Presentation is loading. Please wait.

Presentation is loading. Please wait.

April 2008 Lead and Copper Rule: Short-Term Revisions and Clarifications.

Similar presentations


Presentation on theme: "April 2008 Lead and Copper Rule: Short-Term Revisions and Clarifications."— Presentation transcript:

1 April 2008 Lead and Copper Rule: Short-Term Revisions and Clarifications

2 April 2008 Introduction How the Presentation is Organized Lead and Copper Rule (LCR) IntroductionOverview Lead and Copper Tap Monitoring Requirement Review 90 th Percentile Calculation Review LCR Short-Term Revisions and Clarifications (STR) Overview STR Regulatory Changes Primacy Package

3 April 2008 Introduction Terminology for Primacy Agency State means Primacy Agency 40 CFR §141.2 definition for State Possible Primacy Agencies State Tribal government EPA region

4 April 2008 Introduction Acronyms AL:Action Level ALE:Action Level Exceedance CCT:Corrosion Control Treatment CWS:Community Water System LCR: Lead and Copper Rule LCR STR: Lead and Copper Short-Term Revisions and Clarifications LSLR:Lead Service Line Replacement MCL:Maximum Contaminant Level MCLG: Maximum Contaminant Level Goal M/RMonitoring and Reporting (Violation) NTNCWS: Non-transient Non-community Water System PWS: Public Water System SOWT:Source Water Treatment WQP:Water Quality Parameter

5 Lead and Copper Rule Overview

6 April 2008 Lead and Copper Rule Overview First published on June 7, Established MCLGs for lead and copper. Establishes AL vs. MCL. 90 th percentile sample result is compared to AL. ALE is trigger and not violation. ALE requires treatment techniques and additional monitoring. MCLG Action Level Lead 0 mg/L mg/L Copper 1.3 mg/L 1.3 mg/L

7 April 2008 Lead and Copper Rule Overview Three system size categories. Size is factor for sample number and applicability/timing of some requirements. Large: > 50,000 people Medium: 3,301 to 50,000 people Small: 3,300 or fewer people

8 April 2008 * Includes systems serving ≤ 50,000 people and (b)(3) systems ** Includes non-(b)(3) systems serving > 50,000 people, irrespective of their 90 th percentile levels; (b)(2) systems must collect WQPs. Lead and Copper Rule Overview 90th Percentile Exceeds the Lead Action Level (15 μg/L) 90th Percentile Exceeds the Copper Action Level (1.3 mg/L) 90th Percentile Is at or Below Both Action Levels* CWS or NTNCWS Collects Lead and Copper Tap Samples Begin LSLR replace 7% of LSLs per year Begin CCT steps includes WQP monitoring ** Conduct periodic lead and copper tap monitoring Conduct public education due within 60 days Conduct source water monitoring (Install SOWT, if needed) Conduct periodic lead and copper tap monitoring

9 Lead and Copper Rule Review of Lead and Copper Tap Monitoring Requirements

10 April 2008 Review of Monitoring Requirements Site Selection - CWS Three sampling site tiers: Tier 1, Tier 2, and Tier 3. Tier 1 sample sites are considered high risk sites. Tier 1 sampling pool consists of single* family structures that: Contain copper pipes with lead solder installed Contain copper pipes with lead solder installed after 1982 (but before State’s lead ban) or; after 1982 (but before State’s lead ban) or; Contain lead pipes and/or; Contain lead pipes and/or; Are served by a lead service line. Are served by a lead service line. * May include multiple-family residences in sampling pool when they comprise at least 20 percent of structures served.

11 April 2008 Review of Monitoring Requirements Site Selection - CWS Tier 2 sampling pool consists of buildings including multiple family residences that: Contain copper pipes with lead solder Contain copper pipes with lead solder installed after 1982 (but before State’s installed after 1982 (but before State’s lead ban) or; lead ban) or; Contain lead pipes and/or; Contain lead pipes and/or; Are served by a lead service line. Are served by a lead service line. Tier 3 sampling pool consists of single family structures that: Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.

12 April 2008 Review of Monitoring Requirements Site Selection - NTNCWS Two sampling site tiers: Tier 1 and Tier 2. Tier 1 sampling pool consists of sample sites that: Contain copper pipes with lead solder installed Contain copper pipes with lead solder installed after 1982 (but before State’s lead ban) or; after 1982 (but before State’s lead ban) or; Contain lead pipes and/or; Contain lead pipes and/or; Are served by lead service line. Are served by lead service line. Tier 2 sampling pool consists of sample sites that: Contain copper pipes with lead solder installed before Contain copper pipes with lead solder installed before Use representative sites throughout distribution system if insufficient number of tiered sampling sites are available.

