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January 2023
The Pennsylvania Department of Environmental Protection (DEP) Bureau of Safe Drinking Water is proud to provide updates, information, explanations and reminders to you with this edition of the Drinking Water News. In this issue:
- Service Line Inventory Methods and Expectations
- Risk Mitigation Measures for Lead Service Line Replacement
- UCMR 5: An Overview
- The PFAS MCL Rule
- UCMR 5 and the PFAS MCL Rule
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| January 2023 Special Edition – Regulatory Update
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| Service Line Inventory Methods and Expectations
Sabrina Haydt, Water Program Specialist & William McNamara, Environmental Group Manager DEP Central Office
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Since the last article was published, additional resources for completing a Service Line Inventory have become available. The first is the Environmental Protection Agency (EPA) Guidance for Developing and Maintaining a Service Line Inventory. The second is the DEP Service Line Inventory spreadsheet template which is available on eLibrary and can be accessed by searching under Safe Drinking Water forms for Service Line Inventory Form, or by typing the form number (3930-FM-BSDW0042A) into the search function. Finally, DEP staff have been conducting Service Line Inventory training for water suppliers since October and will continue these efforts through 2023. Water suppliers should occasionally visit DEP’s LCR website for updated information, resources and guidance.
Following release of EPA’s guidance, DEP was also able to set expectations for what is considered sufficient evidence for a water system to categorize a service line as “Non-lead”; these expectations will be the focus of the remainder of this article.
All service lines within a water system must be categorized as one of the following in the Service Line Inventory: “Lead”, “Galvanized Requiring Replacement”, “Non-lead”, or “Lead Status Unknown”. For any service line that is categorized as “Non-lead”, the LCRR specifies that it must be determined through an evidence-based record, method, or technique. Therefore, if your service line investigation concludes that the pipe material is non-lead (e.g. copper), your water system is expected to show sufficient evidence through either one of the “stand-alone” verification options, or a combination of two or more other methods as described below.
- “Stand-Alone” Records Method Options: If your water system is able to use one of the following records verification methods, you do not need an additional method to verify the pipe is non-lead:
- Records indicating an installation/replacement date after January 6, 1991 (the effective date of the PA Lead Ban)
– OR – - Record of a local ordinance prohibiting lead service line installation and water system records indicating service line installation/replacement after the ordinance effective date.
- Combination of Two (or more) Other Methods: If your water system records do not meet either of the criteria above, you may use any TWO other investigation techniques from the following list.
- Records review
- Modeling/Statistical analysis
- Water sampling (only for water systems without corrosion control treatment)
- Field verification; options include*:
- Visual inspection at existing access point
- This includes any access points in which you can clearly determine the material type of the service line, such as a meter pit, or the service line entry to the basement at the customer side.
- Closed-Circuit Television (CCTV) inspection outside the pipe – at curb box
- Mechanical excavation at a location along each half of the service line (i.e. customer-side and system-side)
- Other method reviewed by DEP
- These include emerging technologies and need to be approved by DEP to determine acceptance. If there is an emerging technology that you would like to utilize be sure to reach out to DEP prior to use.
- Representative Field Verification: Note that if a system is verifying records using a field method, a statistically sound subset of service lines can be field verified, rather than every line. Systems should follow the procedure established in the Michigan EGLE “Minimum Service Line Material Verification Requirements” document. This method should only be used for a homogeneous area, such as a residential neighborhood in which the houses were built in the same time period.
Example Use of Combination of Two Methods for “Non-lead” Evidence: A water system has records that indicate a service line that was installed in 1985 is made of copper. Since this is prior to the PA lead ban, a second verification of the records is expected. The system chooses to verify the records through CCTV inspection of both sides of the service line at the curb box.
- “Stand-Alone” Field Method Options: For a water system unable to utilize any methods previously discussed, there are two stand-alone field verification methods. Use ONE of the following verification methods:
- Internal CCTV inspection inside the full length of the service line
– OR – - Mechanical excavation in at least 3 locations over the length of the service line as follows (see visual diagram below):
- Curb stop to building:
- A minimum of 18 inches from the curb stop
- If the distance to the building is less than 18 inches, halfway to the building
- Curb stop to water main:
- A minimum of 18 inches from the curb stop
- If the distance to the water main is less than 18 inches, halfway to the main
- Third point (choose one):
- Inside the home where the service line enters (inspected by water system personnel, not customer)
- A second excavation point in the longer section of service line that is at least halfway between the first point and the building or water main.
