Leah A. Guzman Environmental Program Specialist Drinking Water Program

1. Sustained Compliance for Public Water Systems, • Chapter 2 • Lead and Copper Issues – • An Overview • September 29, 2011 • Anchorage, Alaska • Presented by Leah A. Guzman Environmental Program Specialist Drinking Water Program Alaska Department of Environmental Conservation

2. PRESENTATION OUTLINE Public Health Risks Overview of the Lead and Copper Rule (LCR) Sampling Protocols Corrosion Control Treatment (CCT) Process Getting Back To Compliance Guidance and References Summary

3. Health Risks of Lead and Copper Lead and Copper come from corrosion of household plumbing system or erosion of natural deposits. • Corrosion is the degradation of metal. • Lead – May cause delays in physical or mental development in infants and children; kidney problems and high blood pressure among adults. • Copper – May cause gastrointestinal (GI) distress from short-term exposure; kidney or liver damage from long-term exposure.

4. Overview of the Lead and Copper Rule

5. Overview of the LCR 40 CFR 141 EPA publishedLCR June 7, 1991. Revisions were made between 2000-2006. Final short-term revision to LCR was public-noticed on Oct 10, 2007. Purpose: Protect public health by minimizing lead (Pb) and copper (Cu) levels in drinking water, primarily by reducing water corrosivity. Action Level: 0.015 mg/L (Pb) and 1.3 mg/L (Cu) Applicability: CWS and NTNCWs

6. Overview of the LCR Public Water System (PWS)* is a water system that serves regularly at least 25 persons daily, at least 60 days of the year, or has at least 15 service connections. PWS is either Community (CWS) or Non-Community (NCWS) water system. CFR 141.2 *NOTE: These are public water systems that must comply with federal regulations.

7. Overview of the LCRRegulatory Distinctions Among Water Systems LCR does not apply to TNCWs

8. Overview of the LCRPublic Water Systems in Alaska L C R? YES NO

9. Overview of the LCR

10. Overview of the LCR, cont’d

11. Overview of the LCR, cont’d

12. Overview of the LCR, cont’d

13. Overview of the LCR, cont’d Monitoring Provisions First-draw samples at taps/distribution (homes/buildings) Number of Samples - Population-based (system size) Monitoring Frequency Initial/Standard: every 6 months Reduced: annually, every 3 years

14. Overview of the LCR, cont’d Action Levels and Consumer Notification (CWS + NTNCWS) (CWS ) • EFFECTIVE IN 2008 • Public water system owners or operators should notify consumers from sites sampled of individual Lead tap results • CWS consumers need to be educated about lead in their drinking water through annual CCRs

15. Consumer Notification40 CFR 141.85(d) CWS CWS + NTNCWS

16. Monitoring Protocols

17. Lead and Copper Sampling Protocols Planning is important! What needs to be done (Sampling Plan)? When and where to sample? What forms to fill out? Who should we send the sample to?

18. Monitoring Summary as one of the Planning Tools 1.What to sample for & where to sample 2. Sample Frequency 3. Date of last sample 4. Date next sample is due 5. Definitions and explanations

19. Monitoring Summary as one of the Planning Tools 6. DEC contact information

21. Lead and Copper Sampling PlanSite Selection • Distribution materials evaluation • (pipes & fixtures; residential or commercial) • Accessibility • Activity / Inactivity • First-draw samples – water remains motionless for 6 to 8 hours • Do not include sites with Point-of-use (POU) or Point-of-Entry (POE) treatment devices • Consistent locations provide results that can be compared over time • Newly replaced pipes or fixtures may influence analytical results

22. Lead and Copper Sampling PlanSite Selection, cont’d Community Water Systems (CWS) • Tier 1 – considered high risk sites. Single Family Residences (SFRs) • Contain copper pipes with lead solder installed after 1982 (but before State’s lead ban) or; • Contain lead pipes and/or; • Are served by a lead service line • Tier 2 – Buildings (BLDGs) including MFRs that contain copper pipes w/ lead solder (installed after 1982) or contain lead pipes or lead service lines. • Tier 3 – SFRs that contain copper pipes w/ lead solder installed in 1982 or prior years. Tier 1 - May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served.

23. Lead and Copper Sampling PlanSite Selection, cont’d Non-Transient, Non-Community Water Systems (NTNCWS) Tier 1 – Buildings (BLDGs) that contain copper pipes with lead solders installed after 1982 (1983 & beyond but before the year the state bans the use of lead solders) or contain lead pipes; also buildings with lead service lines. Tier 2 – Buildings (BLDGs) that contain copper pipes with lead solder installed before1983 (1982 and earlier years). In 1986, the Congress banned the use of lead solders with > 0.2% lead

24. Lead and Copper Sampling PlanSite Selection, cont’d Special Cases Non-Tier residences or buildings – No lead or soldered copper pipes to meet tier sampling site requirements. Special-case residences and buildings still need to monitor for lead and copper. Non-tier CWS or NTNCW should collect sampling pool from representative sites – plumbing used is common to other sites in the distribution system served by the PWS.

