april 2008 lead and copper rule: short-term revisions and clarifications

April 2008

Lead and Copper Rule: Lead and Copper Rule: Short-Term Revisions and Short-Term Revisions and

ClarificationsClarifications

April 2008

IntroductionIntroductionHow the Presentation is OrganizedHow the Presentation is Organized

Lead and Copper Rule (LCR) Lead and Copper Rule (LCR) IntroductionIntroduction

OverviewOverview

Lead and Copper Tap Monitoring Requirement ReviewLead and Copper Tap Monitoring Requirement Review

9090thth Percentile Calculation Review Percentile Calculation Review

LCR Short-Term Revisions and Clarifications (STR) LCR Short-Term Revisions and Clarifications (STR) OverviewOverview

STR Regulatory ChangesSTR Regulatory Changes

Primacy PackagePrimacy Package

April 2008

IntroductionIntroductionTerminology for Primacy AgencyTerminology for Primacy Agency

State means Primacy AgencyState means Primacy Agency

40 CFR 40 CFR §141.2 definition for State§141.2 definition for State

Possible Primacy AgenciesPossible Primacy Agencies

StateState

Tribal governmentTribal government

EPA regionEPA region

April 2008

IntroductionIntroductionAcronymsAcronyms

AL:AL: Action Level Action Level

ALE:ALE: Action Level ExceedanceAction Level Exceedance

CCT:CCT: Corrosion Control TreatmentCorrosion Control Treatment

CWS:CWS: Community Water SystemCommunity Water System

LCR: LCR: Lead and Copper RuleLead and Copper Rule

LCR STR: LCR STR: Lead and Copper Short-Term Revisions and Lead and Copper Short-Term Revisions and ClarificationsClarifications

LSLR:LSLR: Lead Service Line ReplacementLead Service Line Replacement

MCL:MCL: Maximum Contaminant LevelMaximum Contaminant Level

MCLG: MCLG: Maximum Contaminant Level GoalMaximum Contaminant Level Goal

M/RM/R Monitoring and Reporting (Violation)Monitoring and Reporting (Violation)

NTNCWS: NTNCWS: Non-transient Non-community Water SystemNon-transient Non-community Water System

PWS: PWS: Public Water SystemPublic Water System

SOWT:SOWT: Source Water TreatmentSource Water Treatment

WQP:WQP: Water Quality ParameterWater Quality Parameter

Lead and Copper RuleLead and Copper Rule

OverviewOverview

April 2008

Lead and Copper RuleLead and Copper Rule OverviewOverview

First published on June 7, 1991.First published on June 7, 1991.

Established MCLGs for lead and copper.Established MCLGs for lead and copper.

Establishes AL vs. MCL.Establishes AL vs. MCL.

9090thth percentile sample result is compared to AL. percentile sample result is compared to AL.

ALE is trigger and not violation.ALE is trigger and not violation.

ALE requires treatment techniques and additional monitoring. ALE requires treatment techniques and additional monitoring.

MCLG Action Level

Lead 0 mg/L 0.015 mg/L

Copper 1.3 mg/L 1.3 mg/L

April 2008

Lead and Copper RuleLead and Copper Rule OverviewOverview

Three system size categories. Three system size categories.

Size is factor for sample number and Size is factor for sample number and applicability/timing of some requirements.applicability/timing of some requirements.

Large: > 50,000 people

Medium: 3,301 to 50,000 people

Small: 3,300 or fewer people

April 2008

** Includes systems serving Includes systems serving ≤ 50,000 people and (b)(3) systems≤ 50,000 people and (b)(3) systems**** Includes non-(b)(3) systems serving > 50,000 people, irrespective of their 90 Includes non-(b)(3) systems serving > 50,000 people, irrespective of their 90 thth percentile percentile levels; (b)(2) systems must collect WQPs.levels; (b)(2) systems must collect WQPs.

Lead and Copper RuleLead and Copper RuleOverviewOverview

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)

Conduct periodic lead and copper

tap monitoring


Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements

April 2008

Review of Monitoring RequirementsReview of Monitoring RequirementsSite Selection - CWSSite Selection - CWS

Three sampling site tiers: Tier 1, Tier 2, and Tier 3.Three sampling site tiers: Tier 1, Tier 2, and Tier 3.Tier 1 sample sites are considered high risk sites.Tier 1 sample sites are considered high risk sites.

Tier 1 sampling pool consists of single* family structures that:Tier 1 sampling pool consists of single* family structures that: Contain copper pipes with lead solder installed Contain copper pipes with lead solder installed

after 1982 (but before State’s lead ban) or;after 1982 (but before State’s lead ban) or; Contain lead pipes and/or;Contain lead pipes and/or; Are served by a lead service line.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.

