Environmental Trade Fair
& Conference
Lead and Copper Rule (LCR)
May 5, 2015
Austin, Texas
Laurie Gehlsen
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
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
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
AESTHETIC COMPLAINTS
• Bitter Taste
• Stained Laundry
• Greenish-blue stains around basins and drains
5
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
SAMPLE SITE SELECTION
• TCEQ Form 20467 / Materials Survey and
Sampling Pool paperwork
• Sampling Pool: must include all sampling
locations in the initial sampling pool.
7
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
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
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
10
LCR POPULATIONS
PWS Size
> 100,000
Standard
Reduced
100
50
10,001 – 100,000
60
30
3,301 – 10K
40
20
501 – 3,300
20
10
101- 500
10
5
5
5
< 100
11
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
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 90th percentiles
• 90th percentiles determine schedules
13
MONITORING SCHEDULE
• Changes - increases & decreases can be
dependent on different criteria:
• 90th 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
14
DETERMINING 90th 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 90th
percentile compliance value
15
90th PERCENTILE
90th PERCENTILE CALCULATIONS
Average of the 4th and
5 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
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
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
METHOD EXAMPLES
• Lead & Copper
• 200.5
• 200.8
• 200.9
• SM 3113 B
• Copper only
• 200.7
19
EPA METHOD LIST
• Official Lead & Copper Method List
http://www.epa.gov/safewater/methods/pdfs/me
thods/methods_inorganic.pdf
20
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
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
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
DRINKING WATER WATCH
• http://dww.tceq.texas.gov/DWW/
• Public view of SDWIS
24
Drinking Water Watch
25
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
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
CONCLUSION
• Compliance with the LCR
• Provide education and outreach
• Protecting public health
28
QUESTIONS
Laurie Gehlsen
TCEQ
Drinking Water Quality Team
Laurie.gehlsen@tceq.texas.gov
512/239-4660