1. Beyond The Lead Sample Site Plan
J K Bunderson P.E.
4/25/18

2. Agenda LCR Overview Action Level Exceedance
Corrosion Control Treatment Steps

3. Regulatory History - 1 1986 Safe Drinking Water Act Lead Ban
Required only lead-free materials be used in new plumbing and plumbing repairs
The Lead Contamination Control Act (LCCA) (1988)
Aimed at identification and reduction of lead in DW at schools and child care facilities
1989 – Banned fixtures that were not “lead free”
The Lead Ban(1986):
A requirement that only lead free materials be used in new plumbing and in plumbing repairs.
Required use of “lead free” pipe, solder, and flux
0.2% lead consider lead free in flux/solder
Was 50% prior to 1986
<8% lead for pipes and pipe fixtures
Lead Ban 1986
Amended the SDWA to prohibite any use of pope, solder, or flux in public water system that is not “Lead Free”
Special public notice requirements ofr lead
State enforcement of prohibition and special notice for lead: and
Definition of “Lead free” materials
Ban on lead water pipes, solder, and flux in VA
LCCA – 1988
Identification of water coolers that are not lead free
Repair or removal of water coolers with lead-lined tanks
Ban on manufacture and sale of water coolers that were not lead free
The identification and resolution of lead problems I schools’ drinking water
The authorization of additional funds for lead screening programs for children.
1) Prohibition. Any pipe, solder, or flux, which is used after June 19, 1986, in the installation or repair of—
(i) Any public water system, or
(ii) Any plumbing in a residential or nonresidential facility providing water for human consumption which is connected to a public water system shall be lead free as defined by paragraph (d) of this section. This paragraph (a)(1) shall not apply to leaded joints necessary for the repair of cast iron pipes.
The Lead Contamination Control Act (LCCA) (1988):
The LCCA further amended the SDWA. The LCCA is aimed at the identification and reduction of lead in drinking water at schools and child care facilities.
However implementation and enforcement of the LCCA has been at each state’s discretion. School monitoring and compliance has varied widely. There is NO federal law requiring schools or child care centers to test
drinking water for lead.
The Lead and Copper Rule (1991):
A regulation by EPA to minimize the corrosively and amount of lead and copper in water supplied by public water systems. The Reduction of Lead in Drinking Water Act (2011): Revising the definition of lead free by lowering the maximum lead content of the wetted surfaces of plumbing products from 8% to a weighted average of 0.25%
The Lead and Copper Rule (LCR) is a United States federal regulation which limits the concentration of lead and copper allowed in public drinking water at the consumer's tap, as well limiting the permissible amount of pipe corrosion occurring due to the water itself. The U.S. Environmental Protection Agency (EPA) first issued the rule in 1991 pursuant to the Safe Drinking Water Act. EPA promulgated the regulations following studies that concluded that copper and lead have an adverse effect on individuals.
These dates are important to note when investigating lead contamination. Note that many states and municipalities, began banning lead as early as the 1950’s ’s.
Lead pipes were not banned nationally until 1986.
In 1986 the Lead Ban took effect. This provision of the SDWA requires the use of “lead-free” pipe, solder, and flux in the installation or repair of any public water system or any plumbing in a residential or non-residential facility connected to a public water system. Solders and flux are considered to be lead-free when they contain less than 0.2 percent lead. Before this ban took effect on June 19, 1986, solders, used to join water pipes, typically contained about 50 percent lead.
Pipes and pipe fittings are considered “lead-free” under the Lead Ban when they contain less than 8 percent lead. Plumbing fixtures that are not “lead-free” were banned from sale after August 6, Plumbing fixtures are subject to the National Sanitation Foundation International standard 61.
In 2011 Congress passed the Reduction of Lead in Drinking Water Act (RLDWA) revising the definition of lead free by lowering the maximum lead content of the wetted surfaces of plumbing products (such as pipes, pipe fittings, plumbing fittings and fixtures) from 8% to a weighted average of 0.25%,  establishing a statutory method for the calculation of lead content and  eliminating the requirement that lead free products be in compliance with voluntary standards established in accordance with SDWA 1417(e) for leaching of lead from new plumbing fittings and fixtures.

