Conning Towers-2019 LCR.pdf

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

2019 LEAD AND COPPER RULE

DRINKING WATER MONITORING PLAN UPDATE

CONNING TOWERS

July 2019

Draft

NAVFAC MID-ATLANTIC

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

DRAFT

2019 LEAD AND COPPER RULE DRINKING

WATER MONITORING PLAN UPDATE – CONNING

TOWERS

NAVAL SUBMARINE BASE NEW LONDON,

CONNECTICUT

Prepared For:

Taylor Jones

NAVFAC MIDLANT

9742 MARYLAND AVE

NORFOLK, VA 23511-2095

CONTRACT: N62470-14-D-9022

DELIVERY ORDER: N4008518F6644

July 2019

AH/BC Navy JV, LLC.

11837 Rock Landing Drive, Suite 300 Newport News, Virginia 23606

2019 LCR DRINKING WATER MONITORING PLAN UPDATE

SUBASENLON - CONNING TOWERS

NAVAL SUBMARINE BASE NEW LONDON, CT TABLE OF CONTENTS

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1. INTRODUCTION .............................................................................................1-1

1.1 PURPOSE ................................................................................................1-2

1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS ...........................................1-4

1.3 PLAN ORGANIZATION ................................................................................1-5

2. SUBASENLON CONNING TOWERS WATER SYSTEM ...............................2-1

2.1 SERVICE CONNECTIONS ...........................................................................2-2

3. REGULATORY BACKGROUND ....................................................................3-1

3.1 LEAD AND COPPER ACTION LEVELS ...........................................................3-3

3.2 LEAD IN PRIORITY AREAS .........................................................................3-4

3.2.1 Lead and Copper in Family Housing ...........................................3-4

4. SAMPLER TRAINING AND SAMPLING PROCEDURES ..............................4-1

4.1 SAMPLER TRAINING AND SAMPLE HANDLING REQUIREMENTS .....................4-1

4.2 QUALITY ASSURANCE/QUALITY CONTROL ..................................................4-3

5. SAMPLING REQUIREMENTS ........................................................................5-1

5.1 SUBASENLON LCR REQUIRED NUMBER OF TAP SAMPLING SITES ...........5-1

5.2 WHEN TO SAMPLE FOR LEAD AND COPPER ................................................5-4

5.2.1 Lead and Copper Monitoring Waivers .........................................5-5

5.2.2 PM EV Approval of Waiver Application .......................................5-6

5.3 HIERARCHY IN IDENTIFYING SAMPLING LOCATIONS .....................................5-6

5.4 WHERE TO SAMPLE FOR LEAD AND COPPER ..............................................5-7

5.5 SAMPLING PROCEDURES ........................................................................ 5-12

5.6 DOCUMENTATION OF FIELD ACTIVITIES AND OBSERVATIONS ..................... 5-14

5.7 HEALTH AND SAFETY HAZARDS ............................................................... 5-16

6. LCR TEST RESULTS EVALUATION .............................................................6-1

6.1 SAMPLING RESULTS EVALUATION ..............................................................6-1

6.2 ACTIONS TRIGGERED IF AN AL IS EXCEEDED .............................................6-1

6.3 CONSUMER NOTICE OF LEAD TAP RESULTS ...............................................6-3

6.4 CONSUMER CONFIDENCE REPORT REQUIREMENT .....................................6-3

7. REPORTING, RECORDKEEPING, PUBLIC EDUCATION, AND

NOTIFICATION REQUIREMENTS .................................................................7-1

7.1 RECORDKEEPING .....................................................................................7-1

7.2 PUBLIC EDUCATION REQUIREMENT ...........................................................7-1

8. PUBLIC NOTIFICATION ................................................................................8-1

9. REFERENCES................................................................................................9-1

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APPENDICES

A. STATEMENT OF WORK

B. LEAD AND COPPER RULE: A QUICK REFERENCE GUIDE (EPA)

C. LEAD ACTION LEVEL - DRINKING WATER NOTIFICATION

D. STATE OF CONNECTICUT CERTIFIED LABORATORIES LIST AND EXAMPLE

CHAIN OF CUSTODY FORM

• D1 – In-state Approved Commercial Laboratories Certified to Test Drinking Water

• D2 – Example Chain of Custody Form

E. CONSTRUCTION DATES OF BUILDINGS/LOCATIONS SUBASENLON

CONNING TOWERS

F. DOD CLARIFICATION OF LEAD AND COPPER RULE SAMPLING PRACTICES

G. PRE-SAMPLING SIGN FOR LEAD AND COPPER SAMPLING

H. LCR CORROSION CONTROL AND COSUMER NOTICE EXAMPLE

TEMPLATES

• H1 – LCR Failure to Install Corrosion Control Notice General Template

• H2 – Consumer Notice of Tap Water Results Template for Community Water Systems

I. GROTON UTILITIES 2017 ANNUAL WATER QUALITY REPORT

J. PUBLIC EDUCATION FOR COMMUNITY WATER SYSTEMS TEMPLATES AND

DPH-CT INFORMATION DOCUMENT

• J1 – Public Education Pamphlet - Lead in Drinking Water

• J2 – Press Release Template (for SUBASENLON Newsletter)

• J3 – Public Service Announcement Template

• J4 – Lead and Copper Rule: Public Education and Other Public Information Requirements for Community Water Systems

• J5 – DPH-CT Information Document “Lead in Drinking Water”

K. PUBLIC NOTIFICATION EXAMPLE TEMPLATES

• K1 – LCR Failure to Conduct Public Education (Tier 2) Public Notification Ex-ample Template

