pennsylvania DEPARTMENT OF ENVIRONMENTAL PROTECTION June 3,2016  Re: Requirements and Recommendations for Community Water Systems (Population <5 50,000)  Under the Lead and Copper Rule  Dear Public Water Supplier:  This letter isi intended to remind you of your responsibilities under the Lead and Copper Rule (LCR) and to provide some recommendations for improving public health protection and consumer confidence. The purpose of the LCR is to protect public health by minimizing lead and copper levels in drinking water, primarily by making water less corrosive. Thel LCR establishes an action level of 0.015 mg/L for lead and 1.3 mg/L: for copper. An action level exceedance is not a violation but can trigger other requirements that include water quality parameter monitoring, corrosion control treatment, source water monitoringtreatment, public education, and lead service line replacement. The following requirements and recommendations fall into three categories: sample site selection,  monitoring and reporting, and optimized corrosion control treatment.  Sample Site Selection:  As per $109.1103(g), all systems monitoring under the LCR are required to develop a sample site  location plan that includes the following elements:  Ar materials evaluation oft the distribution system Lead and copper tap sample site locations Water quality parameter sample site locations Certification that proper sampling procedures are used  As part of the materials evaluation, water suppliers are required to review several sources of information (including plumbing codes, permits, and records ini the: files ofeach municipality) in order to identify a sufficient number ofl lead and copper tap sampling sites. The materials evaluation shall be updated, as necessary, to ensure a sufficient number ofs sampling sites. Water suppliers are: required to select all Tier 1 sample sites for both initial and reduced monitoring. Tier 1 sample sites consist of single family structures that have one or more oft the following:  Copper pipes with lead solder installed after 1982  Lead pipes Lead service lines  Iflead service lines exist, at least 50j percent oft the sample sites shall be sites with lead service lines. The use ofTier 2 or Tier 3 sites must be properly documented along with aj justification ofwhya sufficient number ofTier 1 sites are not available. An acceptable justification would be that Tier 1  Bureau of Safe Drinking Water  Rachel Carson State Office Building! P.O. Box 8467 Harrisburg, PA 17105-8467 717.772.4046 www.c dep. pa.gov    -2-  sites do not exist, or that homeowners at Tier 1 sites refused toj participate in the monitoring program.  An incomplete materials evaluation is not an acceptable justification.  IfTier 2 or Tier 3 sample sites must be used, the sites shall consist oft the following:  Tier 2 sites shall consist ofb buildings, including multi-family residences, that have one or  more oft the following: Lead pipes Lead service lines installed before 1983  Copper pipes with lead solder installed after 1982  Tier3 sites shall consist of single family structures that contain copper pipes with lead solder Ifadditional compliance samples are collected above the minimum required number of samples, the samples should be from the highest risk sample sites in order to avoid diluting the sampling pool. As per $109.1107(a)(1), the sample site location plan must be submitted to the Department of Environmental Protection (DEP) prior toi initial monitoring or upon request. DEP notified all water suppliers in 2004 to submit any remaining sample site location plans. Additionally, water suppliers are responsible for updating the plan within the first 10 days following the end of each applicable  monitoring period as follows:  Identify lead and copper tap sample sites that are different from sites sampled during Identify any changes to water quality parameter sample sites from sites sampled during  previous monitoring periods previous monitoring periods Update the sample procedure certitication  In addition to the above-mentioned requirements, both DEP and the U.S. Environmental Protection Agency (EPA) strongly recommend that water suppliers increase transparency by posting on their public website the sample site location plan and materials evaluation (including the locations oflead service lines), together with any updated inventory or map oflead service lines and lead plumbing in the system. These plans should be posted for the 2016-2 2018 monitoring cycle. Ifa public website isi not available, the sample site location plan and materials evaluation should be made available to the public upon request. Homeowner names and exact addresses may be redacted for privacy  purposes.  Monitoring and Reporting: include the following:  As per $109.1103(h), the LCR specifies lead and copper tap sample collection procedures that  Each sample must be a first-draw sample that is 1 liter in volume and has stood motionless in  thej plumbing system of each sampling site for at least 61 hours.    