lead and copper rule: short-term revisions and clarifications jim moore vdh – office of drinking...
TRANSCRIPT
Lead and Copper Lead and Copper RuleRule
Short-Term Revisions Short-Term Revisions and Clarificationsand Clarifications
Jim MooreJim Moore
VDH ndash Office of Drinking WaterVDH ndash Office of Drinking Water
22
Training ObjectivesTraining Objectives
11 Present a brief history of EPA lead and Present a brief history of EPA lead and copper regulationscopper regulations
22 Summarize basic elements of the Summarize basic elements of the original LCR and LCRMRoriginal LCR and LCRMR
33 Summarize the changes and Summarize the changes and clarifications contained in the new Short clarifications contained in the new Short Term Revisions RuleTerm Revisions Rule
44 Present and discuss some lead and Present and discuss some lead and copper monitoring examples and copper monitoring examples and resulting required actionsresulting required actions
33
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR Clarifications (LCR
STR) is the fourth EPA Rule dealing with lead and copper in STR) is the fourth EPA Rule dealing with lead and copper in drinking waterdrinking water
bull The The Lead Contamination Control ActLead Contamination Control Act was promulgated in 1988 was promulgated in 1988
bull The original Lead and Copper Rule (LCR) was promulgated on The original Lead and Copper Rule (LCR) was promulgated on June 7 1991June 7 1991
bull The Lead and Copper Rule Minor Revisions (LCRMR) were The Lead and Copper Rule Minor Revisions (LCRMR) were promulgated on January 12 2000promulgated on January 12 2000
bull The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR STR) were promulgated on October 10 Clarifications (LCR STR) were promulgated on October 10 20072007
bull EPA is not done ndash work on a Lead and Copper Rule Long Term EPA is not done ndash work on a Lead and Copper Rule Long Term Revision is underwayRevision is underway
44
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
All of these LeadAll of these Leadand Copper Rulesand Copper Rulesapply to apply to bull CommunityCommunity
andandbull Non transient Non transient
non communitynon community waterworkswaterworks
55
Original LCR Original LCR OverviewOverview
bull First published on June 7 1991First published on June 7 1991bull Established MCLGs for lead and copperEstablished MCLGs for lead and copperbull Established Action Levels in lieu of MCLrsquosEstablished Action Levels in lieu of MCLrsquos
bull 9090thth percentile sample result is compared to AL percentile sample result is compared to ALbull ALE is a trigger and is ALE is a trigger and is not a violationnot a violationbull ALE requires waterworks to initiate various treatment ALE requires waterworks to initiate various treatment
techniques and additional monitoring activitiestechniques and additional monitoring activities
MCLGMCLG Action LevelAction Level
Lead 0 mgL 0015 mgLLead 0 mgL 0015 mgL
Copper 13 mgL 13 mgLCopper 13 mgL 13 mgL
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
22
Training ObjectivesTraining Objectives
11 Present a brief history of EPA lead and Present a brief history of EPA lead and copper regulationscopper regulations
22 Summarize basic elements of the Summarize basic elements of the original LCR and LCRMRoriginal LCR and LCRMR
33 Summarize the changes and Summarize the changes and clarifications contained in the new Short clarifications contained in the new Short Term Revisions RuleTerm Revisions Rule
44 Present and discuss some lead and Present and discuss some lead and copper monitoring examples and copper monitoring examples and resulting required actionsresulting required actions
33
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR Clarifications (LCR
STR) is the fourth EPA Rule dealing with lead and copper in STR) is the fourth EPA Rule dealing with lead and copper in drinking waterdrinking water
bull The The Lead Contamination Control ActLead Contamination Control Act was promulgated in 1988 was promulgated in 1988
bull The original Lead and Copper Rule (LCR) was promulgated on The original Lead and Copper Rule (LCR) was promulgated on June 7 1991June 7 1991
bull The Lead and Copper Rule Minor Revisions (LCRMR) were The Lead and Copper Rule Minor Revisions (LCRMR) were promulgated on January 12 2000promulgated on January 12 2000
bull The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR STR) were promulgated on October 10 Clarifications (LCR STR) were promulgated on October 10 20072007
bull EPA is not done ndash work on a Lead and Copper Rule Long Term EPA is not done ndash work on a Lead and Copper Rule Long Term Revision is underwayRevision is underway
44
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
All of these LeadAll of these Leadand Copper Rulesand Copper Rulesapply to apply to bull CommunityCommunity
andandbull Non transient Non transient
non communitynon community waterworkswaterworks
55
Original LCR Original LCR OverviewOverview
bull First published on June 7 1991First published on June 7 1991bull Established MCLGs for lead and copperEstablished MCLGs for lead and copperbull Established Action Levels in lieu of MCLrsquosEstablished Action Levels in lieu of MCLrsquos
bull 9090thth percentile sample result is compared to AL percentile sample result is compared to ALbull ALE is a trigger and is ALE is a trigger and is not a violationnot a violationbull ALE requires waterworks to initiate various treatment ALE requires waterworks to initiate various treatment
techniques and additional monitoring activitiestechniques and additional monitoring activities
MCLGMCLG Action LevelAction Level
Lead 0 mgL 0015 mgLLead 0 mgL 0015 mgL
Copper 13 mgL 13 mgLCopper 13 mgL 13 mgL
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
33
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR Clarifications (LCR
STR) is the fourth EPA Rule dealing with lead and copper in STR) is the fourth EPA Rule dealing with lead and copper in drinking waterdrinking water
bull The The Lead Contamination Control ActLead Contamination Control Act was promulgated in 1988 was promulgated in 1988
bull The original Lead and Copper Rule (LCR) was promulgated on The original Lead and Copper Rule (LCR) was promulgated on June 7 1991June 7 1991
bull The Lead and Copper Rule Minor Revisions (LCRMR) were The Lead and Copper Rule Minor Revisions (LCRMR) were promulgated on January 12 2000promulgated on January 12 2000
bull The Lead and Copper Rule Short Term Revisions and The Lead and Copper Rule Short Term Revisions and Clarifications (LCR STR) were promulgated on October 10 Clarifications (LCR STR) were promulgated on October 10 20072007
bull EPA is not done ndash work on a Lead and Copper Rule Long Term EPA is not done ndash work on a Lead and Copper Rule Long Term Revision is underwayRevision is underway
44
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
All of these LeadAll of these Leadand Copper Rulesand Copper Rulesapply to apply to bull CommunityCommunity
andandbull Non transient Non transient
non communitynon community waterworkswaterworks
55
Original LCR Original LCR OverviewOverview
bull First published on June 7 1991First published on June 7 1991bull Established MCLGs for lead and copperEstablished MCLGs for lead and copperbull Established Action Levels in lieu of MCLrsquosEstablished Action Levels in lieu of MCLrsquos
bull 9090thth percentile sample result is compared to AL percentile sample result is compared to ALbull ALE is a trigger and is ALE is a trigger and is not a violationnot a violationbull ALE requires waterworks to initiate various treatment ALE requires waterworks to initiate various treatment
techniques and additional monitoring activitiestechniques and additional monitoring activities
MCLGMCLG Action LevelAction Level
Lead 0 mgL 0015 mgLLead 0 mgL 0015 mgL
Copper 13 mgL 13 mgLCopper 13 mgL 13 mgL
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
44
LCR Short-Term RevisionsLCR Short-Term Revisions Rule Making HistoryRule Making History
All of these LeadAll of these Leadand Copper Rulesand Copper Rulesapply to apply to bull CommunityCommunity
andandbull Non transient Non transient
non communitynon community waterworkswaterworks
55
Original LCR Original LCR OverviewOverview
bull First published on June 7 1991First published on June 7 1991bull Established MCLGs for lead and copperEstablished MCLGs for lead and copperbull Established Action Levels in lieu of MCLrsquosEstablished Action Levels in lieu of MCLrsquos
bull 9090thth percentile sample result is compared to AL percentile sample result is compared to ALbull ALE is a trigger and is ALE is a trigger and is not a violationnot a violationbull ALE requires waterworks to initiate various treatment ALE requires waterworks to initiate various treatment
techniques and additional monitoring activitiestechniques and additional monitoring activities
MCLGMCLG Action LevelAction Level
Lead 0 mgL 0015 mgLLead 0 mgL 0015 mgL
Copper 13 mgL 13 mgLCopper 13 mgL 13 mgL
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
55
Original LCR Original LCR OverviewOverview
bull First published on June 7 1991First published on June 7 1991bull Established MCLGs for lead and copperEstablished MCLGs for lead and copperbull Established Action Levels in lieu of MCLrsquosEstablished Action Levels in lieu of MCLrsquos