• K2 – Monitoring Violations (Tier 3) Public Notification Example Template

L. SODIUM ACTION LEVEL DRINKING WATER NOTIFICATION

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TABLES

TABLE PAGE

Table 1-1 SUBASENLON Water System Information ..........................................1-4 Table 2-1 Conning Towers Distribution System Pipe Material and Length ...........2-2 Table 2-2 GU Service Connections to Conning Towers Water System ................2-2 Table 4-1 Sample Handling Requirements ..........................................................4-2 Table 5-1 LCR Standard and Reduced Monitoring for Conning Towers ...............5-2 Table 5-2 Lead and Copper Summary Monitoring Requirements ........................5-4 Table 5-3 Conning Towers Lead and Copper Monitoring Sampling Sites ............5-8 Table 5-4 Conning Towers Monitoring Locations Accessibility ........................... 5-11 Table 5-5 Field Conditions Form ........................................................................ 5-15 Table 8-1 Public Notification Tiers .......................................................................8-1

FIGURES

FIGURE PAGE

Figure 1-1 SUBASENLON Location and Vicinity Map ...........................................1-3 Figure 5-1 LCR Monitoring Frequency Decision Chart ..........................................5-3 Figure 5-2 LCR Sampling Location Map ...............................................................5-9 Figure 6-1 LCR Follow-up Actions Resulting from Lead and Copper

Tap Monitoring .....................................................................................6-2 Figure 8-1 LCR Public Notification Procedure .......................................................8-3

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NAVAL SUBMARINE BASE NEW LONDON, CT ACRONYMS & ABBREVIATIONS

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ACRONYMS AND ABBREVIATIONS

µS micro Siemens

AL action level

AWWA American Water Works Association

BMP best management practice

CCR consumer confidence report

CCT corrosion control treatment

CDC Child Development Center

CFR Code of Federal Regulations

COC chain of custody

CT State of Connecticut

Cu copper

CWS Community Water System

DoD Department of Defense

DPH-CT Connecticut Department of Public Health

EPA United States Environmental Protection Agency

EV Environmental Division

FR Federal Register

GU Groton Utilities

ID identification

LCR Lead and Copper Rule

LIPA Lead in Priority Areas

LSLR lead service line replacement

MCLG maximum contaminant level goal

MFR multiple-family residence mg/L milligrams per liter

Na sodium

NAVFAC MIDLANT Naval Facilities Engineering Command, Mid-Atlantic

NAVSEA Naval Sea Systems Command

OPNAVINST Chief of Naval Operations Instruction

Pb lead

PE Public Education

PM Drinking Water Program Manager

PN Public Notification

POE point of entry ppm parts per million

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PWS public water system

QA Quality Assurance

QC Quality Control

SDWA Safe Drinking Water Act

SDWIS The Safe Drinking Water Information System

SM Standard Method

SOP Standard Operating Procedure

SUBASENLON Naval Submarine Base New London

SWT source water monitoring and treatment

TDS total dissolved solids

US United States

WQP water quality parameter

SUBASENLON - CONNING TOWERS SECTION 1

NAVAL SUBMARINE BASE NEW LONDON, CT INTRODUCTION

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1. INTRODUCTION

Originally founded in 1868, the Naval Submarine Base New London (SUBASENLON) is one of the oldest Navy bases still in use today. Located in the town of Groton, Con-necticut (CT), it is the Navy’s first submarine base and the “Home of the Submarine

Force.” In 1916, many United States (US) submarines used the base as a homeport and a place for repair, resupply, and sailors’ rest and recuperation before returning to the front of World War I. The SUBASENLON is located in the county of New London, CT, along the Thames River. The installation occupies more than 687 acres for

SUBASENLON Main Base and over 530 acres for housing areas, with more than 1,500

Public/Private Venture- family housing units.

This Lead and Copper Rule (LCR) monitoring plan covers the US Navy drinking water system at the SUBASENLON, Conning Towers housing area. Separate sampling plans for other sites maintained by the SUBASENLON Public Works Department (PWD) are contained in separate documents for each of the following areas:

1. Main Base

2. Nautilus Park

3. Trident Park

4. Polaris Park

The potable water system in the housing portion of Dolphin Gardens is owned and maintained by the City of Groton, as was indicated in an agreement between Balfour

Beatty Communities and the City of Groton Utilities (GU) Department of Utilities dated

August 22, 2008. Also, the potable water system in Nautilus Park 3 north of Gun-gywamp Road is owned and maintained by the City of Groton based on an agreement between the two aforementioned parties dated February 13, 2007. Therefore, these parts of the system operated by GU in these areas are not included in the scope of this task order (see Appendix A for Statement of Work (SOW)).

SUBASENLON Conning Towers is not a state-recognized Public Water System (PWS).

Its population includes active duty, reserve and civilian personnel, as well as military families. Under the Safe Drinking Water Act (SDWA), the state or primacy agency is the authority that enforces the SDWA requirements including approvals, monitoring and

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AH/BC Navy JV, LLC. 1-2 Draft, July 2019 119-108 reporting compliance. In addition to Navy drinking water requirements, the Drinking

Water Program Manager (PM) at Naval Facilities Engineering Command (NAVFAC)

Mid-Atlantic (MIDLANT) serves as the SDWA primacy agency entity. Figure 1-1 is a location map that shows the SUBASENLON Conning Towers and the other

SUBASENLON areas.

1.1 PURPOSE

As part of the ongoing effort to ensure the consistent and continuous delivery of safe potable water, as required by the Navy Command, NAVFAC MIDLANT, in cooperation with the Environmental Division (EV) at the SUBASENLON, contracted AH/BC Navy

JV, LLC to update the drinking water monitoring plan of the SUBASENLON Conning

Towers water system. This sampling plan reflects the SUBASENLON Conning Towers compliance with the LCR requirements.