4. Regulatory History - 2 1991 Lead and Copper Rule (LCR)
Regulation by EPA to minimize the corrosively and amount of L&C in water supplied by public water systems
1996- further amended SDWA
endpoint devices to be incompliance with voluntary lead leaching standards
A variety of rules have impacted lead I drinking water. Rules have addressed getting lead out of materials as well standards accompanied by monitoring and control strategies.
Lead Ban 1986
Amended the SDWA to prohibited any use of pope, solder, or flux in public water system that is not “Lead Free”
Special public notice requirements ofr lead
State enforcement of prohibition and special notice for lead: and
Definition of “Lead free” materials
Ban on lead water pipes, solder, and flux in VA
In 1996 Congress further amended the Safe Drinking Water Act, requiring plumbing fittings and fixtures (endpoint devices) to be in compliance with voluntary lead leaching standards. The amendments also prohibited the introduction into commerce of any pipe, pipe or plumbing fitting or fixture that is not lead free.

5. Regulatory History - 3
1998- Plumbing fixtures that were not “lead-free” were banned from sale
2002 and 2007 minor revisions
2003 EPA estimated $276.8 billion and 20 years to replace all LSLs
2011 Reduction of Lead in Drinking Water Act
Reduced “lead free” (pipes 0.25% weighted average with respect to wetted surfaces)
2014 – Effective date that pipes, fittings, or fixtures installed must meet new definition of lead-free 
These dates are important to note when investigating lead contamination. Note that many states and municipalities, began banning lead as early as the 1950’s ’s.
Lead pipes were not banned nationally until 1986.
In 1986 the Lead Ban took effect. This provision of the SDWA requires the use of “lead-free” pipe, solder, and flux in the installation or repair of any public water system or any plumbing in a residential or non-residential facility connected to a public water system. Solders and flux are considered to be lead-free when they contain less than 0.2 percent lead. Before this ban took effect on June 19, 1986, solders, used to join water pipes, typically contained about 50 percent lead.
Pipes and pipe fittings are considered “lead-free” under the Lead Ban when they contain less than 8 percent lead. Plumbing fixtures that are not “lead-free” were banned from sale after August 6, Plumbing fixtures are subject to the National Sanitation Foundation International standard 61.
In 2011 Congress passed the Reduction of Lead in Drinking Water Act (RLDWA) revising the definition of lead free by lowering the maximum lead content of the wetted surfaces of plumbing products (such as pipes, pipe fittings, plumbing fittings and fixtures) from 8% to a weighted average of 0.25%,  establishing a statutory method for the calculation of lead content and  eliminating the requirement that lead free products be in compliance with voluntary standards established in accordance with SDWA 1417(e) for leaching of lead from new plumbing fittings and fixtures.

6. LCR Summary Published on June 7, 1991
In 1991, the LCR rule was promulgated. There were minor revision to this rule in 2000 and The LCR addresses corrosion of lead and copper in drinking water primarily from service lines and household plumbing.
Important to note that the maximum contaminant level goal (MCLG) was set at zero, meaning there is no safe level for lead.
Violations result from failure to perform required actions, including testing, reporting, corrosion treatment and public education. Makes Water System responsible for water quality at end users’ TAP. Primary sources of Lead and copper: premise plumbing and service lines.
Published on June 7, 1991
Applies to CWS, NTNC, and consecutive systems
Establishes MCLGs for lead and copper
Mandates treatment techniques vs. MCL, triggered
by tap monitoring results exceeding the Action Level
MCLGs
0 mg/L
1.3 mg/L
Action Levels (ALs)
0.015 mg/L
1.3 mg/L
Lead
Copper
*AL Exceedance is not a violation

