Lead and Copper Program Changes

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Lead and Copper Program Changes

• Todd Ritter
• Kentucky Division of Water

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About the Lead and Copper Regulation

• Purpose of the regulation is to protect public
  health by minimizing lead and copper levels in
  drinking water
• Applies to all community and non-transient
  non-community water systems
• No maximum contaminant levels. Instead lead and
  copper have action level exceedances.

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Initial Monitoring

• Must sample for 2 consecutive 6 months at the
  maximum number of samples. Jan.-June and
  July-December monitoring periods.
• Population based monitoring.
• Monitoring must be sampled in the distribution
  system at approved lead/copper sites
• Approved lead/copper sites must have Tier and
  Tier type information.

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Population Information

• System Size No. of Samples
• gt100,000 100
• 10,001-100,000 60
• 3,301-10,000 40
• 501-3,300 20
• 101-500 10
• lt100 5

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Reduced Monitoring

• 1st stage of reduced monitoring requires 3
  consecutive years of monitoring, sampling half
  the initially required samples
• 2nd stage of reduced monitoring requires sampling
  every three years
• For reduced monitoring, all samples must be taken
  during June-September monitoring period.

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Pop. Info. Reduced Monitoring

• System Size No. of Samples
• gt100,000 50
• 10,001-100,000 30
• 3,301-10,000 20
• 501-3,300 10
• 101-500 5
• lt100 5

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Action level exceedances

• Lead action level - .015 mg/l
• Copper action level 1.3 mg/l
• To determine whether an action level has been
  exceeded, the value at the 90th percentile of all
  samples is compared against its respective
  action level.

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Calculating 90th percentiles

• For systems collecting more than 5 samples
• Place results in ascending order (low to high)
• Assign each sample a number, 1 for the lowest
  value
• Multiply the total number of samples by .9 (ex.
  20 samples x .9 18, so sample 18 will be your
  90th percentile)
• Compare 90th percentile to respective action
  level

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Calculating 90th percentiles

• For systems required to collect 5 samples
• Place results in ascending order.
• Take the average of the 4th and 5th highest
  sample. This is your 90th percentile.
• Compare 90th percentile against respective action
  level.

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Do I have an exceedance?

• EPAs policy is to
• Round down to the nearest whole number if your
  decimal is 0.4 or lower.
• Example 90th percentile of lead is .0153 mg/l,
  which means your result would be calculated as
  .015 mg/l which is not an exceedance.
• 2. Round up to the nearest whole number if your
  decimal is 0.5 or higher.
• Example 90th percentile of copper is 1.36 mg/l
  which would means your true result would be 1.4
  mg/l. This is an exceedance.

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Reporting Requirements

• Lead and copper results are not sent to DOW by
  the lab. Results should be signed by a water
  supply representative.
• 90th percentiles will now be calculated by the
  water system and sent with the results. The 90th
  percentiles are a required element for a systems
  Consumer Confidence Report (CCR). An Excel
  spreadsheet is available from the state for
  calculations. The public water system has always
  been responsible for these calculations per the
  regulation.
• The DOW is asking systems to send in lead and
  copper results as soon as they are received by
  the water system. This is due to the remedial
  measures required when a system has an action
  level exceedance. We recommend submittal no later
  than October 10th. Regulatory deadline is by
  January 10 the following year.

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Sample site information

• Community Systems
• Tier 1 sampling sites are single family
  structures with copper pipes with lead solder
  installed after 1982 and/or that are served by a
  lead service line.
• Tier 2 sampling consists of buildings,
  including multi-family residences with copper
  pipes with lead solder installed after 1982 or
  contain lead pipes and/or that are served by a
  lead service line.
• Tier 3 sampling sites are single family
  structures with copper pipes having lead solder
  installed before 1983.

