HDR’s safe DRinking WateR act neWsletteRSDWA

A Publication of HDR

INSI

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summer 2012

CaChe la Poudre river | Greeley, Co

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The EPA Redefinition of “Lead Free”: What Does it Mean?

EPA Seeks Advice from the Science Advisory Board on Perchlorate

UCMR3 Finalized: Sampling in 2013-2015

Drought and Fire

[2] SDWA Newsletter | HDR

DRougHt AND fiRe

the SDWA Newsletter generally provides a very short summary of drought and fire conditions across the country. But because this summer has become a season of widespread drought, and fire impacts have been significant in some areas, we thought more information about the drought and fire conditions would be of interest.

DroughtDrought conditions have expanded rapidly this summer, with well above-normal temperatures through the Central and Northern states that have exceeded 100 degrees from Colorado to South Dakota and Kansas to indiana. Heavy rains in southeast texas provided some relief in that area, but the typical monsoon rains across the West have been too little to overcome the accumulated deficit.

Crop conditions in the central Plains are deteriorating as reports indicate 38 percent of the nation’s corn crop is in poor to very poor condition, an all-time high for 1995-2012 records. in addition, 54 percent of the nation’s pasture and rangeland was in poor to very poor condition.

Drought and Fire By Sarah Clark, P.E.Sarah.Clark@hdrinc.com

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U.S. Drought Monitor August 14, 2012Valid 7 a.m. EDT

The Drought Monitor focuses on broad-scale conditions.Local conditions may vary. See accompanying text summaryfor forecast statements. Released Thursday, August 16, 2012

Author: Michael Brewer/Liz Love-Brotak, NOAA/NESDIS/NCDC

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Intensity:D0 Abnormally DryD1 Drought - ModerateD2 Drought - SevereD3 Drought - ExtremeD4 Drought - Exceptional

http://droughtmonitor.unl.edu/

Drought Impact Types:

S = Short-Term, typically <6 months(e.g. agriculture, grasslands)

L = Long-Term, typically >6 months(e.g. hydrology, ecology)

Delineates dominant impacts

Streamflows are in the lower tenth percentile of record or at record lows across much of the Midwest and parts of the central Plains, West, Southeast and even

in parts of New england.

Looking ahead, the prediction is for continued dry weather, with a few monsoon showers in the Southwest and across the northern tier of states.

temperatures for much of the country east of the Rockies will remain above normal – as much as 10 to 15 degrees above normal from the central Plains to the great Lakes. Drought is predicted to persist in the Plains and Midwest through october.

Mandatory water utility drought conservation measures have been initiated in some areas.

High Park fire courtesy of Scott Foreman, City of Fort Collins, Colo.

[3]www.hdrinc.com

DRougHt AND fiRe

Wild Firein conjunction with the hot, dry weather, we have had a season of severe wild fires. the country has experienced two dozen large wild fires this season (greater than 30,000 acres), with five of those fires burning more than 50,000 acres and seven of them larger than 100,000 acres.

for those utilities whose watersheds have burned this year, the prospect of having to treat water that comes from a fire-impacted watershed is difficult. even small rain events can wash out significant sediment and ash because the surface soil properties are altered by heat, a condition known as “soil paving.”

When the loose materials are washed into the water, the turbidity can rise to very high levels and the dissolved fractions of total organic carbon (toC), metals, nutrients and alkalinity drastically increase. treating this water to meet drinking water standards, even with a robust conventional treatment plant, is not realistic.

Preliminary water quality data has just been released from a united States geological Survey study of the fourmile Canyon fire area, which burned 10 square miles in Colorado’s Boulder County in 2010. Sampling sites upstream and within the fire-impacted area were analyzed weekly or more often throughout 2010 and 2011.

Results show that burned areas are prone to flash floods under normal thunderstorm rainfall events. the first rainfall event after the fire in September 2010, a low intensity storm producing relatively little precipitation, increased the dissolved organic carbon (DoC) concentration in fourmile Creek from 1.5 mg/L to 17 mg/L.

Nearly a year after the fire, summer thunderstorms increased the DoC to greater than 70 mg/L, nitrate to 9 mg/L and turbidity to 50,000 Ntu. More information and results from the study can be found at: http://pubs.usgs.gov/fs/2012/3095/ .

Water utilities in Colorado in the area of the High Park fire, which burned the Cache la Poudre River watershed, are negotiating for alternative water rights on water from other watersheds in order to avoid having to use any of the Poudre River water.

