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6.d. Water Meter Replacement
4ROSEMOUNTEXECUTIVE SUMMARY CITY COUNCIL Utility Commission Meeting: March 11, 2013 ISSUE New regulations which reduce the allowable lead content in drinking water will go into effect on January 4, 2014. These new regulations will impact our procedures for repairing/ replacing existing water meters for potable water supply. The new regulations provide exemptions for irrigation meters and any other components that are used exclusively for non - potable services. BACKGROUND The Reduction of Lead in Drinking Water Act was signed on January 4, 2011 as an amendment to the Safe Drinking Water Act. This legislation reduces the limit on lead for wetted surfaces of pipe, pipe fittings, plumbing fittings, fixtures, solder and flux. The new regulations will go into effect on January 4, 2014. As a result of this new legislation, all components in a potable water system (including water meters) must be compliant with the new standards. Whenever an existing (older) meter is removed for repair or replacement, a new compliant meter must be installed. Based on past history of water meter repairs, it is anticipated that 100 to 120 meters per year will need to be replaced, at an estimated cost of $40,000 to $45,000 per year. The budget for meter replacements will be adjusted accordingly beginning in 2014. All water meters purchased, installed and/or distributed by City staff since September 2012 are in compliance with the new standards. SUMMARY This item is intended to provide the Commission with updated information about this issue. No action is necessary. G: \UTILITY COMMISSIOMUC Information \20130311 UC Water Meter Replacement.docx AGENDA SECTION: AGENDA ITEM: Water Meter Replacement New Business PREPARED BY: Andrew J. Brotzler, PE, Director of AGENDA NO. Public Works / City Engineer ATTACHMENTS: Sensus Information and FAQ Sheet APPROVED BY: RECOMMENDED ACTION: None ISSUE New regulations which reduce the allowable lead content in drinking water will go into effect on January 4, 2014. These new regulations will impact our procedures for repairing/ replacing existing water meters for potable water supply. The new regulations provide exemptions for irrigation meters and any other components that are used exclusively for non - potable services. BACKGROUND The Reduction of Lead in Drinking Water Act was signed on January 4, 2011 as an amendment to the Safe Drinking Water Act. This legislation reduces the limit on lead for wetted surfaces of pipe, pipe fittings, plumbing fittings, fixtures, solder and flux. The new regulations will go into effect on January 4, 2014. As a result of this new legislation, all components in a potable water system (including water meters) must be compliant with the new standards. Whenever an existing (older) meter is removed for repair or replacement, a new compliant meter must be installed. Based on past history of water meter repairs, it is anticipated that 100 to 120 meters per year will need to be replaced, at an estimated cost of $40,000 to $45,000 per year. The budget for meter replacements will be adjusted accordingly beginning in 2014. All water meters purchased, installed and/or distributed by City staff since September 2012 are in compliance with the new standards. SUMMARY This item is intended to provide the Commission with updated information about this issue. No action is necessary. G: \UTILITY COMMISSIOMUC Information \20130311 UC Water Meter Replacement.docx ® 8601 Six Forks Road C ® Suite 300 G Raleigh, NC 27615 USA www.sensus.com Many questions have been raised regarding the new low lead initiatives being implemented by NSF and Congress. Here is an overview of the new regulatory requirements; in addition to answering some frequently asked questions. Overview of Regulatory Changes NSF /ANSI Standard 61 (Annex F) • Reduces the allowable lead leach maximum limit of 0.08% (5 ppb) for all NSF Standard 61 certified products • All existing NSF Standard 61 approved products will be retested to the new requirement in order to maintain NSF Standard 61 approval • Effective Date: July 1, 2012 NSF /ANSI Standard 372: • New lead content only approval standard that replaces NSF /ANSI Standard 61, Annex G • NSF standard in accordance with California AB1953 and new national lead -free law requiring a 0.25% (15 ppb) maximum lead content for all wetted components • Effective Date: October 1, 2010 5.3874, Reduction of Lead in Drinking Water Act • New national law (amending the Safe Drinking Water Act or SDWA) requiring products in contact with drinking water to a 0.25% (15 ppb) maximum lead content for all wetted components using a surface based averaging formula • The new NSF Standard 372 will provide independent third party verification to the law • Effective Date: January 4, 2014 Page 1 of 7 8601 Six Forks Road Suite 300 Raleigh, NC 27615 USA www.sensus.com NSF 61 evaluates all potential contaminants from drinking water products NSF 61 -G evaluates potential contaminants and weighted average lead content of <_0.25% wr�s sEnsus NSF 372 evaluates products for a weighted average lead content of <_0.25% Marking for Water Distribution Products Standard 61 Certified Standard 61 & Low Low Lead Lead Certified I Certified NSF®- 61 a) Certified to NSF /ANSI61 NSF®- 61 -G CertitiQd t0 NSF/ANSI 61-G Page 2 of 7 NSF - 372 13 CMified to NSF /ANSI 372 I 8601 Six Forks Road C ®� Suite 300 c Raleigh, NC 27615 USA www.sensus.com Questions & Answers Are my water meters and other system components compliant with the new standards for lead leach and content? The following Sensus products comply with NSF Standard 61 (Annex F and G) and NSF Standard 372 (Reduction of Lead in Drinking Water Act). iPERL accuSTREAM Low Lead (BIA or EBII) SR and SRII OMNI accuMAG Low Lead W- Series chambers If I remove a meter from service for testing or repair, can I put it back into the system? If a meter is physically removed from service and it does not comply with the regulations or standards, it should not be re- installed. A compliant product must be installed. Why has Sensus chosen alternative materials (i.e. composite, coated iron, etc.) instead of bronze material? For more than 100 years, Sensus has continued to deliver products that meet the highest standards for quality, reliability and innovation. New technology and materials enables us to provide our customers metrology products to meet the low lead laws while maintaining and exceeding the product excellence our customers have come to expect. In addition to improving the strength characteristics of the products, these materials enable us to maintain a more stable pricing structure going forward (where we are not tied to fluctuating copper prices). Furthermore because the EPA's contaminant level goal for lead in drinking water is set at zero, by using alternative materials that contain zero lead, we will be in compliance with all future changes to the NSF standards and government laws regarding lead. Page 3 of 7 8601 Six Forks Road C S Suite 300 G - Raleigh, NC 27615 USA www.sensus.com Do these requirements apply to my utility? Drinking water system components fall into two categories of regulation — Municipal and distribution products up through the water meter are typically regulated by state drinking water agencies — Water distribution systems downstream of the water meter or inside a building are typically regulated by state or local plumbing codes 46 states have legislation, regulations or policies requiring or recommending drinking water system components should comply with NSF /ANSI Standard 61. Refer to Appendix A for Associate of State Drinking Water Administrators (ASDWA) Member Survey on State Adoption of NSF /ANSI Standards 60 and 61. Page 4 of 7 - 8601 Six Forks Road - Suite 300 - Raleigh, NC 27615 USA www.sensus.com Appendix A sEnsus AZ: Legislation revised 7/96 to allow exceptions where 60 -61 materials and equipment not available. '- CA: Requires annual testing and inspections for ANSI accredited certification of treatment chemicals to NSF 60. 