www.hudclips.org U. S. Department of Housing and Urban Development Washington, D.C. 20410-8000 July 21, 1994 OFFICE OF THE ASSISTANT SECRETARY FOR HOUSING-FEDERAL HOUSING COMMISSIONER Mortgagee Letter 94-36 MEMORANDUM TO: Approved Mortgagees SUBJECT: Clarification to Mortgagee Letter 92-18, Testing of Individual Wells All water must be tested to determine if it meets all applicable local, State or EPA standards for water quality. Mortgagee Letter 92-18 addressed the acceptance of individual residential purification equipment in existing and proposed construction. Paragraph B-3 states "If there are no local (or State) water quality standards, then water quality must meet the standards set by the Environmental Protection Agency (EPA), as presented in the National Primary Drinking Water requirements in 40 CFR Parts 141 and 142." In addition to state and local requirements, a test for lead in the water is also necessary as described in the attached statement from the EPA, dated April 18, 1994, because of the recommendation for lead-free submersible pumps in all wells. In the absence of specific codified state and/or local requirements for testing individual residential wells, and in addition to a bacteriological test, chemical analysis must be conducted using the test parameters in the State Drinking Water Regulations for "Non-Transient, Non-Community (NTNC)" water systems. A NTNC water system is a public system that regularly serves at least 25 of the same persons over six months per year such as in schools. Each State will normally maintain a list of test parameters for a NTNC water system. Each State will have slightly different requirements and a list of test parameters depending upon local conditions and circumstances. The State Drinking Water Regulations contain both the list of test parameters and accompanying maximum contaminant levels (MCL). The list of test parameters will normally include parameters with health and/or aesthetic significance. If there is an MCL for a parameter which is not satisfied, treatment of some kind is typically required. If a parameter has an MCL, it is considered important enough to apply in the determination for treatment, whether health related or not. Aesthetic parameters which are not satisfied will prohibit routine use of the water which can affect liveability and pose health risks indirectly. _____________________________________________________________________ 2 Therefore, it is important to run all tests required and recommended by each State for NTNC systems and routinely apply the MCL's at the drinking tap allowing those standards to dictate the need for treatment. The following procedures are required prior to accepting an individual well for FHA mortgage insurance: a. Water well testing must be in accordance with the latest version of the State Drinking Water Regulation. This includes all microbiological and chemical test parameters in the regulation, for both those required and recommended, for NTNC systems. A test for lead in the water is required (see attached EPA statement dated April 18, 1994, on lead in submersible brass pumps). b. The test sample(s) necessary for NTNC Microbiological and Chemical Testing must be in accordance with the State Drinking Water Regulation. New well samples should be taken from the nearest tap. In some states, County Health Authorities collect the test samples; however, if they will not collect the test samples, then a state licensed private laboratory can provide the sampling service. c. The sample must be tested in accordance with the State Drinking Water Regulation by either a state laboratory or a state licensed private laboratory. d. A copy of the test results must be forwarded to the County Sanitarian or Environmental Specialist for information with a request for comment regarding the maximum contaminant levels (MCL) appearing on that report for each test parameter. The County Sanitarian should recommend any needed water treatment. If the County Sanitarian, for any reason, refuses to provide an opinion as to whether the MCL's are satisfied, obtain a review and recommendation from the State Drinking Water Section. e. Manufacturer's letter showing the make and model number of any submersible pump in a newly constructed property or a newly (within one year) installed submersible pump in an existing property must be provided with the well/water testing report. The manufacturer's letter must say that the submersible pump is made of lead-free material. _____________________________________________________________________ 3 f. If water purification equipment is required to meet the State Drinking Water Regulation, then follow the instructions in Mortgagee Letter 92-18. If you have any procedural questions, you should contact the local HUD office. Technical questions should be referred to HUD Environmental Engineer, Les Prescott (Atlanta Office, 404 331-4129) or Wayne Klenck (San Francisco Office, 415-556-4791). Attachment Very sincerely yours, Nicolas Retsinas Assistant Secretary for Housing - Federal Housing Commissioner _____________________________________________________________________ United States Communications, Education, Environmental Protection And Public Affairs Agency (1703) _______________________________________________________ EPA Environmental News MONDAY, APRIL 18, 1994 EPA STATEMENT ON SUBMERSIBLE BRASS PUMPS ___________________________________________________________________________ Based upon data received recently, EPA advises homeowners with submersible brass pumps to have their water tested to see if it contains levels of lead in excess of our action level of 15 parts per billion (ppb). If the test indicates lead above 15 ppb, EPA has prepared information on various things the homeowner can do to reduce exposure to lead. A water test for lead typically costs from $15 to $40, depending on the