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WaterOperator.org Blog

Articles in support of small community water and wastewater operators.

Effective Lead Sampling

Effective Lead Sampling

While the Lead and Copper Rule (LCR) has helped reduce lead in drinking water over the past 25 years, complying with sampling requirements can certainly be challenging! Even when a water system faithfully follows protocols, results can be inconsistent and/or unreliable. While the conditions in which samples are taken, or procedures used, are often out of the hands of water operators, the results of these tests can have significant consequences for their water systems, not to mention the communities involved. Just ask the residents of Flint, Michigan. 

Last year, in response to these concerns, the EPA released this memo to clarify tap sampling procedures. In addition, in a move towards a rule revision due out soon, the EPA has also recently issued a LCR Revisions White Paper that offers suggestions on how to improve the rule as well as considerations for improving tap sampling. 

In this white paper, the NDWAC Lead and Copper Rule Working Group corroborates what operators have been saying all along:  the LCR sample site selection and sampling process "provides opportunity for error, particularly given that samples are collected by residents themselves."  In addition, the group says the current system provides "opportunities for systems to implement sampling procedures to avoid exceeding the action level..." 

How to fix the problem? The group suggests substituting a voluntary customer-initiated sampling program for the current LCR tap sampling requirements and/or partnering with technology developers to identify and develop real-time monitoring technologies (such as this inexpensive lead monitor), among other things.

All this is well and good, but until this technology becomes available, and/or a more prescriptive sampling guidance or revised rule released, what is a water operator to do? Is there any sampling method that offers the most reliable results in the most efficient way?

This is the topic of a recent AWWA/WRF study entitled “Evaluation of Lead Sampling Strategies”. The study found that the answer to this question does not come easily. In fact, according to the study, "no sampling method was particularly proficient at finding the peak lead level compared to doing a full profile for each sampling event”. In addition, the type of lead found in samples was inconsistent: “even at a specific site, on some occasions the sampling can be particulate dominated and on other dates the lead can be dissolved dominated or some combination,” the report states.

It is no wonder that water operators across the country may welcome further guidance on this rule. In the meantime, Michigan's DEQ offers a couple of helpful resources: these sampling instructions can help water systems assure residents are following proper procedure and this sample site selection criteria factsheet can help systems ensure a large and diverse enough sampling pool. Please note that the use of guidance material from EPA, other states, and third-parties can offer insight and clarification, but should not be considered a substitute for policies and guidance from your primacy agency. 

To get an update on lead issues in the water industry, join this webinar that will be presented by the VA-AWWA in November. 

Finally, be sure to check out this AWWA video featured on our blog earlier this year: Lead and Copper Sampling.

Preparing a consumer confidence report

July 1 is around the corner, the deadline for community water suppliers to deliver their annual Consumer Confidence Report (CCR) to their customers. The CCR is a water quality report or a drinking water quality report, and is required under the U.S. Environmental Protection Agency’s Consumer Confidence Report Rule.

Every community water system serving at least 15 service connections and/or 25 people year round must prepare and distribute a report. To assist with preparing these, the EPA provides compliance tools and documents.

Gathering Results

The reports are based on calendar-year data, so your report due to customers this July 1, 2017 will be based on data collected between January and December 2016. CCRs must show the highest level of each detected contaminant (this is usually the value you report to the state to determine compliance) and the range of levels of that contaminant you found during the CCR calendar year assuming more than one sample was collected.

Additionally, the CCR Rule requires that drinking water standards and water sample results are presented as numbers greater than or equal to 1.0 in order to enhance consumer understanding of their drinking water quality. These units are often referred to as CCR units. For conversion assistance, view Converting Laboratory Units into CCR Units.

Writing the Report

Briefly, CCRs must include contact information for your utility, identify the water source, define acronyms and technical terms, report and explain levels of contaminants, explain any violations, variations and exemptions, and finally, include some required educational language. A complete explanation of CCR requirements begins on page 7 of the EPA document Preparing Your Drinking Water Consumer Confidence Report: Guidance for Water Suppliers. The document also includes sample language and definitions you can use, a certification form, and examples of CCRs.

As you begin formatting your CCR report, be sure to check the EPA’s Best Practices Fact Sheet for tips on formatting and language that will make your report easy for customers without your technical knowledge to understand.

Distribution to Customers

Distribution requirements can vary. In some states, the mailing requirement may be waived for systems serving less than 10,000 and substituted with a different option, such as publishing the CCR results in one or more local newspapers. If the mailing requirement is waived and your system serves less than 500, then you do not need to publish in a newspaper, but at least once a year, you must notify customers through a mailed, delivered, or posted notice that the CCR is available from your water system upon request.

In addition to sharing sampling results with your customers, the CCR is an opportunity to share the work you’ve completed to produce their drinking water, manage problems, and introduce future improvements and requirements for your utility.

Information for Your State

And finally, don’t forget to visit WaterOperator.org’s document library to find help documents and samples specific to your state. Simply select your state from the filters and enter a keyword search for “Consumer Confidence Report” or “CCR.”

Featured Video: Arsenic Treatment in a Rural Town

Over time, low levels of exposure to arsenic can result in cancer. This is a sobering fact for anyone, but it's particularly challenging for small rural towns with arsenic in their drinking water. When neither the utility nor the residents have access to other water options, treatment is of the utmost importance. But because arsenic doesn't cause taste or odor issues, or produce immediate health effects, getting that treatment in place can sometimes be difficult. Learning how other small utilities did it can help. In this week's video, the manager of a small rural utility in Montana introduces his utility and describes how they chose to put arsenic treatment in place for their system.