The purpose of the Lead and Copper Rule (LCR) is to protect the general population from exposure to Pb and Cu in drinking water and reduce potential health risks. Office of the Chief of Naval Operations Instruction (OPNAVINST) 5090.1D1, requires the up-dating and completion of LCR monitoring requirements. SDWA (40 Code of Federal

Regulations [CFR] §141.86) Subpart I state that the LCR drinking water monitoring plan must contain the elements of monitoring locations, dates, and compliance calculation procedure in a consecutive water distribution system. This LCR sampling plan meets

Navy regulations i.e., OPNAVINST 5090.1D and EPA 816-R-10-0042, March 2010 and conforms with common industrial drinking water industry standards and practices, such as the American Water Works Association (AWWA) standards and guidance docu-ments.

This work was performed under Contract Number: N62470-14-D-9022 and Task Order

Number: N4008518F6644, as indicated in the SOW in Appendix A.

1 Office of the Chief of Naval Operations Instruction (OPNAVINST) 5090.1D, 10 Jan 2014.

2 EPA. March 2010. Lead and Copper Rule Monitoring and Reporting Guidance for Public Water Sys-tems, EPA 816-R-10-004. Internet accessed: 7/17/2019.

https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100DP2P.txt https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100DP2P.txt

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Figure 1-1 SUBASENLON Location and Vicinity Map

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1.2 SITE SPECIFIC SAMPLING PLAN COMPONENTS

This LCR sampling plan for SUBASENLON Conning Towers considers the following components:

1. Water System Classification: Table 1-1 describes the SUBASENLON Conning Towers water system classification.

Table 1-1 SUBASENLON Water System Information

Water System Classification Summary

Component Description

System Name SUBASENLON Conning Towers

PWS Identification (ID) Number

Not applicable

System Type Inactive (state exempt) consecutive Community Water System (CWS)

Water Sources List

- including facility Safe Drinking Water ID*

Master meter customer of GU - PWSID: CT0590011 (GU’s water is supplied from a series of five intercon-nected reservoirs covering a watershed of 16 square miles, and also includes three wells. Four reservoirs – Morgan, Ledyard, Poheganut, and Smith Lake - flow into Poquonock, their terminal reservoir)

System’s Owner/Oper-ator Contact Infor-mation

Mike Brown, Environmental Division Director

PWD ‐ SUBASENLON

Naval Submarine Base New London Box 44 Groton, CT 06349-5044 Phone: (860) 694-3976, Cell: (860) 287‐7268 Email: michael.brown13@navy.mil

Total Number of Ser-vice Connections:

Population Served ~425

Wholesaler (Water Pur-veyor)

Groton Utilities (PWSID: CT0590011) Groton Utilities, 295 Meridian Street, Groton, CT 06340 T: (860) 446-4000, F: (860) 446-4098

Prepared Date Plan July 2019

Plan Point of Contact Rich Massad (SUBASENLON PWD EV): (860) 694-5140

* As reported under The Safe Drinking Water Information System (SDWIS) https://www3.epa.gov/en-viro/facts/sdwis/search.html

2. Distribution System Map indicates water system components (i.e., layout of distri-bution mains, city interconnections, and routine sampling sites).

mailto:michael.brown13@navy.mil https://www3.epa.gov/enviro/facts/sdwis/search.html https://www3.epa.gov/enviro/facts/sdwis/search.html

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3. Minimum Number of Routine Samples required per monitoring period based on the population served in accordance with 40 Code of Federal Regulations (CFR)141.21(a)(2) and (a)(3) for SUBASENLON Conning Towers.

4. Frequency of Sample Collection at each sample site per monitoring period and a sample collection schedule.

Note: In accordance with 40 CFR 141.21(a)(4), the water system is expected to collect samples at regular time intervals throughout the month.

5. Appropriate Sampling Sites within the distribution network that characterize the areas of the distribution system with different water ages, having cross-connection hazards, representing low or no chlorine residuals, and/or representing water sup-ply to critical/sensitive facilities.

Note: Samples should not be collected from fire hydrants, faucets that point up-ward (i.e., drinking water fountains), faucets that are corroded or have leaking packing material, swivel type faucets, faucets with threads on the inside of their spouts, faucets with aerators or screens (aerators or screens should be removed with care), automatic faucets, faucets that are close to or below ground level, fau-cets that are dirty or surrounded by excessive foliage, or taps that are dirty, cor-roded, or leaking. Samples should not be collected from a hose or other faucet at-tachment.

1.3 PLAN ORGANIZATION

Section 2 of this document summarizes the SUBASENLON Conning Towers water system classification and distribution network information. Section 3 describes the reg-ulatory drivers for the plan, as well as applicable monitoring requirements under

OPNAVINST 5090.1D Navy policy and the SDWA 40 CFR §141.21. Section 4 outlines the sampler training and sampling procedures. Section 5 presents LCR sampling re-quirements. Section 6 details the LCR test results evaluation. Section 7 presents LCR public recordkeeping and reporting requirements. Section 8 presents Public Notification

(PN) procedures as they apply to SUBASENLON Conning Towers water system and

Section 9 provides a list of references cited in this plan.

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SUBASENLON - CONNING TOWERS SECTION 2

NAVAL SUBMARINE BASE NEW LONDON, CT SUBASENLON CONNING TOWERS WATER SYSTEM

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2. SUBASENLON CONNING TOWERS WATER SYSTEM

This section identifies the main features of the SUBASENLON Conning Towers water system (including Child Development Center (CDC) and Navy Lodge).

