Plumbing Replacement Program

1. Plumbing Replacement Program A Non-Chemical Corrosion Control Treatment Option Presenter: Russ Kazmierczak, DHS DWP, Springfield Office

2. Background • The Plumbing Replacement Program for Non-Transient Non-Community Water Systems is an outcome of the Lead Contamination Control Act (LCCA) of 1988 and the Lead and Copper Rule (LCR) of 1991. • The intent of the LCCA was to help schools served by a public water systems identify and reduce lead in drinking water. • The 1991 LCR addressed lead and copper in all community water systems (CWS) and non-transient non-community (NTNC) water systems. • Schools or other NTNC systems that own and operate their own public water system are subject to the LCR.

3. Act/Rule HighlightsLCCA • Identification of coolers that are not lead free. • The repair or removal of water coolers with lead lined tanks • A ban on the manufacture and sale of water coolers that are not lead free • The identification and resolution of lead problems in schools drinking water. • The authorization of additional funds for lead screening programs for children. • Not federally enforceable, states have the option to enforce.

4. Act/Rule HighlightsLCR • Protects public health by minimizing lead (Pb) and copper (Cu) levels in drinking water, primarily by reducing water corrosivity. • Establishes action level (AL) of 0.015 mg/L for Pb and 1.3 mg/L 90th percentile level of tap water samples. • AL exceedance can trigger other requirements that include water quality parameter monitoring, corrosion control treatment (CCT), source water monitoring/public education, and lead service line replacement (LSLR). • Monitoring not required at Schools or Non-Residential Buildings (NRBs), unless they have their own water supply.

5. Issues with LCR • LCR testing protocol used to identify system wide problems and not problems in single outlets (i.e. individual faucets and drinking water fountains). • LCR rule requires water system to follow testing protocol different than the one used to evaluate fixtures in schools. Plumbing Replacement Program uses LCR sampling protocol. • LCR primarily addresses Pb and Cu throughout the entire system using corrosion control treatment and does not address specific sources such as fixtures.

6. Action Level Exceedance Compliance Requirements • Public education (does not apply to Copper). • Water quality parameter (WQP) monitoring. • Source water monitoring and source water treatment. • Corrosion Control Treatment (CCT) – Chemical and Non-Chemical (Plumbing Replacement Program).

7. CCT Evaluation • Must submit a Letter of Recommendation to DWP, based on consultation with the County, on how system is to address AL exceedance. • Chemical CCT Option- Recommendation based on the Guidance Manual for Selecting Pb/Cu Control Strategies document (see web site links handout). • Non-Chemical CCT Option (Plumbing Replacement Program) – Recommendation based on the 3Ts for Reducing Lead in Drinking Water in Schools (replaces the 1994 EPA guidance document Drinking Water in Schools and Non-Residential Buildings).

8. Plumbing Replacement Program Guidance Procedure Overview • Develop Plumbing Profile. • Develop a Sampling Plan and receive approval from County/DWP prior to implementing. • Sample all reasonable sites using First Draw Sampling Procedure (see web page links for EPA guidance). You should include: • All fountains, coolers and bubblers readily accessible to students (particularly the youngest students). • Other faucets or outlets regularly used to gather drinking or cooking water. • At least one sample from each area used for food preparation. You do not need to include: • Faucets and outlets used for cleaning, maintenance or other non-consumptive uses. • Lab, washroom, art room and shop outlets. • Irrigation outlets.

9. Guidance Procedure Overview(continued) • Replace sites that exceed AL and try use Zero/Ultra Low Lead fixtures. • Resample sites that continue to exceed, use Follow-Up Flush Sampling Protocol (see attached handout).

10. Guidance Procedure Overview(continued) • If fixture was replaced with low lead brass (8% or less lead) and remains a problem, may need replacement with Zero/Ultra Low Lead fixture. • After sampling and replacement complete, submit to County/DWP a written description of Plumbing Replacement Program (see attached Plumbing Replacement Program Procedure).

11. Plumbing Replacement Program Misunderstandings • Guidance documents referenced in the Plumbing Replacement Program Procedures were written for Schools or Non-Residential Buildings on a PWS. They are not guidance documents for compliance with the LCR. • Sample collection procedures in guidance documents do not comply with the Pb and Cu LCR and if followed could result in invalidation of sample results. • What is reasonable a sample site (see web page links handout)?

12. Plumbing Replacement Program Highlights • Developed by Oregon DWP staff and based on a common sense approach using the historic Lead Contamination Control Act (LCCA) and at the same time complies with the LCR. • Non-Chemical Corrosion Treatment/Plumbing Replacement Program (LCCA) is specific to Oregon and is not referenced in the LCR or any of the guidance documents or fact sheets. • Gives NTNC (schools and non-residential buildings) water systems an alternative to adding corrosion chemicals to their water supply and can potentially save the school money in labor and maintenance costs.

13. Plumbing Replacement Program Highlights • Schools and non-residential buildings receive the benefit of being able to eliminate the cause of the problem instead of treating the symptom. • EPA recognizes Oregon’s Plumbing Replacement Program, as long water systems remain in compliance with the LCR rule.

14. Questions?