After the few monsoon rains that have fallen this summer on that watershed, the water in the river has been completely black. With river intakes that bring water directly to water plants without attenuation in a large reservoir, the utilities on the Poudre River are highly stressed. See our cover photo of the Poudre River.

the best source for details on current active fires is the incident information System at http://inciweb.org/ . Currently there are approximately 190 fires listed, with about half of them still active. the current u.S. forest Service (uSfS) large incident map is shown above.

fire maps can be found at http://activefiremaps.fs.fed.us/ . the summary from the forest Service as of July 23, 2012, indicated 234 new fires, with 11 new large fires and 32 large fires currently uncontained. v

Cache la Poudre River water after normal afternoon rainfall. Courtesy of John McCutchan, City of Greeley, Colo.

[4] SDWA Newsletter | HDR

ReguLAtioNS

Monitoring samples are collected at the entry point to the distribution system (ePtDS), and, for a few analytes, at the distribution system maximum residence time (DSMRt). Representative sampling locations for ground water systems with multiple wells may be established with prior approval. the selected well must be representative of the highest producing and most consistently active well.

Similarly, if a system has multiple connections from the same wholesaler, a selected entry point may be representative. for the purposes of the uCMR3, the DSMRt is defined as an active distribution system location where water has been in the system the longest relative to the ePtDS. Systems that must meet the Stage 2 Disinfection Byproduct Rule should use their total trihalomethane highest concentration sampling site as the DSMRt sampling site.

Monitoring frequency is determined by source water type. Surface water systems or ground water under the direct influence of surface water must sample quarterly within a 12-month period. ground water sources must sample twice (5–7 months apart) within 12 months.

Data collected through the uCMR process is stored in NCoD – the National Drinking Water Contaminant occurrence Database – and is used to review contaminant occurrence and support regulatory determination decisions made by the ePA (whether or not to regulate a particular contaminant). the ePA estimates that the total cost of uCMR3 is approximately $87 million. v

in 1996, the Safe Drinking Water Act Amendments mandated that the united States environmental Protection Agency (ePA) issue a new list of unregulated contaminants every five years for monitoring in drinking water supplies.

the third unregulated Contaminant Monitoring Rule (uCMR3) was published in May 2012, listing the unregulated contaminants that will be monitored by utilities between 2013 and 2015. the monitoring list is divided into three parts:• Assessment Monitoring, composed of the List

1 contaminants plus total chromium, will be monitored by all systems serving more than 10,000 and 800 systems serving fewer than 10,000.

• Screening Survey, composed of the List 2 contaminants, will be monitored by all systems serving more than 100,000; 320 systems serving 10,001 to 100,000; and 480 systems serving 10,000 or fewer

• Pre-Screen testing, composed of the List 3 contaminants plus indicator organisms (total coliforms, e. coli, bacteriophage, enterococci and aerobic spores), will be monitored by 800 non-disinfecting ground water systems in vulnerable areas serving 1,000 or fewer. included in this group of systems are community, non-transient, non-community water systems and transient systems.

the ePA will pay for sample kit preparation, sample shipping and analysis for small systems (systems fewer than 10,000) and no small system will be required to monitor for more than one list. Large systems will pay for shipping and analysis for the List 1 and applicable List 2 contaminants.

A change from previous uCMR rules is that consecutive systems are required to sample under uCMR3, because the basis for determining monitoring status is retail population served. Systems that purchase 100 percent of their water and serve more than 10,000 people are subject to the rule. Wholesalers that serve a retail population of 10,000 or fewer are only required to monitor if they are selected as part of the national sample of small systems.

UCMR3 Finalized: Sampling in 2013-2015 By Sarah Clark, P.E.Sarah.Clark@hdrinc.com

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ReguLAtioNS

List 1: Assessment Monitoring Chemical Contaminants

Contaminant Minimum Reporting Level Sampling Location Method

1,2,3-trichloropropane 0.03 ug/L ePtDS

ePA 524.3 (gC/MS)