3-  Samples from residential housing shall be collected from the cold water kitchen tap or bathroom sink tap. First-draw samples from ai nonresidential building shall be collected at an First-draw samples may be collected by the water supplier or by residents (ifthe residents are The water supplier must make every reasonable effort to collect tap samples from the same sampling sites that were used fori initial monitoring. Ifan original sampling site is not available, a tap sample may be collected from another sampling sitei in the sampling pool as long as the new site meets the same targeting criteria, and is within reasonable proximity to EPA recently posted new guidance on lead and copper tap sample collection procedures. A copy of this guidance, Clarification of Recommended Tap Sampling Procedures for Purposes oft the Lead and  interior tap from which water is typically drawn for drinking. properly instructed oft the sampling procedures).  the original site.  Copper Rule is enclosed for your reference and includes the following:  Water suppliers should NOT recommend the removal or cleaning of aerators prior to or during the collection of lead and copper tap samples because this practice could mask the Water suppliers should NOT include aj pre-stagnation flushing step in the sampling instructions for homeowners because pre-stagnation flushing may potentially lower the lead Lead and copper tap samples should be collected using wide-mouth bottles because wide- mouth bottles allow fora al higher flow rate during sample collection - which is more representative oft the flow that a consumer may use to fill up a glass ofwater.  added contribution ofl lead at the tap.  levels as compared to when it is not practiced.  DEP concurs with this guidance and strongly recommends that you update your sample collection Asar result of recent events and national media coverage, many water systems have been conducting additional first-draw lead and copper testing or are responding to customer requests for additional sampling. Please note that these sample results must be reported to DEP. Some of the results may also bei included in the 90th percentile compliance value calculation. Ifa sample is collected from a site that meets the sample site location and sample collection criteria during an LCR compliance monitoring period, the results would be included ini the 90th percentile compliance value calculation and should be reported as sample type 'D. Any other first-draw sample result that does not meet the required criteria should be reported as sample type 'S' -t these are NOT: included in any 90th percentile compliance value calculation. A copy ofEPA's 2004 memo on Clarification of Requirements, for Colleting Samples and Calculating Compliance is also enclosed for your reference. Finally, both DEP and EPA strongly recommend that you enhance your efforts to ensure that residents promptly receive lead sampling results from their homes, together with clear information on lead risks and how to abate them, and that the general public receives prompt information on high  procedures for the 2016- : 2018 monitoring cycle.  lead levels in your drinking water system.    4-  Optimized Corrosion Control Treatment:  As per $109.1102(b), all water: systems are required to optimize corrosion control treatment (OCCT), and maintain OCCT at all times to ensure public health protection. Thisi includes before, during, and Any changes in source water or treatment must be approved by DEP via aj permit or permit amendment prior to making the change. As per $109.602(a), PWSI Permit Module 1- Completeness: Report( 0900-NEBSDW02540) and the Instructions for PWS Permit Application 090-PNEBSDW0259. the application must include an assessment ofs simultaneous compliance with thel LCR and other rules. Evaluating simultaneous compliance may involve a system-wide assessment prior to changing sources or treatment facilities. You may also be required to conduct additional lead and copper tap or other compliance monitoring to assess baseline and post-change Changes in source water include the addition or removal of sources or interconnections. It may include changes in flow or blending ratios ift these changes have the potential to affect water quality parameters or OCCT. Finally, it may also include the use of permitted but unused sources that may not have been included in any previous LCR monitoring or evaluation ofOCCT. Itisi imperative that any changes in sources and/or treatment are: fully assessed and approved by DEP prior to making the In closing, the LCR was first promulgated in 1989 and has undergone several revisions since then. The rule is arguably one oft the most complex rules and is often difficult to understand. However, lead in drinking wateri is a serious health concern and we trust that yous share our commitment to protecting public health. Ifyou have any questions regardings your responsibilities under the LCR or the requirements and recommendations includedi in this letter, please feel free to contact your local  after making a modification or change in source water or treatment.  water quality.  change.  DEP district office. Sincerely, hi Lisa) Daniels Director Enclosures  D Caie  Bureau ofSafe Drinking Water  cc: DEPI District Office