April 2008

Review of Monitoring RequirementsReview of Monitoring Requirements Site Selection - CWSSite Selection - CWS

Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple family residences that:family residences that: Contain copper pipes with lead solder Contain copper pipes with lead solder installed after 1982 (but before State’s installed after 1982 (but before State’s lead ban) or;lead ban) or; Contain lead pipes and/or;Contain lead pipes and/or; Are served by a lead service line.Are served by a lead service line.

Tier 3 sampling pool consists of single family structures that: Tier 3 sampling pool consists of single family structures that: Contain copper pipes with lead solder installed before 1983.Contain copper pipes with lead solder installed before 1983.

Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.

April 2008

Review of Monitoring RequirementsReview of Monitoring Requirements Site Selection - NTNCWSSite Selection - NTNCWS

Two sampling site tiers: Tier 1 and Tier 2.Two sampling site tiers: Tier 1 and Tier 2.Tier 1 sampling pool consists of sample sites that:Tier 1 sampling pool consists of sample sites that:

Contain copper pipes with lead solder installed Contain copper pipes with lead solder installed

after 1982 (but before State’s lead ban) or;after 1982 (but before State’s lead ban) or; Contain lead pipes and/or;Contain lead pipes and/or; Are served by lead service line.Are served by lead service line.

Tier 2 sampling pool consists of sample sites that: Tier 2 sampling pool consists of sample sites that: Contain copper pipes with lead solder installed before 1983.Contain copper pipes with lead solder installed before 1983.

Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.

April 2008

Review of Monitoring RequirementsReview of Monitoring Requirements Sample Collection MethodSample Collection Method

First-draw. First-draw.

6-hour standing time.6-hour standing time.

One-liter volume.One-liter volume.

System or residents can collect.System or residents can collect.

April 2008

Review of Monitoring RequirementsReview of Monitoring Requirements Minimum Number of Tap SamplesMinimum 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


Review of 90Review of 90thth

Percentile CalculationsPercentile Calculations

April 2008

Step 1:Step 1: Place lead or copper results in ascending order. Place lead or copper results in ascending order.

Step 2:Step 2: Assign each sample a number, 1 for lowest value. Assign each sample a number, 1 for lowest value.

Step 3:Step 3: Multiply the total number of samples by 0.9. Multiply the total number of samples by 0.9.

Example: 20 samples x 0.9 = 18Example: 20 samples x 0.9 = 18th th sample.*sample.*

Step 4:Step 4: Compare 90 Compare 90thth percentile level percentile level to AL (in above example, 18to AL (in above example, 18thth sample). sample).

Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples More than 5 Samples

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

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples: Example Question More than 5 Samples: Example Question

Assume 10 samples are collected with lead results as follows:

Site A: 0.005 mg/LSite B: 0.015 mg/LSite C: 0.005 mg/L Site D: 0.014 mg/LSite E: 0.014 mg/L What is the 90th Percentile Value?Site F: 0.005 mg/L Site G: 0.040 mg/LSite H: 0.014 mg/LSite I: 0.014 mg/LSite J: 0.005 mg/L

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples: Example Answer More than 5 Samples: Example Answer

Step 1: Order results from lowest to highest:1. Site A: 0.005 6. Site E: 0.0142. Site C: 0.005 7. Site H: 0.0143. Site F: 0.005 8. Site I: 0.0144. 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 Step 2: Multiply number of samples by 0.9 to determine which

represents 90th percentile levelrepresents 90th percentile level

10 x 0.9 = 9th sample (or 0.015 mg/L)

Step 3: Compare to lead action level Step 3: Compare to lead action level No ExceedanceNo Exceedance

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples 5 Samples

Step 1:Step 1: Place results in ascending Place results in ascending order.order.

Step 2:Step 2: Average 4 Average 4thth and 5 and 5thth highest highest sample results.sample results.

Step 3:Step 3: Compare 90 Compare 90thth percentile level percentile level to action level.to action level.

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples: Example Question 5 Samples: Example Question

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

Assume 5 samples are collected with lead results as follows:

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples: Example Answer 5 Samples: Example Answer

Step 1:Step 1: Order results from lowest to highest: Order results from lowest to highest: 1. Site A: 0.009 mg/L2. Site D: 0.009 mg/L3. Site E: 0.010 mg/L4. Site B: 0.011 mg/L5. Site C: 0.020 mg/L

Step 2: Average 4th & 5th samples highest samples to get 90th Step 2: Average 4th & 5th samples highest samples to get 90th percentile value = 0.016 mg/Lpercentile 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 Step 3: Compare average to lead action level Exceedance

April 2008

Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 Samples Fewer than 5 Samples

Procedure has changed under STR. Procedure has changed under STR. Some systems may collect < five samples.Some systems may collect < five samples.Sample with Sample with highest resulthighest result is 90 is 90thth percentile level. percentile level.