13 April 2008 Review of Monitoring Requirements Sample Collection Method First-draw. First-draw. 6-hour standing time. 6-hour standing time. One-liter volume. One-liter volume. System or residents can collect. System or residents can collect.

14 April 2008 Review of Monitoring Requirements Minimum Number of Tap Samples System Population Number of Sampling Sites (on Routine Monitoring) Number of Sampling Sites (on Reduced Monitoring) >100, ,001 to 100, ,301 to 10, to 3, to ≤10055

15 Lead and Copper Rule Review of 90 th Percentile Calculations

16 April 2008 Step 1: Place lead or copper results in ascending order. Step 2: Assign each sample a number, 1 for lowest value. Step 3: Multiply the total number of samples by 0.9. Example: 20 samples x 0.9 = 18 th sample.* Step 4: Compare 90 th percentile level to AL (in above example, 18 th sample). to AL (in above example, 18 th sample). Review of 90 th Percentile Calculations More than 5 Samples * When more than minimum number of samples are collected, may need rounding or interpolation to determine 90 th percentile sample.

17 April 2008 Review of 90 th Percentile Calculations More than 5 Samples: Example Question Assume 10 samples are collected with lead results as follows: Site A:0.005 mg/L Site B:0.015 mg/L Site C:0.005 mg/L Site D:0.014 mg/L Site E:0.014 mg/L What is the 90th Percentile Value? Site F:0.005 mg/L Site G:0.040 mg/L Site H:0.014 mg/L Site I:0.014 mg/L Site J:0.005 mg/L

18 April 2008 Review of 90 th Percentile Calculations More than 5 Samples: Example Answer Step 1: Order results from lowest to highest: 1. Site A: Site E: Site C: Site H: Site F: Site I: Site J: Site B: Site D: Site G:0.040 Step 2: Multiply number of samples by 0.9 to determine which represents 90th percentile level 10 x 0.9 = 9th sample (or mg/L) Step 3: Compare to lead action level  No Exceedance

19 April 2008 Review of 90 th Percentile Calculations 5 Samples Step 1: Place results in ascending order. Step 2: Average 4 th and 5 th highest sample results. Step 3: Compare 90 th percentile level to action level.

20 April 2008 Review of 90 th Percentile Calculations 5 Samples: Example Question Site A: mg/L Site B: mg/L Site C: mg/L What is the 90th Percentile Value? Site D: mg/L Site E: mg/L Assume 5 samples are collected with lead results as follows:

21 April 2008 Review of 90 th Percentile Calculations 5 Samples: Example Answer Step 1:Order results from lowest to highest: 1. Site A: mg/L 2. Site D: mg/L 3. Site E: mg/L 4. Site B: mg/L 5. Site C: mg/L Step 2: Average 4th & 5th samples highest samples to get 90th percentile value = mg/L mg/L mg/L = mg/L 2 Step 3: Compare average to lead action level  Step 3: Compare average to lead action level  Exceedance

22 April 2008 Review of 90 th Percentile Calculations Fewer than 5 Samples Procedure has changed under STR. Some systems may collect < five samples. Sample with highest result is 90 th percentile level. No M/R violation. Assume 3 lead samples: mg/L, mg/L, and mg/L. 90 th percentile = mg/L

23 April 2008 Review of Monitoring Requirements Management of Aerators during Sample Collection Memo addressed taps with aerators: Regularly clean aerators. Do not remove/clean prior to or during sampling.* Could fail to identify typical lead contribution. If initial result > AL, recommend 2 nd sample (without aerator or with clean aerator). Use both results in 90 th percentile calculation. * Does not apply to tap samples collected for WQP analysis.

24 April 2008 Review of Monitoring Requirements Collecting Samples and Calculating Compliance Review of Monitoring Requirements Collecting Samples and Calculating Compliance Memo addressed 7 aspects of tap sample collection and management: Include all valid sample results in 90 th percentile calculation: Meet sample selection criteria Meet sample selection criteria Collected within compliance monitoring period* Collected within compliance monitoring period* Do not include in 90 th percentile calculation: Customer-requested sample unless meet site selection criteria Customer-requested sample unless meet site selection criteria Samples collected outside compliance monitoring period* Samples collected outside compliance monitoring period* Calculate 90 th percentile even if < minimum sample number (M/R violation). * Would include replacement sample(s) collected within 20 days of invalidation (even if collected after monitoring period end).