The SUBASENLON Conning Towers water system purchases treated water from the

GU Water Treatment Plant (WTP), a private entity that supplies water to the city and other towns and industrial facilities in the area. The SUBASENLON Conning Towers provides water to the public, but does not sell water3, is not a carrier, and does not provide treatment (as in additional filtration or by adding disinfectant). The CT Depart-ment of Public Health (DPH-CT) September 13, 1993 letter confirmed SUBASENLON status as a service connection or a Master Meter customer to GU and therefore, exempt from the requirements of the SDWA. Consequently, the DPH-CT removed

SUBASENLON from both the state and federal inventories of PWSs. Under the Navy water system certification program, the SUBASENLON Conning Towers system is classified as a consecutive CWS.

The SUBASENLON Conning Towers housing area has a population of approximately

425 and operates a water distribution system that provides water for human consump-tion to the base population through pipes and other constructed storage and convey-ances.

Table 2-1 summarizes the SUBASENLON Conning Towers distribution system piping length by material type.

3 If any of the SUBASENLON water systems sells water, that system becomes a regulated PWS subject to the SDWA and CT State primacy regulations. OPNAVINST 5090.1D Section 21-3.3 (b), states the following: ”There is no definition of "selling water" in SDWA however, EPA’s “Operator Certification Guide-lines Implementation Guidance” January 2000 defines selling water as follows: "A distributor of water for human consumption "sells" water within the meaning of the Act if it charges consumers for the water as a separate item or bills separately for the water it provides (House Report No. 93-1185). Conversely, if the entity includes charges for water in the rental fee, then it is not selling water within the context of the Act."

The Navy does not consider reimbursement for distribution system maintenance costs and water from one federal entity to another as selling water; this is merely an internal allocation of funds within the executive branch. The EPA definition above would apply to non-federal consumers including banks, credit unions, private companies, and restaurants to which Navy distributes water.

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Table 2-1 Conning Towers Distribution System Pipe Material and Length

Miles (kilometers) of Distribution Pipe of Each Material Best Estimate for Construction

Year(s) Cast Iron Copper Total

1.73 (2.78) 0.97 (1.6) 2.7 (4.3) 1940’s

2.1 SERVICE CONNECTIONS

The DPH-CT classifies SUBASENLON Conning Towers water system as a service connection to GU and does not regulate it as a PWS, consecutive or otherwise, nor require the system to monitor water quality. The SUBASENLON Conning Towers water distribution system receives potable water from GU through three (3) service connec-tions, as summarized in Table 2-2.

Table 2-2 GU Service Connections to Conning Towers Water System

SUBASENLON

Water System

Total Number of Service

Connections Location

Conning Towers 3

One (1) at Tomkins Street

One (1) at Pleasant Valley Road

One (1) at Lester Town Road

The GU WTP source water includes a series of five interconnected reservoirs covering a watershed of 16 square miles (four reservoirs – Morgan, Ledyard, Poheganut and

Smith Lake - flow into Poquonock, the final terminal reservoir), and three backup wells.

GU owns and maintains the water meters and the Navy owns the pits (structure, pipe, and cover).

GU has no notices of violation of the SDWA for at least the last 10 years. Therefore, any water quality issues experienced by SUBASENLON Conning Towers water system customers related to pipe or fittings corrosion, microbial contamination, or lead and copper in drinking water most probably originate within its distribution system.

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The system includes a pumping station and ground and elevated water storage tanks.

The original drinking water distribution system was installed in the 1940s. The system is a combined potable and fire protection system. All three inter-connections with the

GU distribution system are metered by GU-owned meters housed in Navy owned meter vaults. The GU supplied water pressure ranges between 61 and 72 psi. The drinking water distribution system consists of approximately 2.7 miles (4.3 km) of distribution piping up to 8 inches in diameter. Pipe materials include approximately 64% cast iron and 36% copper.

The Navy Instruction (OPNAVINST 5090.1D) requires SUBASENLON to develop an

LCR sampling plan for the site specific SUBASENLON Conning Towers water system.

This sampling plan meets the monitoring requirements of the LCR as mandated in 40

CFR 141.86 and requires periodic updates based on sampling site availability and base population changes.

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SUBASENLON - CONNING TOWERS SECTION 3

NAVAL SUBMARINE BASE NEW LONDON, CT REGULATORY BACKGROUND

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3. REGULATORY BACKGROUND

This section summarizes the regulatory requirements applicable to the drinking water systems at SUBASENLON Conning Towers. Under the SDWA, consecutive PWSs are not generally subject to the monitoring requirements of the SDWA if they satisfy all of the following criteria specified in the National Primary Drinking Water Regulations

(NPDWR) 40 CFR 141.3:

• The PWS consists of only distribution and storage facilities and does not have any collection or treatment facilities

• The PWS obtains all its water from, but is not owned or operated by, a PWS to which the regulations apply

• The PWS does not sell water to any persons

• The PWS is not a carrier that conveys passengers in interstate commerce

All Navy systems, including unregulated consecutive systems, must develop a drinking water LCR sampling plan and consumer notification, in compliance with OPNAVINST

5090.1D4 requirements.

The SDWA and the OPNAVINST 5090.1D (10 January 2014), classify the

SUBASENLON Conning Towers water system as a PWS and a CWS. As an exempt consecutive water system, SUBASENLON Conning Towers water system is not sub-ject to the Connecticut Public Health Code Section 19-13-B102, including the consec-utive system monitoring requirements for Pb and Cu.