No M/R violation.No M/R violation.

Assume 3 lead samples: 0.020 mg/L, 0.008 mg/L, and 0.005 mg/L. 90th percentile = 0.020 mg/L

April 2008

Review of Monitoring RequirementsReview of Monitoring Requirements Management of Aerators during Sample CollectionManagement of Aerators during Sample Collection

Memo addressed taps with aerators:Memo addressed taps with aerators:

Regularly clean aerators.Regularly clean aerators.

Do not remove/clean prior to or during sampling.*Do not remove/clean prior to or during sampling.*

Could fail to identify typical lead contribution.Could fail to identify typical lead contribution.

If initial result > AL, recommend 2If initial result > AL, recommend 2ndnd sample sample (without (without aerator or with clean aerator)aerator or with clean aerator)..

Use both results in 90Use both results in 90thth percentile calculation. percentile calculation.

* Does not apply to tap samples collected for WQP analysis.

April 2008

Review of Monitoring Requirements Review of Monitoring Requirements Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliance

Memo addressed 7 aspects of tap sample collection and Memo addressed 7 aspects of tap sample collection and management:management:

Include all valid sample results in 90Include all valid sample results in 90thth percentile calculation: percentile calculation: Meet sample selection criteriaMeet sample selection criteria Collected within compliance monitoring period* Collected within compliance monitoring period*

Do not include in 90Do not include in 90thth percentile calculation: percentile calculation: Customer-requested sample unless meet site selection criteriaCustomer-requested sample unless meet site selection criteria Samples collected outside compliance monitoring period* Samples collected outside compliance monitoring period*

Calculate 90Calculate 90thth percentile even if < minimum sample number percentile even if < minimum sample number (M/R violation)(M/R violation). .

* Would include replacement sample(s) collected within 20 days of invalidation (even if collected after monitoring period end).

April 2008

Defines proper sample:Defines proper sample: First-draw, First-draw, 1-liter, 1-liter, From inside tap used for consumption (kitchen or bathroom From inside tap used for consumption (kitchen or bathroom

sink), andsink), and Minimum 6-hours standing time.Minimum 6-hours standing time.

System can collect sample or review collection System can collect sample or review collection information before analysis.information before analysis.

States can invalidate sample if:States can invalidate sample if: Improper sample analysis, orImproper sample analysis, or Site selection criteria not met, orSite selection criteria not met, or Sample container was damaged in transit, orSample container was damaged in transit, or Sample subjected to tampering.Sample subjected to tampering.

Review of Monitoring Requirements Review of Monitoring Requirements Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance (cont.)(cont.)

Lead and Copper Short-Term Lead and Copper Short-Term Revisions and ClarificationsRevisions and Clarifications

April 2008

Overview Regulatory Changes Primacy Package

April 2008

Short-Term Revisions OverviewShort-Term Revisions OverviewScope of RevisionsScope of Revisions

Published in Published in Federal RegisterFederal Register, October 10, 2007 p.57782, October 10, 2007 p.57782

Addresses implementation issues with existing rule:Addresses implementation issues with existing rule: Monitoring revisions (sample number, timing clarifications).Monitoring revisions (sample number, timing clarifications).

Additional requirements for providing public information.Additional requirements for providing public information.

Advanced notification of treatment changes and source Advanced notification of treatment changes and source

additions.additions.

Reevaluation of “tested-out” lead service lines.Reevaluation of “tested-out” lead service lines.

Targeted changes based on input from National LCR Review.Targeted changes based on input from National LCR Review.

Key elements of treatment technique requirements are Key elements of treatment technique requirements are unchanged.unchanged.

Long-term revision process likely to start soon.Long-term revision process likely to start soon.

April 2008

Short-Term Revisions OverviewShort-Term Revisions OverviewGuidance DocumentsGuidance Documents

Six draft guidance documents to assist with Six draft guidance documents to assist with implementation:implementation:

Two public information fact sheetsTwo public information fact sheets

Separate CWS and NTNCWS consumer Separate CWS and NTNCWS consumer information guidanceinformation guidance

State Implementation GuidanceState Implementation Guidance

Water System Monitoring and Reporting Guidance.Water System Monitoring and Reporting Guidance.

Final expected Spring 2008.Final expected Spring 2008.

Available at: Available at: http://www.epa.gov/safewater/lcrmr/compliancehelp.htmlhttp://www.epa.gov/safewater/lcrmr/compliancehelp.html

On Training CD !

April 2008

Short-Term Revisions OverviewShort-Term Revisions Overview Compliance DatesCompliance Dates

180 days after promulgation (April 7, 2008) 180 days after promulgation (April 7, 2008) unless State has not adopted rule.unless State has not adopted rule.

