LCR

CORROSION CONTROL

INVENTORY

REPLACEMENT

TAP MONITORING

RESOURCES

Intro

INTRO

“TRIGGER” LEVEL

TAP MONITORING

INTRO

“TRIGGER” LEVEL

CORROSION CONTROL

INVENTORY

REPLACEMENT

RESOURCES

PART 1

Wide-mouth bottles

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 final

Fifth Liter Sample Collection

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.

Service Line & Water Meter

Sample Site Tiers

SOLDER Buildings constructed prior to 1987 may contain lead solder.

Lead and Copper Rule Timeline

Fifth Liter Requirement

The Revisions require systems to collect both a first and a fifth liter sample from all sites with LSLs. The fifth liter will be analyzed for lead only.

PART 2

Schools and Child Care Facilities

Key Revisions

No aerator removal

BRASS FIXTURES Prior to 2014, “lead free” fixtures and valves could contain as much as 8% lead by weight. In 2014 the standard was lowered to 0.25% lead by weight.

More details on LCR Changes

Lead And Copper Tap Monitoring

The Revisions require sampling at these locations where high-risk populations for lead exposure and health effects are present.

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.

Overview

No pre- stagnation flush

The USEPA published a final draft the LCR Revisions in January 2021. See timeline below for more key dates:

LEADED SOLDER BRASS FIXTURES

Sources of Lead

Tier Requirements.

Fifth Liter Details

New Fifth Liter Requirement

Lead Service Line

Tier Requirements

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Sample Collection Requirements

Sample Bottle

RESOURCES

Stagnant, first-draw samples

Collection of Fifth Liter after first draw sample.

LEAD

COPPER

Timeline

The LCR Revisions revise the sample site selection requirements, introduce a local “find and fix” approach, the collection of a fifth liter source, and require sampling of schools and childcare facilities by public water systems.

Update compliance sample site selection to include all LSL sites. Develop new sampling procedures for the fifth liter sample collection and monitoring of schools and childcare facilities.

What are the proposed requirements?

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.

How could systems be affected?

“Find-and-Fix” Approach

1-Liter Water Sample Sequence

How Can Systems Prepare?

RESOURCES

More details on LCR Changes

Tier Requirements.

Fifth Liter Requirement

PART 1

PART 2

William Becker

Roger Arnold

Some additional EPA resources are linked below. Hazen contacts are also listed, click envelope to launch your email. Please contact us for more information on the LCR Revisions.

Additional Resources

HAZEN CONTACTS

MORE HAZEN RESOURCES

Becki Rosenfeldt

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US EPA RESOURCES Click on images to download:

MORE HAZEN RESOURCES

Public and private inventory required for systems with lead or unknown service lines.

Lead and Copper Tap Monitoring

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Corrosion Control Treatment (CCT)

Lead “Trigger" Level

Service Line Inventory

Revised sample site selection require- ments, fifth liter sample collection, 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.

90th Percentile Lead Concentration Levels

ACTION LEVEL

The LCR Revisions establish 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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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

The LCR Revisions maintain that pH/Alkalinity/DIC is an acceptable corrosion control strategy, but require the evaluation of orthophosphate if the trigger level is exceeded.

Flow-Through Pipe Loop

pH/ Alkalinity/ DIC Adjustment

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. Specific orthophosphate dose alternatives up to 3 mg/L as PO4 are required for corrosion control testing.

Pipe Loop Testing Methods

Orthophosphate

Systems may need to improve WQP monitoring and control. Some systems could also be required to add higher ortho-phosphate 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, as required under the Final 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. LSL inventories are required to be updated annually.

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. LSL inventories must be submitted by Jan. 16, 2024.

Track Service Line Materials

Service Line Inventory

Household Flushing Instructions

Point-of-Use 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 or lead gooseneck.

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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.

FLOW-THROUGH • Pilot-scale demo of CCT with flow condition • Harvested materials • Scale analysis • Long-term monitoring POSSIBLE CHALLENGES • More complex to implement • Large footprint • Expensive operation

Click on buttons to learn more about each pipe loop.

RECIRCULATION • Batches of water with flow conditions • Harvested materials • Scale analysis POSSIBLE CHALLENGES • Sample collection • Water quality changes in recirculation reservoir