CORROSION CONTROL
|
INVENTORY
REPLACEMENT
TAP MONITORING
RESOURCES
Intro
COPYRIGHT © 2019
HOME
“TRIGGER” LEVEL
TAP MONITORING
HOME
“TRIGGER” LEVEL
CORROSION CONTROL
INVENTORY
REPLACEMENT
RESOURCES
Timeline
Overview
Key Revisions
The LCR Revisions revise the sample site selection requirements, introduce a local “find and fix” approach, and require sampling of schools and childcare facilities by public water systems.
Systems may need to improve WQP monitoring and control and could be pushed to add higher orthophosphate doses.
What are the proposed requirements?
How could systems be affected?
The USEPA released the draft LCR Revisions in October 2019.
For more on LCR Regulations see
the timeline below:
At any individual sampling site with a Pb concentration above 15 ppb, the system will be required to conduct follow-up lead testing and local water quality parameter monitoring. The system must submit a recommended solution to the State within
6 months.
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“Find-and-Fix” Approach
RESOURCES
COPYRIGHT © 2019
How Can Systems Prepare?
The LCR revisions re-define sample site tiers to focus on sampling at sites with lead service lines. Water systems may need to re-evaluate their sample site selection to determine if compliance monitoring locations comply with the proposed Tier requirements.
Lead and Copper Rule Timeline
Sample Site
Tiers
In Hazen’s 2019 corrosion control survey, coordinating compliance sampling was reported to be the most challenging aspect of the LCR. The new LCR Revisions may increase this challenge by changing sample sites and increasing customer coordination.
The Revisions will require sampling at these locations where high-risk populations for lead exposure and health effects are present.
Schools and Child Care Facilities
Lead And
Copper Tap
Monitoring
X
More details on LCR Changes
Systems will need to re-evaluate sample site selection and document the materials evaluation for each site. Systems will need to identify schools and childcare facilities and develop a new tap sampling plan and communication strategy.
RESOURCES
More details on LCR Changes
Click the button below to make comments on the proposed revisions. Some additional EPA resources are linked below; click on each image to download a PDF. Hazen contacts are listed on the card, click name to launch your email. Please contact us for more information on the LCR Revisions.
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Additional Resources
HAZEN CONTACTS
William Becker
wbecker@hazenandsawyer.com
Roger Arnold rarnold@hazenandsawyer.com
Becki Rosenfeldt brosenfeldt@hazenandsawyer.com
PUBLIC COMMENT PERIOD – Submit comments about proposed revisions affecting your system to the USEPA for consideration in the final Rule.
US EPA RESOURCES – Click on images to download PDFs:
Public and private inventory required for systems with lead or unknown service lines.
Lead and
Copper Tap
Monitoring
Page 1 of 7
Corrosion
Control
Treatment
(CCT)
Lead
“Trigger"
Level
Service Line Inventory
Revised sample site selection require- ments, and testing of schools and childcare facilities.
Lead
Service Line
Replacement
(LSLR)
New “Trigger Level” for lead of 10 ppb requires tiered response actions.
Explore key regulatory changes expected to impact water systems summarized below:
LSLR Plan required for systems with lead or unknown service lines.
Revisions include specific ortho-phosphate dose alternatives and clarify corrosion control study approaches.
15+
ppb
ppb
TRIGGER LEVEL
Tap Sampling: Reduced monitoring every 3 years
CCT: Maintain treatment and WQPs
LSLR: Voluntary
Systems can plan to reliably meet the Trigger Level by analyzing the full range of historical compliance results and conducting an optimal corrosion control treatment study. It is critical to carefully evaluate corrosion impacts of any source water or treatment changes to remain under the Trigger Level.
Only if no LSL's present in system.
10
90th Percentile Lead Concentration Levels
ACTION LEVEL
The LCR Revisions propose a new “Trigger Level” for lead of 10 ppb in addition to the original Action Level
of 15 ppb based on
the 90th percentile
lead value.
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15
In Hazen’s 2019 corrosion control treatment survey, approximately 10% of systems surveyed reported 90th percentile Pb levels between 10 and 15 ppb and would be affected by the proposed Trigger Level.
Systems experiencing 90th percentile lead levels of 10 to 15 ppb would be triggered to increase monitoring, evaluate CCT, and perform LSLR.
0-10
ppb
The new “Trigger Level” changes adds requirements affecting the tap sampling frequency, CCT, and LSLR.