bull 9090thth percentile sample result is compared to AL percentile sample result is compared to ALbull ALE is a trigger and is ALE is a trigger and is not a violationnot a violationbull ALE requires waterworks to initiate various treatment ALE requires waterworks to initiate various treatment
techniques and additional monitoring activitiestechniques and additional monitoring activities
MCLGMCLG Action LevelAction Level
Lead 0 mgL 0015 mgLLead 0 mgL 0015 mgL
Copper 13 mgL 13 mgLCopper 13 mgL 13 mgL
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
66
Lead and Copper RuleLead and Copper RuleOverviewOverview
90th Percentile Exceeds the Lead
Action Level (15 μgL)
90th Percentile Exceeds the Copper
Action Level (13 mgL)
90th Percentile Is at or Below
Both Action Levels
CWS or NTNCWS Collects Lead and Copper Tap Samples
Begin LSLR replacement
if LSL are present
Begin CCT steps
includes WQP
monitoring
Conduct periodic lead and
copper tap monitoring
Conduct public
education
Conduct source water
monitoring (Install
SOWT if needed)
Conduct periodic lead and
copper tap monitoring
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
77
Lead and Copper RuleLead and Copper Rule
Review of Lead and Copper Tap Review of Lead and Copper Tap Monitoring RequirementsMonitoring Requirements
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
88
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systems bull Prior to sampling each waterworks must submit a materials Prior to sampling each waterworks must submit a materials
surveysurveyand sample site selection justification and sample site selection justification
bull LCR requires that samples be collected from the LCR requires that samples be collected from the highest risk highest risk locationslocations
bull Three sampling site tiers Tier 1 Tier 2 and Tier 3Three sampling site tiers Tier 1 Tier 2 and Tier 3bull Tier 1 sample sites are considered high risk sitesTier 1 sample sites are considered high risk sitesbull Tier 1 sampling pool consists of single family structures Tier 1 sampling pool consists of single family structures
thatthatbull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between
1983 and 1986 (date of Virginiarsquos lead solder ban) or1983 and 1986 (date of Virginiarsquos lead solder ban) orbull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
99
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash Community SystemsSite Selection ndash Community Systemsbull Tier 2 sampling pool consists of buildings including multiple Tier 2 sampling pool consists of buildings including multiple
family residences thatfamily residences that
bull Contain copper pipes with lead solder installed between 1983 Contain copper pipes with lead solder installed between 1983 and 1986 (date of Virginiarsquos lead solder ban) orand 1986 (date of Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 3 sampling pool consists of single family structures that Tier 3 sampling pool consists of single family structures that
bull Contain copper pipes with lead solder installed before 1983Contain copper pipes with lead solder installed before 1983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1010
Review of Monitoring Review of Monitoring RequirementsRequirements
Site Selection ndash NTNC SystemsSite Selection ndash NTNC Systems
Two sampling site tiers Tier 1 and Tier 2Two sampling site tiers Tier 1 and Tier 2bull Tier 1 sampling pool consists of sample sites thatTier 1 sampling pool consists of sample sites that
bull Contain copper pipes with lead solder installed between Contain copper pipes with lead solder installed between 1983 and 1986 (Virginiarsquos lead solder ban) or1983 and 1986 (Virginiarsquos lead solder ban) or
bull Contain lead pipes andorContain lead pipes andorbull Are served by a lead service lineAre served by a lead service line
bull Tier 2 sampling pool consists of sample sites thatTier 2 sampling pool consists of sample sites that bull Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before
19831983
Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1111
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Site SelectionSample Site Selection
The LCR STR clarifies that an acceptable sampling The LCR STR clarifies that an acceptable sampling location location
should be a tap that is should be a tap that is ldquonormallyrdquoldquonormallyrdquo used for human used for humanconsumptionconsumption
bull Typically cold water kitchen or bathroom sinksTypically cold water kitchen or bathroom sinks
bull Drinking fountains and water coolers in schools Drinking fountains and water coolers in schools or other buildingsor other buildings
bull Do not sample from outside hose bibs or utility Do not sample from outside hose bibs or utility sinkssinks
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1212
Review of Monitoring Review of Monitoring RequirementsRequirements
Sample Collection MethodSample Collection Methodbull First-draw samplesFirst-draw samples
bull MinimumMinimum 6-hour standing time 6-hour standing time
bull One-liter volumeOne-liter volume
bull System or residents can collectSystem or residents can collect
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1313
Review of Monitoring Review of Monitoring RequirementsRequirements
Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem Population
Number of Number of Sampling SitesSampling Sites (Initial Routine (Initial Routine
Monitoring)Monitoring)
Number of Number of Sampling SitesSampling Sites
( Reduced ( Reduced Monitoring)Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1414
Review of Monitoring Review of Monitoring RequirementsRequirements
Lead and Copper Tap MonitoringLead and Copper Tap Monitoringbull Initial monitoring includes two 6-month periods Initial monitoring includes two 6-month periods
(January ndash June and July ndash December)(January ndash June and July ndash December)
bull After the two 6-months of initial monitoring w After the two 6-months of initial monitoring w results below both ALrsquos monitoring can be results below both ALrsquos monitoring can be reduced to once per year at the reduced number reduced to once per year at the reduced number of sitesof sites
bull After three years of monitoring w results below After three years of monitoring w results below both ALrsquos monitoring can be reduced to once per both ALrsquos monitoring can be reduced to once per three calendar yearsthree calendar years
bull Waterworks in reduced monitoring must collect Waterworks in reduced monitoring must collect all samples during the months of all samples during the months of June - SeptemberJune - September
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1515
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating ComplianceCollecting Samples and Calculating Compliancebull All All valid valid sample results will be included in the 90sample results will be included in the 90thth
percentile calculationpercentile calculationbull Sample must meet the selection criteria (tier and category)Sample must meet the selection criteria (tier and category)
bull Sample must be collected within the compliance monitoring Sample must be collected within the compliance monitoring period (June ndash September for reduced monitoring)period (June ndash September for reduced monitoring)
bull Some samples are not included in the 90Some samples are not included in the 90thth percentile percentile calculationcalculation
bull Customer-requested sample - unless meet site selection Customer-requested sample - unless meet site selection criteriacriteria
bull Samples collected outside compliance monitoring periodSamples collected outside compliance monitoring periodbull 9090thth percentile concentrations will be calculated even if less percentile concentrations will be calculated even if less
than the minimum number of samples are submittedthan the minimum number of samples are submittedbull This is also monitoring violationThis is also monitoring violation
bull A NOV will be issuedA NOV will be issued
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1616
bull Define a valid sampleDefine a valid samplebull First-draw ndash minimum of 6 hours standing timeFirst-draw ndash minimum of 6 hours standing timebull 1-liter in volume1-liter in volumebull Collected from an inside tap normally used for human Collected from an inside tap normally used for human
consumption (kitchen or bathroom sink drinking consumption (kitchen or bathroom sink drinking fountain)fountain)
bull Waterworks can collect samples or review collection Waterworks can collect samples or review collection information before analysis ndash information before analysis ndash if something is not right do if something is not right do not have the sample testednot have the sample tested
bull States can only invalidate a sample if States can only invalidate a sample if bull Improper sample analysis orImproper sample analysis orbull Site selection criteria not met orSite selection criteria not met orbull Sample container was damaged in transit orSample container was damaged in transit orbull Sample subjected to tamperingSample subjected to tampering
Review of Monitoring Review of Monitoring RequirementsRequirements
Collecting Samples and Calculating Compliance Collecting Samples and Calculating Compliance contcont
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1717
Review of Monitoring Review of Monitoring RequirementsRequirements