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It is important to note that DEP’s Service Line Inventory spreadsheet will determine if you have provided sufficient evidence for a “Non-lead” service line and will appropriately categorize the service line for you based on information provided.
As we have discussed, there are a lot of verification options available to water systems as you are working on completing your Service Line Inventory. In most cases you will find that your water system utilizes several different methods for verification across the entire water system and that is encouraged. Most important is that the Service Line Inventory developed by your water system is accurate and complete.
Don’t forget the deadline for submitting an initial Service Line Inventory is October 16, 2024, so if you haven’t started yet, the time to begin is NOW.
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| Risk Mitigation Measures for Lead Service Line Replacement
Sabrina Haydt, Water Program Specialist, DEP Central Office
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Is your water system in the process of replacing, or planning to replace lead service lines, galvanized service lines or lead pigtails, goosenecks or connectors in your distribution system?
If your answer to this question is “Yes”, then it’s great to hear that you are working to complete service line improvements to your drinking water distribution system. However, it is important to note that the Environmental Protection Agency (EPA) has stated that lead service line replacements (LSLR) are associated with short-term elevated drinking water lead levels for some period of time after replacement. To combat these elevated lead levels and ensure that LSLR are completed properly, risk reduction measures (RMM) have been developed for water systems to implement.
In accordance with §109.4(4), public water suppliers shall take whatever investigative or corrective action is necessary to assure that safe and potable water is continuously supplied to the users. Therefore, to comply with this regulation and address concerns associated with elevated lead levels, any water system that is conducting LSLR, including galvanized requiring replacement service lines, or that removes a lead pigtail, gooseneck or connector, is expected to follow the RMM outlined in this document for the associated customer(s).
What risk mitigation measures must be followed?
There are three RMM outlined below that are expected to be completed in conjunction with replacement of each lead service line, galvanized requiring replacement service line, and the removal of lead pigtails, goosenecks or connectors.
1) Provide notice to the owner of the affected service line, or the owner’s authorized agent, as well as non-owner resident(s) served by the affected service line before the affected service line is returned to service.
The notice must meet the following requirements:
a. Include the following mandatory health effects language established by the EPA under 40 CFR 141.85(a)(1).
“Exposure to lead in drinking water can cause serious health effects in all age groups. Infants and children can have decreases in IQ and attention span. Lead exposure can lead to new learning and behavior problems or exacerbate existing learning and behavior problems. The children of women who are exposed to lead before or during pregnancy can have increased risk of these adverse health effects. Adults can have increased risks of heart disease, high blood pressure, kidney or nervous system problems.”
b. Explain that consumers may experience a temporary increase of lead levels in their drinking water due to the replacement of their service line.
c. Include information about removing and cleaning faucet aerators, flushing service lines and re-installing cleaned faucet aerators before the affected service line is returned to service.
d. Include the following informational statement in Spanish regarding the importance of the notice.
“ESTE INFORME CONTIENE INFORMACIÓN IMPORTANTE ACERCA DE SU AGUA POTABLE. HAGA QUE ALGUIEN LO TRADUZCA PARA USTED, O HABLE CON ALGUIEN QUE LO ENTIENDA.”
e. Contain information regarding the importance of the notice in the appropriate non-Spanish language(s) if either of the following criteria are met:
i. A system serving at least 1,000 people has a non-English-speaking group other than Spanish that exceeds 10% of the community residents.
ii. A system serving less than 1,000 people has a non-English-speaking group other than Spanish that exceeds 100 community residents.
f. In lieu of providing information in Spanish and other language(s) as specified in (d) and (e), the notice may contain a telephone number or address where persons served may contact the water system to obtain a translated copy of the notice or to request assistance.
g. In instances where multi-family dwellings are served by the lead service line to be replaced, the water system may elect to post the information required in (a)-(f) at a conspicuous location instead of providing individual notification to all residents.
DEP has developed a public notice that water suppliers can use to provide the information specified above, it can be found on eLibrary by searching under Safe Drinking Water forms for Lead Service Line Replacement Customer Notification, or by typing the form number (3930-FM-BSDW0089) into the search function.
