Acknowledgement: EPA National Priority Area 1: Training and - - PDF document

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

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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 RCAP Rural Community Assistance Corporation (916) 447-2854 www.rcac.org Midwest RCAP Midwest Assistance Program (952) 758-4334 www.map-inc.org Southern RCAP Community Resource Group (479) 443-2700 www.crg.org Northeast RCAP RCAP Solutions (800) 488-1969 www.rcapsolutions.org Great Lakes RCAP WSOS Community Action Commission (800) 775-9767 www.glrcap.org Southeast RCAP Southeast Rural Community Assistance Project (866) 928-3731 www.southeastrcap.org RCAP National Office 1701 K St. NW, Suite 700 Washington, DC 20006 (800) 321-7227 www.rcap.org | info@rcap.org

Rural Community Assistance Partnership

Practical solutions for improving rural communities

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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

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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

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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

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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

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• 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

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• 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)

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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%

• f LSLs

per year Begin CCT steps includes WQP monitoring ** Conduct periodic lead and copper tap monitoring Conduct public education due 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

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• 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

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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

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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

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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

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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

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• 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

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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

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• 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

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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 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

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• 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

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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

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• 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.

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• 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

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• 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

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• 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

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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

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• 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:

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AWWA: http://www.awwa.org EPA Lead and Copper Rule Quick Reference Guide: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=600 01N8P.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!

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