Management of Aerators during Sample Management of Aerators during Sample CollectionCollectionbull Encourage homeowners to regularly Encourage homeowners to regularly
clean aeratorsclean aerators
bull Do not removecleanDo not removeclean prior to or prior to or during sampling as this could fail to during sampling as this could fail to identify typical lead contributionsidentify typical lead contributions
bull DCLS sampling instructions have DCLS sampling instructions have been modifiedbeen modified
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1818
Lead and Copper RuleLead and Copper Rule
Review of 90Review of 90thth
Percentile CalculationsPercentile Calculations
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
1919
bull Step 1Step 1 Place lead or copper results in ascending Place lead or copper results in ascending order order
bull Step 2Step 2 Assign each sample a number 1 for Assign each sample a number 1 for lowest valuelowest value
bull Step 3Step 3 Multiply the total number of samples by Multiply the total number of samples by 0909
Example 20 samples x 09 = 18Example 20 samples x 09 = 18th th samplesample
bull Step 4Step 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
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2020
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Site A 0005 mgLSite B 0015 mgLSite C 0005 mgL Site D 0014 mgLSite E 0014 mgL What is the 90th Percentile ValueSite F 0005 mgL Site G 0040 mgLSite H 0014 mgLSite I 0014 mgLSite J 0005 mgL
Assume 10 samples are collected with lead and copper results as follows
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2121
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
Step 1 Order results from lowest to highest
1 Site A 0005 6 Site E0014
2 Site C 0005 7 Site H0014
3 Site F 0005 8 Site I0014
4 Site J 0005 9 Site B0015
5 Site D 0014 10 Site G0040
Step 2 Multiply number of samples by 09 to Step 2 Multiply number of samples by 09 to
determine which represents 90th percentile determine which represents 90th percentile
levellevel10 x 09 = 9th sample (or 0015 mgL)
Step 3 Compare to lead action level Step 3 Compare to lead action level No No
ExceedanceExceedance
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2222
bull Suppose when you multiply the number of samples Suppose when you multiply the number of samples the result is not a whole numberthe result is not a whole number
bull As an example consider a sample set that contains As an example consider a sample set that contains 24 lead and copper samples24 lead and copper samples
bull Example 24 samples x 09 = 216Example 24 samples x 09 = 216th th sample resultsample result
bull In this situation you can use rounding (round the In this situation you can use rounding (round the 216 up to 22 and compare the 22216 up to 22 and compare the 22ndnd highest sample highest sample result to the Action Levelresult to the Action Level
bull As an alternative method you can use interpolationAs an alternative method you can use interpolation
Review of 90Review of 90thth Percentile Calculations Percentile Calculations More than 5 Samples ExampleMore than 5 Samples Example
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2323
Review of 90Review of 90thth Percentile Calculations Percentile Calculations 5 Samples Example5 Samples Example
bull Step 1Step 1 Place results in Place results in ascending orderascending order
bull Step 2Step 2 Average 4 Average 4thth and 5 and 5thth highest sample resultshighest sample results
bull Step 3Step 3 Compare 90 Compare 90thth percentile level to action percentile level to action levellevel
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2424
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Site A 0009 mgLSite B 0011 mgLSite C 0020 mgL What is the 90th Percentile ValueSite D 0009 mgLSite E 0010 mgL
Assume 5 samples are collected with lead and copper results as follows
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2525
Review of 90th Percentile CalculationsReview of 90th Percentile Calculations
5 Samples Example5 Samples Example
Step 1Step 1 Order results from lowest to highest Order results from lowest to highest 1 Site A 0009 mgL2 Site D 0009 mgL3 Site E 0010 mgL4 Site B 0011 mgL5 Site C 0020 mgL
Step 2 Average 4th amp 5th samples highest samples to get 90th Step 2 Average 4th amp 5th samples highest samples to get 90th percentile value = 0016 mgLpercentile value = 0016 mgL
0011 mgL + 0020 mgL = 00155 mgL 2
Step 3 Compare average to lead action level Step 3 Compare average to lead action level Exceedance
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2626
Review of 90Review of 90thth Percentile Calculations Percentile Calculations Fewer than 5 SamplesFewer than 5 Samples
bull Procedure has changed under LCR STR Procedure has changed under LCR STR bull Some systems may collect lt five samplesSome systems may collect lt five samplesbull Sample with Sample with highest resulthighest result is 90 is 90thth percentile percentile
levellevel
bull No MR violationNo MR violation
Assume 3 lead samples 0020 mgL 0008 mgL and 0005 mgL 90th percentile = 0020 mgL
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2727
Lead and Copper Rule Lead and Copper Rule Short-Term Revisions and Short-Term Revisions and
ClarificationsClarifications
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2828
LCR Short Term RevisionsLCR Short Term Revisions Major ChangesMajor Changes
11 Monitoring Revisions Monitoring Revisions bull Minimum Number of Samples RequiredMinimum Number of Samples Requiredbull Definitions for Compliance and Monitoring PeriodsDefinitions for Compliance and Monitoring Periodsbull Reduced Monitoring CriteriaReduced Monitoring Criteria
22 Consumer Notice of Lead Tap ResultsConsumer Notice of Lead Tap Results33 Consumer Confidence Report Mandatory Consumer Confidence Report Mandatory
LanguageLanguage44 Notification of Treatment and Source Notification of Treatment and Source
ChangesChanges55 Public Education ChangesPublic Education Changes66 Reevaluation of Tested Out Lead Service Reevaluation of Tested Out Lead Service
LinesLines
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
2929
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull LCR STR was published on October 10 2007 LCR STR was published on October 10 2007 and has an effective date of December 10 2007and has an effective date of December 10 2007
bull For States that ldquoAdopt by Referencerdquo the rule For States that ldquoAdopt by Referencerdquo the rule compliance date is 180 days after promulgation compliance date is 180 days after promulgation - or by April 8 2008- or by April 8 2008
bull For Statersquos with a formal adoption process the For Statersquos with a formal adoption process the rule compliance date is two years after the rule compliance date is two years after the effective date - or by December 10 2009 - effective date - or by December 10 2009 - Virginia is in this categoryVirginia is in this category
bull States can request up to an additional two years States can request up to an additional two years extension ndash or by December 10 2011extension ndash or by December 10 2011
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3030
LCR Short Term RevisionsLCR Short Term Revisions Compliance DatesCompliance Dates
bull As noted above Virginia technically has until As noted above Virginia technically has until December 10 2009December 10 2009 to implement this new to implement this new rulerule
bull However as we have done with other EPA However as we have done with other EPA rules ODW will proceed with implementation rules ODW will proceed with implementation during the interim period of formal adoption during the interim period of formal adoption
bull Implementation will begin with samples Implementation will begin with samples collected this summercollected this summer
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3131
Minimum Number of Minimum Number of Samples RequiredSamples Required
Systems affectedSystems affectedbull Small systems Small systems serving 100 or fewer people serving 100 or fewer people
with less than five taps used for human with less than five taps used for human consumptionconsumption (primarily non-transient (primarily non-transient non-community water systems ndash NTNCWS)non-community water systems ndash NTNCWS)
1048630 1048630 Regulatory revisionRegulatory revisionbull Retain the 5 sample minimum but also Retain the 5 sample minimum but also
allow States discretion to reduce allow States discretion to reduce monitoring to one sample per tap used for monitoring to one sample per tap used for human consumption where there are fewer human consumption where there are fewer than 5 such tapsthan 5 such taps
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3232
Minimum Number of Minimum Number of Samples RequiredSamples Required
bull For systems taking fewer than 5 For systems taking fewer than 5 samples the samples the highest single samplehighest single sample lead and copper values are used to lead and copper values are used to determine if the system meets the determine if the system meets the Action LevelsAction Levels
bull The ODW is adopting the lt 5 sample The ODW is adopting the lt 5 sample provision for very small waterworksprovision for very small waterworks
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3333
Minimum Number of Minimum Number of Samples RequiredSamples Required
