Plumbing Replacement Program . A Non-Chemical Corrosion Control Treatment Option Presenter: Russ Kazmierczak, DHS DWP, Springfield Office. Background.
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Plumbing Replacement Program A Non-Chemical Corrosion Control Treatment Option Presenter: Russ Kazmierczak, DHS DWP, Springfield Office
Background • The Plumbing Replacement Program for Non-Transient Non-Community Water Systems is an outcome of the Lead Contamination Control Act (LCCA) of 1988 and the Lead and Copper Rule (LCR) of 1991. • The intent of the LCCA was to help schools served by a public water systems identify and reduce lead in drinking water. • The 1991 LCR addressed lead and copper in all community water systems (CWS) and non-transient non-community (NTNC) water systems. • Schools or other NTNC systems that own and operate their own public water system are subject to the LCR.
Act/Rule HighlightsLCCA • Identification of coolers that are not lead free. • The repair or removal of water coolers with lead lined tanks • A ban on the manufacture and sale of water coolers that are not lead free • The identification and resolution of lead problems in schools drinking water. • The authorization of additional funds for lead screening programs for children. • Not federally enforceable, states have the option to enforce.
Act/Rule HighlightsLCR • Protects public health by minimizing lead (Pb) and copper (Cu) levels in drinking water, primarily by reducing water corrosivity. • Establishes action level (AL) of 0.015 mg/L for Pb and 1.3 mg/L 90th percentile level of tap water samples. • AL exceedance can trigger other requirements that include water quality parameter monitoring, corrosion control treatment (CCT), source water monitoring/public education, and lead service line replacement (LSLR). • Monitoring not required at Schools or Non-Residential Buildings (NRBs), unless they have their own water supply.
Issues with LCR • LCR testing protocol used to identify system wide problems and not problems in single outlets (i.e. individual faucets and drinking water fountains). • LCR rule requires water system to follow testing protocol different than the one used to evaluate fixtures in schools. Plumbing Replacement Program uses LCR sampling protocol. • LCR primarily addresses Pb and Cu throughout the entire system using corrosion control treatment and does not address specific sources such as fixtures.
Action Level Exceedance Compliance Requirements • Public education (does not apply to Copper). • Water quality parameter (WQP) monitoring. • Source water monitoring and source water treatment. • Corrosion Control Treatment (CCT) – Chemical and Non-Chemical (Plumbing Replacement Program).
CCT Evaluation • Must submit a Letter of Recommendation to DWP, based on consultation with the County, on how system is to address AL exceedance. • Chemical CCT Option- Recommendation based on the Guidance Manual for Selecting Pb/Cu Control Strategies document (see web site links handout). • Non-Chemical CCT Option (Plumbing Replacement Program) – Recommendation based on the 3Ts for Reducing Lead in Drinking Water in Schools (replaces the 1994 EPA guidance document Drinking Water in Schools and Non-Residential Buildings).
Plumbing Replacement Program Guidance Procedure Overview • Develop Plumbing Profile. • Develop a Sampling Plan and receive approval from County/DWP prior to implementing. • Sample all reasonable sites using First Draw Sampling Procedure (see web page links for EPA guidance). You should include: • All fountains, coolers and bubblers readily accessible to students (particularly the youngest students). • Other faucets or outlets regularly used to gather drinking or cooking water. • At least one sample from each area used for food preparation. You do not need to include: • Faucets and outlets used for cleaning, maintenance or other non-consumptive uses. • Lab, washroom, art room and shop outlets. • Irrigation outlets.
Guidance Procedure Overview(continued) • Replace sites that exceed AL and try use Zero/Ultra Low Lead fixtures. • Resample sites that continue to exceed, use Follow-Up Flush Sampling Protocol (see attached handout).
Guidance Procedure Overview(continued) • If fixture was replaced with low lead brass (8% or less lead) and remains a problem, may need replacement with Zero/Ultra Low Lead fixture. • After sampling and replacement complete, submit to County/DWP a written description of Plumbing Replacement Program (see attached Plumbing Replacement Program Procedure).
Plumbing Replacement Program Misunderstandings • Guidance documents referenced in the Plumbing Replacement Program Procedures were written for Schools or Non-Residential Buildings on a PWS. They are not guidance documents for compliance with the LCR. • Sample collection procedures in guidance documents do not comply with the Pb and Cu LCR and if followed could result in invalidation of sample results. • What is reasonable a sample site (see web page links handout)?
Plumbing Replacement Program Highlights • Developed by Oregon DWP staff and based on a common sense approach using the historic Lead Contamination Control Act (LCCA) and at the same time complies with the LCR. • Non-Chemical Corrosion Treatment/Plumbing Replacement Program (LCCA) is specific to Oregon and is not referenced in the LCR or any of the guidance documents or fact sheets. • Gives NTNC (schools and non-residential buildings) water systems an alternative to adding corrosion chemicals to their water supply and can potentially save the school money in labor and maintenance costs.
Plumbing Replacement Program Highlights • Schools and non-residential buildings receive the benefit of being able to eliminate the cause of the problem instead of treating the symptom. • EPA recognizes Oregon’s Plumbing Replacement Program, as long water systems remain in compliance with the LCR rule.