25 April 2008 Defines proper sample: First-draw, First-draw, 1-liter, 1-liter, From inside tap used for consumption (kitchen or bathroom sink), and From inside tap used for consumption (kitchen or bathroom sink), and Minimum 6-hours standing time. Minimum 6-hours standing time. System can collect sample or review collection information before analysis. States can invalidate sample if: Improper sample analysis, or Improper sample analysis, or Site selection criteria not met, or Site selection criteria not met, or Sample container was damaged in transit, or Sample container was damaged in transit, or Sample subjected to tampering. Sample subjected to tampering. Review of Monitoring Requirements Collecting Samples and Calculating Compliance (cont.) Review of Monitoring Requirements Collecting Samples and Calculating Compliance (cont.)

26 Lead and Copper Short-Term Revisions and Clarifications April 2008 Overview Regulatory Changes Primacy Package

27 April 2008 Short-Term Revisions Overview Scope of Revisions Published in Federal Register, October 10, 2007 p Addresses implementation issues with existing rule: Monitoring revisions (sample number, timing clarifications). Monitoring revisions (sample number, timing clarifications). Additional requirements for providing public information. Additional requirements for providing public information. Advanced notification of treatment changes and source Advanced notification of treatment changes and sourceadditions. Reevaluation of “tested-out” lead service lines. Reevaluation of “tested-out” lead service lines. Targeted changes based on input from National LCR Review. Key elements of treatment technique requirements are unchanged. Long-term revision process likely to start soon.

28 April 2008 Short-Term Revisions Overview Guidance Documents Six draft guidance documents to assist with implementation: Two public information fact sheets Two public information fact sheets Separate CWS and NTNCWS consumer Separate CWS and NTNCWS consumer information guidance information guidance State Implementation Guidance State Implementation Guidance Water System Monitoring and Reporting Guidance. Water System Monitoring and Reporting Guidance. Final expected Spring Final expected Spring Available at: Available at: On Training CD !

29 April 2008 Short-Term Revisions Overview Compliance Dates 180 days after promulgation (April 7, 2008) unless State has not adopted rule. Date applies to: EPA regions (WY, DC, Tribal). EPA regions (WY, DC, Tribal). States that incorporate by reference using Federal publication date (e.g., MN) States that incorporate by reference using Federal publication date (e.g., MN) Otherwise, earlier of: State’s adoption of rule after April 7, State’s adoption of rule after April 7, December 10, December 10, 2009.

30 Lead and Copper Short Term Revisions and Clarifications Regulatory Changes Monitoring Revisions In F.A.C. The Term “State” shall mean “Department”

31 April 2008 STR Regulatory Revisions Monitoring Revisions Three Areas Revised: Minimum number of samples required. Monitoring and compliance period definitions. Reduced monitoring criteria.

32 April 2008 STR Monitoring Revisions Minimum Number of Samples Required Systems Affected Systems with fewer than 5 taps for human consumption. Regulatory Revision Collect multiple samples from same location on different days to meet 5 sample minimum. States may allow 1 sample per tap for human consumption if < 5 such taps. If < 5 samples, highest result is 90 th percentile level.

33 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (Changes) STR Monitoring Revisions Compliance and Monitoring Period Definitions (Changes) Systems Affected Systems with ALE or qualifying for reduced monitoring. Rule Revisions Provide monitoring and compliance period definitions. Define ALE as date on which monitoring period ends. Clarify timing of actions following ALE. Clarify timing of monitoring. Clarify reduced Pb/Cu tap monitoring period is 4 months. Require reporting to State by October 10 for reduced lead and copper monitoring.

34 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (State Actions) Clarifies timeframe for State actions triggered by ALE. State Decision Months from monitoring period end with ALE Need for corrosion control study12 Optimal CCT for medium systems (no study required) 18 Optimal CCT for small systems (no study required) 24

35 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (System Actions) Clarifies timeframe for system actions triggered by ALE. System Actions From monitoring period end with ALE Public education (lead ALE only)60 days* CCT recommendation6 months Initial source water monitoring and SOWT recommendation 180 days 1 st year of LSLR (lead ALE only)1 day** Materials evaluation w/ initial LSL number12 months** Provide documentation that LSLR requirements were met 12 months** and every 12 months thereafter. *State may grant extension in writing. **Corresponds to 1 st monitoring period with lead ALE after treatment.

