Controlling Lead and
Copper in Drinking Water
Your name and contact info
Your name and contact info
Developed by RCAP/AWWA and funded by the USEPA
Acknowledgement:
• 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
Western RCAP
Rural Community
Assistance Corporation
(916) 447-2854
www.rcac.org
Rural Community
Assistance Partnership
Practical solutions for improving rural communities
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
RCAP National Office
1701 K St. NW, Suite 700
Washington, DC 20006
(800) 321-7227
www.rcap.org | [email protected]
Southeast RCAP
Southeast Rural Community
Assistance Project
(866) 928-3731
www.southeastrcap.org
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
4
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
5
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
6
Pre-test: Controlling Lead and Copper
in Drinking Water
• The pre-test will be handed out
7
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
Why address lead?
• 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.
Copper
• 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
Rules that impact lead
• 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)
Lead Regulations – In materials
• 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 – Standards and
monitoring requirements
• 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
LCR (1991)
• 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)
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
CWS or NTNCWS Collects Lead
and Copper Tap Samples
90th Percentile
Is at or Below
Both Action Levels*
Conduct
periodic lead
and copper tap
monitoring
*
90th Percentile
Exceeds the Lead
Action Level (15 μg/L)
Begin LSLR
replace 7%
of LSLs
per year
Conduct
public
education
due within 60
days
Begin CCT
steps includes
WQP
monitoring **
90th Percentile
Exceeds the Copper
Action Level (1.3 mg/L)
Conduct
source water
monitoring
(Install SOWT, if
needed)
Conduct
periodic lead
and copper tap
monitoring
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.
**
Activity- EPA Quick Reference
Guide
• 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.
Potential future standards
• NDWAC recommendation - Development of a
household action level
• Potentially lowering of the action level
• Requiring lead service line replacement
To calculate the
th
90
• Rank the samples according
to their lead or copper
concentrations
percentile:
Sample
#
Lead
(mg/L)
1
0.004
2
0.005
3
0.005
4
0.006
– 90% of all samples have a
lower concentration
5
0.006
6
0.006
7
0.009
– 10% of all samples have a
higher concentration
8
0.010
9
0.011
10
0.017
• Find the “sample” that:
Activity: Determining the 90th
Percentile
• Your instructor will distribute handouts for
this activity
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
Sources of Lead
• 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
Ownership of System Components
Forms of lead
There are two forms of lead:
• Dissolved lead
• Particulate lead
Factors that impact dissolved
lead concentrations
• 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 particulate
lead concentrations
Operations practices that can impact lead levels
• Physical disturbances
⁻ Repairing a main break
⁻ Meter repair
• Hydraulic changes
⁻ Flushing
⁻ Valve/ hydrant testing
Factors that can impact both
dissolved and particulate
concentrations
•
•
•
•
Change in source water
Changes in water chemistry
Change in pH
Change in chlorine residual levels
Discussion
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
Module Three:
Conducting an Inventory
Module Three Learning Objectives
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
Conducting an inventory
•
•
•
•
•
Installation records
Codes, regulations
Main renewal records
Observations during construction
Observation during meter
replacement
• Customer reporting
Ways to tell if pipe is lead
• Scratch test
– Grey or color like a
penny?
– Easy to scratch?
• Lead swabs
• Shape
• Magnet (will stick to
steel, not lead)
Question
Who has lead service lines?
• Have you conducted an inventory?
• What are the ages of homes in your
system?
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
Monitoring Requirements
• Sampling sites – with highest potential levels
• Frequency – Set by regulation – Reduced
monitoring possible
• Procedures – First-draw, try to observe the
highest concentrations
Site selection CWS
• 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
NTCNWS
• 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
Minimum number of sites
• 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 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
Monitoring schedules
• Standard monitoring:
– Conducted at 6-month intervals from JanuaryJune or July-December
• Reduced monitoring
– Can be annual, triennial, or 9-year monitoring
schedules.
• Must take sample for 4 consecutive months
• Time of normal operation when highest likely lead
levels
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
Issues and recent recommendations
• No water softeners or POU/POE
• Aerators – Leave on
• Use wide mouth sample bottles (encourages
higher flow rates)
• No pre-stagnant flushing
States may invalidate a sample if
•
•
•
•
Improper sample analysis
Site selection criteria not met
Sample container damaged
Sample subjected to tampering
It’s difficult to invalidate a sample
Other samples
• 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)
Activity - Monitoring
• Your instructor will distribute handouts for
this activity
Module Five: Treatment Requirements Optimal Corrosion Control Treatment
(OCCT)
Module Five Learning Objectives
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
Optimal corrosion control
treatment (OCCT)
• 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
Water Quality Parameter
Monitoring
• 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.
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.
Purpose of WQP monitoring
• To assist in determining water corrosivity
• To identify appropriate corrosion control
treatment
• To determine whether corrosion control
treatment is being properly maintained
Corrosion Control Treatment Steps
• Study/treatment
recommendation by
system
• State treatment
determination
• Treatment installation
• Follow-up Pb/Cu tap &
WQP monitoring
• State-specified operating
parameters
Determining The Best Corrosion
Control Treatment
• 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
Discussion
• Has anyone modified corrosion control
practices
Module Six:
Public Notification Requirements
Module Six Learning Objectives
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
Without an action level
exceedance
• Notify consumers of lead tap results
• Consumer Confidence Reports
Lead Consumer Notice
• 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
Consumers tips for reducing lead
exposure
•
•
•
•
Flushing – Stagnant water
Clean aerators
Get your water tested
Filters
Module Seven:
Lead Service Line Replacement
Module Seven Learning Objectives
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
Lead service lines – do they need
to be replaced
• Full replacement – From main to inside the
home
• Partial replacement – From the main to the
meter
• Disturbance on the main or service line
Case Against Partial
Replacement
Galvanic Series
Referenced to Copper-Copper
Sulfate
Metal
Volts
Magnesium
-1.6 to -1.75
Zinc
-1.10
Aluminum
-1.05
Carbon Steel
-0.5 to -0.8
Cast/Ductile Iron
-0.5
Lead
-0.5
Copper
-0.2
Carbon, Graphite
+0.3
Galvanic Corrosion from
partial replacement
Activity
• 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
Summary
• 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
You are not required, but
recommended to:
• Have a program to replace lead service lines
• Have a program to help customers monitor
their tap
• Sample schools and other public buildings
Resources
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
Post-test: Controlling Lead and
Copper in Drinking Water
• Post-test will be handed out
THANKS FOR ATTENDING!
YOUR NAME
CONTACT INFO