2) Provide the consumer(s) with the following before the affected service line is returned to service:
a. A pitcher filter or point-of-use device that is ANSI certified to reduce lead
b. Six months of replacement cartridges
c. Instructions for use of the filter and replacement cartridges
d. If the affected service line serves more than one residence, such as a multi-unit building, or a non-residential unit, the water system shall provide the items listed in (a)-(c) to every residence in the building.
3) Offer to collect one set of follow up first draw and 5th liter tap samples that must be taken between three months and six months after completion of the full LSLR. The first draw sample should be reported to the Department as a ‘S’ (special) sample type and the 5th liter sample should be reported to the Department as a ‘K’ (5th liter) sample type.
a. If either of the follow up samples exceed 15 µg/L of lead, the water system shall provide the results of both samples to residents as soon as practicable but no later than 3 calendar days after becoming aware of the result(s).
b. If neither of the follow up samples exceeds 15 µg/L of lead, the water system shall provide the results of the sample(s) to residents within 30 days after receiving the results.
c. The following information must accompany the sample results provided to the applicable resident:
i. An explanation of the health effects of lead.
ii. A list of steps consumers can take to reduce exposure to lead in drinking water.
iii. Contact information for the water system.
iv. The maximum contaminant level goal and the action level for lead and the definitions for these two terms specified by the EPA in 40 CFR 141.153(c).
d. The follow up sample results and accompanying information must be delivered to persons served by the tap that was sampled through one of the following methods:
i. Electronically
ii. By mail
iii. By phone
iv. Hand delivery
v. Another method approved by the Department
Can my water system receive funding to complete RMM?
There is currently funding available to water systems to complete LSLR, including the RMM that have be described within this article. This funding originates from the Federal Infrastructure Investment & Jobs Act (also known as the Bipartisan Infrastructure Law) and is being distributed in Pennsylvania through PENNVEST. You can find out more background on this funding source, as well as how to apply, by visiting the following website Infrastructure Investment & Jobs Act (IIJA) (pa.gov).
What additional sources can my water system utilize to ensure that RMM are completed correctly and thoroughly?
The American Water Works Association (AWWA) has a couple of resources that may be helpful to water systems when completing LSLR and RMM.
• For additional information on LSLR and completion of RMM, water suppliers may reference the AWWA Standard C810-17, Replacement and Flushing of Lead Service Lines.
• For more information on communicating with consumers on LSLR, please reference the following AWWA guide Communicating About Lead Service Lines: A Guide for Water Systems Addressing Service Line Repair and Replacement.
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| UCMR 5: An Overview
Matt Menendez, Environmental Engineer
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The fifth Unregulated Contaminant Monitoring Rule (UCMR 5) was published in the federal register on December 27, 2021. UCMR 5 requires sample collection for 30 chemical contaminants between 2023 and 2025 using analytical methods specified by EPA.
All community water systems (CWS) and nontransient noncommunity water systems (NTNCWS) serving more than 10,000 people (i.e., large systems) will monitor; all CWSs and NTNCWSs serving 3,300 to 10,000 people and 800 representative PWSs serving fewer than 3,300 (i.e., small systems) will monitor, subject to availability of appropriations and sufficient laboratory capacity. Sampling will occur during a 12-month period from January 2023 through December 2025. If EPA does not receive the appropriations needed in a given year, then a reduced number of small systems will perform monitoring. As EPA finalizes its sampling design plan for each sample collection year, the Agency will notify the participating small systems.
The contaminants included in UCMR 5 monitoring include 29 per- and polyfluoroalkyl substances (PFAS) and lithium, as noted in Table 1:
• PFAS - a group of synthetic chemicals used in a wide range of consumer products and industrial applications including: non-stick cookware, water-repellent clothing, stain resistant fabrics and carpets, cosmetics, firefighting foams, electroplating, and products that resist grease, water, and oil. PFAS are found in the blood of people and animals and in water, air, fish, and soil at locations across the United States and the world
• Lithium - a naturally occurring metal that may concentrate in brine waters; lithium salts are used as pharmaceuticals, used in electrochemical cells, batteries, and in organic syntheses
Table 1: Contaminants, Minimum Reporting Levels and Analytical Methods
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1. CASRN – Chemical Abstracts Service Registry Number
2. MRL – Minimum Reporting Level
3. SM – Standard Methods
4. ASTM – ASTM International
UCMR 5 samples will be collected at entry points (EPs) for all 30 contaminants, at a frequency as noted in Table 2. All systems required to participate in UCMR 5 will collect samples. As with previous UCMRs, large systems make arrangements with approved laboratories and pay for their own sample shipping and analytical costs. For small systems, EPA arranges for the analysis of samples and pays for shipping and analytical costs. All laboratories conducting analyses for UCMR 5 must receive EPA approval to perform those analyses (UCMR Laboratory Approval Program).