7. CWS Sample Sites CWS - three tiers of sample sites
Solder before 1983 may have already leached
CWS Sample Sites
CWS - three tiers of sample sites
Tier 1 (Highest Risk)
Single family homes
If lead service lines (50% of the sites)
Lead pipe
Copper pipe with lead solder after 1982 (and before lead ban 1988)
Tier 2 - Building/multi-family that meet Tier 1 criteria
Tier 3 – Single Family Homes - copper pipe with lead solder before 1983  

8. NTNCWS Sample Sites NTNCWS - two tiers of sample sites
Tier 1 (Highest Risk)
Lead service lines or
Lead pipe
Copper pipe with lead solder after 1982 (and before lead ban 1988)
Tier 2
Copper pipe with lead solder before 1983

9. Minimum Number of Samples
System size determines the sample number and applicability/timing of some requirements.
Three system size categories.
Minimum Number of Samples
System Population
Number of Sampling Sites (Initial / Routine Monitoring)
Number of Sampling Sites (Reduced Monitoring)
>100,000
100 50
10,001 to 100,000 60 30
3,301 to 10,000 40 20
501 to 3,300 10
101 to 500 5
≤100

10. 90th Percentile Calculations
EPA’s database automatically calculates the 90th percentile
90% spreadsheet is on EPA’s Drinking Water Website link -
The Spreadsheet will Rank your samples and calculate the 90th % for you 

11. Sample location, collection methods, and number of samples.
(1) A water system that fails to meet the lead or copper action level on the basis of tap samples collected in accordance with § shall collect lead and copper source water samples in accordance with the following requirements regarding sample location, number of samples, and collection methods:
(i) Groundwater systems shall take a minimum of one sample at every entry point to the distribution system which is representative of each well after treatment (hereafter called a sampling point). The system shall take one sample at the same sampling point unless conditions make another sampling point more representative of each source or treatment plant.
(ii) Surface water systems shall take a minimum of one sample at every entry point to the distribution system after any application of treatment or in the distribution system at a point which is representative of each source after treatment (hereafter called a sampling point). The system shall take each sample at the same sampling point unless conditions make another sampling point more representative of each source or treatment plant.

12. Sample Collection Method
Water Softeners:
Do not collect samples form taps at homes with water softeners or other point of use or point of entry devices for inorganic removal.
If the only available sites have these devices, collect samples from the sites with the highest tier rating. (Tier 1, then 2 then 3 – Tier 1 being the highest)
Sample Collection Method
First-draw samples from kitchen or bathroom taps normally used for consumption
Minimum 6-hour standing time
One-liter volume
System or residents can collect
Wide-mouth container
Do not pre-flush

13. Consumer Notification
Consumer Notification (CN) of Lead Tap Water Results (including CN Certification Form)
Consumer Confidence Report (CCR) Lead Informational Statement
The following slides review the revisions under the LCR Short term Revisions that affect system requirements to inform the public prior to an AL exceedance
A separate lead consumer notice of lead tap results must be provided for each lead test result.
Thus, a water system that collects 10 samples must provide 10 separate notices within 30 days of receiving each result This notice should include the test result that is specific to that home or building (i.e., do not provide all 10 lead results to each home/building).
Send the notice by mail or other State-approved method (e.g., NTNCWSs can post the results on a bulletin board in the tested facility, if approved by the State).
Provide the consumer notice of lead tap results to your consumers within 30 days of when you learn of the results
Provide this notice to each individual unit that was tested (i.e., notification does not need to extend to the entire building), where testing occurs in buildings with many units:
Submit to the State a sample copy of the consumer notice of lead tap results and a certification that you met your delivery requirements (refer to 40 CFR (f)(3)). For example, if you sent out 10 notices, you only need to provide a copy of one of these notices and one certification for these 10 notices. Appendix E provides a sample consumer notice of lead tap results certification form that you can adapt for your use.
Although the requirements to notify consumers of their lead tap results have been added to 40 CFR , they are distinct from other public education requirements. They apply to all CWSs and NTNCWSs, including those with 90th percentiles at or below the lead action level of mg/L.. A violation of the consumer notice of lead tap results is a reporting violation and does not trigger public notification. On the other hand, a public education violation is a treatment technique violation and triggers Tier 2 public notification.