36 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (Three-Year Compliance Period)  Triennial monitoring must occur once every 3-year compliance period.  Monitoring period is June – Sept. of same calendar year.  Cannot exceed 3 years between sampling events (see example) June – September Monitoring period June – September Monitoring period Three-year compliance period

37 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (Nine-Year Compliance Period)  Nine-year monitoring must occur once every nine-year compliance period.  Monitoring period is June through September of same calendar year.  Cannot exceed nine years between sampling events (see example). June–September Monitoring period st 9-year compliance period2 nd 9-year compliance period June–September Monitoring period

38 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications) STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications) The STR clarify that: Annual reduced lead and copper tap monitoring starts in CY after 2 nd 6-month period. 1 st annual source period begins during CY State sets MPLs or determines SOWT not needed. If 2 nd 6-month is: Annual Monitoring Begins January – June June 1 of next CY July - December

39 April 2008 STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications – cont.) STR Monitoring Revisions Compliance and Monitoring Period Definitions (Other Monitoring Clarifications – cont.) The STR clarify WQP begin dates: After State sets OWQPs begins: Jan 1 or July 1 for PWSs on standard monitoring. Jan 1 or July 1 for PWSs on standard monitoring. June 1 for small/medium on reduced monitoring.* June 1 for small/medium on reduced monitoring.* Annual WQP monitoring begins during CY after end of the 3 rd consecutive year of 6-month periods of meeting OWQPs. Triennial monitoring begins no later than 3 years after 3 rd consecutive year of meeting OWQPs. * 6-month OWQP compliance period will be June 1 – November 30.

40 April 2008 STR Monitoring Revisions Criteria for Reduced Monitoring Systems Affected Systems qualifying for reduced monitoring based on OWQPs (primarily > 50,000). Rule Revision Cannot qualify for or remain on reduced monitoring if exceed lead AL. Previously, could qualify based on meeting OWQPs. Clarifies standard monitoring resumes Jan. 1 of CY following lead ALE or OWQP excursion.

41 Lead and Copper Short-Term Revisions and Clarifications Regulatory Changes Requirements to Inform the Public

42 April 2008 STR Regulatory Revisions Requirements to Inform the Public Three New or Revised Requirements: Consumer Notification of Lead Tap Water Results. Consumer Confidence Report Lead Informational Statement. Public Education following Lead ALE.

43 April 2008 STR Public Information Lead Consumer Notice Systems Affected All CWSs and NTNCWSs. Rule Revision Provide notice of lead tap water monitoring results. Provide irrespective of whether sample exceeds lead AL. Provide to all served by sampling site -- not just ones with water bills. Provide as soon as practical but within 30 days after receives results. Provide by mail or other State-approved methods. On Training CD !

44 April 2008 STR Public Information Lead Consumer Notice (cont.) Notice must include: Results of lead tap water monitoring. Results of lead tap water monitoring. Explanation of lead health effects. Explanation of lead health effects. Steps consumers can take to reduce exposure. Steps consumers can take to reduce exposure. Facility contact information. Facility contact information. MCLG and AL for lead and their definitions.* MCLG and AL for lead and their definitions.* * Must use CCR Rule language.

45 April 2008 STR Public Information Lead Consumer Notice (cont.) Within 3 months after monitoring period end, send State: Sample of lead consumer notice, and Certification that notification meets delivery requirements. Sample certification available in revised M/R and State implementation guidances.* * * On Training CD !

46 April 2008 STR Public Information Lead Consumer Notice (cont.) New consumer notice M/R violation. Brings number of violations types to 11. Separate violation from public education. Begin date = 3 months and 1 day after monitoring period end. End date = defaulted by SDWIS/ODS to 12/31/2025. Lead Consumer Notification Violation Violation Type Code Contaminant Code Violation Name Definition Lead Consumer Notice Failure to meet any of the following: Provide notice of lead results to individuals served by taps used for lead and copper tap monitoring in accordance with §141.85(d)(1); Meet the timing requirements for providing the notice in accordance with §141.85(d)(2); Meet the content requirements in §141.85(d)(3); Meet the delivery requirements in §141.85(d)(4); and Meet the State reporting requirements in §141.90(f)(3).