If a waterworks chooses this option to collect If a waterworks chooses this option to collect fewerfewer
than five samples the ODW must ensure thatthan five samples the ODW must ensure that
bull The LCR Monitoring Plan is revised to indicate the number The LCR Monitoring Plan is revised to indicate the number of samples to be collected and the specific sample of samples to be collected and the specific sample locationslocations
bull AllAll sample taps used for human consumption are sampled sample taps used for human consumption are sampled
bull The owner is aware that the single highest sample result The owner is aware that the single highest sample result will be compared to the Action Levelswill be compared to the Action Levels
bull This sampling plan is approved in writing prior to the This sampling plan is approved in writing prior to the sampling eventsampling event
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3434
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
Systems affectedSystems affectedbull All systems when they exceed an action levelAll systems when they exceed an action level
Regulatory RevisionRegulatory Revisionbull Clarify definitions for monitoring period and Clarify definitions for monitoring period and
compliance periodcompliance period
bull For waterworks in reduced monitoring the For waterworks in reduced monitoring the end of the monitoring period is typically end of the monitoring period is typically September 30September 30 (samples must be collected (samples must be collected during June through September) whereas during June through September) whereas the compliance period would end the compliance period would end December 31December 31
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3535
Definitions of Compliance andDefinitions of Compliance andMonitoring PeriodsMonitoring Periods
bull Timing of actions required after an AL Timing of actions required after an AL exceedance is not clearly defined for exceedance is not clearly defined for waterworks in reduced monitoring ndash waterworks in reduced monitoring ndash ie is compliance calculated from the ie is compliance calculated from the end of the monitoring period or from end of the monitoring period or from the end of the compliance periodthe end of the compliance period
bull LCR STR revisions clarify that systems LCR STR revisions clarify that systems are deemed to be exceeding the AL as are deemed to be exceeding the AL as of the end of the monitoring period of the end of the monitoring period (ie September 30)(ie September 30)
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3636
Definitions of Compliance andDefinitions of Compliance and
Monitoring PeriodsMonitoring Periods bull LCR STR revises the various timeframes from LCR STR revises the various timeframes from
end of monitoring period for actions trigger by end of monitoring period for actions trigger by AL exceedanceAL exceedance
bull Example ndash Waterworks corrosion control Example ndash Waterworks corrosion control treatment recommendation is required within 6 treatment recommendation is required within 6 months following the end of the monitoring months following the end of the monitoring period (September 30 2007) or by March 30 period (September 30 2007) or by March 30 20082008
bull Example ndash Waterworks Public Education is Example ndash Waterworks Public Education is required within 60 days following the end of the required within 60 days following the end of the monitoring period (September 30 2007) or by monitoring period (September 30 2007) or by November 30 2007November 30 2007
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3737
Deadlines Are CriticalDeadlines Are Critical
From the end of the monitoring period ndash From the end of the monitoring period ndash September 30September 30
bull 10 days to report LCR monitoring 10 days to report LCR monitoring resultsresults
bull 60 days to complete public education60 days to complete public educationbull 3 months to certify consumer 3 months to certify consumer
notificationnotificationbull 6 months for corrosion control 6 months for corrosion control
treatment recommendationstreatment recommendations
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3838
Three Year Compliance Cycle forThree Year Compliance Cycle forSystems on Triennial MonitoringSystems on Triennial Monitoring
bull Samples must be collected during a four Samples must be collected during a four month period every 3 calendar years month period every 3 calendar years (typically June ndash September)(typically June ndash September)
bull Systems on triennial monitoring Systems on triennial monitoring can notcan not spread sampling out over a three-year spread sampling out over a three-year period (samples must be collected in the period (samples must be collected in the same year)same year)
bull System can not exceed 3 years between System can not exceed 3 years between sampling events ndash calendar yearssampling events ndash calendar years
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
3939
LCR STR Monitoring RevisionsLCR STR Monitoring Revisions Compliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Three-Year Compliance Period)(Three-Year Compliance Period)
bull Triennial monitoring must occur once every 3-year compliance Triennial monitoring must occur once every 3-year compliance periodperiod
bull Monitoring period is June ndash Sept of same calendar yearMonitoring period is June ndash Sept of same calendar yearbull Cannot exceed 3 years between sampling events (see example)Cannot exceed 3 years between sampling events (see example)
2009 2010 2011
JunendashSeptemberMonitoring period
2012 2013 2014
JunendashSeptemberMonitoring period
Three-year compliance period Three-year compliance period
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4040
STR Monitoring RevisionsSTR Monitoring RevisionsCompliance and Monitoring Period Definitions Compliance and Monitoring Period Definitions
(Other Monitoring Clarifications)(Other Monitoring Clarifications)
The LCR STR clarify that The LCR STR clarify that
bull Annual reduced lead and copper Annual reduced lead and copper tap monitoring starts the next year tap monitoring starts the next year after 2after 2ndnd 6-month period 6-month period
If 2If 2ndnd 6-month 6-month isis
Annual Monitoring Annual Monitoring BeginsBegins
January ndash JuneJanuary ndash JuneJune 1 of next yearJune 1 of next year
July - DecemberJuly - December
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4141
Criteria forCriteria forReduced MonitoringReduced Monitoring
Systems AffectedSystems Affectedbull All systems exceeding the lead action levelAll systems exceeding the lead action level
Rule RevisionRule Revisionbull Systems on reduced monitoring for lead and Systems on reduced monitoring for lead and
copper that are currently exceeding the lead copper that are currently exceeding the lead Action Level Action Level (but meeting WQPrsquos)(but meeting WQPrsquos) will will
need to go back on standard 6-month tap need to go back on standard 6-month tap monitoring schedulemonitoring schedule
bull Limits reduced monitoring to those systemsLimits reduced monitoring to those systemsmeeting optimal water quality parameters meeting optimal water quality parameters andandthe lead Action Levelthe lead Action Level
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4242
Reduced Monitoring ExampleReduced Monitoring Example
bull WQPrsquos that define optimal corrosion control WQPrsquos that define optimal corrosion control treatment have been established for a large treatment have been established for a large waterworks in triennial reduced monitoringwaterworks in triennial reduced monitoring
bull Monitoring results indicate that the Monitoring results indicate that the waterworks meets the established WQPrsquos waterworks meets the established WQPrsquos during all 6 month compliance periodsduring all 6 month compliance periods
bull Monitoring results indicate a 90Monitoring results indicate a 90thth percentile percentile lead concentration of 18 ppb which exceeds lead concentration of 18 ppb which exceeds the 15 ppb Action Levelthe 15 ppb Action Level
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4343
Reduced Monitoring ExampleReduced Monitoring Example
bull Under current LCR language this waterworks is Under current LCR language this waterworks is eligible to remain in triennial reduced monitoringeligible to remain in triennial reduced monitoring
bull The LCR STR Rule clarifies that any waterworks The LCR STR Rule clarifies that any waterworks can only become eligible for or be allowed to can only become eligible for or be allowed to remain in reduced monitoring remain in reduced monitoring if the 90if the 90thth percentile percentile lead concentration is below the lead Action Levellead concentration is below the lead Action Level
bull Under the LCR STR Rule this large waterworks Under the LCR STR Rule this large waterworks would be required to return to initial monitoring would be required to return to initial monitoring (6 month frequency at the initial number of (6 month frequency at the initial number of samples)samples)
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4444
Letrsquos Take a Break Letrsquos Take a Break
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4545
Consumer NotificationConsumer Notification
