The Long-Term Lead and Copper Rule

Transcription

1 Ohio WEA-AWWA 2014 Technical Conference & Expo UNITING THE WORLD of WATER August 26-29, 2014 Columbus, OH The Long-Term Lead and Copper Rule Understanding Potential Changes and Impacts on Community Water Systems

2 Presentation Outline

3 What changes are being considered under the LT-LCR?

4 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]

5 Potential Revisions Being Considered Under the LT-LCR Pb & Cu Tap Sampling Requirements Tier 1 site must be served by a LSL Samples collected from a LSL Adding a separate pool for Cu sampling Optimized Corrosion Control Treatment More stringent WQPs or phosphate addition benchmark for effective optimization Public Education Adding a requirement for Cu in the event of a Cu AL exceedance Lead Service Line Replacement Elimination of test-out provision

6 Potential Revisions Being Considered Under the LT-LCR Pb & Cu Tap Sampling Requirements 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) Optimized Corrosion Control Treatment Systems must re-optimize if AL is exceeded More stringent WQPs or phosphate addition benchmark for effective optimization Public Education Adding a requirement for copper in the event of a copper AL exceedance Lead Service Line Replacement Elimination of test-out provision Delay replacement until after CCT re-optimization

7 Who will be affected?

8 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 Sampling Directly from LSLs Temperature Variation Method 2 Sampling Directly from LSLs Standard Volume Flushing Method Sampling Directly from LSLs Sequential Sampling Method 3 Targeted Cu Monitoring

9 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 Sampling Directly from LSLs Temperature Variation Method 12.5% of systems with LSLs Sampling Directly from LSLs Standard Volume Flushing Method Sampling Directly from LSLs Sequential Sampling Method 3 Targeted Cu Monitoring

10 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 Sampling Directly from LSLs Temperature Variation Method 12.5% of systems with LSLs 9.5% of systems with LSLs 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 Targeted Cu Monitoring

11 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 Sampling Directly from LSLs Temperature Variation Method 12.5% of systems with LSLs 9.5% of systems with LSLs 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 Targeted Cu Monitoring 8% of systems with high alkalinity and low ph 10.9

12 What are the compliance options and how much will it cost?

13 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, nonporous layer Carbonate Precipitation Not Considered An Effective Strategy for LT-LCR Compliance

14 Treatment Strategies Considered for Compliance with the LT-LCR Systems not adding phosphate Systems adding phosphate Raise ph and/or alkalinity Add phosphate Add phosphate and adjust ph Boost phosphate Lower ph

15 Baseline National Cost is Significant Annual Cost ($Million) $200 $180 $160 $140 $120 $100 $80 $60 $40 $20 $0 $168 $120 $73 $48 $ Scenario

16 Multiple Uncertainties Impact Cost Lead service line occurrence LSL sampling method Phosphoric acid cost Systems impacted by copper monitoring

17 National Cost Impacts of Uncertainty Total Annual Cost ($Million) $400 $350 $300 $250 $200 $150 $100 $50 $ Scenario Total Annual Cost of Regulatory Scenario ($ Million) Baseline $25 $120 $48 $73 $168 Range $11 - $49 $50 - $272 $30 - $107 $30 - $156 $50 - $379

18 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 Total Population Affected by OCCT Upgrade 15,000 (<0.01%) Up to 42,000,000 (<1% - 14%) 66,000 (<0.04%) Up to 150,000,000 (2% - 49%)

19 What are the unintended consequences we need to consider?

20 Potential LT-LCR Unintended Consequences Description of Potential UIC ph/alkalinity Adjustment OCCT Strategy 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

21 National Cost Impacts of UICs Total National Cost ($Millions) $600 $500 $400 $300 $200 $100 $0 Potential Cost of UICs Annual Cost of OCCT Scenario National Cost of Regulatory Scenario ($ Million) 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

22 What s next for the LT-LCR and PWSs?

23 Regulatory Framework for LT-LCR 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

24 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

25 Acknowledgements AWWA and Project Steering Committee Members Steve Via Stephen Estes-Smargiassi Steve Schindler Matt Smith Jeff Swertfeger Participating public water systems ARCADIS Team Chris Hill Sean Chaparro Roger Arnold Doug Owen

26 Thank you! Rebecca Slabaugh, PE, ENV SP ARCADIS (317)