3 DE: Lases NSF list or equivalent guide but does not require for compounds not listed under either standard. FL: 1993 is for coatings and chemicals. 1994 is for other components. 51-H: Adopted for Standard 60, Legislation for Standard 61, section 9 signed May ?, 2001. 6 State policy or regulations reference the "10 State Standards for Water Worts" which references Standard 60 for treatment chemicals and Standard 61 for certain water treatment and distribution products. T KS: KA.R- 28 -15 -18 (h) authorizes approval of treatment chemicals and protective coatings exposed to water for public consumption. KS has no regulations specifically for standards 60 or 61. Page Al of 7 Adopted I SI Effective Date of Regulation and Latest State Legislation State Citation Accredited Update or Certifier Regulations Required Standard 60 Standard 61 Alabama Yes 335 -7- 6.12/8.04 No November 9, 1992 November 9, 1992 Alaska Yes 18 AAC 80.030 No May 18, 1994 May 19. 1994 Arizona Yes) AAC RI 8-4-213 Yes January 1, 1993 January 1, 1993 Arkansas Yes PWS Reg_ Yes (policy) October 1, 1994 October 1, 1994 California Yes'- CCR Title 22: Yes'- January 1, 1994 March 9, 2008 64590/64591 Colorado Policy Yes (policy) Connecticut No No Delaware 6 Yes PWS Reg. No3 August 11, 1999 August 11, 1999 2.11.1.1 Florida Yes 62- 555.320(3) +3 220 FAC No January I I993 , January 1, 1993 January 1, 1994 4 nu Georgia Yes Rules 391 -3 -5 Yes July, 199'2 July, 1992 Hawaii Yes- HAR 11 -20 -38 Yes September 7- 1999 Idaho Yes 58.01-08.501.01 Yes October 1, 1993 October 1, 1993 58.01.08.510.02 Illinois' Pohcy6 Indiana6 Yes 3271AC 8 -1 -2 Yes May 1, 1999 May 1, 1999 iowa6 Yes 41.4 (3) b; 4'3.3 (8) Yes October 1, 2000 August 11, 1999 Kansas Policy' Yes (policy) Kentucky Policy Yes (policy) Louisiana No No Maine Yes 10- 144 -231 Yes July 1, 2008 July 1, 2008 Sec 3 F.7, 8 AZ: Legislation revised 7/96 to allow exceptions where 60 -61 materials and equipment not available. '- CA: Requires annual testing and inspections for ANSI accredited certification of treatment chemicals to NSF 60. 3 DE: Lases NSF list or equivalent guide but does not require for compounds not listed under either standard. FL: 1993 is for coatings and chemicals. 1994 is for other components. 51-H: Adopted for Standard 60, Legislation for Standard 61, section 9 signed May ?, 2001. 6 State policy or regulations reference the "10 State Standards for Water Worts" which references Standard 60 for treatment chemicals and Standard 61 for certain water treatment and distribution products. T KS: KA.R- 28 -15 -18 (h) authorizes approval of treatment chemicals and protective coatings exposed to water for public consumption. KS has no regulations specifically for standards 60 or 61. Page Al of 7 8601 Six Forks Road — Suite 300 — Raleigh, NC 27615 USA www.sensus.com sEnsus s MID: Also accepts third party certifications. 9 MLA: Also requires maximum lead content of 3% in brass products. Page A2 of 7 Adopted AN-S1- Effective Bate of Regulation and Latest State LegiislatioII State Citation Accredited Update or Certifier Regulations Required Standard 60 Standard 61 Maryland Yes 2COMAR Yess December, 1992 December, 1992 Massachusetts' Yes 310 Cbi1t ??.04(8) Ye, November, 1942 November, 1992 NII SDWA M� Yes 325.1013 Yes September 16, 1993 September 16, 1993 +325.12102 bfinnesota° Policy Yes (policy) bfississippi Policy Yes (policy) Misscun6 Yes 10 CSR 60 Yes ApiL 1992 Apo 1992 Montana Yes ARM 17.38:101 Yes September, 1992 September, 1992 Nebraska No No Nevada Yes NAC 445A_6663 Yes February, 1997 February, 1947 New Hampshire Yes Em- -Ws 305 Yes Jane, 1997 June, 1997 New Jersey Yes NJAC 7:10 -8 Yes Jane, 1947 June, 1947 New lvfesico s Ye, WSR Yes July, 1992 July, 1992 20.7.10.400K Re%ised 2007 Resised M07 New York6 Policy Yes (policy) Jaly, 1993 July, 1993 North Carolina Yes 15A NCAC 18c 1537 Yes July 1, 1994 July 1, 1994 North Dakota Yes NDAC 33- 17 -01- Yes January 31,1997 January 31, 1997 19.4 Ohio 6 Yes OAC 3745 -83- Yes Fz�ised Rz%ised 01(d) April 21, 2001 April 21, 2001 Oklahoma Yes OAC 252:626- Yes (policy) Update effective Update effective 11.1+19.1 June 1, 2003 lime 1, 2003 �gO° Yes 333-61 - 0087(05)8x(06) Yes (policy) November 13, 1959 November 13,19S9 pennsyh—a6 Yf-- 25 PA Code Yes October 8, 1994 October S, 1994 109.606 RhodeI.landb Yes DWQ 4613 4 iA Yes January, 1493 January, 1943 South Carolina° Yes R.61 -58.2 (B) 4& (E) 3 Yes July 28, 1995 December 31, 1995 South Dakota Policy Yes (policy) Tennessee Yes 1200 -5 -1- .17(36) Yes January, 1995 January, 1495 TAC 290 42Q- Texas Yes 43 (c) (8); 44 (a) (12); Yes January 1, 1943 January L 1993 44 Utah Yf-- R309 -105- 10(1)(a}t100)(e) Yes July, 1984 July, 1959 s MID: Also accepts third party certifications. 9 MLA: Also requires maximum lead content of 3% in brass products. Page A2 of 7 ® 8601 Six Forks Road - Suite 300 ® Raleigh, NC 27615 USA www.sensus.com sEnsus 10 WY: Reconunends use of the standards. Cannot require because state does not have primacy for drinkui my water regulations. Page A3 of 7 Adopted ,ANSI_ Effective Date of Regulation and Latest Legislation Accredited Update State or State Citation Certifier Regulations Required Standard 60 Standard 61 Vermont Yes V R Ch- 21 Yes September 24, 1992 September 24, 1992 App . A 5:22 pp Virginia Yes 12 VAC 5 -590- Yes November 15, 1995 November 15, 1995 860 & 1110 Washington Yes WAC -246 290 - Yes April, 1999 April, 1999 220 West Virginia Yes 64 CFR 77 Yes July, 2000 July, 2000 Wisconsin" Yes NR811(}0)7(4)(c), Yes May, 1993 May, 1993 Wyoming Policy10 10 WY: Reconunends use of the standards. Cannot require because state does not have primacy for drinkui my water regulations. Page A3 of 7 I of 9 03/01/2013 2:07 PM UL Summary Lead Levels Drinking Water System Components.pdf E http://www.vchstate.va.us/ODW/documents/2013/pdf/UL Summary L... Lead Levels in Drinking Water System Components An Overview of Regulations for Lead Levels in Drinking Water System Components Since the establishment of the federal Safe Drinking Water Act (SDWA) m ore than 35 years ago, the safety of the U.S. drinking water supply has been an ongoing priority for heal th regulatory officials. Star tirig with a list Of just 25 potential contaminants in 1c97q, federal regulations administered by the U.S. Environmental Protection Agency (EPA) currently identify maxim urn concentration levels in drinkingwater for more than loo different