the long-term lead and copper rule · ohio wea-awwa uniting the world of water 2014 technical...
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August 26-29, 2014 | Columbus, OHUNITING THE WORLD of WATEROhio WEA-AWWA
2014 Technical Conference & Expo
The Long-Term Lead and Copper Rule Understanding Potential Changes and Impacts on Community Water Systems
UNITING THE WORLD of WATER
Presentation Outline
What changes are being considered under the LT-LCR?
Research Suggests The Current Rule Is Not Capturing Some High Pb/Cu Samples
• Lead service lines (LSLs) contribute 50-75% of lead at the tap [1]
• Elevated lead concentrations in drinking water after partial lead service line replacement (PLSLR) [2]
• Elevated copper concentrations in drinking water from new construction [3,4,5]
• Tier 1 site must be served by a LSL • Samples collected from a LSL • Adding a separate pool for Cu sampling
• More stringent WQPs or phosphate addition benchmark for effective optimization
• Adding a requirement for Cu in the event of a Cu AL exceedance
• Elimination of “test-out” provision
Potential Revisions Being Considered Under the LT-LCR
Public EducationPublic EducationPublic Education
Pb & Cu Tap Sampling Requirements
Pb & Cu Tap Sampling Requirements
Optimized Corrosion Control Treatment
Optimized Corrosion Control Treatment
Optimized Corrosion Control Treatment
Lead Service Line Replacement
Lead Service Line Replacement
Lead Service Line Replacement
• Tier 1 site must be served by a LSL (Scenario 1)• Samples collected from a LSL (Scenario 2)• Adding a separate pool for Cu sampling (Scenario 3)
• Systems must re-optimize if AL is exceeded• More stringent WQPs or phosphate addition benchmark for
effective optimization
• Adding a requirement for copper in the event of a copper AL exceedance
• Elimination of “test-out” provision• Delay replacement until after CCT re-optimization
Potential Revisions Being Considered Under the LT-LCR
Public EducationPublic EducationPublic Education
Pb & Cu Tap Sampling Requirements
Pb & Cu Tap Sampling Requirements
Optimized Corrosion Control Treatment
Optimized Corrosion Control Treatment
Optimized Corrosion Control Treatment
Lead Service Line Replacement
Lead Service Line Replacement
Lead Service Line Replacement
Who will be affected?
Scenario No. Description
Percent of Systems Above AL with LT-LCR
Changes
Population Impacted
(in Millions)
1 Changing sample site Tier Definition
2
Sampling Directly from LSLs –Temperature Variation Method
Sampling Directly from LSLs –Standard Volume Flushing Method
Sampling Directly from LSLs –Sequential Sampling Method
3 Targeted Cu Monitoring
Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems
Scenario No. Description
Percent of Systems Above AL with LT-LCR
Changes
Population Impacted
(in Millions)
1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2
2
Sampling Directly from LSLs –Temperature Variation Method
Sampling Directly from LSLs –Standard Volume Flushing Method
Sampling Directly from LSLs –Sequential Sampling Method
3 Targeted Cu Monitoring
Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems
Scenario No. Description
Percent of Systems Above AL with LT-LCR
Changes
Population Impacted
(in Millions)
1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2
2
Sampling Directly from LSLs –Temperature Variation Method
9.5% of systems with LSLs 11.8
Sampling Directly from LSLs –Standard Volume Flushing Method
54.5% of systems with LSLs 74.0
Sampling Directly from LSLs –Sequential Sampling Method
70.5% of systems with LSLs 96.4
3 Targeted Cu Monitoring
Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems
Scenario No. Description
Percent of Systems Above AL with LT-LCR
Changes
Population Impacted
(in Millions)
1 Changing sample site Tier Definition 12.5% of systems with LSLs 15.2
2
Sampling Directly from LSLs –Temperature Variation Method
9.5% of systems with LSLs 11.8
Sampling Directly from LSLs –Standard Volume Flushing Method
54.5% of systems with LSLs 74.0
Sampling Directly from LSLs –Sequential Sampling Method
70.5% of systems with LSLs 96.4
3 Targeted Cu Monitoring 8% of systems with high alkalinity and low pH 10.9
Evaluated Three Potential LT-LCR Tap Sampling Requirements to Identify Impacted Systems
What are the compliance options and how much will it cost?