Chapter 21 of the Environmental and Natural Resources Program Manual

(OPNAVINST) 5090.1D (10 January 2014) provides environmental guidance for SDWA compliance ashore for Navy installations in the United States (US). The policies and procedures in the manual apply to all Navy personnel and activities within the Chief of

Naval Operations’ chain of command. OPNAVINST 5090.1D states that Navy shore activities shall comply with all applicable federal, state, and local safe drinking water regulations, executive orders, and Navy policy. Section 21-3.4 (c) of OPNAVINST

4 OPNAVINST 5090.1D dated 10 January 2014 is the most updated version of OPNAVINST 5090.1D.

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5090.1D mandates that all Navy PWSs comply with all applicable requirements for the control of Pb and Cu, as stated in the federal LCR (Subpart I of 40 CFR Part 141), to ensure that levels of Pb and Cu remain below the action levels (ALs) at the consumer's free flowing tap. Per Subpart I of 40 CFR Part 141, if approved by the state regulatory agency or the EPA (whichever has primacy), installations may combine their consecu-tive PWS monitoring plan as part of the supplier's plan, instead of treating each as a separate system.

The EPA issued the LCR in 56 Federal Register (FR) 26460 – 26564, June 7, 1991.

The June 1991 LCR was revised with the following technical amendments:

• 56 FR 32112, July 15, 1991

• 57 FR 28785, June 29, 1992

• 59 FR 33860, June 30, 1994

• 65 FR 1950, January 12, 2000 (LCR Minor Revisions)

• 72 FR 57782, October 10, 2007 (LCR Short-Term Revisions)

The LCR5 rule includes the following provisions:

• Pb and Cu monitoring

• Corrosion control treatment (CCT)

• Water quality parameters (WQP) monitoring

• Source water monitoring and treatment (SWT)

• Lead service line replacement (LSLR)

• Reporting (consumer notice of Pb tap results and information in consumer confidence report (CCR) of Pb in drinking water) and recordkeeping

The LCR establishes maximum contaminant level goals (MCLGs) for Pb (0 milligrams per liter [mg/L]) and Cu (1.3 mg/L), and mandates treatment techniques that are trig-gered by AL exceedance for Pb (0.015 mg/L) and Cu (1.3 mg/L) based on the 90th percentile of first draw tap water samples. Appendix B includes the EPA quick refer-ence guide and fact sheet for LCR. This monitoring applies to all Navy water systems regardless of state variance or exemptions from regulatory monitoring requirements.

5 United States Environmental Protection Agency Memorandum, Clarification of Recommended Tap Sampling Proce-dures for Purposes of the Lead and Copper Rule, dated 29 February 2016.

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3.1 LEAD AND COPPER ACTION LEVELS

The Pb AL is exceeded if the Pb concentration in more than 10 percent of tap water samples collected during any monitoring period conducted per Subpart I of 40 CFR

Part 141 is greater than 0.015 mg/L (i.e., if the 90th percentile Pb level is greater than

0.015 mg/L). The AL is exceeded if Cu concentrations in more than 10 percent of tap water samples collected during any monitoring period conducted per Subpart I of 40

CFR Part 141 is greater than 1.3 mg/L (i.e., if the 90th percentile Cu level is greater than 1.3 mg/L). Appendix C provides a sample Lead Action Level notification including mandatory language.

While an AL exceedance does not constitute a violation, it does trigger the following mandated actions:

As specified in Subpart I of 40 CFR Part 141, if an AL is exceeded, installation

PWSs must collect additional WQP samples. Optimal CCT may also be re-quired. Should prescribed treatment options fail to bring Pb levels below the

AL, Pb service lines or other water fittings may have to be replaced. If Pb or

Cu concentrations exceed the AL of 15 ppb for Pb or 1.3 ppm for Cu in more than 10% of customer taps sampled, the system must undertake a number of additional actions to control corrosion. If the AL for Pb is exceeded, the system must also inform the public about steps they should take to protect their health and may have to replace Pb service lines under their control.

In accordance with 40 CFR 141.82, a CWS serving a population of less than 50,000 is required to perform CCT, and WQP monitoring if it exceeds Pb or Cu ALs. The EPA monitoring and reporting guidance (EPA 2010) cites the preamble to the 1991 LCR regarding the responsibilities of the water supplier and the consecutive system. The consecutive system is responsible for Public Education delivery6. The wholesaler water system (i.e., GU), is responsible for SWT, CCT, and WQP monitoring (pH, calcium, alkalinity, silica, orthophosphate, TDS, and temperature). Requirements for SWT, CCT, and WQP monitoring do not apply to the consecutive (state-exempt) SUBASENLON

Conning Towers water system and are beyond its control.

6 Delivery of Public Education Materials for a Community PWS (serving > 3,300) within 60 days after the end of the monitoring period, Instructions for Public Education under the Lead and Copper Rule – (Lead Only).

https://www.epa.gov/sites/production/files/2016-08/documents/lcr_pe_cws_gt_3300.pdf.Internet accessed:

06.24.2019 https://www.epa.gov/sites/production/files/2016-08/documents/lcr_pe_cws_gt_3300.pdf

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Additionally, as specified in Subpart I of 40 CFR Part 141, water systems that meet the Pb and Cu ALs during specified monitoring periods may reduce the number and frequency of sampling per Subpart I of 40 CFR Part 141.

3.2 LEAD IN PRIORITY AREAS

The 8 February 2014 memorandum titled, “Sampling and Testing for Lead in Drinking

Water in Priority Areas” and the follow-up memorandum7 updates Navy policy in

OPNAV M-5090.1D on Pb topics including sampling and testing for Pb in drinking water in priority areas at Navy installations. The update requires Navy facilities to sample, test, and maintain test results for all drinking water coolers and outlets in priority areas

(child development centers [CDCs], child development group homes, youth centers, and schools) to determine the presence of Pb. The only Lead in Priority Areas (LIPA) facility at SUBASENLON Conning Towers is a CDC constructed in 1999.