chemicals. In addition, a num ber of individual states and I ocal jurisdictions have implemented requirem entsto ensure the safety of drinking water from source to tap. While the list of regulated chemicals in drinkingwater expands as new potential contaminants are identified, the presence of lead continues to receive special scrutiny Lead isnot norm allyfound in source water, but can enter drinkingwater systemsthrough the corrosion of the pipes and plumbing fixtures. Therefore, regulatory efforts to reduce the presence of lead in drinkingwater prim arily focus on the lead content of drinking water system components. Am Ong the most recent efforts in this area is the passage of the federal Reduction of lead in Drinking Water Act signed into law by President Barack Obama in January 2oi1. The new law redefines "lead- free" under the SDWA to further restrict permissible levels of lead in drinking water system components. In this case, federal action followsthe implementation of strict regulations in California and Vermont, where tighter limits on lead content have been in place since early zoio, and in Maryland where similar restrictions becorn e effective in January2012. While the complete im plem entation of these recent regulatory changes will play out over the next few years, the trend toward increased regulation of the lead content of drinking water system components is clear. Yet, confusion still exists among manufacturers and distributors regarding federal and state requirements for lead content in drinkingwater system components, and what steps manufacturers should take to ensure that their products are compliant now and in the future. This white paper from UL presents an overview of the federal and state requirements governing the lead content in drinkingwater system components. It also reviews and discusses the standards and testing protocols that currently apply to these products as well as anticipated changes in the current standards. Finally, the paper identifies the likely enforcement mechanisms for lead content regulations and outlines compliance options for manufacturers. page 2 2 of 03/01/2013 2:07 PM UL Summary Lead Levels Drinking Water System Components.pcif V� Federal Regulations on Lead in Drinking Water System Components Although lead has been used extensively for thousands of years in a wide range of household products, including plumbing materials and paint, it is a potent, neurotoxic metal that accumulates in both soft tissue and bones. Even low -level exposure can lead to a range of adverse health effects, including brain, nervous system and blood disorders. According to the EPA, children six years old and younger are at greatest risk, since exposure can adversely affect brain development, leading to learning disabilities and behavior problem s'. Concentrations of lead found in drinking water do not usually derive from natural sources. Instead, the m ost com m on cause of lead concentrations in water is due to contamination from the gradual corrosion of water supplypipes and plumbing fixtures as well as the solder or flux used in their installation and repair. Accordingly, m ost current regulatory effortsto control lead in drinkingwater focus primarily on reducing the lead content of these system components. Federal efforts to control concentrations of lead and other contaminants in drinkingwater began in 1974with the passage of the SDWA. Under the SDWA, the EPA is m andated to set enforceable maximum containment levels (MCLs) for contam inants. Publ i c water system s are then required to ensure that the concentrations of contaminants in their water supplies comply with the MCLs, most often by using suitable technologies to treat the water and to page 3 http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... Lead Levels in Drinking Water System Components minimize the risk of the contaminants. As origina11yimplernented, the SDWA required public water systems to m inirn ize lead concentrations by controlling the corrosion that resulted in lead leaching from the water system infrastructure. Typically, such control was achieved through careful management of the water's m ineral content, acidity and temperature aswell as through the proper m aintenance and replacem ent of the water system's piping. Butwhile effective in controlling lead concentrations after the fact, this approach did little to control the original source of the lead found in drinkingwater, that is, the pipes and fittings used in the installation and repair of public water systems. It also did not address plumbing fixturesfound in residences and other extensions of public water systems. To address these and other concerns, the SDWA was amended in 1986. Under a new Section 1417, the amended SDWA mandated that all pipes, solders, pipe fittings and plum bingfixtures used in the installation or repair of any public water system, or any residential or nonresidential facility that provides water for human consumption be "lead- free:' Under the SDWA lead -free restrictions, pipes and fittings were limited to not m ore than 8.o% lead, and solders and flux could not contain rnore than 0.20% lead by weight. In addition, plumbing fittings and fixtures were limited to not m ore than 4.0% (m easured by dry weight) after Au g. 6, 2001. The EPA's control over the lead content of drinking water system s and com ponents was further strengthened in 1996, with UL's Involvement in Development of Pb Standards and Testing • Ensure safety of U.S.water supply and has played a key role in the development of standards and testing protocols regarding lead. • Evaluation of products and materials for lead content as part of the Restricted Substance Compliance Solutions program. • Contribute expertise in development of lead content requirements for evaluating products against the new California regulations. • Interpreted the California law as also requiring manufacturers to test their products as part of the initial certification of drinking water system components. • Published Subject Outline 116875 —Lead (Pb) Content Verification Of Products In Contact With Potable Water, which contained material testing requirem ents for lead. • Support the development of a new industry standard that would address the lead content testing requirem ents. • Provide manufacturers with a clear path to demonstrate compliance with existing and anticipate state and federal requirements. • Exemplify the historic mission to protect the safety and health of consumers in the United States and around the world. 