14. Lead Consumer Notice (CN)
Notice must include:
Results of lead tap water monitoring
Explanation of lead health effects
Steps consumers can take to reduce exposure
Facility contact information
MCLG and AL for lead and their definitions*
Use template available on Drinking Water online
* Must use CCR Rule language in §141.13(c).
In addition to the test results, the notice must include:
an explanation of the health effects of lead,
steps consumers can take to reduce exposure to lead in drinking water,
contact information for the water utility,
the MCLG and the action level for lead, and the definitions for these two terms from § (c) of the CCR Rule.
The public education guidances available on EPA’s website contain templates letters systems may use. Templates are available for different scenarios.

15. Consumer Confidence Reports
Systems Affected - All CWSs
All CCRs must include:
Sources of lead in drinking water
Health effects from lead exposure
Ways to reduce lead in drinking water
Recommended flushing times
Sources of further information including lead testing
Required regardless of lead sample levels
The LCR Short Term Revisions revised the requirements of the CCR Rule. Previously an informational statement was only required if >5% of tap samples were above the lead AL.
Now EPA is requiring all CWS to provide information in every CCR on lead in drinking water irrespective of whether the system detected lead in any of its samples.
CWS must still report the 90th percentile value and the number of sample sites exceeding the lead AL.

16. Action Level Exceedance (ALE)
Exceeding the action level is not a violation
Failure to perform actions after an exceedance is a violation

17. Actions for Lead Exceedance
Put up this form on the overhead
Replace 7% of LSLR per year. Must inventory water system. Difficult to know how much lead service lines are in the ground.
Calculator will tell you immediately if you exceeded. Demonstrate
You must analyze for both lead and copper even if you exceeded only one of the action levels in lead or copper tap monitoring.
See the Handout

18. Action Letter
Put up this form on the overhead

19. Two Types of Monitoring After an Action Level Exceedance (In addition to 6 month lead & copper tap samples)
Go over in detail – Handout also. Where to Monitor. Where to take POE. What to do if you have ALE
What about Corrosion Control treatment ?
Measure WQP
Purpose of WQP Sampling: To assist in determining water corrosivity, To identify appropriate corrosion control treatment, To determine whether corrosion control treatment is being properly maintained.
WQPs are used to determine the corrosivity of the water, and if needed, to help the State to determine the type of corrosion control that a system should install and how the treatment should be operated. For most water systems that require treatment, corrosion control treatment is the primary mechanism for reducing their lead and copper levels.

20. WQP Monitoring Parameters
Typical Water Quality Parameters
pH1
Orthophosphate2
Alkalinity
Silica3
Calcium
Temperature1
Conductivity
1 Measured on-site. 2 Applies when a phosphate-containing inhibitor is used. 3 Applies when a silicate-containing inhibitor is used.
Measure at different locations... entry point and in distribution system

21. WQP Monitoring Form
Due every 6 months

22. Water Quality Parameter Monitoring
Required for all large systems (systems serving more than 50,000 people)
Required for small/medium systems that exceed the lead or copper action level
Sample site locations
Representative distribution system locations (e.g., coliforms and disinfectant residual sites)
Entry points to the distribution system
Not first draw, sample cold well flushed taps
WQP monitoring is required for all large systems and small and medium systems that exceed the lead or copper action level.
Unlike lead and copper tap samples, WQP samples should be taken from taps that are fully flushed.
Samples collected at entry points to the distribution system must be collected at locations representative of each source of water after treatment.
If a system draws water from more than one source, the sources are combined before distribution, and samples are not collected at the entry point to the distribution system, the system must collect samples at sites in the distribution system where the water is representative of all sources being used.

