- [Jeni] Hi, my name is Jeni Bolt.
I'm with the Drinking Water and Environment Health division
of the Michigan Department of Environment,
Great Lakes and Energy.
We're going to be going over the Lead and Copper Sample
Site Plan that's due from public water supplies,
January 1st, 2020.
It's going to be a general overview,
if it's possible you missed some
of our other site trainings, we're going to have
a separate video that's just going over the form itself.
To review, we're going to go through a little bit
of the changes to the tiering criteria in the
2018 revisions to lead and copper provisions
of the Michigan Safe Drinking Water Act.
So, in general, the rule sets up tiering criteria
that all sites are determined to be
Tier 1, Tier 2, Tier 3, or Other.
And where you should be sampling for compliance
is based on the risk of lead containing materials
and lead exposure.
All systems should be sampling Tier 1 sites
unless they don't have Tier 1 sites,
and then they must exhaust all higher tier options
before moving to a lower tier like Tier 2, 3, or Other.
If possible, you should be using the same sampling
locations over and over to reduce variability.
And then with the revisions to the rule,
we've refocused the tiering criteria, slightly,
to focus more on lead.
So, just as review, the service line is the discharge
of the corporation fitting, and that's at the main,
the water main and includes the service line,
that's the pipe that connects the water main to the home,
and 18 inches into the home,
or the first shut-off valve, whichever is shorter.
And then if any portion of that is lead,
that includes any lead pigtail, gooseneck, or other lead
fitting connected between that discharge of the corporation
fitting, the 18 inches within the home, is of a lead
containing component, then it is a lead service line.
Just to go over a quick diagram, you've got the water main
that's out in the street, you've got the corporation fitting
that comes off the main, that's the discharge of that
corporation fitting is the start of the service line,
and then it goes all the way into the home to the first
shut-off valve, or 18 inches, whichever's shorter,
and if any portion of that service line is lead,
then it's a lead service line.
So, how this translates into the tiering criteria
is that if a home, a single family residential home
has a lead service line, or lead interior plumbing,
that's a Tier 1 site, with the highest risk of lead
exposure, and that you would sample all of those
locations before moving to a lower tier site.
Tier 2 is the same criteria with the lead service line
or lead interior plumbing, but it isn't a single family
residential home, it's a multi family residence,
or other building.
Tier 3 is then any single family residential site
that's been built before 1988 and has copper plumbing
with lead solder.
And then if you've exhausted all of those options,
then you're to Other sites.
And Other sites should be chosen
based on representative plumbing materials
that are found in the distribution system.
Also part of this is galvanized service lines.
Galvanized service lines pose a potential source of lead
exposure and have been written into the 2018 rule revisions.
But how they effect tiering criteria is if that lead portion
is still there, connected to a galvanized service line,
and that top scenario, it would be a Tier 1
if it's a single family residential home,
or a Tier 2 if it's a multi family home or other building.
Once that lead portion of the service line has been removed,
you know, this may have happened historically,
through some other project,
but if it's only the galvanized portion that still remains,
it's no longer a lead service line,
and is considered to be a Tier 3 or Other
based on the plumbing materials in the home.
Tier 3 would be if that home has copper
with lead solder, before 1988,
and Other would be any other type of building material.
So the Lead and Copper Sampling Plan
has you put these tiering criteria in these sites
that are chosen based on risk of lead exposure
into a plan for your normal compliance sampling.
Like I said, it's going to be required for every community
and non-transient non-community supply,
and needs to be to EGLE by January 1st, 2020.
We do have a sampling plan form that includes instructions,
and it's available on the EGLE website
at michigan.gov/LCR for lead and copper rule.
The number of sampling sites for any given
public water system is based on population.
And if you'll see the two different columns,
there's one column for standard monitoring,
and there's one column for reduced monitoring.
If you're a system that's sampling annual or tri-annual,
you're on reduced monitoring.
What the sampling plan requires you to do
is plan for a number of sampling sites
based on the standard monitoring.
So, you may have only been taking 10 sites
for your reduced monitoring but you need to plan
for your standard monitoring of 20 sites,
if you're a system between 501 to 3,300 people served.
In addition to that, you have to have the minimum
number of sites in your sampling plan,
be the standard number, but preferably,
you would also add in some additional alternate sites.
And we're recommending that you have
about one and half times the standard number of sites.
So, I've got two examples down at the bottom here,
a system that serves 20,000 people
and a system that serves 2,000 people.
For the system with 20,000 people,
the standard monitoring is 60 sites.
If you look at your current monitoring schedule,
and you're of that same population bracket,
but you're only sampling 30 sites,
you're more than likely on a reduced schedule,
either annual or tri-annual.
Your standard is 60, what should be on your sampling
plan is 60 sites, and then we're also recommending
this buffer to have between 60 and 90 sites.
For a system with 2,000, more than likely,
you're sampling 10 sites.
Your standard monitoring is 20 sites,
and your plan should include 20 to 30 sites
to have that buffer for your standard number of sites
that's required in the sampling plan.
We have instructions in the plan, like I said,
it's also online at michigan.gov/lcr and there's
a checklist to go along with this as well.
With the main purpose of it being to review your
current sites, retain those sites with the new,
if they still apply, and are your highest risk
based on those changes to tiering criteria,
replace any of those sites as necessary, and identify new,
appropriately tiered sites, if you need them,
to get up to that standard number of samples.
All right, if you guys have any questions,
[laughs] sorry, skipped ahead just a little bit.
Like I said, the document's available for your convenience
online in either Word or PDF, depending on if
you'd like to fill it on online, and you should
submit that to your local district email box
by January 1st, 2020.
Just to review, these plans are not static documents.
They should be routinely evaluated,
especially, if you find something in distribution system
that's of a higher tier that you should be sampling,
and should be included in your plan.
Couple of a examples would be is if you've had
an entire lead service line replaced, that you would
need to re-evaluate the tier of that site.
If it's no longer a high risk tier, then you would not
include that in your sampling plan, and you would
replace it with another higher tier appropriate site.
If you've had a major home remodel be done, especially,
in that copper with lead solder, before 1988,
that may change the tiering criteria of the site,
and you should re-evaluate whether or not it
should be included in your plan.
And then if you're a system that didn't know that they
had lead service lines but found them through some type
of project, that would change what the highest tier criteria
you would have in your distribution system,
and where you should be sampling
for your compliance samples.
And that would also mean that you need to document that
as far as updating your sampling plan with those sites.
Within the sampling plan, like I said, you should use
the same sites if possible, but there are always reasons
that you may need to find an alternate site, and choose
a different site that's already on your plan,
but that's where that buffer comes in.
These are still samples that are taken at private
residences, the homeowner can refuse, it may be vacant,
or it's had one of those scenarios where you've
had a change in tiering criteria, or the homeowner
has chosen to install a point of use or point of entry
treatment device, such as a softener, a filter,
or a reverse osmosis device.
And that would also change whether or not you should
be sampling at that location.
If you have any questions regarding this,
please contact Heather Jackson or myself at the
email addresses and numbers listed on the slide.
Thank you very much.