SUBASENLON Conning Towers CDC’s LIPA test results must be maintained for 12 years, and the water system must make a copy of the test results available for this CDC facility, where testing has been conducted. The CDC must send a notice of availability of the testing results to the parents or legal guardians of all attending children. To help reduce Pb exposure at priority areas, the EPA issued a guidance document to childcare facilities with problems associated with Pb in drinking water8.

3.2.1 Lead and Copper in Family Housing

Navy consecutive PWSs that serve family housing and were not included in the primary system sampling pool (at the time the primary system performed LCR monitoring), must sample for Pb and Cu. Installations must ensure the number and location of samples are sufficient to be representative of the system and in conformance with LCR proce-dures. This requirement can be waived if Navy installations operating consecutive

PWSs document that the water supplier passed its LCR monitoring and that the water

7 See the Department of the Navy Director, Energy and Environmental Readiness Division (OPNAV N45), memorandum (Ser N45/14Ul32588) dated 22 March 2019, regarding the subject of Update to Policy on Sampling and Testing for Lead in Drinking Water in Priority Areas.

8 http://www.epa.gov/safewater/schools/guidance.html(accessed on 04/22/2019) http://www.epa.gov/safewater/schools/guidance.html

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SUBASENLON - CONNING TOWERS SECTION 4

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4. SAMPLER TRAINING AND SAMPLING PROCEDURES

This section outlines the Standard Operating Procedures (SOPs) and Quality Assur-ance (QA)/Quality Control (QC) procedures for use by SUBASENLON Conning Towers staff during LCR sample collection. The sampling SOP is in accordance with the EPA

LCR Monitoring and Reporting Guidance for PWS and Naval Sea Systems Command

(NAVSEA) T0300-AZ-PRO-010 Revision 1. This section also includes documentation of field activities and health and safety hazard issues.

If sampling is contracted to the laboratory conducting the analysis, the laboratory’s sampling SOP should be documented. Appendix D provides typical sampling docu-mentation maintained at SUBASENLON Conning Towers water system, including an example chain of custody (COC) form and a list of outside contractors (e.g., state-cer-tified laboratory or GU).

4.1 SAMPLER TRAINING AND SAMPLE HANDLING REQUIREMENTS

As a best management practice (BMP), if SUBASENLON Conning Towers chooses to collect its own samples, only trained individuals should collect LCR samples. Prospec-tive samplers should successfully complete the A-4A-0026 Environmental Quality Sam-pling course offered by the Inter-service Environmental Education Review Board, spon-sored by Civil Engineer Corps Officers' School. The course satisfies Navy training re-quirements for environmental samplers (Chapter 29, paragraph 5.6(b) OPNAVINST

5090.1D) by providing the following training:

• Basic sampling techniques (avoidance of cross-contamination, use of preserv-atives)

• Specific sampling techniques for all environmental media including potable water

• Completion of environmental sampling paperwork (sample container labeling, field log books, COC documentation)

• Health and safety considerations

• Field testing techniques (use of pH meter, temperature indicator)

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• Site specific training developed by the state and operator training that supports operator certification.

If SUBASENLON Conning Towers sampling is contracted out, it should maintain a copy of the contract laboratory’s valid state certification form and QA/QC Management Plan updates in this sampling plan for drinking water testing (as included in Appendix D).

The EPA recommends including trip blanks in at least 10% of the samples collected. In addition, at least 3 blind spikes9 should be included during each 6-month monitoring period (or other applicable period under reduced monitoring). Table 4-1 presents sam-ple handling requirements.

Table 4-1 Sample Handling Requirements

Parameter Analytical

Method Preservative1 Container2

Maximum Holding Time

Pb

EPA 200.8

EPA 200.9

SM* 3113 B

Concentrated HNO3 to pH <2

1-L certified metal-free glass or poly-ethylene bottles

6 months

Cu

EPA 200.7

EPA 200.8

EPA 200.9

SM 3111 B

SM 3113 B

SM 3120 B

Concentrated HNO3 to pH <2

1-L certified metal-free glass or poly-ethylene bottles

6 months

1) Samplers should not handle nitric acid (HNO3). Samples will be acidified (generally to pH < 2 with concentrated HNO3) at the laboratory upon receipt of the samples, as soon as possible, but no later than 14 days after sample collection. Samples must stand in the original container used for sampling for at least 28 hours after acidification. The laboratory should match the acid matrix of the samples, QC, and calibration standards for accurate results. The latter two sets of solu-tions will have the same, fixed concentration of acid. The recommended laboratory BMP is to determine by prior tests the amount of acid necessary to achieve a pH <2 and make it con-sistent with the standards used.

2) Most laboratories will provide sample bottles with proper preservative (acid).

* SM = Standard Method

9 The 3 blind spikes can be ordered from Supelco (of the Sigma-Aldrich Group) and ERA, which can prepare custom spike standards, for examples, spiking levels of 5, 10, and 15 micrograms per liter.