25. Lead and Copper Sampling PlanSite Selection, cont’d Do not include sites with point-of-use (POU) or point-of-entry (POE) treatment devices for inorganic chemicals. POU treatment control is the use of devices attached to water taps or in lines near water outlets such as: filter units ion exchangers reverse osmosis units adsorber cartridges

26. Developing A Lead and Copper Sampling Plan • Explain selection of sites • Provide clear descriptions and names for each site, and include alternative sites • Sample procedures • Emphasize flushing and use cold water tap • Flushing procedures • Describe how 6-hour no-flow time will be met • Note if residents will collect samples

27. Collecting Samples

28. Pre-collectionPreparations • Supplies • Sample bottles • Packing materials • Paper towels • Labels, Forms, and Pens • Watch • Other items as needed • Arrangements • Lab hours • Flights • Coordinate with any relevant contractors • Courtesy reminders to home or business owners – ensure access • Payments • Other items as situation warrants

29. Sampling Protocols:Aerators/faucet screens

30. Lead and Copper First-Draw Sampling Reminders Do NOT remove the aerator Flush cold water tap 6 hours of NO water activity (6-8 hrs is optimal) Use 1-Liter bottle (1,000 ml) Fill bottle to neck with first water from cold tap Do NOT overflow Label accurately

31. Lead and Copper First-Draw Sampling Words of Caution DO NOT OVERFLOW OR RINSE while filling up the bottle; you need to keep the liquidpreservative in the bottle. DO NOT USE THE PRESERVATIVE NAME as the sample or analysis type. Indicate “lead and copper” for analysis or sample type on bottle labels and lab forms. Keep Data Consistency

32. Lab Forms

33. Partially Completed Forms the lab the lab

34. First-Draw Lead/Copper Sampling

35. LCR – Sample Invalidation40 CFR 141.86 (f) (1) The State may invalidate a lead or copper tap water sample if at least one of the following conditions is met. (i) Laboratory analysis error (ii) The State determines sample was taken from an inappropriate site (iii) The sample container was damaged in transit (iv) There is substantial reason to believe that the sample was subject to tampering

36. LCR – Sample Invalidation40 CFR 141.86 (f), cont’d (2) The system must report the results of all samples to the State and all supporting documentation for samples the system believes should be invalidated (3) To invalidate a sample under paragraph (f)(1) of this section, the decision and the rationale for the decision must be documented in writing States may not invalidate a sample solely on the grounds that a follow-up sample result is higher or lower than that of the original sample

37. Reporting • Ensure that time and money are not wasted: • Recheck forms & labels for accuracy & completeness • Label on bottle • Labs are required to report results directly to DEC • PWSs are responsible to ensure that DEC receives results

38. Example of DEC Lead & Copper Monitoring Summary Report

39. Sampling: Key Points • Develop Sampling Plan • Plan, coordinate, and sample early • Use reminder & scheduling tools • Keep water motionless 6-8 hrs prior to sampling (no toilet flushing) • Complete forms accurately • Know that your job is important! • Drinking Water is important!

40. Lead and Copper Rule 90th Percentile Calculations Courtesy of EPA presentation on Short-term Revisions to LCR

41. 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). * When more than minimum number of samples are collected, may need rounding or interpolation to determine 90th percentile sample

42. Review of 90thPercentile Calculations More than 5 Samples: Example Question Assume 10 samples are collected with lead results as follows: Site A: 0.005 mg/L Site B: 0.015 mg/L Site C: 0.005 mg/L Site D: 0.014 mg/L Site E: 0.014 mg/L What is the 90th Percentile Value? Site F: 0.005 mg/L Site G: 0.040 mg/L Site H: 0.014 mg/L Site I: 0.014 mg/L Site J: 0.005 mg/L

43. Review of 90th Percentile Calculations More than 5 Samples: Example Answer Step 1: Order results from lowest to highest: 1.Site A: 0.005 6. Site E: 0.014 2. Site C: 0.005 7. Site H: 0.014 3. Site F: 0.005 8. Site I: 0.014 4. Site J: 0.005 9. Site B: 0.015 5. Site D: 0.014 10. 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 0.015 mg/L) Step 3: Compare to lead action level No Exceedance

44. Review of 90th Percentile Calculations 5 Samples • 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.

45. Review of 90th Percentile Calculations 5 Samples: Example Question Assume 5 samples are collected with lead results as follows: Site A: 0.009 mg/L Site B: 0.011 mg/L Site C: 0.020 mg/L What is the 90th Percentile Value? Site D: 0.009 mg/L Site E: 0.010 mg/L

46. Review of 90th Percentile Calculations 5 Samples: Example Answer Step 1:Order results from lowest to highest: 1. Site A: 0.009 mg/L 2. Site D: 0.009 mg/L 3. Site E: 0.010 mg/L 4. Site B: 0.011 mg/L 5. Site C: 0.020 mg/L • Step 2: Average 4th & 5th samples highest samples to get 90th percentile value = 0.016 mg/L • 0.011 mg/L + 0.020 mg/L = 0.0155 mg/L • 2 Step 3: Compare average to lead action level Exceedance

47. Review of 90th Percentile Calculations Fewer than 5 Samples • Procedure has changed under LCR Short-Term Revision (LCRSTR). • Some systems may collect < five samples. • Sample with highest result is 90th percentile level. Assume 3 lead samples: 0.020 mg/L, 0.008 mg/L, and 0.005 mg/L. 90th percentile = 0.020 mg/L

48. Action Level Exceedance

49. What happens when the action level is exceeded?

50. What happens when the action level is exceeded?