Systems AffectedSystems Affectedbull All systems (Community and NTNC) ndash All systems (Community and NTNC) ndash even if even if
both lead and copper Action Levels are metboth lead and copper Action Levels are met
Rule RevisionRule Revisionbull Waterworks must provide notification of the Waterworks must provide notification of the
lead and copper sampling results to the lead and copper sampling results to the occupants at each site that was tested in the occupants at each site that was tested in the LCR tap monitoring program within 30 days LCR tap monitoring program within 30 days of receipt of resultsof receipt of results
bull This 30 day time period begins on the date This 30 day time period begins on the date the waterworks receives the lead and copper the waterworks receives the lead and copper results notification letter from the ODWresults notification letter from the ODW
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4646
Consumer NotificationConsumer Notification
bull In addition to the lead and copper sample In addition to the lead and copper sample results waterworks must also provideresults waterworks must also provide
Health effects languageHealth effects language Actions residents can take to reduce exposure to lead Actions residents can take to reduce exposure to lead
in drinking waterin drinking water Utility contact informationUtility contact information Maximum contaminant level goal (MCLG)Maximum contaminant level goal (MCLG) Action Level DefinitionAction Level Definition
bull The Consumer Notification is required The Consumer Notification is required following each lead and copper monitoring following each lead and copper monitoring eventevent ndash regardless of the results ndash regardless of the results
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4747
Consumer NotificationConsumer Notification
bull Delivery Mechanisms ndash Direct mail or Delivery Mechanisms ndash Direct mail or another method approved by the Stateanother method approved by the State
bull NTNC systems could post the results on a bulletin NTNC systems could post the results on a bulletin board in the facilityboard in the facility
bull Small waterworks could provide notification by Small waterworks could provide notification by hand deliveryhand delivery
bull Must provide notice to the occupants of the Must provide notice to the occupants of the building that was tested ndash even if those building that was tested ndash even if those residents do not receive water billsresidents do not receive water bills
10486301048630
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4848
Consumer NotificationConsumer Notification
Reporting requirementsReporting requirements
bull Within 3 months from end of monitoring Within 3 months from end of monitoring period the waterworks must submit a copy period the waterworks must submit a copy of notification that was provided and must of notification that was provided and must certify that all notification requirements certify that all notification requirements have been methave been met
bull Consumer Notification templates are Consumer Notification templates are provided in the handout materialprovided in the handout material
10486301048630
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
4949
New ViolationNew Violation
bull LCR STR Rule adds an additional violation LCR STR Rule adds an additional violation for failure to meet the lead for failure to meet the lead consumer consumer notificationnotification requirements requirements
bull Note that is part of the Public Education Note that is part of the Public Education portion of the rule but is a separate portion of the rule but is a separate violationviolation
bull This is a MR violation This is a MR violation and not a TT and not a TT violationviolation like failure to meet the PE like failure to meet the PE requirements following a lead Action requirements following a lead Action Level exceedanceLevel exceedance
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5050
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
Systems AffectedSystems Affectedbull All systems ndash All systems ndash even if results are ldquonot detectedrdquo for lead even if results are ldquonot detectedrdquo for lead
and copperand copper
Rule RevisionRule Revisionbull All CCRrsquosAll CCRrsquos must include mandatory language must include mandatory language
concerning lead in drinking water The mandatory concerning lead in drinking water The mandatory language includeslanguage includes
bull Health effects on childrenHealth effects on childrenbull Flushing recommendation of 15 to 30 secondsFlushing recommendation of 15 to 30 secondsbull Waterworks can write its own educational statement in Waterworks can write its own educational statement in
consultation with the ODW Field Officeconsultation with the ODW Field Office
bull This new language must be in included in all CCRrsquos This new language must be in included in all CCRrsquos beginning with the 2008 CCRrsquos (to be delivered by beginning with the 2008 CCRrsquos (to be delivered by June 2009)June 2009)
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5151
Consumer ConfidenceConsumer ConfidenceReport (CCR) RevisionsReport (CCR) Revisions
bull Must include following mandatory language Must include following mandatory language Any modifications must be approved by ODWAny modifications must be approved by ODW
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 15 to 30 seconds or until it becomes cold or reaches a steady temperature 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 httpwwwepagovsafewaterlead
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5252
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
Systems affected Systems affected bull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring making a long-term treatment monitoring making a long-term treatment changechange
Rule RevisionRule Revisionbull Requires waterworks owners to notify the State Requires waterworks owners to notify the State
in writing and in writing and obtain approvalobtain approval prior to prior to implementing a long-term change in water implementing a long-term change in water treatmenttreatment
bull Notification timeframe for systems ndash at a timeNotification timeframe for systems ndash at a timespecified by the State or if none specified then specified by the State or if none specified then asasearly as possible prior to the long-term changeearly as possible prior to the long-term change
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5353
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Examples of long-term treatment changesExamples of long-term treatment changes
bull Changing disinfectants such as chlorine to Changing disinfectants such as chlorine to chloramineschloramines
bull Changing primary coagulants such as alum to ferric Changing primary coagulants such as alum to ferric chloridechloride
bull Changing corrosion inhibitor chemicals such as Changing corrosion inhibitor chemicals such as orthophosphate to a blended phosphateorthophosphate to a blended phosphate
bull Making a change in dose of an existing chemical if Making a change in dose of an existing chemical if the waterworks is planning a long-term change to its the waterworks is planning a long-term change to its finished water pH or inhibitor residual concentration finished water pH or inhibitor residual concentration
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5454
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Additional examples of long-term treatment Additional examples of long-term treatment changeschanges
bull Installation of a major unit process such as Installation of a major unit process such as membrane filtration ozonation enhanced membrane filtration ozonation enhanced coagulationcoagulation
bull Other treatments or processes that can greatly affect Other treatments or processes that can greatly affect the pH oxidation-reduction potential or alkalinitythe pH oxidation-reduction potential or alkalinity
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5555
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Waterworks Regulations 12 VAC 5-590-190 PermitsWaterworks Regulations 12 VAC 5-590-190 Permits - - require waterworks owners to obtain a Construction require waterworks owners to obtain a Construction Permit for any changes in treatment or the addition Permit for any changes in treatment or the addition of a new water sourceof a new water source
bull ODWrsquos ODWrsquos approval approval as required by the LCR STR implies as required by the LCR STR implies an assessment as to whether treatment changes may an assessment as to whether treatment changes may have an adverse impact on corrosion andor result in have an adverse impact on corrosion andor result in elevated lead levels in the distribution systemelevated lead levels in the distribution system
bull ODW may require the waterworks to conductODW may require the waterworks to conductbull A new OCCT studyA new OCCT study prior to the treatment change prior to the treatment changebull Additional lead and copper monitoringAdditional lead and copper monitoring to assess any to assess any
impactsimpacts
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5656
Notification amp Approval forNotification amp Approval forLong-term Treatment ChangesLong-term Treatment Changes
bull Potential impacts on corrosion or elevated Potential impacts on corrosion or elevated lead levels should be addressed during the lead levels should be addressed during the Preliminary Engineering Conference or as Preliminary Engineering Conference or as part of the Preliminary Engineering Report part of the Preliminary Engineering Report review processreview process
bull Each situation must be evaluated on a case-Each situation must be evaluated on a case-by-case basisby-case basis
bull Additional monitoring requirements will be Additional monitoring requirements will be determined on a case by case basisdetermined on a case by case basis
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5757
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
Systems affectedSystems affectedbull All systems on reduced lead and copper tap All systems on reduced lead and copper tap
monitoring adding a new water sourcemonitoring adding a new water source
Rule RevisionRule Revisionbull Requires waterworks owners to notify the Requires waterworks owners to notify the
State in writing and obtain State in writing and obtain approvalapproval prior to prior to adding a new source of wateradding a new source of water
bull Notification timeframe for systems to Notification timeframe for systems to provide written documentation ndash at a time provide written documentation ndash at a time specified by the State or if none specified specified by the State or if none specified then as early as possible prior to adding a then as early as possible prior to adding a new water sourcenew water source
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
5858
Notification amp Approval forNotification amp Approval forAddition of New SourcesAddition of New Sources
bull Notification and approval are not required Notification and approval are not required every year if source is used seasonallyevery year if source is used seasonally
bull ODW will deal with new sources on a case-ODW will deal with new sources on a case-by-case basis in the same manner as by-case basis in the same manner as adding a new treatment process or making adding a new treatment process or making a long-term change in treatmenta long-term change in treatment
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
Public Education Public Education RevisionsRevisions
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6060
Public Education RevisionsPublic Education Revisions
Systems affected Systems affected bull All systems exceeding lead ALAll systems exceeding lead AL
Rule Revision Rule Revision bull LCR STR Rule makes LCR STR Rule makes significant changessignificant changes
in the message content delivery in the message content delivery requirements and the timing of when requirements and the timing of when waterworks must complete required waterworks must complete required Public Education activitiesPublic Education activities
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6161
Public Education Revisions Public Education Revisions Written MaterialsWritten Materials
bull PE written materials (Community and PE written materials (Community and NTNC) includeNTNC) include
bull Introductioninformation statement - Introductioninformation statement - this is this is mandatory language and can not be alteredmandatory language and can not be altered
bull New health effects language that provides greater New health effects language that provides greater specificity on lead health effects ndash ie lower IQ specificity on lead health effects ndash ie lower IQ impacts in children - impacts in children - this is mandatory language this is mandatory language and can not be alteredand can not be altered
bull Sources of leadSources of leadbull Steps to take to reduce exposure to lead in Steps to take to reduce exposure to lead in
drinking water - Flushing recommendations can drinking water - Flushing recommendations can be tailored to the systemrsquos specific situationbe tailored to the systemrsquos specific situation
bull What happened and what is being doneWhat happened and what is being donebull Sources of additional information ndash Sources of additional information ndash this mandatory this mandatory
language and can not be alteredlanguage and can not be altered
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6262
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
Required content for community waterworks Required content for community waterworks onlyonly
bull Tell consumers how to get their water testedTell consumers how to get their water tested
bull Discuss lead in plumbing components and Discuss lead in plumbing components and the difference between low lead and lead the difference between low lead and lead freefree
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6363
Public Education RevisionsPublic Education Revisions Written MaterialsWritten Materials
ldquoldquoSpecialrdquo Community Waterworks maySpecialrdquo Community Waterworks may
bull Limit the Public Education written materials by eliminating the Limit the Public Education written materials by eliminating the language telling customers how to get their water tested and language telling customers how to get their water tested and the discussion of plumbing components the discussion of plumbing components
bull Limit the Public Education deliver to the delivery requirements Limit the Public Education deliver to the delivery requirements for NTNC waterworksfor NTNC waterworks
If the waterworks is a facility such as a prison hospital boardingIf the waterworks is a facility such as a prison hospital boardingschool where the population served is not capable of or is school where the population served is not capable of or is
prevented fromprevented frommaking improvements to plumbing or installing POU treatment making improvements to plumbing or installing POU treatment
devices anddevices and
The waterworks provides water as a part of the cost of services The waterworks provides water as a part of the cost of services andand
does not separately charge for water consumptiondoes not separately charge for water consumption
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6464
Public Education RevisionsPublic Education Revisions Delivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
Community WaterworksCommunity Waterworksbull Deliver written materials (pamphlets brochures etc) to all Deliver written materials (pamphlets brochures etc) to all
bill paying customersbill paying customers
bull Deliver written materials to facilities and organizations Deliver written materials to facilities and organizations that are served by the waterworksthat are served by the waterworks that are most likely to be that are most likely to be visited regularly by pregnant women and children visited regularly by pregnant women and children
bull Local Heath Departments Local Heath Departments bull Public and private schools and preschoolsPublic and private schools and preschoolsbull WIC and Head Start programsWIC and Head Start programsbull Public and private hospitalsPublic and private hospitalsbull Pediatricians Gynecologists and MidwivesPediatricians Gynecologists and Midwivesbull Family Planning ClinicsFamily Planning Clinicsbull Local welfare agenciesLocal welfare agencies
bull Within 60 days of the end of the monitoring periodWithin 60 days of the end of the monitoring period
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6565
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LHD ContactDelivery Requirements ndash LHD Contact
Community WaterworksCommunity Waterworksbull Are required to Are required to make contact with the Local make contact with the Local
Health Department Health Department in person or by telephonein person or by telephone - - this is addition to sending the PE written this is addition to sending the PE written materials The LHD contact must be made materials The LHD contact must be made even if the LHD is not served by the even if the LHD is not served by the waterworks waterworks
bull Request assistance from the LHD in notifying Request assistance from the LHD in notifying specific organizations that serve ldquoat-riskrdquo specific organizations that serve ldquoat-riskrdquo customers such as licensed day care centers customers such as licensed day care centers public and private preschools obstetricians-public and private preschools obstetricians-gynecologists and midwivesgynecologists and midwives
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6666
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash LDH ContactDelivery Requirements ndash LDH Contact
Community WaterworksCommunity Waterworksbull If the LDH provides a list all organizations If the LDH provides a list all organizations
must be contacted and provided with the must be contacted and provided with the written materialwritten material
bull For large waterworks serving gt 3300 persons For large waterworks serving gt 3300 persons all organizations must be contacted all organizations must be contacted even if even if the organization is not served by the the organization is not served by the waterworkswaterworks
bull For waterworks serving 3300 or fewer For waterworks serving 3300 or fewer persons all organizations must be contacted persons all organizations must be contacted that are that are served by the waterworksserved by the waterworks
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6767
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Additional ActivitiesDelivery Requirements ndash Additional Activities
Implement additional Public Education activities from the Implement additional Public Education activities from the following listfollowing listWaterworks serving gt 3300 persons must implement at Waterworks serving gt 3300 persons must implement at least 3least 3Waterworks serving le 3300 persons must implement at Waterworks serving le 3300 persons must implement at least 1least 1
Public Service AnnouncementsPublic Service Announcements Paid advertisementsPaid advertisements Public area information displaysPublic area information displays E-mails to customersE-mails to customers Public meetingsPublic meetings Household deliveriesHousehold deliveries Targeted individual customer contactsTargeted individual customer contacts Direct material distribution to all multi-family homes or Direct material distribution to all multi-family homes or
institutionsinstitutions Other methods approved by the stateOther methods approved by the state
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6868
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Billing Cycle Delivery Requirements ndash Billing Cycle
NotificationNotification
Community WaterworksCommunity Waterworksbull Provide information about lead in drinking water on or in Provide information about lead in drinking water on or in
each customer water bill each customer water bill with each billing cyclewith each billing cyclebull This notification must be done at least quarterlyThis notification must be done at least quarterlybull If water bills are not sent at least quarterly a separate If water bills are not sent at least quarterly a separate
mailing is requiredmailing is required
bull Waterworks serving gt 100000 must post material on Waterworks serving gt 100000 must post material on web siteweb 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]
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
6969
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Press ReleaseDelivery Requirements ndash Press Release
Community WaterworksCommunity Waterworks
bull Submit a press release to newspapers television Submit a press release to newspapers television and radio stationsand radio stations
bull The press release delivery requirement may be The press release delivery requirement may be waived for a waterworks serving 3300 or fewer waived for a waterworks serving 3300 or fewer persons if the waterworks delivers the written persons if the waterworks delivers the written material to material to every household servedevery household served
bull Within 60 days after the end of the monitoring Within 60 days after the end of the monitoring periodperiod
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7070
Public Education RevisionsPublic Education RevisionsDelivery Requirements ndash Written MaterialsDelivery Requirements ndash Written Materials
NTNC WaterworksNTNC Waterworks
bull Post informational posters containing the Post informational posters containing the required written materials in a public place or required written materials in a public place or common area in each building served by the common area in each building served by the waterworks waterworks andand
bull Deliver written materials to each person servedDeliver written materials to each person served
bull Notification by electronic transmission may be Notification by electronic transmission may be approved if it achieves at least the same approved if it achieves at least the same coveragecoverage
bull Within 60 days following the end of the Within 60 days following the end of the monitoring periodmonitoring period
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7171
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
Community waterworks must repeat every 12 Community waterworks must repeat every 12 monthsmonths
bull Delivery of written materials to each billing customerDelivery of written materials to each billing customerbull Delivery of written materials to LHD and facilities and Delivery of written materials to LHD and facilities and
organizations that are most likely to be visited regularly organizations that are most likely to be visited regularly by pregnant women and children by pregnant women and children
bull Implement the additional Public Education activities Implement the additional Public Education activities from the approved listfrom the approved list
Community waterworks must repeat Community waterworks must repeat twicetwice every every 1212
monthsmonths
bull Press ReleasePress Release
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7272
Public Education RevisionsPublic Education RevisionsRepeat Delivery RequirementsRepeat Delivery Requirements
NTNC waterworks must repeat every 12 NTNC waterworks must repeat every 12 monthsmonths
bull Post informational posters containing the required Post informational posters containing the required written materials in a public place or common area in written materials in a public place or common area in each building served by the waterworks - within 60 each building served by the waterworks - within 60 days following the end of the monitoring period days following the end of the monitoring period
andand
bull Deliver written materials to each person served - Deliver written materials to each person served - within 60 days following the end of the monitoring within 60 days following the end of the monitoring periodperiod
For as long as the lead Action Level is exceededFor as long as the lead Action Level is exceeded
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7373
Public EducationPublic EducationDelivery CertificationDelivery Certification
Within 10 days after the end of the Within 10 days after the end of the each periodeach period in in whichwhich
the waterworks is required to perform Public the waterworks is required to perform Public EducationEducation
bull Send written documentation to the state certifying Send written documentation to the state certifying that that
the waterworks written material met all of the the waterworks written material met all of the contentcontent
requirements andrequirements and
bull That all of the delivery requirements have been metThat all of the delivery requirements have been met
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7474
Re-evaluation of Tested-outRe-evaluation of Tested-outLead Service LinesLead Service Lines
Systems affected Systems affected bull Systems required to implement the Lead Service Line Systems required to implement the Lead Service Line
Replacement treatment techniqueReplacement treatment technique
bull Under current LCR language waterworks can test each LSL Under current LCR language waterworks can test each LSL prior to replacement If the lead result is below 15 ppb the prior to replacement If the lead result is below 15 ppb the LSL does not have to be replaced but can be counted as LSL does not have to be replaced but can be counted as being replacedbeing replaced
Rule RevisionRule Revisionbull LSLrsquos that tested below 15 ppb would LSLrsquos that tested below 15 ppb would notnot be considered be considered
permanently replaced and would have to be re-evaluated if permanently replaced and would have to be re-evaluated if system later re-exceeds action levelsystem later re-exceeds action level
bull Re-evaluation could consist of either testing the line again Re-evaluation could consist of either testing the line again or physical replacement of the line because previous or physical replacement of the line because previous sample may no longer be representative of the lead service sample may no longer be representative of the lead service line lead concentrationsline lead concentrations
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7575
Lead Service Line ReplacementLead Service Line Replacement
bull LSL replacement schedule is more explicitLSL replacement schedule is more explicit
bull First year requires 7 replacement First year requires 7 replacement begins immediately at end of the begins immediately at end of the monitoring periodmonitoring period
bull Still have all existing testing and Still have all existing testing and notification requirementsnotification requirements
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7676
Lead Service Line ReplacementLead Service Line Replacement
bull To date no waterworks in Virginia have To date no waterworks in Virginia have been required to implement the LSL been required to implement the LSL Replacement treatment techniqueReplacement treatment technique
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7777
Lead and Copper Tap SampleLead and Copper Tap SampleMonitoring Example Monitoring Example
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7878
Monitoring ExampleMonitoring Example
bull Anytown is a community waterworks Anytown is a community waterworks serving a serving a total population of 3800 persons Anytown total population of 3800 persons Anytown is currently in triennial reduced monitoring is currently in triennial reduced monitoring collecting lead and copper tap samples collecting lead and copper tap samples once every three yearsonce every three years