Date applies to:Date applies to: EPA regions (WY, DC, Tribal).EPA regions (WY, DC, Tribal). States that incorporate by reference using Federal States that incorporate by reference using Federal

publication date (e.g., MN)publication date (e.g., MN)

Otherwise, earlier of:Otherwise, earlier of: State’s adoption of rule after April 7, 2008.State’s adoption of rule after April 7, 2008. December 10, 2009.December 10, 2009.

Lead and Copper Short Term Lead and Copper Short Term Revisions and ClarificationsRevisions and Clarifications

Regulatory Changes Regulatory Changes

Monitoring RevisionsMonitoring Revisions

In 62-550.800 F.A.C. The Term “State” shall mean “Department”

April 2008

STR Regulatory RevisionsSTR Regulatory RevisionsMonitoring RevisionsMonitoring Revisions

Three Areas Revised:Three Areas Revised:

Minimum number of samples required.Minimum number of samples required.

Monitoring and compliance period definitions.Monitoring and compliance period definitions.

Reduced monitoring criteria.Reduced monitoring criteria.

April 2008

STR Monitoring RevisionsSTR Monitoring RevisionsMinimum Number of Samples RequiredMinimum Number of Samples Required

Systems Affected

Systems with fewer than 5 taps for human consumption.Systems with fewer than 5 taps for human consumption.

Regulatory Revision

Collect multiple samples from same location on different Collect multiple samples from same location on different days to meet 5 sample minimum. days to meet 5 sample minimum.

States may allow 1 sample per tap for human consumption States may allow 1 sample per tap for human consumption if < 5 such taps.if < 5 such taps.

If < 5 samples, highest result is 90If < 5 samples, highest result is 90thth percentile level. percentile level.

April 2008

STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions (Changes)Compliance and Monitoring Period Definitions (Changes)

Systems Affected

Systems with ALE or qualifying for reduced monitoring. Systems with ALE or qualifying for reduced monitoring.

Rule Revisions

Provide monitoring and compliance period definitions. Provide monitoring and compliance period definitions.

Define ALE as date on which monitoring period ends.Define ALE as date on which monitoring period ends.

Clarify timing of actions following ALE.Clarify timing of actions following ALE.

Clarify timing of monitoring.Clarify timing of monitoring.

Clarify reduced Pb/Cu tap monitoring period is 4 months.Clarify reduced Pb/Cu tap monitoring period is 4 months.

Require reporting to State by October 10 for reduced lead Require reporting to State by October 10 for reduced lead and copper monitoring. and copper monitoring.

April 2008

STR Monitoring RevisionsSTR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions

(State Actions)(State Actions)

Clarifies timeframe for State actions triggered by ALE.Clarifies timeframe for State actions triggered by ALE.

State DecisionState Decision Months from monitoring Months from monitoring period end with ALEperiod end with ALE

Need for corrosion control study 12

Optimal CCT for medium systems (no study required)

18

Optimal CCT for small systems

(no study required)24

April 2008

STR Monitoring RevisionsSTR Monitoring Revisions Compliance and Monitoring Period DefinitionsCompliance and Monitoring Period Definitions

(System Actions)(System Actions)

Clarifies timeframe for system actions triggered by ALE.Clarifies timeframe for system actions triggered by ALE.

System ActionsSystem Actions From monitoring period From monitoring period end with ALEend with ALE

Public education (lead ALE only) 60 days*

CCT recommendation 6 months

Initial source water monitoring and SOWT recommendation

180 days

1st year of LSLR (lead ALE only) 1 day**

Materials evaluation w/ initial LSL number 12 months**

Provide documentation that LSLR requirements were met

12 months** and every 12 months thereafter.

*State may grant extension in writing.

**Corresponds to 1st monitoring period with lead ALE after treatment.

April 2008


(Three-Year Compliance Period)(Three-Year Compliance Period)

Triennial monitoring must occur once every 3-year compliance period.Triennial monitoring must occur once every 3-year compliance period. Monitoring period is June – Sept. of same calendar year.Monitoring period is June – Sept. of same calendar year. Cannot exceed 3 years between sampling events (see example).Cannot exceed 3 years between sampling events (see example).

2009 2010 2011

June–SeptemberMonitoring period

2012 2013 2014


Three-year compliance period Three-year compliance period

April 2008


(Nine-Year Compliance Period)(Nine-Year Compliance Period)

Nine-year monitoring must occur once every nine-year compliance period.Nine-year monitoring must occur once every nine-year compliance period. Monitoring period is June through September of same calendar year.Monitoring period is June through September of same calendar year. Cannot exceed nine years between sampling events (see example).Cannot exceed nine years between sampling events (see example).