3 of 03/01/2013 2:07 PM UL Summary Lead Levels Drinldng Water System Components.pdf a an additional amendment to Section 1417 of the SDWA. In addition to requiring water system s to issue an annual public report on their water quality, the am ended SDWA established a two -year deadline for the creation of a voluntary standard addressing maximum leaching levels for lead used in plumbing fittings and fixtures. The amended law also gave the EPA temporary enforcement authority against noncompliant plumbing fittings and fixtures. The irni Reduction of Lead in Drinking Water Act The rn ost recent developm ent in federal regulations governing the lead content of drinking water system components is the enactment of the Reduction of Lead in Drinking Water Act, signed into law by President Barack Obam a in January 2o11'. The Act effectively reduces the permissible lead content in plumbing fittings and fixtures by further modifying the SDWA definition of lead -free. However, rather than setting new lead limit benchmarks, the Act effectively brings federal lead content lim its in line with those already in force in California and Verm ont and adopts lead content assessm ent protocols consistent with those developed in support of these state regulatory efforts. Under the Reduction of Lead in Drinking Water Act, the SDWA definition of the term lead -free has been m odified to reduce the m axim um lead content to "not m ore than a weighted average of 0.25% (lead) when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures" Page 4 http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... e Lead Levels in Drinking Water System Components At the same time, the Act retains the 0.20% lead limit for solders and flux first implemented in 1986 and stipulates a method for calculating the weighted average lead content. Exempted from the provisions of the Act are pipes and plumbing fixtures that are used exclusively for nonpotable water services, such as those found in manufacturing and industrial processing applications, and for those used in outdoor irrigation and watering system s. Alsoexempt are toilets, bidets, urinals, flushom eter valves, shower valves and water distribution m ain gate valves two inches or larger in diameter. The provisions of the federal Reduction of lead in Drinking Water Act com e into effect in January 2014. However, more restrictive state limits are already in effect in California and Vermont, and new lead content restrictions are set to take effect in Maryland in January 2o12. Therefore, in an effort to achieve market acceptance in these and other states, it is anticipated that m anufacturers will bring their products into compliance with the new federal lead content limits as soon as possible. State Regulations on Lead in Drinking Water System Components As previously noted, recent federal efforts to reduce the lead content of plumbing fittings and fixtures have followed the lead of state jurisdictions. The most notably developments have occurred in California, beginning with the passage of California Assembly Bill 1953 (AB 1953) in September 2oo6. Since then, other states, including Vermont and Maryland, have passed comparable laws limiting lead content in plum bing fittings and fixtures as a way of reducing lead concentrations in drinking water, and other states are evaluating legislation with similar import. In California, AB 1953 was the first state effort to implement limits on lead content in plumbing fittings and fixtures that were m ore restrictive than federal requirements. AB 1953 became law in September 2oo6, with an effective enforcem ent date of Jan. 1, 2010. The law has been codified in the state's Health and Safety Code (HSC), Section 116875, and falls under the jurisdiction of the California Department of Toxic Substances Control (DTSC). The key change mandated by AB 1953 is the reduction of lead in wetted surfaces of pipes, pipe fittings, plum bing fittings and fixtures to a weighted average of not m ore than 0.25% (the 0.20% lead content lim it for solder and flux rem ained unchanged). Further, as implemented under HSC 116875, "no person shall introduce into commerce any pipe, pipe or plumbing fitting, or fixture intended to convey or dispense water for hum an consumption through drinking or cooking that is not'lead- free'3." As originally written, AB 1953 contained no provisions regarding the implementation or enforcement of its more restrictive lead content limits for plumbing fittings and fixtures. These issues were partially addressed by subsequent legislation in 2oo8, specifically California Senate Bill (SB) 1395 and SB 1334- SB 1395 grants the DTSC the authority to annually test up to 75 faucet, fitting and fixture sam pies for 4 of 9 03/01/2013 2:07 PM UL Summary Lead Levels Drinlang Water System Components.pcif 9 'compliance with AB 1953's lead content limits and to post the results of that testing on its website. Under the law, the DTSC m ust use "test m ethods, protocols, and sample preparation procedures that are adequate to determine total lead concentration in a drinkingwater plumbing fitting or fixture to determine compliance with the lead content standards4." Of potentially even greater importance to manufacturers, California SB 1334 requires that all plumbing products that come in contact with potable water be certified by an independent third -party accredited by the American National Standards Institute (ANSI). Such third party certification must include the testing of plumbing products consistent with the testing m ethods and protocols used by the DTSC. As implemented under California HSC 116875, the product certification provisions of SB 1334 becam e m andatory as of Jan. 1, 20105. In Verm ont, the Lead in Consum er Products Law, Act 193, implements lead content restrictions for plumbing fittings and fixtures consistent with those in California and with the new federal limits under the Reduction of Lead in Drinking Water Act, i.e., not more than a weighted average of 0.25% for plumbing fixtures and 0.20% for solder or flux used in plumbing. Under Vermont 193, which came into effect on tan. 1, 2olo, noncompliant plum bingfittings or fixtures in ay not be sold or offered for sale in or into Verm ont or installed in Vermont. Unlike California's requirements, Act 193 does not require plumbing supplies to be certified byan independent third -party laboratoryto be legally sold in Vermont. However, "sellers and installersmust page 5 http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... Lead Levels in Drinking Water System Components have a reasonable basis for believing that a particular product is corn pliant before selling or installing it6:' In Maryland, House Bill 372 was signed into law by Governor Martin O'Mall ey in May 2010 and takes effect on January i, 2012. The Maryland lead -free materials law limits the lead content of specified plumbing materials to levels consistent with the current laws in California and Vermont, and prohibits the installation of a plumbing fixture or device that does not complywith the lead content limits. Importantly, the law authorizes the Maryland State Board of Plumbing to modify the state's plumbing code in order to implement and enforce the new requi rem ents7. As previously noted, the current laws in California and Vermont governing the lead content of plumbing fittings and fixtures as well as pending laws in Maryland and other states are likely to lead m anufacturers to -seek corn pliance with reduced lead content lim its well ahead of the January 2014 im pl em entation date of the federal Reduction of Lead in Drinking Water Act. In addition, even without federal certification requirements regardingthe lead content of plumbing products, California's mandate for third -party certification establishes a de facto national testing and certification requirement, since most manufacturers will likely seek a single approval path that