For more on arsenic in drinking water topics, see this USEPA factsheet (PDF), or search our document database using the category Arsenic.

Featured Video: Coliform Sampling Best Practices

Have you ever had a coliform sample come back positive, gone through the trouble and expense of re-sampling, and discovered your first result was a false positive? If so, you know what a frustrating, time consuming, and expensive process it can be. One way to avoid having this happen to you is to be very rigorous in your sampling technique when you collect the sample. This video from our partners at the Rural Community Assistance Partnership (RCAP) walks you through the 13 steps of total coliform sampling, and discusses how to find a good sampling site.

For more RCAP videos, visit their channel on Vimeo. For more on the Total Coliform and Revised Total Coliform Rules, see the EPA's website.

Featured Video: Lead and Copper Sampling

For the past three weeks, we've talked about the dangers to drinking water quality posed by water storage facilities, and discussed what you can do to combat them. But there's another source of drinking water contamination that's gotten a lot more press in the past few years, and that's the distribution system. Lead and copper pipes are known for their ability to leach metal into the water they contain. When the pipes are particularly exposed or the water chemistry is particularly favorable, they can leach a lot. If your customers have an increased interest in getting their water tested---or you'd like a refresher on how lead and copper sampling works yourself---this video from AWWA can be a great place to start. The two-and-a-half minute video briefly outlines the basic provisions of the Lead and Copper Rule, and goes on to discuss the proper technique for collecting lead and copper samples.

The Quick Reference Guides mentioned in the video can be found on the USEPA website here. The page with additional resources on the rule is here. To see what consumer information resources other utilities and states have developed for the Lead and Copper Rule, search our document database using the category Lead and Copper and the type Factsheets/Case Studies.

Featured Video: Safe Drinking Water Act Anniversary

As December draws to a close, let's take a moment to commemorate the passing of the Safe Drinking Water Act 42 years ago, in December of 1974. For the fortieth anniversary, the Minnesota Department of Health released this video. The reminiscences on this landmark legislation include interview excerpts with former Vice President Walter Mondale (a Minnesota native) who was part of the Senate that passed the bill.

As we get ready to begin a new year, it's worth remembering how much public water utilities have accomplished in their vital work protecting public health. Though they may sometimes feel invisible, your efforts help protect the health and well-being of the people in your communities. Whatever else this past year might have brought you, that is certainly a reason to celebrate this New Year's Eve.

What We Can Learn from Flint

It’s not often that drinking water gets in-depth news coverage and front page headlines, but I think we’re all just sad that it happened this way. The story of Flint, Michigan’s drinking water crisis has unfolded over nearly two years, but the national media attention escalated rapidly in the past month.

I believe I speak for every one of our WaterOperator.org readers when I say this just hits too close to home. This is our industry, these are our friends and colleagues, and of course, the people of Flint are our neighbors in trusting that tap water will always deliver.

There’s no role for blame because we’ve all lost on this one. And when you go beyond the issues of oversight, social justice, and politics, there’s a story about the challenging decisions that operators, utility managers, and local government officials make day-to-day. These jobs have aways been hard, but we now have an opportunity to grow, change, and do better.

This could have happened anywhere, but it doesn’t have to happen in your community. Here’s what everyone can learn from Flint:

Unintended consequences are real.

The story of Flint highlights the critical balancing act required to serve drinking water that meets every standard. One change (large or small) can have cascading effects on the entire treatment train and distribution system, so decisions should not be made lightly. Appendix C (Guidance for Evaluating Impacts of Treatment Changes on Distribution Systems) and D (Tools for Evaluating Impacts of Treatment Changes on Lead and Copper Rule Compliance) within the Simultaneous Compliance Guidance Manual are solid, first-step references.

Don’t be afraid to ask for help.

State and federal agencies are made up of people who care about what they do. So not only is it their job to help systems make better decisions, they want to do the right thing. They also know others with additional technical expertise, including researchers and technical assistance providers, who can consult with you at no cost. Ask for assistance when planning changes or as soon as you know there is a problem. If you’re not sure whom to contact, here’s the list of primacy agency websites. You can also contact us (info@wateroperator.org) and we’ll find someone who can help.

Public health is the priority.

A water system’s ultimate job is not to meet compliance, but to provide safe drinking water and protect public health. Regulations are the baseline mechanism for getting there, but thinking holistically about what’s logical can prevent unintended consequences. There are certainly flaws in the Safe Drinking Water Act regulations, so the Water Supply Guidance (WSG) manual offers policy statements and clarifications on intent as a starting point.

Trust is easier to break than restore.

It is always better to act out of an abundance of caution and be wrong, than it is to do nothing out of fear. Early, active, and consistent public communication (even when the answers are still uncertain) will go far to maintain the public’s trust in the water system and the local government. We’ve compiled some of the best resources on risk communication requirements and best practices.

The situation in Flint is more than unfortunate, but we can all reduce the chance that it will happen again and be more prepared to react in any emergency situation. Our thoughts are with each and every one of you working beyond measure to make this right.

Coliform Sampling Best Practices

Our partners at the Rural Community Assistance Partnership (RCAP) have released a new instructional video on how to collect coliform samples.

"Coliform sampling is an important part of monitoring the water quality in all drinking water systems. Collecting coliform samples correctly is absolutely critical in protecting public health. Improper sampling is the most common reason for false positive results. Positive results, even false positives, require repeat sampling, which result in extra effort, time, and money. In this video, we will cover 13 steps to proper coliform sampling and discuss how to find a good sampling site."


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