCWS) 􀀶
Regulatory revision
Retain the 5 sample minimum, but also allow States discretion to reduce monitoring to one sample per tap used for human consumption where there are fewer than 5 such taps

32. Minimum Number of Samples Required
For systems taking fewer than 5 samples, the highest single sample lead and copper values are used to determine if the system meets the Action Levels
The ODW is adopting the < 5 sample provision for very small waterworks

33. Minimum Number of Samples Required
If a waterworks chooses this option to collect fewer
than five samples, the ODW must ensure that:
The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample locations
All sample taps used for human consumption are sampled
The owner is aware that the single highest sample result will be compared to the Action Levels
This sampling plan is approved in writing prior to the sampling event

34. Definitions of Compliance 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

35. 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)

36. 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

37. Deadlines Are Critical
From the end of the monitoring period –
September 30
10 days to report LCR monitoring results
60 days to complete public education
3 months to certify consumer notification
6 months for corrosion control treatment recommendations

38. Three Year Compliance Cycle 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

39. (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

40. 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

41. 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

42. 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

43. Reduced Monitoring Example
Under current LCR language, this waterworks is eligible to remain in triennial reduced monitoring
The LCR STR Rule clarifies that any waterworks can only become eligible for, or be allowed to remain in reduced monitoring if the 90th percentile lead concentration is below the lead Action Level
Under the LCR STR Rule this large waterworks would be required to return to initial monitoring (6 month frequency at the initial number of samples)

44. Let’s Take a Break !!

45. Consumer Notification
Systems Affected:
All systems (Community and NTNC) – even if both lead and copper Action Levels are met
Rule Revision:
Waterworks must provide notification of the lead and copper sampling results to the occupants at each site that was tested in the LCR tap monitoring program within 30 days of receipt of results
This 30 day time period begins on the date the waterworks receives the lead and copper results notification letter from the ODW

46. Consumer Notification
In addition to the lead and copper sample results, waterworks must also provide:
Health effects language
Actions residents can take to reduce exposure to lead in drinking water
Utility contact information
Maximum contaminant level goal (MCLG)
Action Level Definition
The Consumer Notification is required following each lead and copper monitoring event – regardless of the results

47. Consumer Notification
Delivery Mechanisms – Direct mail or another method approved by the State
NTNC systems could post the results on a bulletin board in the facility
Small waterworks could provide notification by hand delivery
Must provide notice to the occupants of the building that was tested – even if those residents do not receive water bills 􀀶

48. Consumer Notification
Reporting requirements:
Within 3 months from end of monitoring period, the waterworks must submit a copy of notification that was provided and must certify that all notification requirements have been met
Consumer Notification templates are provided in the handout material 􀀶

49. New Violation
LCR STR Rule adds an additional violation for failure to meet the lead consumer notification requirements
Note that is part of the Public Education portion of the rule but is a separate violation
This is a M/R violation and not a TT violation like failure to meet the PE requirements following a lead Action Level exceedance

50. Consumer 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)

51. 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 51

52. 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

53. 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

54. 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

55. Notification & Approval for Long-term Treatment Changes
Waterworks Regulations 12 VAC 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

56. 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

57. 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

58. 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

59. Public Education Revisions

60. Public Education Revisions
Systems affected
All systems exceeding lead AL
Rule Revision
LCR STR Rule makes significant changes in the message content, delivery requirements, and the timing of when waterworks must complete required Public Education activities

61. Public Education Revisions Written Materials
PE written materials (Community and NTNC) include:
Introduction/information statement - this is mandatory language and can not be altered
New health effects language that provides greater specificity on lead health effects – i.e., lower IQ impacts in children - this is mandatory language and can not be altered
Sources of lead
Steps to take to reduce exposure to lead in drinking water - Flushing recommendations can be tailored to the system’s specific situation
What happened and what is being done
Sources of additional information – this mandatory language and can not be altered

62. Public Education Revisions Written Materials
Required content for community waterworks only:
Tell consumers how to get their water tested
Discuss lead in plumbing components and the difference between low lead and lead free

63. Public Education Revisions Written Materials
“Special” Community Waterworks may:
Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and the discussion of plumbing components
Limit the Public Education deliver to the delivery requirements for NTNC waterworks
If the waterworks is a facility such as a prison, hospital, boarding
school where the population served is not capable of, or is prevented from,
making improvements to plumbing or installing POU treatment devices, and
The waterworks provides water as a part of the cost of services and
does not separately charge for water consumption