lab. While waiting for the test results, which can take a week or two, homeowners with new pumps less than a year old, may want to use bottled water to prevent possible additional lead exposure, since new brass leaches lead at higher rates. This step is especially appropriate if there are children in the home, since children are particularly sensitive to lead. The data on submersible pumps came from the Environmental Defense Fund which performed laboratory studies following an NSF International test protocol. Submersible pumps are often used in homes that are not on public water and have their own wells. EPA does not have data that would tell how long the high lead leaching continues or how much of the lead coming from such pumps will appear at the water tap and expose the residents. To better document the levels at which people are actually exposed, EPA will undertake further testing of its own and subject it to peer review, as well as consult with pump manufacturers to obtain any data they have. However, because the levels in this initial study are high, EPA is offering advice to homeowners that emphasizes public health protection above all else. R-95 (more) _____________________________________________________________________ 2 EPA has prepared its hot lines (800-426-4791 for drinking water, 800-424-LEAD for lead) to answer questions about this problem and assembled some factual material and suggestions to the public on how to have water tested and what actions the public can take to reduce potential exposure to lead. When EPA completes its studies, it will provide the public with additional information. R-95 _____________________________________________________________________ United States Office of Prevention, Environmental Protection Pest , and Toxic Substances Agency (7404) _______________________________________________________ EPA Environmental News Fact Sheet _______________________________________________________ LEAD LEACHING FROM SUBMERSIBLE WELL PUMPS Introduction Lead is an element that is found in air, food, paint, dust, soil, and drinking water. The Environmental Protection Agency estimates that on average, we receive 15 to 20 percent of our total lead intake from drinking water. Lead exposure has been associated with a wide range of risks including delays in normal mental and physical development, impaired learning abilities in young children, and at extreme exposure levels, irreversible damage to the brain. This fact sheet is concerned with drinking water submersible well pumps. Some submersible well pumps are made of stainless steel and plastic components but the majority are constructed with brass fittings contained in a cast brass housing. While the plastic and stainless pumps do not pose a problem with lead leaching, EPA is concerned for residents of homes and other buildings with submersible well pumps made with brass fittings, because the brass alloys used in such pumps contain lead. These pumps have the potential to leach high levels of lead into drinking water, especially if the water is soft and corrosive. What Is A Submersible Well Pump? A submersible well pump is typically four inches in diameter and is specially designed to fit into a water well pipe. Lead can leach into drinking water when water sits in contact with the brass in the pump. This could create a health risk with the water pumped into the home or other building by the pump. Is There A Certification Program For Well Pumps? NSF international (NSF) is an independent certification and testing organization in the areas of environmental and public health. NSF develops voluntary standards for various products and provides testing and certification against those standards. ANSI/NSF Standard 61 is part of the NSF Drinking Water Additives Program and it addresses the health effects concerns of indirect water additives, including lead. Section 8.0 of Standard 61 outlines the requirements for various mechanical plumbing devices that contact drinking water, including submersible _____________________________________________________________________ well pumps. Currently, one brand of pump has been evaluated, tested and certified by NSF against Standard 61, Section 8.0. Others have applied for Certification and are being evaluated. What Is The Environmental Protection Agency Doing? Although EPA does not regulate individual home water wells, it does regulate public water systems, those serving 15 or more connections or those that regularly serve at least 25 individuals, to monitor for lead and install corrosion control treatment if lead is found in excess of 15 parts per billion lead in more than 10 percent of homes tested. EPA is in the process of testing lead leaching levels from submersible well pumps. Laboratory and statistical analysis of the lead leaching data will be performed to determine to what extent lead leaching from water pumps poses a public health concern to anyone using them. What Should You Do? If you are uncertain about the composition of your pump, or you know it contains brass components, you should get your drinking water tested. Select a certified laboratory in your area and be sure to follow the proper EPA sampling protocol. The protocol can be obtained from EPA's Safe Drinking Water Hotline (800-426-4791). EPA's Safe Drinking Water Hotline can provide you with the name, address, and phone number of your State lab certification officer. They, in turn, can provide a list of State-certified laboratories. If your submersible well pump was installed within the last year, EPA advises you to drink bottled water while you wait for the results of the laboratory analysis. EPA's action level for lead is 15 parts per billion. If the test results indicate that your drinking water has lead levels above the action level, there are several steps you can take. There are a number of cartridge and reverse osmosis