47 April 2008 STR Revisions Lead Consumer Notice (cont.) Example System must provide: Consumer notice by 8/14/2009 (30 days after learns results). Sample notice/certification to State by 12/31/2009 (3 mos after monitoring period end). System actually provides: Notice on 1/10/2010. Certification on 4/01/2010. State reports: One 66 violation on 2/15/2010. Begin date = 1/1/2010 (3 mos and 1 day after monitoring period end). End date = 12/31/2025* Compliance achieved = 4/01/2010 PWS monitors June – Sept Receives results on 7/15/09. All results are < 15 ppb. * SDWIS/ODS defaults to 12/31/2025. State reports end date when system returns to compliance

48 April 2008 STR Public Information Consumer Confidence Report Requirement Systems Affected All CWSs Rule Revision All CCRs must include: Sources of lead in drinking water. Sources of lead in drinking water. Health effects from lead exposure. Health effects from lead exposure. Ways to reduce lead in drinking water. Ways to reduce lead in drinking water. Recommended flushing times. Recommended flushing times. Places to go for more information including lead testing. Places to go for more information including lead testing. Required regardless of lead sample levels. Some PWSs must include in 2008 CCR (due July 1, 2009).

49 April 2008 STR Public Information Consumer Confidence Report Requirement (cont.) Must include following mandatory language, or Write own statement in consultation with State. 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 30 seconds to 2 minutes 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 On Training CD !

50 April 2008 STR Public Information Public Education Requirements Systems Affected All systems exceeding lead AL. Rule Revision Shortened mandatory language consisting of: Opening statement, Opening statement, New health effects language provide greater specificity on lead health effects, and New health effects language provide greater specificity on lead health effects, and Sources of further information. Sources of further information. Flushing recommendations can be tailored. Unless waived, State must review and approve materials. Additional delivery requirements to target sensitive populations.

51 April 2008 STR Public Information Public Education – Content Requirements STR Public Information Public Education – Content Requirements Required content for CWSs & NTNCWSs: Information Statement * Information Statement * Health Effects of Lead * Health Effects of Lead * Sources of Lead Sources of Lead Steps to Reduce Exposure Steps to Reduce Exposure What Happened? What is Being Done? What Happened? What is Being Done? For More Information * For More Information * Information must be in appropriate languages. * Must use STR mandatory language. On Training CD !

52 April 2008 STR Public Information Public Education – Content Requirements (cont.) STR Public Information Public Education – Content Requirements (cont.) Required content for CWSs only: Tell consumers how to get their water tested. Tell consumers how to get their water tested. Discuss lead in plumbing components and difference between low lead and lead free. Discuss lead in plumbing components and difference between low lead and lead free. “Special CWSs” can ask to forego these requirements.

53 April 2008 STR Public Information Public Education – CWS Delivery Requirements Printed materials (pamphlets, brochures, posters) to all bill paying customers. Materials to: Local public health agencies Local public health agencies Public and private schools or school boards Public and private schools or school boards Women Infants and Children (WIC) and Head Start programs Women Infants and Children (WIC) and Head Start programs Public and private hospitals and medical clinics Public and private hospitals and medical clinics Pediatricians Pediatricians Family planning clinic Family planning clinic Local welfare agencies. Local welfare agencies.

54 April 2008 STR Public Information Public Education – CWS Delivery Requirements (cont.) Contact local health departments by phone/in- person. Must make good faith effort to locate and deliver materials to following organizations in service area: Licensed child care centers. Licensed child care centers. Public and private preschools. Public and private preschools. Obstetricians-gynecologists and midwives. Obstetricians-gynecologists and midwives. Submit press release to newspaper, TV, and radio stations. Small system can limit activities.

55 April 2008 STR Public Information Public Education – CWS Delivery Requirements At least quarterly provide information on water bill. Water bill must include following statement: Systems serving > 100,000 must post material on web site. material on web 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].

56 April 2008 CWSs must conduct additional outreach activities from list. CWSs serving > 3,300 conduct 3 or more. CWSs serving 3,300 or fewer conduct at least 1. STR Public Information Public Education – CWS Delivery Requirements Public service announcement (PSA) Paid advertisement Display information in public areas to customers Public meetings Delivery to every household Provide materials directly to multi-family homes Other methods approved by State

57 April 2008 STR Public Information Public Education – CWS Timing Requirements Continue as long as ALE persists: Repeat water bill mandatory language at least quarterly. Repeat press releases twice every 12 months. Maintain materials on website (> 100,000 only). Repeat other materials/activities every 12 months. * From end of monitoring period with lead ALE. Delivery within 60 days:* Applies if not already subject to public education. State may grant extension. Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.