2001 2002 2003 2004 2005 20072006 2008 2009 2010 2011 2012 2013 2014 20162015 2017 2018

1st 9-year compliance period 2nd 9-year compliance period


April 2008

STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions

(Other Monitoring Clarifications)(Other Monitoring Clarifications)

The STR clarify that: The STR clarify that:

Annual reduced lead and copper tap monitoring Annual reduced lead and copper tap monitoring starts in CY after 2starts in CY after 2ndnd 6-month period. 6-month period.

11stst annual source period begins during CY State sets annual source period begins during CY State sets MPLs or determines SOWT not needed.MPLs or determines SOWT not needed.

If 2If 2ndnd 6-month is: 6-month is: Annual Monitoring BeginsAnnual Monitoring Begins

January – JuneJune 1 of next CY

July - December

April 2008

STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions

(Other Monitoring Clarifications – cont.)(Other Monitoring Clarifications – cont.)

The STR clarify WQP begin dates:The STR clarify WQP begin dates:

After State sets OWQPs begins:After State sets OWQPs begins:

Jan 1 or July 1 for PWSs on standard monitoring. Jan 1 or July 1 for PWSs on standard monitoring. June 1 for small/medium on reduced monitoring.*June 1 for small/medium on reduced monitoring.*

Annual WQP monitoring begins during CY after end of the Annual WQP monitoring begins during CY after end of the 33rdrd consecutive year of 6-month periods of meeting consecutive year of 6-month periods of meeting OWQPs. OWQPs.

Triennial monitoring begins no later than 3 years after 3Triennial monitoring begins no later than 3 years after 3rdrd consecutive year of meeting OWQPs.consecutive year of meeting OWQPs. * 6-month OWQP compliance period will be June 1 – November 30.

April 2008

STR Monitoring RevisionsSTR Monitoring RevisionsCriteria for Reduced MonitoringCriteria for Reduced Monitoring

Systems Affected

Systems qualifying for reduced monitoring based on Systems qualifying for reduced monitoring based on OWQPs (primarily > 50,000).OWQPs (primarily > 50,000).

Rule Revision

Cannot qualify for or remain on reduced monitoring if Cannot qualify for or remain on reduced monitoring if exceed lead AL.exceed lead AL.

Previously, could qualify based on meeting OWQPs. Previously, could qualify based on meeting OWQPs.

Clarifies standard monitoring resumes Jan. 1 of CY Clarifies standard monitoring resumes Jan. 1 of CY following lead ALE or OWQP excursion.following lead ALE or OWQP excursion.


Regulatory ChangesRegulatory Changes

Requirements to Inform the PublicRequirements to Inform the Public

April 2008

STR Regulatory Revisions STR Regulatory Revisions Requirements to Inform the PublicRequirements to Inform the Public

Three New or Revised Requirements:

Consumer Notification of Lead Tap Water Consumer Notification of Lead Tap Water Results.Results.

Consumer Confidence Report Lead Informational Consumer Confidence Report Lead Informational Statement. Statement.

Public Education following Lead ALE.Public Education following Lead ALE.

April 2008

STR Public InformationSTR Public InformationLead Consumer NoticeLead Consumer Notice

Systems AffectedSystems Affected

All CWSs and NTNCWSs.All CWSs and NTNCWSs.

Rule RevisionRule Revision

Provide notice of Provide notice of leadlead tap water monitoring results. tap water monitoring results.

Provide irrespective of whether sample exceeds lead AL. Provide irrespective of whether sample exceeds lead AL.

Provide to all served by sampling site -- not just ones with Provide to all served by sampling site -- not just ones with water bills.water bills.

Provide as soon as practical but within 30 days after Provide as soon as practical but within 30 days after receives results. receives results.

Provide by mail or other State-approved methods. Provide by mail or other State-approved methods.

On Training CD !

April 2008

STR Public InformationSTR Public InformationLead Consumer Notice (cont.)Lead Consumer Notice (cont.)

Notice must include:Notice must include:

Results of lead tap water monitoring.Results of lead tap water monitoring.

Explanation of lead health effects.Explanation of lead health effects.

Steps consumers can take to reduce exposure.Steps consumers can take to reduce exposure.

Facility contact information.Facility contact information.

MCLG and AL for lead and their definitions.MCLG and AL for lead and their definitions.**

* Must use CCR Rule language.* Must use CCR Rule language.

April 2008


Within 3 months after monitoring Within 3 months after monitoring period end, send State:period end, send State:

Sample of lead consumer notice, andSample of lead consumer notice, and

Certification that notification meets delivery Certification that notification meets delivery requirements.requirements.

Sample certification available in revised M/R Sample certification available in revised M/R

and State implementationand State implementation guidances.*guidances.*

* * http://www.epa.gov/safewater/lcrmr/compliancehelp.html

On Training CD !