covers both federal and state requirem ents. For that reason, it is important to understand the standards and testing protocols that support third -party certification of lead content in plumbing fittings and fixtures. Applicable Standards and Testing Protocols While a number of states have moved quickly over the past few years to enact regulations aim ed at reducing the lead content of plumbing products, implementation of these regulations generally depends on the development of standards and testing protocols that support manufacturers' efforts to complywith new limits. Further, effective enforcement of both state and federal requirements largelydepends on updating applicable plumbing and building codes to reflect standards development efforts. Although efforts to develop new standards and update applicable codes usually lag the pace of regulations, standards development groups and code officials have worked energetically with industryto provide appropriate guidance to manufacturers seeking compliance with the lower lead content requirements for plumbing fittings and fixtures. ANSI /NSF 61 was first published in 1988 to establish minimum requirements for products that contact drinking water in order to prevent adverse health effects in humans from the unintentional ingestion of metallic and non -rn etallic contaminants, including lead. The standard includes criteria for evaluating a wide range of plumbing products, including pipes and related products, and mechanical plumbing devices. The requirements found in model plum bing codes like the IPC and the UPC are often the basis for plumbing regulations in local jurisdictions. These requirements are typically incorporated 5 of 03/01/2013 2:07 PM UL Summary Lead Levels Drinldng Water System Components.pdf UL by reference in local building and plumbing regulations, and local plumbing inspectors effectively enforce these requirements through the permitting process and follow -up inspections. The adoption of ANSI /NSF 61 by both the ]PC and the UPC enabled enforcement of the SDWA by leveraging the oversight and infrastructure alreadyin place through local plumbing officials and inspectors. In this context, the passage of California AB 1953 in 2oo6 presented several challenges for both manufacturers and code officials. First, the testing m ethod described in ANSI /NSF 61 assessed the content of lead and other regulated substances by m easuringthe amount of contaminants that leached from tested products into water. But ANSI /NSF 61 did not specify analytical m ethods or protocols that would allow manufacturers to directly m easure the lead content of the materials themselves, consistent with the weighted average lead content requi rem ents of AB 1953 Second, the scope of products covered under ANSI /NSF 61 was m ore limited than that covered under the California law. The requirements of ANSI /NSF 61 applied prim arily to plumbing products. But AB 1953 (as codified in HSC Section 116875) applies to "any pipe, pipe or plumbing fitting, or fixture intended to convey or dispense water for hum an consumption through drinking or cooking,$" and som e interpretations of the law have included item s as diverse as hot water heaters and fire hydrants. Finally, updating industry standards to reflect regulatory changes is a lengthy process, and the adoption by new and page 6 http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... I Lead Levels in Drinking Water System Components revised standards by national code organizations can take years. Since the product scope and testing requirements of California AB 1953 were not consistent with those of ANSI /NSF 61, oversight and enforcement of the requirements through the local plumbing code system would not be possible. In partial response to these challenges, the NSF Joint Comm ittee on Drinking Water Additives was tasked with am ending ANSI /NSF 61 to incorporate criteria for the weighted average lead content requirement of AB 1953. The result of this effort was the development of Annex G for ANSI /NSF 61 published in January2009. Intended to be used in conjunction with ANSI /NSF 61, Annex G defined a method for calculatingthe weighted average lead content of a product, consistent with the requirem ents of AB 19534. However, while the publication of Annex G provided a m ethod for calculating lead content, it did not expand the scope of ANSI /NSF 61 to include the full range of products identified in the California law. More important, Annex G failed to define specific testing requirements and methods for analyzing the lead content of m aterials. So the NSF Joint Comm ittee turned its attention to the development of a new standard that would address these shortcomings. The result was the development of ANSI/NSF 372 — Drinking Water System Components, Lead Content released in late 2010. ANSI/NSF 372 contains the lead content evaluation procedure originally detailed in ANSI /NSF 61 Annex G, as well as testing requirem ents and rn ethodologies for material lead content analysis. Further, the scope of the standard applies "to any drinking water system component that conveys or dispenseswater for hum an consumption through drinking or cooking,1O" mirroringthe scope of AB 1953. Because ANSI/NSF 377 does not address contaminants other than lead, it can be used in those jurisdictions which have adopted requirements similar to those in California, but which do not mandate compliance with ANSI /NSF 61. With the introduction of ANSI/NSF 372, Annex G of ANSI /NSF 61 has been revised to reference ANSI /NSF 372 for the evaluati on of the wei ghted average lead content and lead content material analysis. This change makes ANSI /NSF 372 the primary standard regarding lead content in drinking water system components. 6 of 9 03/01/2013 2:07 PM UL Summary Lead Levels Drinking Water System Components.pdf Anticipated Enforcement and Compliance Efforts At the national level, integrating ANSI/ NSF 372 into national plumbing codes and applicable product perform ante standards is likely to take some tim e. Revisions to the 2012 edition of the UPC and IPC have alreadybeen completed, and the underlying performance standards for plumbing products are now being updated to reference ANSUNSF 372. It is expected that these changes will be com pl eted in time for the January 2014 implementation date of the provisions of the federal Reduction of Lead in Drinking Water Act, thereby providing the necessary mechanism to achieve enforcers entthrough local plum bing officials and inspectors. In the m eantim e, m anufacturers of drinking water system components are still subject to the lead content page 7 http: / /www.vdh.state.va.us /ODW /documents /2013 /pdFUL Summary L... Lead Levels in Drinking Water System Components requirements already in force in California and Verm on and the certification requirements in force in California. As previously noted, the California DTSC has the authority to test up to 75 faucet, fitting and fixture sam pies annually for compliance with that state's lead content lim its, and to post the results on its website. The DTSC's "Interim Drinking Water Plum bing Products Sampling and Evaluation Strategy and Procedures" provides m anufactures with detailed information