Plumbing Replacement Program

1
Plumbing Replacement Program

• A Non-Chemical Corrosion Control Treatment Option
• Presenter Russ Kazmierczak, DHS DWP,
  Springfield Office

2
Background

• The Plumbing Replacement Program for
  Non-Transient Non-Community Water Systems is an
  outcome of the Lead Contamination Control Act
  (LCCA) of 1988 and the Lead and Copper Rule (LCR)
  of 1991.
• The intent of the LCCA was to help schools served
  by a public water systems identify and reduce
  lead in drinking water.
• The 1991 LCR addressed lead and copper in all
  community water systems (CWS) and non-transient
  non-community (NTNC) water systems.
• Schools or other NTNC systems that own and
  operate their own public water system are subject
  to the LCR.

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Act/Rule HighlightsLCCA

• Identification of coolers that are not lead free.
• The repair or removal of water coolers with lead
  lined tanks
• A ban on the manufacture and sale of water
  coolers that are not lead free
• The identification and resolution of lead
  problems in schools drinking water.
• The authorization of additional funds for lead
  screening programs for children.
• Not federally enforceable, states have the option
  to enforce.

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Act/Rule HighlightsLCR

• Protects public health by minimizing lead (Pb)
  and copper (Cu) levels in drinking water,
  primarily by reducing water corrosivity.
• Establishes action level (AL) of 0.015 mg/L for
  Pb and 1.3 mg/L 90th percentile level of tap
  water samples.
• AL exceedance can trigger other requirements that
  include water quality parameter monitoring,
  corrosion control treatment (CCT), source water
  monitoring/public education, and lead service
  line replacement (LSLR).
• Monitoring not required at Schools or
  Non-Residential Buildings (NRBs), unless they
  have their own water supply.

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Issues with LCR

• LCR testing protocol used to identify system
  wide problems and not problems in single outlets
  (i.e. individual faucets and drinking water
  fountains).
• LCR rule requires water system to follow testing
  protocol different than the one used to evaluate
  fixtures in schools. Plumbing Replacement
  Program uses LCR sampling protocol.
• LCR primarily addresses Pb and Cu throughout the
  entire system using corrosion control treatment
  and does not address specific sources such as
  fixtures.

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Action Level Exceedance Compliance Requirements

• Public education (does not apply to Copper).
• Water quality parameter (WQP) monitoring.
• Source water monitoring and source water
  treatment.
• Corrosion Control Treatment (CCT) Chemical and
  Non-Chemical (Plumbing Replacement Program).

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CCT Evaluation

• Must submit a Letter of Recommendation to DWP,
  based on consultation with the County, on how
  system is to address AL exceedance.
• Chemical CCT Option- Recommendation based on the
  Guidance Manual for Selecting Pb/Cu Control
  Strategies document (see web site links handout).
• Non-Chemical CCT Option (Plumbing Replacement
  Program) Recommendation based on the 3Ts for
  Reducing Lead in Drinking Water in Schools
  (replaces the 1994 EPA guidance document Drinking
  Water in Schools and Non-Residential Buildings).

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Plumbing Replacement Program Guidance Procedure
Overview

• Develop Plumbing Profile.
• Develop a Sampling Plan and receive approval from
  County/DWP prior to implementing.
• Sample all reasonable sites using First Draw
  Sampling Procedure (see web page links for EPA
  guidance).
• You should include
• All fountains, coolers and bubblers readily
  accessible to students (particularly the youngest
  students).
• Other faucets or outlets regularly used to gather
  drinking or cooking water.
• At least one sample from each area used for food
  preparation.
• You do not need to include
• Faucets and outlets used for cleaning,
  maintenance or other non-consumptive uses.
• Lab, washroom, art room and shop outlets.
• Irrigation outlets.

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Guidance Procedure Overview(continued)

• Replace sites that exceed AL and try use
  Zero/Ultra Low Lead fixtures.
• Resample sites that continue to exceed, use
  Follow-Up Flush Sampling Protocol (see attached
  handout).

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Guidance Procedure Overview(continued)

• If fixture was replaced with low lead brass (8
  or less lead) and remains a problem, may need
  replacement with Zero/Ultra Low Lead fixture.
• After sampling and replacement complete, submit
  to County/DWP a written description of Plumbing
  Replacement Program (see attached Plumbing
  Replacement Program Procedure).

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Plumbing Replacement Program Misunderstandings

• Guidance documents referenced in the Plumbing
  Replacement Program Procedures were written for
  Schools or Non-Residential Buildings on a PWS.
  They are not guidance documents for compliance
  with the LCR.
• Sample collection procedures in guidance
  documents do not comply with the Pb and Cu LCR
  and if followed could result in invalidation of
  sample results.
• What is reasonable a sample site (see web page
  links handout)?

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Plumbing Replacement Program Highlights

• Developed by Oregon DWP staff and based on a
  common sense approach using the historic Lead
  Contamination Control Act (LCCA) and at the same
  time complies with the LCR.
• Non-Chemical Corrosion Treatment/Plumbing
  Replacement Program (LCCA) is specific to Oregon
  and is not referenced in the LCR or any of the
  guidance documents or fact sheets.
• Gives NTNC (schools and non-residential
  buildings) water systems an alternative to adding
  corrosion chemicals to their water supply and can
  potentially save the school money in labor and
  maintenance costs.

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Plumbing Replacement Program Highlights

• Schools and non-residential buildings receive the
  benefit of being able to eliminate the cause of
  the problem instead of treating the symptom.
• EPA recognizes Oregons Plumbing Replacement
  Program, as long water systems remain in
  compliance with the LCR rule.

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Questions?