Table 2: Sampling Frequency
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| The PFAS MCL Rule
Jill Anderson, Technical Support Section Manager, DEP Central Office
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The PFAS MCL Rule was published in the PA Bulletin on January 14, 2023, establishing enforceable standards in Pennsylvania for two PFAS chemicals in drinking water. PFAS, or per- and polyfluoroalkyl substances, are a class of synthetic chemicals that have been manufactured and in use since at least the 1940s. They are known for their unique properties that make products resistant to water, grease, and stains; reduce friction; and reduce heat. PFAS are found in a variety of consumer and industrial products, including clothing, carpeting, food packaging, non-stick cookware, personal care products, firefighting foam, adhesives, metal plating, and wire manufacturing, to name a few.
PFAS are sometimes referred to as “forever chemicals,” because they do not readily breakdown in the environment. They consist of a chain of carbon and fluorine atoms. The carbon to fluorine bonds are very strong and are what make these compounds so persistent. Two of the most researched and understood PFAS are perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) (Figure 1). PFAS, including PFOA and PFOS, are potentially linked to a number of adverse health effects, including adverse developmental effects for PFOA (such as neurobehavioral and skeletal effects) and adverse immune system effects for PFOS (including immune suppression).
Figure 1. Chemical structures of PFOA and PFOS.
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As a result of widespread use of products containing PFAS for decades, some areas of Pennsylvania now experience elevated levels of exposure to these chemicals. On September 19, 2018, Governor Wolf signed Executive Order 2018-08, which established the PFAS Action Team. The PFAS Action Team is tasked with developing a comprehensive response to identify and eliminate sources of PFAS contamination; ensure drinking water is safe; manage environmental contamination; review gaps in data and oversight authority; and recommend actions to address those gaps. One of the recommendations of the PFAS Action Team was for DEP to establish drinking water standards for PFAS so that public water suppliers can determine appropriate treatment options with an overall goal of improved public health protection.
The PFAS MCL Rule establishes maximum contaminant levels (MCLs) and maximum contaminant level goals (MCLGs) for PFOA and PFOS (Table 1). The rule also establishes MCL compliance provisions, including monitoring and reporting requirements, analytical methods, acceptable treatment technologies, and public notification. The MCLs and MCLGs, established at 25 Pa. Code § 109.202(a)(4)(ii), are effective immediately and are applicable to all PWSs in Pennsylvania.
Table 1. MCLs and MCLGs established for PFOA and PFOS.
| | MCLG
(ng/L or ppt) | MCL
(ng/L or ppt) | | PFOA | 8 | 14 | | PFOS | 14 | 18 |
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Monitoring and reporting requirements established by the PFAS MCL Rule at 25 Pa. Code § 109.301(16) and § 109.1003(a)(1)(xv) apply to all community water systems (CWS), nontransient noncommunity water systems (NTNCWS), and bottled, vended, retail and bulk water hauling (BVRB) water systems.
Initial monitoring is required quarterly for 4 consecutive calendar quarters at each Entry Point (EP) to the distribution system, beginning January 1, 2024 for PWSs serving more than 350 persons and for BVRBs, and January 1, 2025 for CWS and NTNCWS serving 350 or fewer. Repeat monitoring is quarterly, annual, or triennial, based on whether analytical results are detected and at what level. Compliance with the MCLs is determined based on a running annual average (RAA) at each EP; if any quarterly result causes the RAA to exceed the MCL, an MCL violation is incurred for that quarter.
In addition to the monitoring and reporting requirements, the PFAS MCL Rule also establishes MCL violations as Tier 2 violations requiring issuance of Tier 2 public notice (PN) (§ 109.409) and requires CWSs to report results in their annual Consumer Confidence Report (CCR) (§ 109.416). The rule also establishes analytical requirements, including approved methods for analysis and minimum reporting limits (§ 109.304). It also establishes granular activated carbon (GAC), ion exchange, and reverse osmosis as approved treatment technologies, with the option of other treatment technologies that may be approved by the Department if demonstrated to provide an adequate and reliable quantity and quality of water (§ 109.602).