23. Corrosion Control Treatment Steps
Recommend type of CCT to be installed (due to EPA 6 months after the end of monitoring period exceedance)
EPA may require a CCT study
System must install CCT within 24 months of EPA concurrence of recommendation
System must conduct follow-up WQP monitoring for 2 consecutive 6 months
EPA designates Optimal Water Quality Parameters OWQP within 6 months of follow-up monitoring
System conducts ongoing WQP monitoring to show compliance with the OWQP
Hyperlink to Page 51 of OCCT Manual

24. EPA Guidance Manual
Many communities in Region 8 use Orthophosphates

25. Corrosion Control Methods
Calcium carbonate coating
From OCCT Manual Ch 3 pg 25: The mechanisms by which silicate inhibitors control lead and copper release have been debated in the literature. Silicates may form an adherent film on the surface of the pipe that acts as a diffusion barrier. Silicates will also increase the pH of the water, which may reduce lead and copper release. The effectiveness of the formation of a diffusion barrier depends on pre-existing corrosion products on the scale to provide a site for the binding of the silicate layer (LaRosa-Thompson et al., 1997).
Sodium silicate coating
From the OCCT Manual Ch 3 pg 22: Calcium hardness adjustment is not discussed in this chapter because newer research has shown that calcium carbonate films only rarely form on lead and copper pipe and are not considered an effective form of corrosion control (Schock and Lytle, 2011; Hill and Cantor, 2011). Calcium hardness is important, however, in evaluating the amount of pH adjustment that can be made without causing calcium carbonate precipitation and resultant scaling problems in the distribution system
Aeration removes excess DIC and oxidizes Mn, Fe, and H2S
Sodium Silicate can be expensive. One benefit is that it does not add a phosphorus based chemical to the drinking water and in turn to the wastewater. Wastewater treatment has been focusing on removing phosphorus. Almost all drinking water eventually ends up at the wastewater treatment plant.
Alkalinity, pH, and DIC adjustment
Chemical - NaHCO3, CO2, NaOH, KOH, Ca(OH)2, Na2CO3, KCO3, Na2SiO3
Nonchemical - limestone contactor, aeration
Phosphate based corrosion inhibitors
Silicate based corrosion inhibitors
OCCT Manual
Ch 3 - Screening level CCT flowcharts
Appendix F - CCT tools

26. Adjustment of pH and Alkalinity
A moderate increase in pH and alkalinity can decrease corrosion
Lime
Soda ash
Sodium bicarbonate
Caustic soda
A moderate decrease in pH and alkalinity can decrease scale formation
Carbon dioxide
Sulfuric acid

27. Corrosion Control Study
EPA discretion for < 50,000
EPA Region 8 typically accepts system recommendations without a study.
18 months to complete
System must identify parameters for:
pH and alkalinity adjustment
Calcium hardness adjustment
Corrosion inhibitors
Fully document treatment recommendation

28. Designation of OWQPs
EPA-specified operating parameters become compliance measures pH
Alkalinity
Calcium
Orthophosphate
Silica
EPA sets OWQPs within 6 months of receiving follow-up results after CCT installation. See WQP Monitoring form

29. What if CCT is Unsuccessful?
You Must Begin Lead Service Line Replacement within 1 year if CCT is not working for lead
Inventory the system for Lead Service Lines
Collect Lead Service Line Samples and Analyze
If lead concentration is over mg/L you must begin replacing, at minimum, 7% of your Lead Service Lines per year. Sampling is required
Partial LSL replacements must be sampled
Monitoring is required. Partial LSL replacement occurs when the entire line is not replaced due to private ownership or building inlet cannot be replaced. Keep replacing lead lines at 7% per year until you do not exceed the AL or all the LSL have been replaced.
A materials evaluation and these locations must be reported to the EPA or PA.
Annual replacement of LSL needs to be 7% minimum.