filtering devices that are available to remove lead from drinking water at the tap. NSF International evaluates and certifies both bottled water and drinking water treatment devices, the latter with regard to lead reduction performance. Lists of certified products are available from NSF upon request. The Water Quality Association (WQA) can provide advice on treatment units for specific uses at home. As a last resort, you may want to replace the existing water pump with a stainless steel model. However, this option is expensive, and still may not eliminate all the lead in your drinking water, because some of the lead produced by the pump may have settled out in different parts of the home's piping. In addition, other components of the home plumbing system, such as solder, brass fittings, and faucets are also potential sources of lead. For More Information For more information about lead in drinking water, contact the EPA Safe Drinking Water Hotline at 800-426-4791 or the National Lead Information Center at 800-424-LEAD. For more information about the NSF drinking water additives, bottled water, or drinking water treatment unit programs contact NSF International at 3475 Plymouth Road P.O. Box 130140 Ann Arbor. MI 48113-0140 (313)769-5106. WQA can be contacted at (708)505-0161, ext. 270. _____________________________________________________________________ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR 18 1994 THE ADMINISTRATOR EPA Statement on Submersible Brass Pumps Based upon data received recently, EPA advises homeowners with submersible brass pumps to have their water tested to see it it contains levels of lead in excess of our action level of 15 parts per billion (ppb). If the test indicates lead above 15 ppb, we have prepared information on various things the homeowner can do to reduce exposure to lead. A water test for lead typically costs from $15 to $40, depending on the lab. While waiting for the test results, which can take a week or two, homeowners with new pumps less than a year old, may want to use battled water to prevent possible additional lead exposure, since new brass leaches lead at higher rates. This step is especially appropriate if there are children in the home, since children are particularly sensitive to lead. The data on submersible pumps came from EDF who performed laboratory studies following an NSF International test protocol. Submersible pumps are often used in homes that are not on public water and have their own wells. We do not have data that would tell us how long the high lead leaching continues or how much of the lead coming from such pumps will appear at the water tap and expose the residents. To better document the levels at which people are actually exposed, EPA will undertake further testing of its own and subject it to peer review, as well as consult with pump manufacturers to obtain any data they have. However, because the levels in this initial study are high, we are offering advice to homeowners that emphasizes public health protection above all else. We have prepared our hot lines (800-426-4791 for drinking water, 800-424-LEAD for lead) to answer questions about this problem and assembled some factual material and suggestions to the public on how to have your water tested and what actions the public can take to reduce their potential exposure to lead. When EPA completes its studies, we will provide the public with additional information. _____________________________________________________________________ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 APR 18 1994 MEMORANDUM FROM: Joe Carra, Deputy Director OPPT Peter Cook, Deputy Director OGWDW OFFICE OF WATER TO: Regional Lead Coordinators Drinking Water Branch Chiefs At 10:30 West Coast time, EDF will hold a press conference announcing results of laboratory testing for lead leaching of a number of submersible drinking water well pumps. It is essential that you include the attached statement, approved by the Administrator, along with the materials we have already forwarded to you. You should make sure to communicate the message on this statement when answering inquiries relating to submersible pumps and include it with any written materials you give to the public or others. EDF has shown EPA the results of their tests, which were based on an NSF International test protocol that involved submersing the pumps overnight in a large cylinder or test water and measuring the lead concentration of the water. The results indicate very high levels of lead leaching throughout the thirty day testing period. The levels are many thousands of ppb during the first few days and remain as high as 700 ppb after 30 days. According to EDF the manufacturers whose pumps have been tested are not disputing the high test levels but argue that dilution will reduce lead to acceptable concentrations at the tap. Unfortunately, no one appears to have empirical data on what the lead levels would be at the tap. Given this and insufficient time to mount a research effort to peer review and duplicate the tests or document true exposure at the tap, EPA has decided to offer advice to the public that emphasizes public health protection above all else to assure the chance of high exposures is eliminated to those who follow the advice. This is the message communicated in the attached statement. We ask that you call all of your state counterparts to alert them of the press conference, the rationale behind our advice, and the likelihood of substantial media interest. While this effort by EDF is directed at pumps sold in California, we expect it to get national coverage in the media. _____________________________________________________________________ U.S. Department of Housing and Urban Development Washington, D.C. 2O410-0000 First-Class Mail Postage & Fees Paid Official Business HUD Permit No. G-51 Penalty for Private Use $300