Three Corrosion Control Methods Identified as Optimum in the Current LCR
Carbonate Passivation
• Metal complexes on pipe surface
• Prevents metal release
Inhibitor Addition
• Phosphates (orthophosphate or blends)
• Silicates
Carbonate Precipitation
• Calcium carbonate coats pipe surface
• Does not form uniform, non-porous layer
Carbonate Precipitation Not Considered An Effective Strategy for LT-LCR Compliance
Treatment Strategies Considered for Compliance with the LT-LCR
Systems not adding phosphate
Raise pH and/or
alkalinityAdd
phosphate
Add phosphate and adjust
pH
Systems adding
phosphate
Boost phosphate Lower pH
Baseline National Cost is Significant
$25
$120
$48
$73
$168
$0
$20
$40
$60
$80
$100
$120
$140
$160
$180
$200
1 2 3 1+3 2+3
Ann
ual C
ost (
$Mill
ion)
Scenario
Multiple Uncertainties Impact Cost
Lead service line occurrence
LSL sampling method
Phosphoric acid cost
Systems impacted by copper monitoring
National Cost Impacts of Uncertainty
$0
$50
$100
$150
$200
$250
$300
$350
$400
1 2 3 1+3 2+3
Tota
l Ann
ual C
ost (
$Mill
ion)
Scenario
Total Annual Cost of Regulatory Scenario ($ Million) 1 2 3 1+3 2+3
Baseline $25 $120 $48 $73 $168Range $11 - $49 $50 - $272 $30 - $107 $30 - $156 $50 - $379
National Cost Equivalence of Full Lead Service Line Replacements (FLSLRs)
Scenario 1 –Changing Sample Site Tier Definition
Scenario 2 –Sampling Directly
from LSLs
Baseline National Cost $25,000,000 $111,000,000
FLSLRs per Year Nationally($5000/replacement) 5,000 22,000
Total Population Affected by FLSLRs 15,000(<0.01%)
66,000(<0.04%)
Total Population Affected by OCCT Upgrade
Up to 42,000,000(<1% - 14%)
Up to 150,000,000(2% - 49%)
What are the unintended consequences we need to consider?
Potential LT-LCR Unintended Consequences
Description of Potential UICOCCT Strategy
pH/Alkalinity Adjustment
Phosphate Addition
Increased scaling resulting in loss of hydraulic capacity or additional system maintenance Reduced distribution system disinfection performance Change in DBP speciation/concentrations Required joint Stage 2 DBPR and LT-LCR compliance Increased phosphorus loading at POTW, with increased sludge production Need for additional operator certification/staffing
National Cost Impacts of UICs
$0
$100
$200
$300
$400
$500
$600
1 2 3 1+2 1+3 2+3
Tota
l Nat
iona
l Cos
t ($M
illio
ns)
Scenario
Potential Cost of UICsAnnual Cost of OCCT
National Cost of Regulatory Scenario ($ Million) 1 2 3 1 +2 1 + 3 2 + 3
Annual OCCT Cost $11 - $49 $50- $272 $30- $107 $50- $272 $30- $156 $50- $379
Annual UIC Costs $19 $77 $28 $77 $47 $106
Total Annual Cost $11 - $68 $50 - $349 $30 - $135 $50- $438 $30 - $203 $50 - $485
What’s next for the LT-LCR and PWSs?
• Goal: • Incorporate changes that will make the rule
more protective of public health and are implementable
• Focus:• Sampling requirements• Optimized corrosion control treatment• Public education for copper• Lead service line replacement
• Anticipated Schedule: • 9 – 12 month stakeholder process began
March 2014• Proposed rule expected 2015• Final rule sometime in 2016 – 2017
Regulatory Framework for LT-LCR
What Can You Do To Prepare?
Manage and review historical data to:
• Establish a baseline• Assess potential compliance with anticipated changes
Conduct additional sampling or testing, where possible
Acknowledgements
AWWA and Project Steering Committee MembersSteve ViaStephen Estes-SmargiassiSteve SchindlerMatt SmithJeff Swertfeger
Participating public water systems
ARCADIS TeamChris HillSean Chaparro Roger Arnold Doug Owen
Thank you!Rebecca Slabaugh, PE, ENV [email protected](317) 231-6500