30. Consecutive Systems
If the bulk water supplier will not install or increase Corrosion Control Treatment, you may be required to install your own
A CCT recommendation will need to be submitted to the EPA within 6 months of ALE
Other CCT steps apply
EPA expects parent water system will take control for CCT- NOT MANDATED

31. Questions / Discussion

32. Federalism Consultation Meeting
Lead and Copper Rule Revisions
Office of Ground Water and Drinking Water
Federalism Consultation Meeting
January 8, 2018

33. Purpose & Overview Purpose:
To obtain input from State and Local Government Officials on potential revisions to key areas of the Lead and Copper Rule
Agenda:
Background on the Lead and Copper Rule (LCR)
Key areas for potential rule revisions
Cost Information
Next steps

34. Lead and Copper Rule (LCR)
The National Primary Drinking Water Regulation for Lead and Copper was promulgated June 7, 1991.
Applies to 68,000 public water systems serving ~300 million people
Lead and copper enter drinking water mainly from corrosion of lead and copper containing plumbing materials.
The LCR requires water systems to sample taps and to take actions including treating water to make it less corrosive to plumbing materials that contain lead and copper, educating consumers and replacing lead service lines.

35. Key Challenges with Current LCR
The LCR is one of the most complicated drinking water regulations for states and drinking water utilities to implement.
The LCR is the only drinking water regulation that requires sampling in homes, often by the consumers themselves, with very specific sampling procedures that are not always followed.
The current structure of the rule compels additional protective actions by water systems only after a potential problem has been identified; under the current rule, up to 10% of samples can have highly elevated levels of lead with no additional requirement for actions.

36. Key Challenges with Current LCR
Many systems have not fully optimized corrosion control treatment or have not maintained optimized treatment, and small systems are not required to optimize corrosion control unless more than 10% of samples exceed the action level.
In most communities, lead service lines are partially or entirely privately owned and a number of homeowners or renters may be unwilling or unable to replace the portion of the line at their home.

37. Key Areas for Rule Revisions
Lead Service Line Replacement
Corrosion Control Treatment
Tap Sampling
Public Education and Transparency
Copper Requirements

38. Lead Service Line Replacement
Current Requirements
Systems that exceed the lead Action Level (AL) after installing corrosion control treatment (CCT) must replace 7% of lead service lines per year (Primacy can accelerate)
Systems are only required to replace portion of LSL owned by PWS
Systems may consider an LSL replaced if a sample from that line is below the AL
Systems must offer to replace customer owned portion at customer cost
LSLR can stop when lead <=AL for 2 consec. mon. periods
Challenges
Most homeowners have declined the opportunity to replace their portion of the lead service line.
Partial replacements may be harmful due to the disruption of the service line dislodging lead

39. Key Questions
What are the opportunities and challenges to state and local governments if EPA were to modify the LCR to:
Require systems to create an inventory of lead service lines
Require proactive full lead service line replacement on a specified schedule (e.g., 10, 15, 25, 35 years from promulgation)
Allow partial LSLR only for emergency repair or “unwilling or unable customers” when conducting infrastructure replacement (e.g., main replacement)
Require pitcher filters to be distributed and regularly maintained by the PWS for three months immediately following lead service replacement

40. Corrosion Control Treatment
Current Requirements
Systems serving >50,000 required to perform CCT
Systems serving ≤50,000 required to perform CCT if AL exceeded
System proposes treatment (or changes) and state approves
Challenges
States and water systems often lack needed expertise
Some small systems with lead service lines are not required to perform CCT

41. Key Questions
What are the opportunities and challenges to state and local governments if the LCR was modified to:
Target systems to required install CCT differently:
Change the 50,000 people system size threshold
Require systems with LSLs (regardless of population served) to install and maintain CCT
Require providing plumbed in POU treatment devices for households with LSLs
Change requirements for designating OCCT to:
Prescribe a default CCT that must be maintained
Require the system to conduct a periodic re-evaluation of CCT
Require system to find and fix problems in corrosion control treatment if a tap sample exceeds an action level? 10

42. Transparency & Public Education
Current Requirements
The annual Consumer Confidence Report sent to all consumers must include lead sampling results and an informational statement about the health effects of lead and actions to reduce exposure
Systems that exceed lead action level must begin public education within 60 days after end of monitoring period:
– Educational materials must include information on health effects of lead, sources of lead, and steps consumers can take to reduce exposure to lead in drinking water
The 2016 Water Infrastructure Improvement for the Nation Act (WIIN) requires notice of exceedance of AL within 24 hrs
Challenges
Intensive PE only occurs after a problem has been identified
Information on lead in drinking water is confusing, particularly results, in comparison to the action level

