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7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 1
Controlling Lead and Copper in Drinking Water
Your name and contact info
Your name and contact info
Developed by RCAP/AWWA and funded by the USEPA
• EPA National Priority Area 1: Training and Technical Assistance for Small Public Water Systems to Achieve and Maintain Compliance with the SDWA, EPA Grant – X6‐83560701
Acknowledgement:
Western RCAPRural CommunityAssistance Corporation(916) 447-2854www.rcac.org
Midwest RCAPMidwest Assistance Program(952) 758-4334www.map-inc.org
Southern RCAPCommunity Resource Group(479) 443-2700www.crg.org
Northeast RCAPRCAP Solutions(800) 488-1969www.rcapsolutions.org
Great Lakes RCAPWSOS Community Action Commission(800) 775-9767www.glrcap.org
Southeast RCAPSoutheast Rural Community Assistance Project(866) 928-3731www.southeastrcap.org
RCAP National Office1701 K St. NW, Suite 700Washington, DC 20006(800) 321-7227www.rcap.org | [email protected]
Rural CommunityAssistance PartnershipPractical solutions for improving rural communities
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 2
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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
5
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
6
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
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 3
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Pre‐test: Controlling Lead and Copper in Drinking Water
• The pre‐test will be handed out
Module One:Regulations
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
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 4
• 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.
Why address lead?
• Exposure to copper can cause stomach and intestinal distress, liver and kidney damage, and complications of Wilson’s disease.
• EPA set an MCLG of 1.3 mg/L
Copper
• 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)
Rules that impact lead
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 5
• 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%
Lead Regulations – In materials
• 1974 – MCL ‐ 0.050 mg/L SDWA
• 1988 ‐ Lead Contamination Control Act
– Lead monitoring and reporting requirements for all schools (not enforceable)
• 1991 ‐ Lead and Copper Rule (LCR)
– Action levels ‐ 0.015 mg/L lead, 1.3 mg/L Cu
– CWS and NTNCWS
– Minor revisions 2000, 2007
• 2017? – Long‐term revisions to the LCR
Lead Regulations – Standards and monitoring requirements
• Maximum Contaminant Level Goals (MCLG)– Lead – 0 µg/L
– Copper – 1.3 mg/L
• Action level based on the 90th percentile – Lead ‐ 15 µg/L
– Copper ‐ 1.3 mg/L
• Requires optimized corrosion control rather than a Maximum Contaminant Level (MCL)
LCR (1991)
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 6
Actions for Lead Exceedance
• Water quality parameter monitoring
• Corrosion Control Treatment
• Source water monitoring
• Public education
• Lead service line replacement
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)
90th Percentile Exceeds the Copper
Action Level (1.3 mg/L)
90th Percentile 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 periodic lead and copper tap monitoring
Conduct public
educationdue within 60
days
Conduct source water monitoring
(Install SOWT, if needed)
• 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.
Activity‐ EPA Quick Reference Guide
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 7
• NDWAC recommendation ‐ Development of a household action level
• Potentially lowering of the action level
• Requiring lead service line replacement
Potential future standards
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 0.005
4 0.006
5 0.006
6 0.006
7 0.009
8 0.010
9 0.011
10 0.017
• Your instructor will distribute handouts for this activity
Activity: Determining the 90th
Percentile
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 8
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
• 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
Sources of Lead
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 9
Ownership of System Components
There are two forms of lead:
• Dissolved lead
• Particulate lead
Forms of lead
• Water quality parameters
– pH, alkalinity, dissolved inorganic carbon, hardness
– Chlorine residual levels,
– Presence of corrosion inhibitors
• Materials
• Other conditions
– Temperature, Flow velocity, Electrical current
Factors that impact dissolved lead concentrations
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 10
Operations practices that can impact lead levels
• Physical disturbances
⁻ Repairing a main break
⁻ Meter repair
• Hydraulic changes
⁻ Flushing
⁻ Valve/ hydrant testing
Factors that impact particulate lead concentrations
• Change in source water
• Changes in water chemistry
• Change in pH
• Change in chlorine residual levels
Factors that can impact both dissolved and particulate
concentrations
What would happen to lead levels if:
1. Seasonally switch between a surface water source and a ground water
2. Bring a new well into service
3. Repair a water main
4. Replace the service line between the main and meter
Discussion
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 11
Module Three:Conducting an Inventory
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
Module Three Learning Objectives
• Installation records
• Codes, regulations
• Main renewal records
• Observations during construction
• Observation during meter replacement
• Customer reporting
Conducting an inventory
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 12
• Scratch test
– Grey or color like a penny?