58 April 2008 STR Public Information Public Education – NTNCWS Delivery Requirements STR does not change NTNCWS delivery requirements: Distribute pamphlet/brochures to each person served. Distribute pamphlet/brochures to each person served. Post informational posters in public places/common areas in each building served. Post informational posters in public places/common areas in each building served. “Special CWSs” may still use NTNCWS delivery methods. delivery methods.

59 April 2008 STR Public Information Public Education – NTNCWS Timing Requirements * From end of monitoring period with lead ALE. Delivery within 60 days:*  Applies if not already subject to public education.  State may grant extension. Continue every 12 months as long as ALE persists. Although the Federal rule offers a case-by-case extension option, the Department has elected not to exercise this option.

60 Lead and Copper Short-Term Revisions and Clarifications Regulatory Changes Notification of Treatment Changes and Source Additions

61 April 2008 STR Revisions Long-Term Treatment Changes and New Source Additions Systems Affected Systems on reduced Pb/Cu tap monitoring. Rule Revision Requires prior notification and approval of treatment change or source addition. Limits notification of treatment changes to “long- term changes.” Notification due as specified by State, or early as possible prior to change or addition.

62 April 2008 STR Revisions Long-Term Treatment Changes and New Source Additions (cont.) Examples of long-term treatment changes: Switching secondary disinfectants. Switching secondary disinfectants. Switching coagulants. Switching coagulants. Switching corrosion inhibitor products. Switching corrosion inhibitor products. Changing dosage of existing chemicals. Changing dosage of existing chemicals. Installation of membrane filters, ozonation, enhanced coagulation/softening. Installation of membrane filters, ozonation, enhanced coagulation/softening. Does NOT include chemical dose fluctuations associated with daily raw water quality changes.

63 April 2008 STR Revisions Long-Term Treatment Changes and New Source Additions (cont.) Examples of source water additions include: Switching source types. Switching source types. Adding treated surface water to ground water only system. Adding treated surface water to ground water only system. Adding new well from different aquifer. Adding new well from different aquifer. Seasonal or interannual source changes DO NOT require notification if: Covered by previous OCCT studies and sampling, and Covered by previous OCCT studies and sampling, and Covered within OCCT designation framework. Covered within OCCT designation framework.

64 April 2008 STR Revisions Long-Term Treatment Changes and New Source Additions (cont.) Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP Rules Format differs from 1999 manual. Treatment change chapters. Improving or optimizing existing treatment. Addition of new carbon or microbial removal technology. Alternate disinfection strategies. Available at:

65 April 2008 STR Revisions Long-Term Treatment Changes and New Source Additions (cont.) Simultaneous Compliance Guidance Manual -- LT2 and Stage 2 DBP Rules Identifies treatment interactions and impact on key WQPs. Discusses operational considerations for treatment modifications. Provides tools to gather information. Is not cookbook -- won’t provide step-by-step procedure to optimal “right” treatment. procedure to optimal “right” treatment. Provides information to assess situation and consider options. Provides tools for monitoring after change.

66 LCR STR Reevaluation of Tested-Out Lead Service Lines

67 April 2008 STR Revisions Reevaluation of Tested-Out Lead Service Lines Systems Affected Systems subject to lead service line replacement. Rule Revisions Must re-evaluate LSLs that tested < 15 ppb if re-exceed lead AL (“replaced through testing”). Must add to inventory of LSLs to be replaced. Previous sample may no longer be representative. Can either re-test line or replace line. Must consider “tested-out” line each time re-exceed.

68 April 2008 STR Revisions Reevaluation of Tested-Out Lead Service Lines Example 2 years of replacement completed prior to resuming LSLR. 7 of the 50 LSLs were “replaced through testing.’’ 15-year LSLR program. Still has 50 LSLs in inventory because must include those lines previously considered replaced through testing. Must replace 50 lines over 13 years (because 2 years of the 15-year LSLR program has elapsed) = about 4 lines per year. Any retested or newly tested lines < 15 ppb are considered replaced through testing.

69 Questions?


Download ppt "April 2008 Lead and Copper Rule: Short-Term Revisions and Clarifications."

Similar presentations


Ads by Google