64. Public Education Revisions Delivery Requirements – Written Materials
Community Waterworks
Deliver written materials (pamphlets, brochures, etc.) to all bill paying customers
Deliver written materials to facilities and organizations that are served by the waterworks that are most likely to be visited regularly by pregnant women and children
Local Heath Departments
Public and private schools and preschools
WIC and Head Start programs
Public and private hospitals
Pediatricians, Gynecologists and Midwives
Family Planning Clinics
Local welfare agencies
Within 60 days of the end of the monitoring period

65. Public Education 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

66. 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

67. 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
s to customers
Public meetings
Household deliveries
Targeted individual customer contacts
Direct material distribution to all multi-family homes or institutions
Other methods approved by the state

68. Public Education 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].

69. 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

70. 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

71. 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

72. 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

73. 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

74. 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

75. Lead Service Line Replacement
LSL replacement schedule is more explicit
First year requires 7% replacement, begins immediately at end of the monitoring period
Still have all existing testing and notification requirements

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

77. Lead and Copper Tap Sample Monitoring Example

78. Monitoring Example Anytown is a community waterworks serving a
total population of 3800 persons. Anytown is currently in triennial reduced monitoring collecting lead and copper tap samples once every three years
Based upon the 3800 population Anytown is required to submit the results of 20 lead and copper tap samples during the reduced monitoring period

79. Monitoring Example Minimum Number of Tap Samples
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

80. Monitoring Example – cont.
Anytown collects 14 samples on July 3, Results are submitted to the ODW Field Office on July 25, 2009 by the laboratory
Anytown collects 10 additional samples on October 2, Results are submitted to the ODW Field Office on October 10, 2009 by the laboratory
All samples were collected from sites that were included in the initial LCR sampling plan that was approved by the ODW

81. Monitoring Example – cont.
What actions will be taken by the ODW Field
Office??
There are only 14 valid lead and copper tap sample results
The 10 samples collected on October 2, 2009 can not be utilized as all reduced monitoring samples must be collected during the months of June through September

82. Monitoring Example – cont.
The ODW Field Office must calculate the 90th percentile lead and copper concentrations using the 14 samples that were collected in July 2009
The ODW Field Office must issue a monitoring violation for failure to submit 20 lead and copper sample results – only 14 valid results were submitted

83. Monitoring Example – cont.
ODW Field Office will calculate the 90th percentiles
Place the 14 samples in ascending order
Multiply the 14 samples by 0.9
14 x 0.9 = 12.6
Round the 12.6 value up to 13 – the 13th highest sample results are compared to the Action Levels

84. Monitoring Example – cont.
Anytown 90th Percentile Calculation:

85. Monitoring Example – cont.
ODW Field Office will calculate the 90th percentiles
The 90th percentile lead concentration is 14 ppb which is below the 15 ppb Action Level
The 90th percentile copper concentration is 1.1 mg/l which is below the 1.3 mg/L Action Level

86. Monitoring Example – cont.
What actions are required by Anytown ??
Anytown must distribute public notification (the M/R violation is a Tier III violation) within 12 months
Anytown must collect their next round of LCR tap samples during the June through September 2010 monitoring period
Anytown must initiate the consumer notification requirements – to be completed within 30 days of receipt of the ODW lead and copper results notification letter

87. Monitoring Example #2 – cont.
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

88. Monitoring Example #2 – cont.
The 17 ppb 90th percentile concentration has exceeded the lead Action Level of 15 ppb
Anytown must submit an optimum corrosion control treatment recommendation to the Field Office within 6 months of the end of the monitoring period or by March 31, 2010.
Anytown must conduct Water Quality Parameter Monitoring within 6 months from the beginning of the monitoring period or by November 30, 2009 (6 months from June 1, 2009)

89. Monitoring Example #2 – cont.
Anytown must conduct source water monitoring for lead within 6 months from the end of the monitoring period or by March 30, 2010 (6 months from September 30, 2009)
Anytown must complete all of the Public Education requirements within 60 days of the end of the monitoring period or by November 30, 2009
Public Education must continue as long as Anytown continues to exceed the lead Action Level
Lead Service Line Replacement is not required since Anytown does not have any lead service lines

90. Monitoring Example #2 – cont.
Anytown is no longer eligible for reduced monitoring
Anytown should continue to monitor
Collect 40 lead and copper samples during January – June 2010
Will end the monitoring violation
If results are below the lead AL will end Public Education
If the AL continues to be exceeded corrosion control treatment must be installed
Treatment must be installed within 24 months of ODW notification, unless an OCCT study is required

91. Questions and Discussion