1,3-butadiene 0.1 ug/L ePtDS

chloromethane 0.2 ug/L ePtDS

1,1-dichloroethane 0.03 ug/L ePtDS

bromomethane 0.2 ug/L ePtDS

chlorodifluoromethane (HCfC-22) 0.08 ug/L ePtDS

bromochloromethane (Halon 1011) 0.06 ug/L ePtDS

1,4-dioxane 0.07 ug/L ePtDS ePA 522 (gC/MS)

vanadium 0.7 ug/L ePtDS and DSMRt

ePA 200.8, AStM D5673-10,

SM3125

molybdenum 0.03 ug/L ePtDS and DSMRt

cobalt 1 ug/L ePtDS and DSMRt

strontium 0.3 ug/L ePtDS and DSMRt

chromium-6 0.03 ug/L ePtDS and DSMRt ePA 218.7

chlorate 20 ug/L ePtDS and DSMRt ePA 300.1, AStM D6581-08, SM 4110D

perfluorooctanesulfonic acid (PfoS) 0.04 ug/L ePtDS

ePA 537

perfluorooctanoic acid (PfoA) 0.02 ug/L ePtDS

perfluorononanoic acid (PfNA) 0.02 ug/L ePtDS

perflluorohexanesulfonic acid (PfHxS) 0.03 ug/L ePtDS

perfluoroheptanoic acid (PfHpA 0.01 ug/L ePtDS

perfluorobutanesulfonic acid (PfBS) 0.09 ug/L ePtDS

List 2: Screening Survey

Contaminant Minimum Reporting Level Sampling Location Method

17-β-estradiol 0.0004 ug/L ePtDS

ePA 539

17-α-ethynylestradiol 0.0009 ug/L ePtDS

estriol 0.0008 ug/L ePtDS

equilin 0.004 ug/L ePtDS

estrone 0.002 ug/L ePtDS

testosterone 0.0001 ug/L ePtDS

4-androstene-3,17-dione 0.0003 ug/L ePtDS

(continued on back cover)

[6] SDWA Newsletter | HDR

ReguLAtoRy DeveLoPMeNt

Perchlorate has moved on and off the united States environmental Protection Agency (ePA) radar screen for regulation with the preliminary determination not to regulate perchlorate in 2008, followed by the final determination to regulate in 2011.

the ePA is now scheduled to propose a perchlorate rule in early 2013. As part of the regulatory development, the ePA has initiated a process for reviewing the science that informs the rulemaking.

A 15-member Science Advisory Board (SAB) committee met in July to provide advice to the agency on what levels to set both a maximum contaminant level goal (MCLg) and a maximum contaminant level (MCL) for perchlorate.

in particular, the SAB committee has been asked to review the analysis published by the ePA in

2009, which developed health reference levels for perchlorate for 14 different life stages, including infants and children.

the analysis used the reference dose (RfD) of 0.7 ug/kg/day and multiple life stage-specific body weights and exposure information (drinking water intake). the HRLs developed in this analysis ranged from 1 ug/L to 47 ug/L.

Specific questions to the SAB include use of the life stage approach in developing the MCLg, the use of current epidemiological and biomonitoring data, the use of physiologically-based pharmakokinetic (PBPK) analyses, and the totality of available health information on perchlorate.

the life stages of concern for perchlorate have been identified as pregnant women, fetuses, neonates, infants and young children. While significant thyroid perturbations in utero are known to cause neurological deficits in infants, this stage is considered at risk for thyroid hormone variability.

Since there currently is no data to directly link perchlorate to neurobehavioral effects in infants and children, the ePA is asking the SAB to comment on the use of the life stage factors in setting the perchlorate MCLg.

the PBPK analyses are model predictions for iodine uptake. the model was developed in 2009 by the ePA using data from a small group of healthy, iodine- sufficient adults, so there is some question about how it can be used to derive an MCLg that is protective of sensitive subpopulations. the SAB has been requested to comment on this.

Similarly, the SAB is being asked to comment on the use of current epidemiological studies and the total body of perchlorate research which show mixed findings around the health impacts of perchlorate. v

Additional information on the SAB process and the questions the SAB committee has been asked to answer regarding perchlorate can be found on the ePA website.

EPA Seeks Advice from the Science Advisory Board on Perchlorate By Sarah Clark, P.E.Sarah.Clark@hdrinc.com

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[7]www.hdrinc.com

LegiSLAtioN

in January 2011, Congress passed Public Law 111-380, which amends Section 1417 of the SDWA with a new definition of the term “lead free,” and stipulates that the provisions of Section 1417 pertaining to lead-bearing components of potable water systems be met with respect to this new definition by Jan. 1, 2014.

PL 111-380 states that “lead free” means:• Not containing more than 0.2 percent lead when

used with respect to solder and flux• Not more than a weighted average of 0.25 percent

lead when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings and fixtures

the second part of this definition, applying to pipes, fittings and fixtures, represents a substantial change from the previous definition of 8 percent lead, which has stood since the Safe Drinking Water Act was amended in 1986. Since then, the voluntary standard of NSf 61 has been accepted by most states for certification of “low lead” plumbing materials.

