Preparing To Tackle The Hydra Of LCR Revisions
As a journalist serving the water industry — but not yet a seasoned technical veteran — I attended a recent Lead In Drinking Water Forum sponsored by AWWA NJ to learn about the challenges of complying with the proposed Lead and Copper Rule Revisions (LCRR). What I heard impressed upon me the technical, administrative, and logistical challenges of delivering safe, lead-free drinking water all the way to user taps.
Even with my reasonable grasp of the causes behind lead in drinking water before the forum, the professional presenters made me appreciate just how much of a Herculean effort it will be to battle the many heads on this Hydra. That includes both the ongoing adjustments of everyday chemistry and the new workload demands of testing, regulatory compliance, and customer collaboration. The bad news is that even with eventual removal of all lead service lines (LSLs), water utilities cannot control all the metal fixtures in a user residence that might impact lead-sampling results from the tap. The good news is that there are knowledgeable, experienced professionals, resources, and recommendations available to help.
Embracing The Multifaceted Challenge
Like it or not, LCRR implementation is coming. Based on the presentations I attended, I view the challenge of delivering lead-free water to user taps as falling into four major categories — chemistry, new regulation, logistics, and communication. Many technical aspects are relatively familiar to water treatment professionals; some of the logistical and communications details might have a longer learning curve — particularly for small- to medium-sized community water systems (CWS). Through it all, however, it seems as though preparation is the common denominator.
The Challenging Chemistry Of Corrosion Control Treatments (CCT)
One of the most awe-inspiring facets of the entire forum — for me, at least — was the sheer range of permutations for codependent factors in traditional water treatment and their influences on eventual CCT strategies.
Everything is interrelated and it all starts with source water conditions. Changing water-supply sources — whether due to contamination, groundwater depletion, or other causes — typically forces utilities to change water treatments. Any alteration in treatment protocols can trigger different chemical reactions that might negate the efficacy of a previously sound CCT approach and result in lead release from piping, fixtures, or existing lead scale. In fact, according to LCRR language, “Systems on any tap monitoring schedule must obtain prior Primacy Agency approval before changing their source or treatment.”
The impacts of lead leaching into drinking water due to changing treatment conditions touch virtually every aspect in the tangled web of variables:
- water composition (pH, dissolved inorganic carbon, oxygen reduction potential, etc.),
- treatment processes (coagulation, softening, disinfection, greensand filtration, aeration, iron or manganese sequestration or removal, etc.),
- chemical additives/treatments (orthophosphate, alum, lime, ion exchange resins, etc.),
- and even chemical changes or physical disturbances caused by the relining/replacement of water mains.
Given all those variables, even a well-established layer of lead scale can deteriorate under changing water chemistry. My takeaway from that long list of potential interactions is that CCT is not a one-size-fits-all-forever solution. As one presenter put it, “the reaction pathway matters as much as the endpoint.” That is why it is important to continually re-evaluate treatment chemistry processes and distribution system results.
Keeping Abreast Of Regulatory Changes
While the underlying goals of the original LCR remain, the proposed revisions address new targets for action levels and trigger levels, tap monitoring, CCT/water quality parameters, LSL inventories and replacement plans, small-system flexibility, public education/outreach, changes in water sources or treatments, schools and childcare facilities, and primacy agency reporting. This U.S. EPA reference guide listing 49 major differences between current and proposed requirements is an excellent place to start.
The change in trigger levels from 15 µg/L to 10 µg/L will surely affect the number of customer sites impacted. Also, the new rule allows just 24 hours (instead of 30 days) for utilities to notify customers whose individual tap samples exceed 15 µg/L and to provide pitcher filters/cartridges to each customer receiving either a full or partial LSL replacement (LSLR). Those represent just several areas that will require significant new levels of advanced planning and preparation.
One entirely new LCRR requirement is that a CWS must conduct lead in drinking water testing at 20 percent of K-12 schools and licensed childcare centers in its service area every year. Searching the web for EPA guidelines, news, and resources from other jurisdictions is a good place to get familiar with the associated challenges.
Identifying And Implementing Critical Logistics
Responses for specific conditions outlined in the LCRR also impact many aspects of utility operations beyond water-treatment chemistry — including management reporting, field staff scheduling, new procurement activity, and new PR/communications efforts. For example, developing customer email/text contact lists to satisfy the 24-hour-notification requirements and materials to support media publicity campaigns should both start well in advance of any testing program. Planning for additional educational materials, notification logistics, pitcher filter/cartridge acquisition, and filter/cartridge changing instructions also needs to be completed by the time LCRR goes into effect.
The Importance Of Clear Communication — Before, During, After
Relying on EPA regulatory language in customer communication runs the risk of confusing consumers or causing disinterest, rather than encouraging the desired level of action. Whether the task at hand is general education or specific LCRR compliance, using clear, action-oriented language with consistent graphics and messaging written at the level of the audience’s understanding is critical to good customer participation. For example:
- doorhangers that communicate desired action steps,
- infographics that use simple, colorful images to educate consumers, and
- interactive map links that encourage customers to monitor the status of their property for testing or LSLR programs,
will all help to eliminate confusion, instill consumer confidence, and achieve water utility objectives sooner and with greater efficiency. While some utilities might have personnel with the experience to handle this new communication workload, others might be better served by joining with another organization experienced in similar community-action activities.
A Final Eye-Opening Bonus
While it did not directly impact LCRR activities, the most eye-opening presentation of the forum was a review of how Dr. Gene Hall of Rutgers University determines the sources of lead in tap water through sequential sampling and lead isotope ratio measurements. Even in communities where all LSLs are replaced or where well water is used, homeowners can still encounter lead in their tap water due to lead in faucet bodies, brass fittings, copper piping, or solder.
Dr. Hall has identified isotope ratios to profile specific sources of lead by individual mines in the U.S., Canada, China, Brazil, and other countries and by more than 500 faucet and plumbing fixtures. By sampling the water flow at specific intervals corresponding to the distance from each fixture, he can identify the presence and concentration of lead being contributed by each one.