43. Key Questions
What do state and local governments think are the most effective ways for water systems to deliver educational information to consumers?
What opportunities/challenges would state and local governments face if the LCR was revised to require:
Water systems to provide on-going targeted outreach with a special emphasis on all customers with LSLs?
Water systems to provide notification to consumers within 24 hours of exceeding an AL (as required by the 2016 WIIN Act)?
Water Systems to make information accessible to consumers on results of all tap sampling, results of WQP monitoring and the number and locations of LSLs?

44. LCR Tap Sampling Current Requirements Challenges
Collect samples at residential taps that are at high risk of lead contamination
90th Percentile result compared to Action Levels based on treatment feasibility
15 ppb (µg/L) lead
1.3 ppm (mg/L) copper
Challenges
Complicated sampling procedure
Procedures are not always followed
Up to 10% of samples can have highly elevated levels of lead with no additional requirement for actions 13

45. Key Questions
What are the opportunities/challenges for states and local governments if the rule changed sampling protocols e.g.:
Changing where water systems are required to collect tap samples?
At sites based on customer request,
At schools served by the system,
Change the way samples are collected to be more representative of exposure?
Increase the number of samples required
Instruct consumers to sample when they are drawing water for drinking or cooking.
Establish a household AL that if exceeded would trigger a report to the consumer and to the health agency for follow up?

46. Copper Current Requirements
Copper samples are collected at the same time and customer taps as lead samples.
The 90th% value of results is compared to the copper AL of 1.3 ug/L.
If the copper AL is exceeded, water systems must implement CCT.

47. If water is aggressive, require:
Key Questions
What opportunities and challenges would state and local governments face if EPA revised the LCR to:
Establish a screen to determine if water systems have water aggressive to copper?
If water is aggressive, require:
monitoring and/or
public education and/or
CCT.
Modify tap sampling to require separate sampling sites for copper?

48. Summary
The LCR is a composite of multiple requirements that apply to systems differently depending on system size and water quality
The revised LCR would similarly bring together multiple key requirements that could vary according to system specific conditions
One important factor in considering potential changes to the LCR is cost. The following slides provide representative examples of the costs of a few key potential requirements

49. Example Costs Lead Service Line Replacement
Based on preliminary estimates, replacing a full LSL would cost on average $4,700 per line replaced
Cost can vary greatly depending on the length and the amount of pavement that must be restored. Costs may range from $1,200 - $12,300 per line replaced

50. Example Costs
Estimated Costs for Centralized Orthophosphate Treatment (CCT) Systems
Public Water System Size (People Served)
Total System Capital Cost ($)
Annual System O&M Cost ($)
Total Capital Cost per Household ($)
Annual O&M Cost per Household ($)
25-100
18,000
2,000
740 78
19,000
170 21
21,000
3,000 72 12
22,000
6,000 31 8
39,000
8,000 17 3
48,000
25,000 5
63,000
81,000 2
92,000
265,000 1
In this table total system and household capital costs are one time costs and are not annualized values. Annualized capital cost would normally be calculated over the useful life of the technology.

51. Example Costs
Plumbed in Point of Use filter devices would have an estimated total annual cost of $120 per household

52. Discussion
Do you have any other approaches that you would like EPA to consider?
Any additional information or concerns you would like to share with EPA?
EPA would appreciate any information, and specific data, state and local governments could provide on their experiences with:
lead service line replacement
corrosion control treatment (studies and implementation)
sampling programs or
other aspects of drinking water lead control programs.

53. Next Steps Comments due: March 8, 2018
Submit comments to OR via to Docket ID No. EPA-HQ- OW :
– If you need assistance submitting your comments to the docket contact Iliriana Mushkolaj,
Additional Information on the LCR:

54. Questions? Consultation Questions and Follow-up: Iliriana Mushkolaj
Phone:
Questions about the LCR: Erik Helm
Phone: