lead and copper rule: short-term revisions and clarifications jim moore vdh – office of drinking...

91
Lead and Copper Lead and Copper Rule: Rule: Short-Term Revisions Short-Term Revisions and Clarifications and Clarifications Jim Moore Jim Moore VDH – Office of Drinking Water VDH – Office of Drinking Water

Upload: adela-reynolds

Post on 27-Dec-2015

217 views

Category:

Documents


1 download

TRANSCRIPT

Page 1: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 2: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – 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

Page 3: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 4: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 5: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 6: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 7: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 8: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 9: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 10: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 11: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 12: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 13: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 14: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 15: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 16: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 17: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 18: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 19: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 20: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 21: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 22: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 23: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 24: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 25: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 26: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 27: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 28: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 29: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 30: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 31: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 32: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 33: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 34: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 35: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 36: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 37: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 38: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 39: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 40: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 41: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 42: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 43: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 44: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 45: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 46: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 47: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 48: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 49: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 50: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 51: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 52: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 53: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 54: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 55: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 56: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 57: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 58: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 59: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 60: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 61: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 62: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 63: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 64: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 65: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 66: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 67: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 68: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 69: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 70: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 71: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 72: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 73: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 74: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 75: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 76: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 77: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 78: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 79: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 80: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 81: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 82: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 83: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 84: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 85: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 86: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 87: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 88: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 89: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 90: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

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

Page 91: Lead and Copper Rule: Short-Term Revisions and Clarifications Jim Moore VDH – Office of Drinking Water

9191

Questions and DiscussionQuestions and Discussion