April 2008


New consumer notice M/R violation.New consumer notice M/R violation.

Brings number of violations types to 11.Brings number of violations types to 11.

Separate violation from public education. Separate violation from public education.

Begin date = 3 months and 1 day after monitoring period end. Begin date = 3 months and 1 day after monitoring period end.

End date = End date = defaulted by SDWIS/ODS to 12/31/2025.defaulted by SDWIS/ODS to 12/31/2025.

Lead Consumer Notification Violation

Violation Type Code

Contaminant Code

Violation Name

Definition

66 5000 Lead Consumer Notice

Failure to meet any of the following:• Provide notice of lead results to individuals served by taps used for

lead and copper tap monitoring in accordance with §141.85(d)(1);• Meet the timing requirements for providing the notice in accordance

with §141.85(d)(2);• Meet the content requirements in §141.85(d)(3);• Meet the delivery requirements in §141.85(d)(4); and• Meet the State reporting requirements in §141.90(f)(3).

April 2008

STR RevisionsSTR RevisionsLead Consumer Notice (cont.) Lead Consumer Notice (cont.)

ExampleExample

System must provide: System must provide:

Consumer notice by 8/14/2009 (30 days after learns results).

Sample notice/certification to State by 12/31/2009 (3 mos after monitoring period end).

System actually provides:System actually provides:

Notice on 1/10/2010.

Certification on 4/01/2010.

State reports:State reports:

One 66 violation on 2/15/2010.

Begin date = 1/1/2010 (3 mos and 1 day after monitoring period end).

End date = 12/31/2025*

Compliance achieved = 4/01/2010

PWS monitors June – Sept 2009. Receives results on 7/15/09. All results are < 15 ppb.

* SDWIS/ODS defaults to 12/31/2025. State reports end date when system returns to compliance

April 2008

STR Public InformationSTR Public InformationConsumer Confidence Report RequirementConsumer Confidence Report Requirement

Systems Affected

All CWSsAll CWSs

Rule Revision

All CCRs must include:All CCRs must include: Sources of lead in drinking water. Sources of lead in drinking water. Health effects from lead exposure. Health effects from lead exposure. Ways to reduce lead in drinking water.Ways to reduce lead in drinking water. Recommended flushing times.Recommended flushing times. Places to go for more information including lead testing. Places to go for more information including lead testing.

Required regardless of lead sample levels.Required regardless of lead sample levels.

Some PWSs must include in 2008 CCR (due July 1, 2009).Some PWSs must include in 2008 CCR (due July 1, 2009).

April 2008

STR Public InformationSTR Public InformationConsumer Confidence Report Requirement (cont.)Consumer Confidence Report Requirement (cont.)

Must include following mandatory language, orMust include following mandatory language, or

Write own statement in consultation with State.Write own statement in consultation with State.

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 30 seconds to 2 minutes 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 http://www.epa.gov/safewater/lead.

On Training CD !

April 2008

STR Public InformationSTR Public InformationPublic Education RequirementsPublic Education Requirements

Systems Affected All systems exceeding lead AL. All systems exceeding lead AL.

Rule RevisionShortened mandatory language consisting of:Shortened mandatory language consisting of:

Opening statement, Opening statement, New health effects language provide greater specificity on lead New health effects language provide greater specificity on lead

health effects, and health effects, and Sources of further information.Sources of further information.

Flushing recommendations can be tailored.Flushing recommendations can be tailored.Unless waived, State must review and approve materials.Unless waived, State must review and approve materials.Additional delivery requirements to target sensitive Additional delivery requirements to target sensitive populations.populations.

April 2008

STR Public InformationSTR Public InformationPublic Education – Content RequirementsPublic Education – Content Requirements

Required content for CWSs & NTNCWSs:Required content for CWSs & NTNCWSs: Information Statement Information Statement ** Health Effects of Lead Health Effects of Lead ** Sources of LeadSources of Lead Steps to Reduce Exposure Steps to Reduce Exposure What Happened? What is Being Done?What Happened? What is Being Done? For More Information For More Information **

Information must be in appropriate languages.Information must be in appropriate languages.

* Must use STR mandatory language.* Must use STR mandatory language.

On Training CD !

April 2008

STR Public InformationSTR Public InformationPublic Education – Content Requirements (cont.)Public Education – Content Requirements (cont.)

Required content for CWSs only:Required content for CWSs only: Tell consumers how to get their water tested. Tell consumers how to get their water tested.

Discuss lead in plumbing components and Discuss lead in plumbing components and difference between low lead and lead free.difference between low lead and lead free.

““Special CWSs” can ask to forego Special CWSs” can ask to forego these requirements.these requirements.