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4.2 QUALITY ASSURANCE/QUALITY CONTROL

It is essential to follow QA/QC measures during the field sampling. Through the QA/QC program, samples can be tracked from collection through analysis. Sampling infor-mation should be noted in the field and entered into a database. The QA/QC sample tracking program requirements include the following:

1. Sample identification and labeling

2. Sample collector’s training and certification

3. Laboratory record keeping and database format

4. Periodic self-audits of the QA/QC procedures

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SUBASENLON - CONNING TOWERS SECTION 5

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5. SAMPLING REQUIREMENTS

This section presents the LCR monitoring sampling requirements. It identifies

SUBASENLON Conning Towers sampling locations that have been selected to meet the requirements of 40 CFR 141.86 for LCR sampling as well as the following infor-mation:

1. Number of required sample sites

2. When to sample

3. Where to sample

4. Sample collection procedures

5.1 SUBASENLON LCR REQUIRED NUMBER OF TAP SAMPLING SITES

Under standard monitoring and based on a served population of 425, the

SUBASENLON Conning Towers water system is required to collect samples from 10 sites every 6 months for standard monitoring, 5 sites annually or 5 sites triennially (once every three years) for reduced monitoring, or 5 sites novennially (once every nine years) with a state (i.e., NAVFAC MIDLANT PM Environmental Division (EV)), ap-proved waiver. Table 5-1 summarizes the sampling type and the number of samples required to meet the criteria outlined in the LCR based on a population of 425 served at SUBASENLON Conning Towers with no monitoring waivers. Figure 5-1 presents the decision chart for monitoring frequency of Conning Towers.

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Table 5-1 LCR Standard and Reduced Monitoring for Conning Towers

SUBASENLON

Site

Monitoring Type

Required Monitoring

Criteria

Conning Towers

Standard Monitoring1,2

10 samples every 6 months3

None

Reduced Monitoring

5 samples every year4

90th percentile Pb and Cu levels are at or below both ALs during two consecu-tive six-month monitoring periods.

5 samples every 3 years

90th percentile Pb and Cu levels are at or below both ALs for three consecu-tive years.

1) Monitor every 6 months for Pb and Cu.

2) If the system is on reduced monitoring, it must go back to standard monitoring and monitor WQPs when an AL is exceeded. Based on 40 CFR §141.86, the system must monitor WQPs every 6 months during the period that follows an AL exceedance. Samples must be representa-tive of water quality throughout the distribution system and include a sample from the entry to the distribution system. Samples must be taken in duplicate for pH, alkalinity, calcium, conduc-tivity or TDS, and water temperatures to allow a corrosivity determination (via an appropriate saturation index); the system must also monitor orthophosphate when a phosphate inhibitor is used and silica when a silicate inhibitor is used.

3) Select sampling sites based on a hierarchical approach. Give priority to single family residences that contain copper pipe with lead solder installed after 1982, contain Pb pipes, or are served by lead service lines; then to structures, including multiple-family residences (MFRs), with the fore-going characteristics; and finally, residences and structures with copper pipe with lead solder installed before 1983. First draw samples must come from a cold-water kitchen or bathroom tap; non-residential samples must come from an interior tap from which water is typically drawn for consumption.

4) Monitor annually for Pb and Cu if ALs are met during each of two consecutive 6-month monitor-ing periods. If the system meets the Pb and Cu ALs during three consecutive years, it may re-duce the monitoring for Pb and Cu from annually to once every three years. Annual or triennial sampling must occur during the four warmest months of the year.

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Figure 5-1 LCR Monitoring Frequency Decision Chart

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5.2 WHEN TO SAMPLE FOR LEAD AND COPPER

Standard Monitoring: For CWSs, collect a set of samples in the first six months and a set of samples in the second six months (recommended one set in the hottest month).

Samples must be analyzed for both Pb and Cu (40 CFR 141.86(a)).

Reduced Monitoring: All samples for reduced monitoring must be collected during the hottest month of the year (July or August, average temperature 34oC).

Two rounds of consecutive standard monitoring with results below the ALs may qualify the system for reduced monitoring. If the system qualifies for reduced monitoring, it must get the NAVFAC MIDLANT PM approval before beginning reduced monitoring activities. The system must maintain reduced monitoring documentation.

Table 5-2 outlines the SUBASENLON Conning Towers, Pb and Cu monitoring require-ments based on its population served.

Table 5-2 Lead and Copper Summary Monitoring Requirements

Monitoring Schedule

Frequency

Number of Tap Sites1

Population Served:

3,301 – 10,000

Population Served:

501– 3,300

Population Served:

101–500

Standard Every 6 months

40 20 10

Reduced2 Annual2

20 10 5 Triennial2

With Waiver Novennial

Number of Samples When AL is Exceeded

WQP 3

- pH

- Alkalinity

- Calcium

- Conductivity /

TDS

- Temperature

- Orthophosphate or silicate if used for corrosion control

Every 6 months

3 [duplicates] (Three duplicate sets of tap sam-ples, and One du-plicate set of samples from

POE to the distri-bution system])

2 [duplicates] (Two duplicate sets of tap sam-ples, and One du-plicate set of samples from

POE to the distri-bution system])

1 [duplicates] [One duplicate set of tap sam-ples, and One du-plicate set of samples from to the distribution system]

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Table 5-2 Lead and Copper Summary Monitoring Requirements (continued)

Monitoring Schedule

Frequency

Number of Tap Sites1

Population Served:

3,301 – 10,000

Population Served:

501– 3,300

Population Served:

101–500

Number of Samples When AL is Exceeded (continued)

Pb and Cu4 Every 6 months

1 Source water 1 Source water 1 Source water

1) The LCR states that, once monitoring is established, the same sites must be used, unless a site is no longer accessible.

2) Annually if ALs are met during each of two consecutive 6-month monitoring periods. A system that meets the ALs during 3 consecutive years may reduce the monitoring from annually to once every 3 years. Annual, triennial, or novennial (every nine years) sampling must be con-ducted during the four warmest months of the year.