bull Based upon the 3800 population Anytown Based upon the 3800 population Anytown is required to submit the results of 20 lead is required to submit the results of 20 lead and copper tap samples during the reduced and copper tap samples during the reduced monitoring periodmonitoring period
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
7979
Monitoring ExampleMonitoring Example Minimum Number of Tap SamplesMinimum Number of Tap Samples
System PopulationSystem PopulationNumber of Number of
Sampling SitesSampling Sites (on (on Routine Monitoring)Routine Monitoring)
Number of Number of Sampling SitesSampling Sites (on (on Reduced Monitoring)Reduced Monitoring)
gt100000gt100000 100100 5050
10001 to 1000010001 to 10000 6060 3030
3301 to 100003301 to 10000 4040 2020
501 to 3300501 to 3300 2020 1010
101 to 500101 to 500 1010 55
lele100100 55 55
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8080
Monitoring Example ndash contMonitoring Example ndash cont
bull Anytown collects 14 samples on July 3 2009 Anytown collects 14 samples on July 3 2009 Results are submitted to the ODW Field Office on Results are submitted to the ODW Field Office on July 25 2009 by the laboratoryJuly 25 2009 by the laboratory
bull Anytown collects 10 additional samples on Anytown collects 10 additional samples on October 2 2009 Results are submitted to the October 2 2009 Results are submitted to the ODW Field Office on October 10 2009 by the ODW Field Office on October 10 2009 by the laboratory laboratory
bull All samples were collected from sites that were All samples were collected from sites that were included in the initial LCR sampling plan that included in the initial LCR sampling plan that was approved by the ODWwas approved by the ODW
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8181
Monitoring Example ndash contMonitoring Example ndash cont
What actions will be taken by the ODW FieldWhat actions will be taken by the ODW FieldOfficeOffice
bull There are only 14 valid lead and copper There are only 14 valid lead and copper tap sample resultstap sample results
bull The 10 samples collected on October 2 The 10 samples collected on October 2 2009 can not be utilized as all reduced 2009 can not be utilized as all reduced monitoring samples must be collected monitoring samples must be collected during the months of during the months of June through June through SeptemberSeptember
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8282
Monitoring Example ndash contMonitoring Example ndash cont
bull The ODW Field Office must calculate the The ODW Field Office must calculate the 9090thth percentile lead and copper percentile lead and copper concentrations using the 14 samples that concentrations using the 14 samples that were collected in July 2009were collected in July 2009
bull The ODW Field Office must issue a The ODW Field Office must issue a monitoring violation for failure to submit monitoring violation for failure to submit 20 lead and copper sample results ndash only 20 lead and copper sample results ndash only 14 valid results were submitted14 valid results were submitted
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8383
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull Place the 14 samples in ascending orderPlace the 14 samples in ascending order
bull Multiply the 14 samples by 09Multiply the 14 samples by 09
14 x 09 = 12614 x 09 = 126
bull Round the 126 value up to 13 ndash the 13Round the 126 value up to 13 ndash the 13thth highest sample results are compared to the highest sample results are compared to the Action LevelsAction Levels
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8484
Monitoring Example ndash contMonitoring Example ndash cont
Anytown 90Anytown 90thth Percentile Calculation Percentile CalculationSample
Collection Date
Ascending Lead
Sample Number
Lead Result (ppb)
Ascending Copper Sample Number
Copper Results (mgL)
3-Jul-09 1 lt 5 1 022
3-Jul-09 2 lt 5 2 033
3-Jul-09 3 lt 5 3 033
3-Jul-09 4 lt 5 4 034
3-Jul-09 5 lt 5 5 05
3-Jul-09 6 lt 5 6 05
3-Jul-09 7 lt 5 7 05
3-Jul-09 8 6 8 055
3-Jul-09 9 73 9 073
3-Jul-09 10 86 10 079
3-Jul-09 11 9 11 089
3-Jul-09 12 13 12 1
3-Jul-09 13 14 13 11
3-Jul-09 14 25 14 19
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8585
Monitoring Example ndash contMonitoring Example ndash cont
ODW Field Office will calculate the 90ODW Field Office will calculate the 90thth percentilespercentiles
bull The 90The 90thth percentile lead concentration is 14 percentile lead concentration is 14 ppb which is below the 15 ppb Action Levelppb which is below the 15 ppb Action Level
bull The 90The 90thth percentile copper concentration is percentile copper concentration is 11 mgl which is below the 13 mgL Action 11 mgl which is below the 13 mgL Action LevelLevel
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8686
Monitoring Example ndash contMonitoring Example ndash cont
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the Anytown must distribute public notification (the
MR violation is a Tier III violation) within 12 MR violation is a Tier III violation) within 12 monthsmonths
bull Anytown must collect their next round of LCR tap Anytown must collect their next round of LCR tap samples during the samples during the June through September 2010June through September 2010 monitoring periodmonitoring period
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed within 30 days of requirements ndash to be completed within 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8787
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
Letrsquos Assume that the 90Letrsquos Assume that the 90thth percentile lead percentile lead concentration forconcentration for
Anytown was calculated to be 17 ppb Anytown was calculated to be 17 ppb
What actions are required by Anytown What actions are required by Anytown bull Anytown must distribute public notification (the MR Anytown must distribute public notification (the MR
violation is a Tier III violation) within 12 monthsviolation is a Tier III violation) within 12 months
bull Anytown must initiate the consumer notification Anytown must initiate the consumer notification requirements ndash to be completed with 30 days of requirements ndash to be completed with 30 days of receipt of the ODW lead and copper results receipt of the ODW lead and copper results notification letternotification letter
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8888
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull The 17 ppb 90The 17 ppb 90thth percentile concentration has percentile concentration has exceeded the lead Action Level of 15 ppbexceeded the lead Action Level of 15 ppb
bull Anytown must submit an optimum corrosion Anytown must submit an optimum corrosion control treatment recommendation to the Field control treatment recommendation to the Field Office within 6 months of the end of the Office within 6 months of the end of the monitoring period or by March 31 2010monitoring period or by March 31 2010
bull Anytown must conduct Water Quality Parameter Anytown must conduct Water Quality Parameter Monitoring within 6 months Monitoring within 6 months from the beginning from the beginning of the monitoring periodof the monitoring period or by November 30 or by November 30 2009 (6 months from June 1 2009)2009 (6 months from June 1 2009)
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
8989
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown must conduct source water monitoring for Anytown must conduct source water monitoring for lead within 6 months lead within 6 months from the end of the from the end of the monitoring periodmonitoring period or by March 30 2010 (6 months or by March 30 2010 (6 months from September 30 2009)from September 30 2009)
bull Anytown must complete all of the Public Education Anytown must complete all of the Public Education requirements within 60 days of the end of the requirements within 60 days of the end of the monitoring period or by November 30 2009monitoring period or by November 30 2009
bull Public Education must continue as long as Anytown Public Education must continue as long as Anytown continues to exceed the lead Action Levelcontinues to exceed the lead Action Level
bull Lead Service Line Replacement is not required Lead Service Line Replacement is not required since Anytown does not have any lead service linessince Anytown does not have any lead service lines
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
9090
Monitoring Example 2 ndash contMonitoring Example 2 ndash cont
bull Anytown is no longer eligible for reduced Anytown is no longer eligible for reduced monitoringmonitoring
bull Anytown Anytown shouldshould continue to monitor continue to monitorbull Collect 40 lead and copper samples during January ndash June Collect 40 lead and copper samples during January ndash June
20102010bull Will end the monitoring violationWill end the monitoring violationbull If results are below the lead AL will end Public EducationIf results are below the lead AL will end Public Education
bull If the AL continues to be exceeded corrosion If the AL continues to be exceeded corrosion control treatment must be installedcontrol treatment must be installed
bull Treatment must be installed within 24 months of Treatment must be installed within 24 months of ODW notification unless an OCCT study is requiredODW notification unless an OCCT study is required
9191
Questions and DiscussionQuestions and Discussion
9191
Questions and DiscussionQuestions and Discussion