April 2008

STR Public InformationSTR Public InformationPublic Education – CWS Delivery RequirementsPublic Education – CWS Delivery Requirements

Printed materials (pamphlets, brochures, posters) Printed materials (pamphlets, brochures, posters) to all bill paying customers. to all bill paying customers.

Materials to:Materials to:Local public health agenciesLocal public health agenciesPublic and private schools or school boardsPublic and private schools or school boardsWomen Infants and Children (WIC) and Head Start Women Infants and Children (WIC) and Head Start

programsprogramsPublic and private hospitals and medical clinicsPublic and private hospitals and medical clinicsPediatriciansPediatriciansFamily planning clinicFamily planning clinicLocal welfare agencies.Local welfare agencies.

April 2008

STR Public InformationSTR Public InformationPublic Education – CWS Delivery Requirements (cont.)Public Education – CWS Delivery Requirements (cont.)

Contact local health departments by phone/in-Contact local health departments by phone/in-person.person.

Must make Must make good faith effortgood faith effort to locate and deliver to locate and deliver materials to following organizations in service materials to following organizations in service area: area: Licensed child care centers.Licensed child care centers. Public and private preschools.Public and private preschools. Obstetricians-gynecologists and midwives.Obstetricians-gynecologists and midwives.

Submit press release to newspaper, TV, Submit press release to newspaper, TV, and radio stations.and radio stations.

Small system can limit activities.Small system can limit activities.

April 2008


At least quarterly provide information on water bill.At least quarterly provide information on water bill.

Water bill must include following statement:Water bill must include following statement:

Systems serving > 100,000 must post Systems serving > 100,000 must post material on web site.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].

April 2008

CWSs must conduct additional outreach activities from list.CWSs must conduct additional outreach activities from list.

CWSs serving > 3,300 conduct 3 or more. CWSs serving > 3,300 conduct 3 or more.

CWSs serving 3,300 or fewer conduct at least 1.CWSs serving 3,300 or fewer conduct at least 1.


Public service announcement (PSA)Paid advertisementDisplay information in public areasEmail to customersPublic meetingsDelivery to every householdProvide materials directly to multi-family

homesOther methods approved by State

April 2008

STR Public InformationSTR Public InformationPublic Education – CWS Timing RequirementsPublic Education – CWS Timing Requirements

Continue as long as ALE persists:Continue as long as ALE persists:Repeat water bill mandatory language at least quarterly.Repeat water bill mandatory language at least quarterly.

Repeat press releases twice every 12 months.Repeat press releases twice every 12 months.

Maintain materials on website (> 100,000 only).Maintain materials on website (> 100,000 only).

Repeat other materials/activities every 12 months.Repeat other materials/activities every 12 months.

* From end of monitoring period with lead ALE.* From end of monitoring period with lead ALE.

Delivery within 60 days:*Delivery within 60 days:*Applies if not already subject to public Applies if not already subject to public education.education.

State may grant extension.State may grant extension.

• Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.

April 2008

STR Public InformationSTR Public InformationPublic Education – NTNCWS Delivery RequirementsPublic Education – NTNCWS Delivery Requirements

STR does not change NTNCWS delivery STR does not change NTNCWS delivery requirements: requirements: Distribute pamphlet/brochures to each person served. Distribute pamphlet/brochures to each person served. Post informational posters in public places/common areas Post informational posters in public places/common areas

in each building served.in each building served.

““Special CWSs” may still use NTNCWSSpecial CWSs” may still use NTNCWS delivery methods.delivery methods.

April 2008

STR Public InformationSTR Public InformationPublic Education – NTNCWS Timing RequirementsPublic Education – NTNCWS Timing Requirements

* From end of monitoring period with lead ALE.* From end of monitoring period with lead ALE.

Delivery within 60 days:*Delivery within 60 days:* Applies if not already subject to Applies if not already subject to

public education.public education. State may grant extension.State may grant extension.

Continue every 12 months as long Continue every 12 months as long as ALE persists.as ALE persists.

• Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.


Regulatory ChangesRegulatory Changes

Notification of Treatment Changes Notification of Treatment Changes and Source Additionsand Source Additions

April 2008

STR RevisionsSTR RevisionsLong-Term Treatment Changes and New Source AdditionsLong-Term Treatment Changes and New Source Additions

Systems AffectedSystems AffectedSystems on reduced Pb/Cu tap monitoring.Systems on reduced Pb/Cu tap monitoring.

Rule RevisionRule RevisionRequires prior notification and approval of Requires prior notification and approval of treatment change or source addition.treatment change or source addition.

Limits notification of treatment changes to “long-Limits notification of treatment changes to “long-term changes.”term changes.”

Notification due as specified by State, or early as Notification due as specified by State, or early as possible prior to change or addition.possible prior to change or addition.