3) Systems must monitor WQPs when ALs are exceeded. Samples must be taken in duplicate for pH, alkalinity, calcium, conductivity or TDS, and water temperatures to allow a corrosivity deter-mination (using an appropriate saturation index). Samples must be representative of water quality throughout the distribution system and include a sample from the entry to the distribution system.

4) Purpose is to determine contribution from source water to total tap water Pb and Cu levels and need for source water treatment. The PM sets maximum permissible levels for Pb and Cu in source water based on initial and follow-up source water monitoring.

5.2.1 Lead and Copper Monitoring Waivers

SUBASENLON Conning Towers water system serves a population of less than 50,000.

The SUBASENLON Conning Towers water system can be eligible for a monitoring waiver after completing at least two consecutive 6-month standard monitoring periods.

SUBASENLON Conning Towers must submit a request to the PM and get approval for reducing sampling to once every nine years. Until an approval is granted, in writing, SUBASENLON Conning Towers water system must continue to monitor for Pb and Cu.

This approval is contingent on satisfying the following conditions:

• The 90th percentile of Pb samples test results must be less than 0.005 mg/L and SUBASENLON Conning Towers must demonstrate that its distribution system, service lines, and all drinking water supply plumbing, including plumb-ing conveying drinking water within all residences and buildings connected to the system, are free of Pb-containing materials and/or Cu-containing materi-als, including the following:

− Plastic pipes and service lines that contain Pb plasticizers

− Pb service lines, Pb pipes, Pb soldered pipe joints, leaded brass or bronze alloy fittings, and Pb containing fixtures including faucets10.

10 Unless SUBASENLON can demonstrate that such fittings and fixtures do not leach Pb into the drinking water, by meeting the specifications established in 42 US Code 300g-6(e) (SDWA section 1417(e)).

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• The 90th percentile of Cu samples test results must be less than 0.65 mg/L and SUBASENLON Conning Towers must demonstrate (by providing certifica-tion and supporting documentation) that its distribution system, service lines, and all drinking water supply plumbing, including plumbing conveying drinking water within all residences and buildings connected to the system, are free of Cu-containing material.

5.2.2 PM EV Approval of Waiver Application

The PM EV waiver determination sets the basis of its decision and any condition of the waiver. An example of a conditional waiver is requiring SUBASENLON Conning Tow-ers to perform specific activities to avoid the risk of Pb or Cu concentration of concern in tap water (e.g., periodic outreach to customers to remind them to avoid installation of materials that might void the waiver).

5.3 HIERARCHY IN IDENTIFYING SAMPLING LOCATIONS

The EPA has established a priority tier classification system for CWSs to include sam-ple sites with the highest probability of corrosion as monitoring sites for Pb and Cu

(Appendix E). Appendix E includes available information on the construction dates of the SUBASENLON Conning Towers buildings.

• Tier 1 sampling sites consist of single-family structures that

− contain Cu pipe with lead solder that was installed after 1982 (i.e., con-structed between 1983-198811, but before the effective date of the CT Pb ban in 198612) and/or

− contain Pb pipe or are served by a Pb service line (any age structure)

Note: When MFRs comprise at least 20% of the structures served by a water sys-tem, the system may count them as Tier 1 sites.

• Tier 2 sampling sites consist of buildings, including MFRs, that

− contain Cu pipe with Pb solder that was installed after 1982 (constructed between 1983-1988) and/or

− contain Pb pipe or are served by a Pb service line (any age structure)

• Tier 3 sampling sites consist of single-family structures that contain Cu pipes with Pb solder installed before 1983.

11 In 1986, CT banned brass and bronze plumbing fittings that contain Pb and solder that contains Pb. This ban took effect on June 19, 1986 (based on the 1986 SDWA Pb Ban). However, in this sampling plan, the buildings (with Cu pipes with Pb solder) built after 1982, but in or before1986 are considered Tier 1 or Tier 2 sampling sites.

12 The SDWA Amendments in 1986 prohibited use of pipe, solder, or flux in public water that is not “Pb free.” This pro-hibition became effective on June 19, 1986. CT also banned the use of pipe, solder, or flux in public water that is not “Pb free” in 1986.

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• Other sampling sites are representative structures with other plumbing mate-rial (i.e., sites with Cu plumbing installed after 1988) may be used if no Tier 1- 3 sites are available.

Tier 1 sites have the highest probability of corrosion, decreasing to Tier 2, and then

Tier 3. If no “Tier” sites are available, “Other” sampling sites may be selected.

Based on the history of the establishment of the SUBASENLON Conning Towers, most buildings at SUBASENLON Conning Towers are classified as “Family housing” con-structed in 1963 (including a few buildings that have no construction date or function identification). Therefore, based on the provided list of structures/buildings constructed in 1963, no Tier 1 or Tier 2 sites exist at SUBASENLON Conning Towers. All the

SUBASENLON “Family Housing” units listed as built in 1963 are classified as Tier 3.

The sampling pool identified for SUBASENLON Conning Towers includes the building sites where water is drawn for human consumption. The sampling locations were cho-sen in accordance with the EPA LCR Monitoring and Reporting Guidance for PWSs

(EPA 2010)13. EPA recommends identifying more sampling sites than the required number of samples for each monitoring period in case primary sites become unavaila-ble due to demolition or renovation. If an original sampling site becomes inaccessible during any monitoring period, a tap water sample must be collected from another site that meets the same targeting criteria as the original site. The replacement site should be located within reasonable proximity of the original site.

5.4 WHERE TO SAMPLE FOR LEAD AND COPPER

Table 5-3 shows the LCR standard and reduced monitoring sampling pool for

SUBASENLON…