– Easy to scratch?
• Lead swabs
• Shape
• Magnet (will stick to steel, not lead)
Ways to tell if pipe is lead
Who has lead service lines?
• Have you conducted an inventory?
• What are the ages of homes in your system?
Question
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 13
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
• Sampling sites – with highest potential levels
• Frequency – Set by regulation – Reduced monitoring possible
• Procedures – First‐draw, try to observe the highest concentrations
Monitoring Requirements
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 14
• 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
Site selection CWS
• 2 tier criteria
– Tier 1
• Lead service lines or
• Copper pipe and lead solder after 1982 (and before lead ban 87/88)
– Tier 2
• Lead solder before 1983
NTCNWS
• 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
Minimum number of sites
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 15
Minimum Number of Tap Samples
System PopulationNumber 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 20 10
101 to 500 10 5
≤100 5 5
• Standard monitoring:
– Conducted at 6‐month intervals from January‐June or July‐December
• Reduced monitoring
– Can be annual, triennial, or 9‐year monitoring schedules.
• Conducted during a 4‐month period from June‐September
• Time of normal operation when highest likely lead levels
Monitoring schedules
Procedures for sampling
First‐draw
6‐hour standing time
One‐liter volume
System or residents can collect
Samples are taken from kitchen/bathroom taps
45
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 16
• No water softeners or POU/POE
• Aerators – Leave on
• Use wide mouth sample bottles (encourages higher flow rates)
• No pre‐stagnant flushing
Issues and recent recommendations
• 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 a sample if
• 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)
Other samples
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 17
Activity ‐Monitoring
• Your instructor will distribute handouts for this activity
Module Five: Treatment Requirements -Optimal Corrosion Control Treatment
(OCCT)
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
Module Five Learning Objectives
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 18
• 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
Optimal corrosion control treatment (OCCT)
• 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 < 0.005 mg/L for 2 consec. 6 mos.
Water Quality Parameter Monitoring
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.
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 19
• To assist in determining water corrosivity
• To identify appropriate corrosion control treatment
• To determine whether corrosion control treatment is being properly maintained
Purpose of WQP monitoring
• Study/treatment recommendation by system
• State treatment determination
• Treatment installation
• Follow‐up Pb/Cu tap & WQP monitoring
• State‐specified operating parameters
Corrosion Control Treatment Steps
• 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
Determining The Best Corrosion Control Treatment
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 20
• Has anyone modified corrosion control practices
Discussion
Module Six:Public Notification Requirements
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
Module Six Learning Objectives
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 21
• Notify consumers of lead tap results
• Consumer Confidence Reports
Without an action level exceedance
• 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
Lead Consumer Notice
• Flushing – Stagnant water
• Clean aerators
• Get your water tested
• Filters
Consumers tips for reducing lead exposure
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 22
Module Seven:Lead Service Line Replacement
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
Module Seven Learning Objectives
• Full replacement – From main to inside the home
• Partial replacement – From the main to the meter
• Disturbance on the main or service line
Lead service lines – do they need to be replaced
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 23
• 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
Activity
• 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
Summary
• Have a program to replace lead service lines
• Have a program to help customers monitor their tap
• Sample schools and other public buildings
You are not required, but recommended to:
7/31/2018
Developed by American Water Works Association with funds from the U.S. Environmental Protection Agency, Published 2016 24
AWWA: http://www.awwa.org
EPA Lead and Copper Rule Quick Reference Guide:
https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt
Rural Community Assistance Partnership (RCAP):http://www.rcap.org
Resources
Post‐test: Controlling Lead and Copper in Drinking Water
• Post‐test will be handed out
THANKS FOR ATTENDING!
YOUR NAME
CONTACT INFO