PROPOSED REVISIONS A R E V I E W O F T H E L O N G T E R M R E - - PowerPoint PPT Presentation

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PROPOSED REVISIONS A R E V I E W O F T H E L O N G T E R M R E - - PowerPoint PPT Presentation

LEAD AND COPPER RULE PROPOSED REVISIONS A R E V I E W O F T H E L O N G T E R M R E V I S I O N S P R O P O S E D B Y T H E N A T I O N A L D R I N K I N G W A T E R A D V I S O R Y C O U N C I L THERE IS NO SAFE LEVEL OF LEAD


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SLIDE 1

A R E V I E W O F T H E L O N G T E R M R E V I S I O N S P R O P O S E D B Y T H E N A T I O N A L D R I N K I N G W A T E R A D V I S O R Y C O U N C I L

LEAD AND COPPER RULE PROPOSED REVISIONS

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SLIDE 2

THERE IS NO SAFE LEVEL OF LEAD

0.015 MG/L IS BASED ON FEASIBILITY

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SLIDE 3

HISTORY OF LEAD REGULATION

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SLIDE 4

BACKGROUND

  • LCR is a treatment technique rule
  • Requires actions to be taken to minimize lead and copper

in drinking water

  • Small/medium systems (Pop. <50,000) must take

specific actions if the action level is exceeded (Lead 0.015mg/L, Copper 1.3mg/L)

  • Large systems (Pop. >50,000) must minimize

corrosivity of the water prior to an exceedance

  • Newly serving 50,000 must also meet this requirement
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SLIDE 5

LCR PROPOSED CHANGES

  • Lead sampling protocols
  • Increased corrosion control treatment
  • Lead material removal
  • Household action level
  • Separate copper rule
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SLIDE 6

LEAD RULE PROPOSED CHANGES

Source: 2015 LCRWG Final Report

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SLIDE 7

SAMPLING

  • Problems:
  • Finding locations and participants can be difficult
  • Inconsistent sampling from customers
  • Results vary based on lead source in home
  • Sampling infrequent and in relatively few homes
  • Proposed changes
  • Customer initiated tap sampling through targeted outreach
  • Increased focus on maintaining water quality conditions
  • New tiering criteria
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SLIDE 8

CORROSION CONTROL

  • Problems:
  • Treatment interactions
  • Difficulty maintaining throughout distribution
  • Improved science without guidance
  • Proposed changes:
  • System specific water quality parameters
  • New guidance provided based on advancing science
  • Increased WQP monitoring
  • Any treatment or source change requires re-evaluation of

corrosion control

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SLIDE 9

LEAD SERVICE LINE REPLACEMENT

  • Problems:
  • Partial replacement
  • Only focuses on LSL while goosenecks and pigtails may be a

similar risk

  • Proposed changes:
  • Remove all lead service

lines and lead components over 30 year period

  • Shared responsibility
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SLIDE 10

HOUSEHOLD ACTION LEVEL

  • Problems:
  • Consumer notice is insufficient
  • Potential violation of section 1431 due to “imminent and

substantial endangerment to the health of persons”

  • Proposed changes:
  • Set HAL based on CDC recommendations
  • Notify residents and local health departments
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SLIDE 11

COPPER RULE PROPOSED CHANGES

  • Problems:
  • Highest risk sites different than lead
  • Lack of public education
  • Proposed changes:
  • Remove in-home sampling
  • Monitoring based on water corrosivity to

copper

  • Non-aggressive water
  • Continue to demonstrate
  • Aggressive water
  • Public education requirement
  • Mitigate risk

Source: 2015 LCRWG Final Report

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SLIDE 12

COPPER CORROSION

  • Low pH and high alkalinity most corrosive to copper

LCRWG defined corrosive conditions – pH and alkalinity

Source: Journal AWWA April 2016 Roth et al.

LCRWG defined corrosive conditions – PO4 and alkalinity

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SLIDE 13

PREPARATION TIPS

Materials Evaluation Recruit Customers Address Copper Corrosion

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SLIDE 14

REMINDERS FOR CURRENT LCR

  • Highest risk sites
  • No “pre-flushing”
  • Aerators on
  • Wide-mouth bottles and fill as you would a drinking

glass

  • Consumer notice and certification to the State is

required

  • Sample early in the monitoring period
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SLIDE 15

THANK YOU

M E G A N L A R S O N I D A H O D E P A R T M E N T O F E N V I R O N M E N T A L Q U A L I T Y M E G A N . L A R S O N @ D E Q . I D A H O . G O V