on its sampling and evaluation process ". Designing m ultiple versions of a product for different markets is a complex and inefficient proposition for product designers and manufacturers, Therefore, many manufacturers of products that come in contact with potable water have already redesigned their products to corn ply with the lead content requi rem ents in force in California and Vermont. Taking such action ensures compliance with the regulations alreadyin place in those states as well as those scheduled to take effect in Maryland in January 2012 and nationwide in January 2014 under the revised SDWA lead -free lim its. To ensure continued legal access to the California m arketplace, m anufacturers whose products com e in contact with potable water are also having their products tested and certified by an accredited third - party, consistent with that state's requirements. Some testing laboratories (including UL) are offering testing and certification to ANSI /NSF 372 for those manufacturers exclusively interested in certifying product compliance with lead content requirem ents. 7 of 03/01 /2013 2:07 PM UL Summary Lead Levels Drinldng Water System Components.pdf U� http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... Lead Levels in Drinking Water System Components Flowchart: Decision Tree for Determining the Need for Compliance to the Reduction of Lead in Drinking water Act Via ANSI /NSF 372 Certification Product does not need to demonstrate Does the product come in compliance with the new law. N0 contact with drinking water? Product does not need to demonstrate compliance with the new law. Product does not need to demonstrate compliance with the new law. Is the product connected to the potable water distribution system? Is the product a toilet, bidet, urinal, fill valve, shower valve, service saddle, or water distribution main gate valve larger than 2 inches? Certification to NSF 372 is required These requirements cover the evaluation of wetted surfaces of products, components, and materials that conveyor dispense water that is intended for human consumption by drinking or cooking for lead (Pb) content. These requirements do not cover other health risk aspects of these products, components, and materials such as contaminants that may leach into the water from materials of which the product i s m anufactured. The final acceptance of a product, component, or material is dependent upon its compliance with the requi rements and standards that a local, state, federal, or other jurisdictional body has defined forth e product or component. All products that are covered bythe scope ofANSI /NSF Standard 61 will require certification to ANSI/NSF372. Figure t: This flowchart depicts a process to assess whether certification requirements apply to specific drinking water system components, and details the prescribed testing sequence. As previously noted, California's certification federal and state requirements. In addition compliant withthe new lead-free limits and requirement is likely to create a defacto to easing the product compliance process, contributes to the over I safety of drinking national testing and certification third- partycertification also provides water. Therefore, manufacturers can realize requirem ent, since m ost rn anufacturers will confidence to di stributors, retailers and tangible benefits from having their products seek a single approval path that covers both consumers that a manufacturer's product is certified by an accredited testing laboratory. page 8 8 of 03/01/2013 2:07 PM UL Summary Lead Levels Drinking Water System Components.pdf 0 Summary http: / /www.vdh.state.va.us /ODW /documents /2013 /pdf/UL Summary L... Lead Levels in Drinking Water System Components Regulatory efforts to m inim ize the lead content in drinking water are currently focused on reducing the lead content in drinking water system com ponents and all other productsthat com a in contact with potable water. While new national lead -free lim its will go into effect in 2014, strict state lim its and testing requirements are already in force. Manufacturers are quicklyworking to bring their products into compliance, and obtainingthe product certifications necessary to com plywith specific state regulations. Taking such steps will ensure uninterrupted market access, provide competitive advantage and contribute to the health of consumers. For more information about the "An Overview of Regulations for Lead Levels in Drinking Water System Components" white paper, please contact Tom Bowman, program manager, UL Water Systems Program, at Thom as.A.Bowman@us.ul.com or Jeff Hebenstreit, UL principal engineer, Drinking Water Systems, at Jeff rey.R.Hebenstreit@us.ul.com. References 1. 'Basic Information about Lead in or Water," Environmental Prot ection Agency (EPA) website, ht I p:llwat er.epa.gov /drink /contaminants /basid nformati on /lead.cfm (last accessed April 16, 2on) 2. "Reduction of Lead in Drinking Water Act" January4, 2o11, http:/Avww.govtrack.us/congress/bilitext.xpd?bill-sl"-3874 (last accessed on April 17, 2011) 3. California Health and Safety Code (HSC), Section 116875, Part bt http: /twww. dtscca. gov /PollutionFYevention /up[oad/Lead in_Plumbing_HSC n6875.pdf (last accessed on May u, xon) 4. California Senate Bill (SB) 1395, 2oo8, http: //Www.leginfo,ca,gov /pub /o7.o8/ bill /sen -/sb_ 1351- 1400 /sb..1395._bill 20080929__ chaptered.html (last accessed onMayu, 2011) s. "Lead in Plumbing" California Department of Toxic Substance Control (DISC) website,http: //www. dtscca. goviPollutionPrevention /LeadlnFlumbng.cfm (last accessed onAprih8.2o11) 6. "Lead in Consumer Products Law: Vermont Attorney General's Guidance on Plumbing Supplies (11/18 /o9); November 18, 2ooa, Office of theAttomey General, Std te of Vermont website http://Www.atg.state.vt.uslassetsifiles/leadinNumbingpdf (last accessed onApril18, eon) 7.MarylandChapter Number 4o7, ht tp:// mlisstatemd .us/2oiors /bilifile/HB0372htm (last accessed on April 18 2011) 8. California Health and Safety Code (HSC), Section 116875, Part bt. http:;/ www .dtscca.gov /POIIUtionPrevention /upload /Lead in_Plumbing_HSC 116875pdf (last accessed on May12, 2011) 9. Annex G, NSF Standard 61- Drinking Water System Components, http: //www.nsf.org /businesst water- dstiibution /pdf /AnnexG.pdf (list accessed on April 20,2011) 1 o. ANSI /NSF 372- Drinking Water System Components. Lea d Conten L 2oto n."Interim Drinking Water Plumbing Products Sampling and Eva luat e Strategy and Procedures' April 22, 2010, California Department of Toxic Substance Control(DTSC) website, http : / /dtsc.ca.gov /PollutionPrevent ion / upload/ SdmplingStrategies2oio- Final.pLP (last accessed an April 21.2on Copyright02on Underwi iters Laboratories lnc.All rights reserved. No part ofthis document maybe copied or cW ributedwithout the prior written consent of Underwriters Laboratories Inc. 5/11 page 9 9 of 03/01/2013 2:07 PM How Does the Reduction of Lead in Drinking Water Act hnpact AME... http : / /www.american - usa.com/news- stories /36 • 1"yl �'` THE RIGHT WAY Home News How Does the Reduction of Lead in Drinking Water Act Impact AMERICAN Flow Control Product? January 9, 2013 How Does the Reduction of Lead in Drinking