As NSf 61 has evolved, the term “low lead” has come to mean lower lead content than the old 8 percent definition. in 2008, the development of NSf 61 Annex g, in conjunction with NSf 372, established of 0.25 percent lead content certification and testing procedures to meet low lead requirements of laws in California and vermont.

the PL 111-380 redefinition to a level commensurate with Annex g may ultimately alleviate the terminological confusion between “lead free” and “low lead.” But implementation of the new definition has raised serious questions among water providers regarding procurement processes, inventory controls, and installation and maintenance practices that need clarification in advance of the 2014 deadline.

PL 111-380 does not include clarification regarding accepted standards to guide utility procurement of new lead free materials. While NSf 61 Annex g is an established standard that addresses a weighted

average 0.25 percent lead content, federal recognition of the existing standard has not yet been explicitly provided.

this leaves utilities hesitant to buy new lead free materials. it also leaves manufacturers without an approved manufacturing and testing standard (i.e., NSf 372).

in addition, utilities are likely to have an existing inventory of distribution system components that may or may not meet Annex g requirements. guidance for control of these inventories, including what will be usable after the deadline and what needs to be replaced, is needed for planning for the 2014 deadline.

inventory control must be coordinated with the availability of new materials, which depends on rapid changes that manufacturers will have to make to meet new requirements. understandably, the lack of explicit guidance is becoming an issue of greater urgency throughout the industry.

in addition to procurement issues, critical utility questions regarding installation and maintenance practices need to be addressed. Concern is increasing around such as including whether or not all lead-containing materials in the vicinity of a repair need replacement, or whether non-lead-free compliant parts that are not replaced may be returned to service after a repair. Such questions imply the need for new installation and construction specifications as utilities prepare for the deadline.

Revisions to the Long term Lead and Copper Rule expected in 2015 will address these issues, but the water industry needs immediate clarification. Amid urging from the American Water Works Association and other industry organizations to provide clarification, the united States environmental Protection Agency (ePA) is planning a stakeholder meeting to discuss implementation issues in August 2012. it is hoped that a letter of guidance from the ePA will be provided shortly thereafter. v

The EPA Redefinition of “Lead Free”: What Does it Mean? By Matt McFaddenMatthew.McFadden@hdrinc.com

PRSRT STDUS POSTAGE

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PERMIT NO. 963

8404 Indian Hills Drive | Omaha, NE 68114-4049www.hdrinc.com© 2012 HDR, Inc., all rights reservedSDWA

SDWA is offset printed on Utopia Two Xtra Green 100# Dull text, which is FSC-certified paper manufactured with electricity in the form of renewable energy (wind, hydro, and biogas) and includes a minimum of 30% post-consumer recovered fiber.

13th Edition SDWA Wall Chart Now Availablethe SDWA update wall chart, published in february 2011, is available from HDR’s website, www.hdrinc.com/SDWA . the poster-sized chart provides an easy-to-use reference to

all drinking water regulations, including a detailed listing of contaminants and maximum contaminant levels, health effects and monitoring requirements.

WaterscapesWaterscapes is another technical publication produced and distributed by HDR. it focuses on the latest innovations and technical issues facing the water and wastewater markets. you can view Waterscapes on our

website at: www.hdrinc.com/waterscapes . if you would like to join our Waterscapes mailing list, please send an e-mail to waterscapes@hdrinc.com.

Career Opportunitiesfor information on career opportunities at HDR, please visit www.hdrinc.com/careers .

SDWA EditorSarah Clark, P.e., is the editor of SDWA. Please contact her with any comments or questions regarding this publication at (303) 764-1560. to join, change an address or be removed from the SDWA mailing list, please send requests

to SDWA@hdrinc.com .

Drinking Water Operations Wall Chart Availablethe Drinking Water operations wall chart, published in May 2009, is available from HDR’s website, www.hdrinc.com/OpChart . this poster-sized chart is designed to assist

utility personnel with the operation and maintenance of their water systems. it includes a combination of reference tools and guidance information designed to improve system performance and achieve optimal water quality for both water treatment and distribution systems.

UCMR3 Finalized(continued from page 5)

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Front Cover Photo: Poudre River at low head dam for the Bellvue Water treatment Plant intake, City of greeley, Co.  Photo courtesy of John McCutchan, City of Greeley, Colo.

List 3: Pre-Screen Testing

Microbiological Contaminants

enteroviruses N/A ePtDS N/A

noroviruses N/A ePtDS N/A

Total Chromium Monitoring

total chromium 0.2 ug/L ePtDS and DSMRt ePA 200.8, AStM D5673-10, SM 3125