1. Environmental Trade Fair & Conference Lead and Copper Rule (LCR) May 5, 2015 Austin, Texas Laurie Gehlsen

2. LEAD & COPPER RULE (LCR) Type of Public Water Systems (PWS) regulated under the LCR: Community Water Systems (CWS) Non Transient Non Community Water Systems (NTNC) Approx. 5,478 PWS must comply with the LCR 2

3. SOURCES Lead and Copper can enter drinking water through the corrosion of plumbing materials The most common problem is with brass or chrome plated brass faucets and fixtures with lead solder Soil contaminated with lead seeps into ground water 3

4. HEALTH EFFECTS Lead Toxicity Permanent damage to brain and nervous system Behavior and learning problems Lower IQ Slowed growth Copper Toxicity Stomach and intestinal distress Liver and kidney damage 4

5. AESTHETIC COMPLAINTS Bitter Taste Stained Laundry Greenish-blue stains around basins and drains 5

6. REGULATIONS 1986 – EPA Lead Ban 1991 – Lead and Copper Rule (LCR) 2000 – Minor Revisions to LCR 2007 – Short Term Revisions to LCR 2011 – Lead Reduction Act ???? – Long Term Revisions to LCR 6

7. SAMPLE SITE SELECTION TCEQ Form 20467 / Materials Survey and Sampling Pool paperwork Sampling Pool: must include all sampling locations in the initial sampling pool. 30 TAC § 290.117(c)(1)(b) 7

8. CWS TIERS Tier 1: Single family structures that contain copper pipes with lead solder installed after 1982 or contain lead pipes and/or are served by a lead service line. Tier 2: Multi-Family structures that contain copper pipes with lead solder installed after 1982 or contain lead pipes and/or are served by a lead service line. 8

9. CWS TIERS Tier 3 – Single family structures that contain copper pipes with lead solder installed before 1983. “Other” – If the water system has no Tier 1, 2, or 3, it should use “other” 9

10. NTNC TIERS Tier 1: Buildings that have copper pipes with lead solder installed after 1982 and/or contain lead pipes and/or served by a lead service line. Tier 2: Buildings that have copper pipes with lead solder installed before 1983. Tier 3: not applicable 30 TAC § 290.117(c)(1)(b) 10

11. LCR POPULATIONS PWS SizeStandardReduced > 100,00010050 10,001 – 100,0006030 3,301 – 10K4020 501 – 3,3002010 101- 500105 < 10055 11

12. LCR MONITORING PERIODS INITIAL / STANDARD (6M1 or 6M2) 6 month sampling schedule Jan 1-June 30 or July 1-Dec 31 New PWSs PWS with action level exceedances REDUCED (RED) 1 year or 3 year sampling schedule Seasonal sampling dates June 1 – Sept 30 12

13. COMPLIANCE LEVELS Action Level (AL) for Lead is 0.015 mg/L Action Level (AL) for Copper is 1.3 mg/L Reduced Monitoring Level (RML) for Lead is 0.005 mg/L Reduced Monitoring Level (RML) for Copper is 0.65 mg/L Compliance is based on 90 th percentiles 90 th percentiles determine schedules 13

14. MONITORING SCHEDULE Changes - increases & decreases can be dependent on different criteria: 90 th percentile Population changes Sample at incorrect # of sites Sample at incorrect sites not on sampling pool Sample off season Analytical results in SDWIS on time 30 TAC § 290.117(c)(2)(A) 14

15. DETERMINING 90 th percentile Separate Lead values from copper values Order samples in order of lowest value to highest value Take the number of samples and multiply by 0.90 (ex. 20 samples x 0.90 = 18) The number derived from step 3 is the 90 th percentile compliance value 15

16. 90 th PERCENTILE 90th PERCENTILE CALCULATIONS 5 Average of the 4th and 5th highest samples 109th Highest Sample 2018th Highest Sample 3027th Highest Sample 4036th Highest Sample 5045th Highest Sample 6054th Highest Sample 10090th Highest Sample 16

17. LABORATORIES TCEQ NELAP accredited Laboratories found at: http://www.tceq.state.tx.us/assets/public/complia nce/compliance_support/qa/txnelap_lab_list.pdf 17

18. BOTTLES NELAP Accredited laboratory will provide you with one liter unpreserved laboratory grade bottles to use for sampling. Official TCEQ Form 20683 – Tap Sample Submission Form accompanies bottles back to laboratory for analysis 18

19. METHOD EXAMPLES Lead & Copper 200.5 200.8 200.9 SM 3113 B Copper only 200.7 19

20. EPA METHOD LIST Official Lead & Copper Method List http://www.epa.gov/safewater/methods/pdfs/me thods/methods_inorganic.pdf 20

21. LEAD CONSUMER NOTICE TCEQ Form 20680 Provide notice of all lead sampling results – regardless of exceedance - to persons served at the sites within 30 days 21

22. LEAD CONSUMER NOTICE Submit copy of certification to TCEQ 90 days after the monitoring period ends. Monitoring Period end dates: June 30 Sept 30 Dec 31 22

23. M/R VIOLATIONS AND RTC PWSs are responsible for making sure they are in compliance with the regulations set forth in 30 TAC 290 Subchapter F TCEQ is currently processing monitoring and reporting violations 23

24. DRINKING WATER WATCH http://dww.tceq.texas.gov/DWW/ Public view of SDWIS 24

25. Drinking Water Watch 25

26. LCR WEB SITE Texas Drinking Water Watch 2015 Systems scheduled to sample PWS Required tap water sample site paperwork Laboratory information Water quality parameters Corrosion Control Study information 26

27. LCR WEB SITE PWS Required Tap water sample site paperwork TCEQ Form 20467 (site selection) TCEQ Form 20683 (tap sample submission) TCEQ Form 20680 (consumer notice) http://www.tceq.texas.gov/drinkingwater/chemica ls/lead_copper/lead-copper.html 27

28. CONCLUSION Compliance with the LCR Provide education and outreach Protecting public health 28

29. QUESTIONS Laurie Gehlsen TCEQ Drinking Water Quality Team Laurie.gehlsen@tceq.texas.gov 512/239-4660