Water Act Impact AMERICAN Flow Control Product? On January 4, 2011, the Reduction of Lead in Drinking Water Act was signed into federal law. It will go into effect January 4, 2014. The law, which amends the Safe Drinking Water Act, 42 U.S.C. §300g -6, defines "lead free" as not exceeding a weighted average of 0.25% lead, calculated against the wetted surfaces of potable drinking water pipes, pipe fittings, plumbing fittings and fixtures. In general, the federal law does not apply to the gate valves and fire hydrants manufactured by AMERICAN Flow Control. More specifically, the law excludes pipes, pipe fittings, plumbing fittings, or fixtures that are used exclusively for non - potable services where the water is not anticipated to be used for human consumption, and excludes distribution main gate valves that are 2 inches in diameter or larger. Fire hydrants are not addressed in the federal law. Likewise, the federal law does not apply to the size range of the gate valves we manufacture. Effective January 1, 2013, all resilient wedge gate valves and check valves manufactured by AMERICAN Flow Control meet the requirements of the new legislation. This notice pertains specifically to the new federal law. However, it should be noted that some states, such as California, Vermont, Maryland and Louisiana, have enacted similar legislation establishing earlier effective dates. Please be aware there may be cases where the state legislation may be more restrictive than the federal legislation. Should you have any questions, please don't hesitate to contact your local AMERICAN Flow Control representative, or request more information by going to the Contact Us Section of this website. © 2013 AMERICAN (American Cast Iron Pipe Company). All rights reserved. SEA[ Is 1 of 1 03/01/2013 2:14 PM C: \DOCUME- 1 \CB4710- 1.SEC\LOCALS —1 \Temp \S3874enr - 13I11.S. S.3874 http : / /www.gpo.gov /fdsys /pkg/BILLS -111 s3874enr /pdf/BlLI S -111 s3... Onc l.undred Elcumth Congress of the Unitcd t$tntt,s of 51merira AT THE SECOND SESSION Begun and Kehl at the City of Washington on Tuesday, the fifth day of January, two thousand and ten 30 act To amend the Safe Drinking Water Act to reduce lead in drinking water. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the `Reduction of Lead in Drinking Water Act ". SEC. 2. REDUCING LEAD IN DRINKING WATER. (a) IN GENERAL.— Section 1417 of the Safe Drinking Water Act (42 U.S.C. 3008 -6) is amended— (1) by adding at the end of subsection (a) the following. "(4) ExEMPTioNs. —The prohibitions in paragraphs (1) and (3) shall not apply to— "(A) Pipes' Xi fittings, plumbing fittings, or fixtures, including back flow preventers, that are used exclusively for nonpotable services such as manufacturing, industrial processing, irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human consumption; or "(B) toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves that are 2 inches in diameter orIarger. "• and (2) by amending subsection (d) to read as follows: "(d) DEFINITION OF LEAD FREE. — "(1) IN GENERAL. —For the purposes of this section, the term lead free' means — "(A) not containing more than 0.2 percent lead when used with respect to solder and flux; and "(B) not more than a weighted average of 0.25 percent lead when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures. (2) CAL mmiom —The weighted average lead content of a pipe, ppipe fitting, plumbing fitting, or fixture shall be cal - culi by using the following formula: For each wetted compo- nent the percentage of lead in the component shall be multi - plie3 by the ratio of the wetted surface area of that component to the total wetted surface area of the entire product to arrive at the weighted percentage of lead of the component. The weighted percentage of lead of each wetted component shall be added together, and the sum of these weighted percentages shall constitute the weighted average lead content of the product. The lead content of the material used to produce 1 of2 03/01/2013 1:57 PM C: \DOCUME-1 \CB4710-1.SECU,OCALS -1 \Temp \S3874enr - BILLS... http: / /www.gpo.gov /fdsys /pkg/ BILLS- 111s3874enr /pdFBILLS -1l ls3... S.3874-2 wetted components shall be used to determine compliance with paragraph UXB). For lead content of materials that are pro- vided as a range, the maximum content of the range shall be used. ". (b) EFFECTIVE DATE. —The provisions of subsections (a)(4) and (d) of section 1417 of the Safe Drinking Water Act, as added by this section, apply beginning on the day that is 36 months after the date of the enactment of this Act Speaker of the House of Representatives. Vice President of the United States and President of the Senate. 2 of 2 03/01/2013 1:57 PM Sensus Meter Burst Pressures WE 1500 1000 500 N SR II accu- iPERL STREAM Composite Meters Meet Environmental Standards On January 4. 2011 President Obama signed the Reduction of Lead in Drinking Water Act an amendment to the Safe Drinking Water Act. The goal of this legislation is to strengthen and clarify standards to protect the public from toxic lead in drinking water by uniformly reducingthe allowable lead content in drinking water pipes. pipe fittings and plumbing fixtures. The legislation reduces the limit on lead from 8 percent to 0.25 percent for wetted surfaces of pipe, pipe fittings and plumbing fittings and fixtures and to 0.2 percent for solder and flux. The new regulation goes into effect on January 4, 2014 (hree years from the date of passage). Legislation Description Effec9ve Date NSF /ANSI Newieadcontentonlyappro valstandard1hat' Oct. 1,x 2010 Standard 372 uses the requirements nNSF/ANSStandard 61, Annex G. NSF standard in accordance with California AB1953 and new national lead-free law I requiring a 02510 (15 ppb) maximum lead content for all wetted components. NSF/ANSI Reduces the alosvable lead leach maximum July 1, 2012 Standard 61 Irnt to 5 ppb for al NSF Standard 61 certified (Annex F) products. All existing NSF Standard 61 approved products will be reviewed to ensure :, i compiancewth the new requremart in order to maintain N SF Standard 61 approval .............- ---- -- Reduction 1 New national law (amending the Safe I Jan. 4, 2014 of Lead in Drinking Wier Pct or SDWA) requiring Drinking products in contact with drinking water to a Water Act 025T% (15 ppb) rrraxmum lead content for al (S.3874) wetted components using a surface used averaging formula- The new NSF Standard 372 and NSF Standard 61, Annex G will provide independent third party %uifcation to the law. ® 2012 iPERL and accuSTREAM are trademarks of Sensus USA. 2 8601 Six Forks Road, Suite 700 Raleigh, NC 27615 1- 800 - 638 -3748 www.sensus.com NSF,ANSI Standard 61 (NSF 61) requires all metallic products and components to be evaluated for the leaching of lead as well as other metal contaminants. The lead leach passifail cdteda of 15 parts per billion (ppb) is scheduled to be reduced to 5 ppb per Annex F of NSF 61, effective July 1, 2012. Annex G of NSF 61 contains an optional lead content verification method. Pipes. fittings. valves and other mechanical devices are all tested with specially formulated waters. The newest metrology products from Sensus comply with and exceed the requirements set by The Safe Drinking