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
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