Lead
“Trigger"
Level
Tap Sampling: Standard monitoring every year
CCT: Conduct new CCT study or re-optimize treatment
LSLR: Full replacement at defined goal rate
10-15
ppb
Tap Sampling: Standard monitoring every 6 months
CCT: Implement or re-optimize treatment
LSLR: Full replacement at 3% per year
Calcium Hardness
Recirculation Pipe Loop
Flow-Through Pipe Loop
Calcium hardness adjustment is, no longer, an acceptable corrosion control treatment strategy, and associated WQPs are no longer required.
WQP Data Reviews
The revisions introduce reviews of regulated WQP data during sanitary surveys by the primary agency.
The LCR Revisions clarify corrosion
control treatment and optimal Water Quality Parameter (WQP) requirements and introduce specific orthophosphate dose alternatives up to
3 mg/L as PO4.
Pipe Loop Testing Methods
Orthophosphate
Systems may need to improve WQP monitoring and control and could be pushed to add higher orthophosphate doses.
Systems can perform an optimal corrosion control treatment study with a desktop analysis of distribution system water quality data and historical WQP levels. Systems can optimize corrosion control treatment by performing lead service line scale analysis or conducting corrosion control testing. Treatment plant optimization may provide benefits for WQP control.
Corrosion
Control
Treatment
Pipe Loops
Corrosion Inhibitors Adding orthophosphate to minimize lead release.
Revisions describe appropriate CCT procedures and focus on pipe loop testing for corrosion control studies.
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The LCR Revisions require systems to evaluate specific orthophosphate doses of
1 mg/L and 3 mg/L as PO4 in corrosion control studies required under the Rule.
This requirement may increase orthophosphate usage in systems that exceed the Trigger Level or Action Level.
Public and Private LSL
The LCR Revisions require systems with lead or unknown service lines to develop a publicly-available service line inventory defining materials for public and private service lines.
The inventory must be publicly-available, and for systems with a population greater than 100,000, must be electronic.
Updating Inventory
Systems with unknown or lead service lines will be required to track public and private service line materials, which is a new paradigm for many water systems.
Systems are required to update the service line inventory in the course of normal operations as service lines are identified and may perform targeted identification to confirm service line materials.
Systems can create a geospatial service line database to track service line materials collected from multiple sources in a central location. Systems will need to review historical plumbing codes and paper records to assess service line materials in the system. Systems should begin documenting service line materials observed during utility replacement or repair projects.
Systems will be required to submit annual notification letters to all customers with lead service lines or service lines of unknown material, noting that the public LSL will be replaced if the customer replaces the private LSL.
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Systems will have three years to develop a service line inventory framework and will be required to submit annual updates.
Track Service Line Materials
Service
Line
Inventory
Household Flushing Instructions
Faucet
Filter
Full replacement of the public and private LSL is strongly encouraged due to the risks of partial LSLR. Water systems must offer to replace the private LSL but are not required to pay for private LSLR.
Systems will need to develop strategies to engage customer participation for private service line replacement, and consider legal issues associated with private property access and funding. Systems can begin prepare customer educational materials related to LSLs, including household flushing and POU filter instructions.
The LCR Revisions require the system to provide point-of-use filters during lead service line disturbance or replacement. Certified point-of-use filters have been proven to be effective for removing lead.
Public and Private LSLR
Gooseneck
Point-of-Use Filters
Systems with unknown or lead service lines will be required to develop a LSLR Plan meeting specific requirements in the Revisions and define a replacement rate goal.
Systems will need to develop a LSLR Plan and develop strategies to facilitate full LSLR on private property.
The LCR Revisions define that a LSL includes a galvanized iron service line downstream of a current or former LSL.
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Define Lead Service Line (LSL)
Water Main
Tap
The LCR Revisions require systems with lead or unknown service lines to develop a LSLR Plan and define a voluntary replacement rate. Systems exceeding the Trigger Level will be required to implement public and private LSLR.
Customer Side
Develop LSLR Plan
Systems exceeding the Trigger Level or Action Level will be required
to replace LSLs.
Lead
Service Line
Replacement
Utility
Side
Flushing
The water system will be required to provide household flushing instructions to customers following LSLR.
• Pilot-scale demo of CCT
with flow condition
• Harvested materials
• Scale analysis
• Long-term monitoring
• Complex to implement
• Large footprint
• Expensive and
challenging to operate
i
Click on buttons to learn more about each pipe loop.
• Batches of water with flow conditions
• Harvested materials
• Scale analysis
• Sample collection challenges
• Water quality changes in
recirculation reservoir