Water Act and NSF 61 Annex F and G by containing zero lead. Composite Meters are Easy to Install Some manufacturers of composite meters have decided to attach metal threads to the material. To date. Sensus chose composite threads due to the strength ofthe composite materials and results from tests we conducted to compare the strength of composite threads with metal threads. Those tests revealed that the integrity of the bond between the composite and metal can be significantly influenced by seasonal temperatures as composite and metal materials expand and contract at different rates. Over time, this difference can cause the materials to separate from each other. Depending on the method used to attach the metal threads to the composite body. the separation may occur at installation (if high torque is applied) or a few years after installation (with the temperature changing over a period of ti me). Composite threads eliminate the "friction feeling" typically experienced with metal threads and metal couplings. which facilitates easier product installation. Some utilities are concerned about composite meters due to a potential interruption of a building's electrical grounding circuit that may cause hazard to occupants and utility personnel alike. The 2011 National Electrical Code (NEC), paragraph 250.53 (D) (1) states "Continuity of the grounding path or the bonding connection to the interior piping shall not rely on water meters or filtering devices and similar equipm ent. "A suitable bonding jumper should be used. Thus, the grounding bypass requirements are no different with today's composite meters than they were with the old bronze meters. In newer construction, plastic pipe is frequently replacing standard metal plumbing. Since plastic does not conduct electricity. it cannot be used as a grounding path. Summary Sensus continually develops and delivers products that meet the highest standards for quality. reliability and innovation. New technology and materials enable us to provide our customers metrology products to meet low -lead regulations while maintaining and exceeding the product excellence Sensus customers have come to expect. In addition to improving the strength characteristics of products, composite materials enable a more stable pricing structure in the future that is not tied to fluctuating copper prices. Furthermore, because the EPA's contaminant level goal for lead in drinking water is set at zero, by using alternative materials that contain zero lead. Sensus and its customers will continue to be in compliance with all future changes to the NSF standards and government laws regarding lead. SEnsus 2 of 03/01/2013 1:35 PM White Paper For the past 150 years, Sensus has brought water metrology products to market that have led the industry in technology, efficiency and accuracy. Today is no different as environmental regulations and sustainable technologies are key concerns for water utilities. Sensus is on the leading edge of these concerns and offers products constructed with durable composite materials that create a new standard in the water metering industry. As environmental responsibility is increasingly mandated, the entire industry is evolving the way it approaches intelligent water distribution systems. Sensus made a conscious decision to develop composite materials for its residential water meters, making them stronger and more durable. The new composite meters have been successfully launched in Europe where they have met with widespread acceptance. Composite meters were introduced in North America in 2010 with the launch of the Sensus iPERLT " residential water meter. The iPERL inte lllge nt water m anagem ent system features a construction with zero lead in the flowtube, comprised of a long- fiber - reinforced polyamide composite material. The Sensus accuSTREAMT"' positive displacement meter is comprised of a fiber reinforced thermoplastic material. Composite Meters Have History In 2009. Sensus launched the 620C composite body meter in Europe. The meter was developed due to demand from utilities and end users for meters that were better for the environment. The composite meter contributes to sustainability plans of European utilities without compromising on quality, security or meter reading accuracy. The composite material used in these meters is a semi - crystalline polyamide reinforced with long glass fiber, which has already proved its merit in the automotive and valve industries. Besides guaranteeing durability, the polyamide material meets the most stringent European drinking water requirements. It resists corrosion from aggressive water and from the chlorinated chemicals used to make the water drinkable. No hea/y metals enter into the makeup of the composite, which is also easily recycled. Sensus subjected the 620C meter to an environmental impact study, showing thatits entire production cycle, including polymer production and injection, consumes only about one -third as much energy as the bronze meter — 45 megajoules, as compared to 150. The injection processing temperature is about 280'C, compared to 1,000 °C for casting the bronze materials. Injection forming is a very controlled process, and it produces netshapes thatrequire no additional machining. even the threadedjoints. The meter can withstand over 1.100 pounds per square inch (psi) of static pressure and more than 150.000 pressure shock cycles (water hammer) at more than 1.400 psi. without damage. Composite Meters are Strong When evaluating alternate materials to replace traditional bronze, Sensus considered many criteria including conductivity, thermal coefficient of expansion. tension strength and compression strength. Yield strength measures the stress point at which a material begins to deform plastically. Prior to the yield point, material will deform elastically and will return to its original shape once the applied stress is removed. Once the yield point is passed, some fraction of the deformation will be permanent. Elongation is calculated as a percentage and is based on the deformation or stretching of a material under stress. The yield strength and elongation material characteristics are important factors in determining suitable materials for use in a water utility system due to the pressurized water systems to which these products are subjected. Figure 1: Yield Strength and Elongation Comparisons The iPERL and accuSTREAM products are composed of a zero lead composite alloy and have undergone comprehensive design and validation testing which proved that the materials significantly surpassed the pressure tolerance levels of conventional bronze alloy meters. SEnsus 1 oft 03/01/2013 1:35 PM Bronze Maincase Composite Material Y field 81 -Metal Low -lead Errvirobrass11 Blallay iPERL " accuSTREAM flowtube-,-_maincase strength 13,000 17,000 1 18,000 20,300 31,900 (psi) Elongation ( "�o) 1 6 30 2 2.5 Figure 1: Yield Strength and Elongation Comparisons The iPERL and accuSTREAM products are composed of a zero lead composite alloy and have undergone comprehensive design and validation testing which proved that the materials significantly surpassed the pressure tolerance levels of conventional bronze alloy meters. SEnsus 1 oft 03/01/2013 1:35 PM