PFAS are currently unregulated in drinking water at the Federal level. This rulemaking puts Pennsylvania, along with a handful of other states, ahead of the federal government in regulating these chemicals in drinking water. In October 2021, EPA announced its PFAS Strategic Roadmap. One of the goals in the roadmap was to establish a national primary drinking water regulation for PFOA and PFOS, with a goal of publishing a proposed rule by fall 2022 and a final rule by fall 2023. For more information on EPA’s actions and progress regarding PFAS in drinking water, go to Per- and Polyfluoroalkyl Substances (PFAS) | US EPA.
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| UCMR 5 and the PFAS MCL Rule
Matt Menendez, Environmental Engineer
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The PFAS MCL Rule was published in the PA Bulletin on January 14, 2023, establishing enforceable standards in Pennsylvania for two per- and polyfluoroalkyl substances (PFAS) chemicals in drinking water, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS). (See the article titled “The PFAS MCL Rule” in this newsletter for more details.) Concurrently, monitoring under EPA’s fifth Unregulated Contaminant Monitoring Rule (UCMR 5) is set to begin in January 2023 and continue through December 2025. (See the article titled “UCMR 5: An Overview” in this newsletter.)
UCMR 5 samples will be collected at the entry point (EP) for 29 PFAS and lithium. PFOA and PFOS are among the 29 PFAS compounds included. UCMR 5 monitoring will follow the criteria outlined in the table below.
Table 1: UCMR 5 Sampling Breakdown
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1. Includes ALL surface water, ground water under the direct influence of surface water and mixed sources systems
A potential overlap in sampling may occur with UCMR 5 monitoring and PFAS MCL Rule compliance monitoring. Under the PFAS MCL Rule, initial compliance monitoring will be required quarterly for PFOA and PFOS beginning in January 1, 2024 at each EP for PWSs serving a population of more than 350, and January 1, 2025 for PWSs serving 350 or fewer. ALL applicable systems regardless of source water will be required to conduct quarterly compliance monitoring.
PWSs may opt to modify their UCMR 5 schedule to align with the initial compliance monitoring schedule required under the PFAS MCL Rule. However, in order for the same sample results to meet both purposes, the monitoring requirements of both rules must be met.
For PA initial compliance monitoring, monitoring must be conducted according to all requirements in the rule. Specifically, samples must be collected properly and within the required time frame, with the required number and frequency of samples, analyzed using one of the approved methods as defined by the rule (EPA Methods 533, 537 Version 1.1, or 537.1), analyzed by a laboratory accredited in PA for analysis by one of those methods, and be reported appropriately and on time.
For UCMR 5, samples must be analyzed by the UCMR 5 specified methods by a laboratory approved by EPA for UCMR 5 and reported to EPA as required. More specifically PFOA and PFOS samples must be analyzed using EPA Method 533 to fulfill UCMR 5 requirements.
To modify the UCMR 5 schedule:
Alternatively, a PWS can submit a request to DEP to modify their initial compliance monitoring schedule, in accordance with § 109.301(16)(i)(C). A schedule change request form (DEP ID 3930-FM-BSDW0051) has been developed to assist water system with this request and includes detailed instructions. This form is available in DEP eLibrary by searching on the document ID. For groundwater systems, keep in mind that EPA only requires sampling 2 times during a consecutive 12-month monitoring period for UCMR 5, with sampling events occurring 5-7 months apart. So, if a groundwater PWS chooses to align monitoring schedules and conduct dual purpose monitoring, it will be the responsibility of the water system to ensure that the quarterly monitoring requirement of initial compliance monitoring is also satisfied.
Additionally, for small and medium systems serving a population of 10,000 or fewer, EPA will be selecting the contract laboratory for UCMR 5 monitoring and paying for sampling kits, shipping costs, and lab and analytical costs, meaning that EPA will be the lab’s client. Therefore, even if the laboratory selected by EPA is also accredited in Pennsylvania for PFAS analysis and all other requirements are met, it may not be possible to have the results also reported for PA initial compliance monitoring.
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Pennsylvania Department of Environmental Protection, 400 Market Street, Harrisburg, PA 17101
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