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Sample Site Information

• Non-Transient Non-Community Systems
• Tier 1 sampling sites consist of buildings with
  copper pipes with lead solder installed after
  1982 or contain lead pipes and/or that are
  served by a lead service line.
• Tier 2 sampling sites consist of buildings with
  copper pipes with lead solder installed before
  1983.
• Tier 3 not applicable

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Sample site information

• Lead and copper sites must have Tier and Tier
  type information to be considered a true
  lead/copper site. Any site used as a lead/copper
  site that is missing that information will not be
  accepted.
• Letter sent out on January 18, 2006 asked that
  all water systems take a closer look at their
  lead/copper sample sites. Corrections or
  additional sites should be sent to my attention
  via mail, email or fax.

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Copper action level exceedance

• Submit the result of a copper test on source
  water
• Perform Water Quality Parameter testing on the
  plant tap and 3 sites in the distribution system.
• Submit an optimal corrosion control treatment
  recommendation
• Install source water treatment, if needed

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Lead action level exceedance

• Submit result of lead test on source water
• Within 60 days of the exceedance perform public
  education. Public Education templates are
  included with letter notifying system of the
  exceedance
• Perform Water Quality Parameter testing on the
  plant tap and 3 sites in the distribution system.
• Submit an optimal corrosion control treatment
  recommendation
• Install source water treatment, if needed
• Replace lead service lines

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Water Quality Parameters

• Who collects them?
• Systems with a population greater than 50,000
• Systems that have exceeded the lead or copper
  action level.
• The reasoning behind submitting lead and copper
  results is that in case of an exceedance, water
  quality parameters should be taken in the same
  monitoring period as the lead and copper results.

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Public Education requirementsPublic Education
Requirements

• Community Water Systems
• Insert notices in each customers water utility
  bill
• Deliver pamphlets/brochures to facilities that
  provide services for pregnant women or children
• Submit information to the editorial department of
  the major daily or weekly newspapers
• Deliver public service announcements to radio and
  television stations
• A community water system must repeat delivery
  every 6 months for public service announcements,
  and every 12 months for other forms of delivery,
  for as long as the system exceeds the lead action
  level.

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Public Education Requirements

• Non-transient non-community water systems
• Post informational posters in public places or in
  common areas of buildings served by the system
• Distribute informational pamphlets and or
  brochures to each person served by the system
• Must repeat this annually for as long as it
  exceeds the lead action level

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Treatment or Source changes

• Treatment or source changes must be pre-approved.
• If a system is on a reduced monitoring schedule
  and a new source is approved, the system will be
  returned to standard monitoring

21
Lead Service Line Replacement

• If treatment is not effective in reducing lead
  levels, systems with lead service lines must
  replace at least 7 percent of their lines
  annually
• The state can also require systems to begin lead
  service line replacement if they do not meet
  their deadline for installing corrosion control
  or source water treatment
• Systems can discontinue lead service if they are
  at or below the lead action level for 2
  consecutive monitoring periods.

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Necessary Info for location code

• Name
• Full Address
• Tier and Tier Type Information

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Things to Remember

• Tier 1 sites are the preferred lead/copper
• sites. If an insufficient number exist then
  Tier 2 followed by Tier 3
• If you have lead service lines in your
  distribution system , you should collect at least
  half of your samples from sites served by lead
  service lines
• You should identify more sampling sites than the
  number of samples you are required to collect.

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Continued

• If you do not have the required number of
  sampling sites, you may collect more than one
  sample from the same location, on different days
• Samples must be 1 liter in volume and taken from
  an interior tap where the water has stood in the
  pipes for at least 6 hours
• You should collect samples early enough in the
  monitoring period in case WQP are required

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Continued

• You must collect source water samples if you
  exceed lead and copper action levels
• If you serve 50,000 or fewer people, you can stop
  corrosion control treatment steps whenever your
  90th percentile lead and copper levels are at or
  below their action levels for 2 consecutive
  6-month monitoring periods. You must recommence
  these steps if you exceed either action level
  again,

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Questions?

• Contacting me
• Phone [phone] ext. 586
• Email todd.ritter_at_ky.gov
• Fax [phone]