April 2008

STR RevisionsSTR RevisionsLong-Term Treatment Changes and New Source Additions Long-Term Treatment Changes and New Source Additions

(cont.)(cont.)

Examples of long-term treatment changes:Examples of long-term treatment changes: Switching secondary disinfectants. Switching secondary disinfectants.

Switching coagulants. Switching coagulants.

Switching corrosion inhibitor products.Switching corrosion inhibitor products.

Changing dosage of existing chemicals.Changing dosage of existing chemicals.

Installation of membrane filters, ozonation, enhanced Installation of membrane filters, ozonation, enhanced coagulation/softening.coagulation/softening.

Does NOT include chemical dose fluctuations Does NOT include chemical dose fluctuations associated with daily raw water quality changes.associated with daily raw water quality changes.

April 2008


(cont.)(cont.)

Examples of source water additions include: Examples of source water additions include:

Switching source types.Switching source types.

Adding treated surface water to ground water only Adding treated surface water to ground water only system.system.

Adding new well from different aquifer.Adding new well from different aquifer.

Seasonal or interannual source changes DO NOT Seasonal or interannual source changes DO NOT require notification if:require notification if:

Covered by previous OCCT studies and sampling, Covered by previous OCCT studies and sampling, andand

Covered within OCCT designation framework.Covered within OCCT designation framework.

April 2008


(cont.)(cont.)

Simultaneous Compliance Guidance Manual -- LT2 and Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP RulesStage 2 DBP Rules

Format differs from 1999 manual.Format differs from 1999 manual.

Treatment change chapters.Treatment change chapters.

Improving or optimizing existing treatment.Improving or optimizing existing treatment.

Addition of new carbon or microbial removal technology.Addition of new carbon or microbial removal technology.

Alternate disinfection strategies.Alternate disinfection strategies.

Available at: http://www.epa.gov/ogwdw/disinfection/stage2/compliance.html

April 2008


(cont.)(cont.)

Simultaneous Compliance Guidance Manual -- LT2 Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP Rulesand Stage 2 DBP Rules

Identifies treatment interactions and impact on key WQPs.Identifies treatment interactions and impact on key WQPs.

Discusses operational considerations for treatment Discusses operational considerations for treatment modifications.modifications.

Provides tools to gather information.Provides tools to gather information.

Is not cookbook -- won’t provide step-by-step Is not cookbook -- won’t provide step-by-step procedure to optimal “right” treatment.procedure to optimal “right” treatment.

Provides information to assess situation and consider Provides information to assess situation and consider options.options.

Provides tools for monitoring after change. Provides tools for monitoring after change.

LCR STRLCR STR

Reevaluation of Tested-Out Reevaluation of Tested-Out Lead Service LinesLead Service Lines

April 2008

STR RevisionsSTR RevisionsReevaluation of Tested-Out Lead Service LinesReevaluation of Tested-Out Lead Service Lines

Systems AffectedSystems Affected

Systems subject to lead service line replacement. Systems subject to lead service line replacement.

Rule RevisionsRule Revisions

Must re-evaluate LSLs that tested Must re-evaluate LSLs that tested << 15 ppb if re-exceed 15 ppb if re-exceed lead AL (“replaced through testing”). lead AL (“replaced through testing”).

Must add to inventory of LSLs to be replaced.Must add to inventory of LSLs to be replaced.

Previous sample may no longer be representative.Previous sample may no longer be representative.

Can either re-test line or replace line. Can either re-test line or replace line.

Must consider “tested-out” line each time re-exceed.Must consider “tested-out” line each time re-exceed.

April 2008

STR RevisionsSTR RevisionsReevaluation of Tested-Out Lead Service Lines Reevaluation of Tested-Out Lead Service Lines

ExampleExample

2 years of replacement completed prior to resuming LSLR.2 years of replacement completed prior to resuming LSLR.

7 of the 50 LSLs were “replaced through testing.’’ 7 of the 50 LSLs were “replaced through testing.’’

15-year LSLR program.15-year LSLR program.

Still has 50 LSLs in inventory because must include those Still has 50 LSLs in inventory because must include those lines previously considered replaced through testing. lines previously considered replaced through testing.

Must replace 50 lines over 13 years (because 2 years of the Must replace 50 lines over 13 years (because 2 years of the 15-year LSLR program has elapsed) = about 4 lines per 15-year LSLR program has elapsed) = about 4 lines per year. year.

Any retested or newly tested lines Any retested or newly tested lines << 15 ppb are considered 15 ppb are considered replaced through testing. replaced through testing.

Questions?Questions?

april 2008 lead and copper rule: short-term revisions and clarifications

Documents

lead solder

organized lead

lead pipes andor

copper rule review of

copper pipes

lead action level

conduct periodic lead

mgl copper