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NARUC Conference Washington, DC February 2013. Overview. Lead and Copper Rule. Long Term LCR Proposed Revisions. Proposed rule available ~August 2013 Potential changes to the rule Sample site collection criteria and sampling procedures for lead and copper tap monitoring

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Naruc conference washington dc february 2013

NARUC Conference

Washington, DC

February 2013

Long term lcr proposed revisions
Long Term LCR Proposed Revisions

  • Proposed rule available ~August 2013

  • Potential changes to the rule

    • Sample site collection criteria and sampling procedures for lead and copper tap monitoring

    • Corrosion control treatment and water quality parameter monitoring requirements

    • Lead service line replacement requirements

    • Sampling in schools and child care facilities

    • Consecutive system requirements

    • Potentially outdated requirements, rule relevancy, and simplicity for systems

Long term lcr proposed revisions1
Long Term LCR Proposed Revisions

  • Potential changes to the rule (contd.)

    • Require Tier 1 samples to be taken from lead service line rather than 50% lead services and 50% copper solder

    • Changes to lead service line replacement requirements and follow up sampling

    • Alternative in home sampling schemes

      • Sample from lead service line, random daytime sample, profile sampling

    • If Action Level exceeded, system must re-optimize

    • Redefine “optimized” based solely on Pb and Cu corrosion control

    • More stringent Water Quality Parameters or phosphate addition as benchmark for effective optimization

    • Additional sampling and separate sites for copper

Reduction of lead in drinking water act
Reduction of Lead in Drinking Water Act

  • Amends SDWA Section 1417 – Prohibition on Use and Introduction into Commerce of Lead Pipes, Solder and Flux

  • Effective January 4, 2014

  • Key Revisions:

    • Creates exemptions for products that are used exclusively for non-potable services

    • Changes the definition of “lead-free” from 8% to a weighted average of not more than 0.25% in the wetted surface material (primarily affects brass/bronze)

    • Establishes requirement for calculating wetted surface area lead content

  • Next Steps:

    • Revise 40 CFR 141.43 section on lead free as part of the LT-LCR revisions

    • Guidance for how to comply available in LT-LCR revisions

Ongoing research projects
Ongoing Research Projects

  • Evaluation of Lead Service Line Lining and Coating Technologies (2014)

  • Impact of Galvanic Corrosion on Lead Release Following Partial Lead Service Line Replacement (2013)

  • Non-Intrusive Methodology for Assessing Lead and Copper Corrosion (2013)

  • Assessing Risk of Lead and Copper Consumption from Drinking Water (2013)

  • Lead and Copper Rule Revision Data Gaps Analysis (2013)

Projects completed in 2012 and other available resources
Projects Completed in 2012 and Other Available Resources

  • Is NSF 61 Relevant for Chloraminating Utilities?

  • Lead (IV) Oxide Formation and Stability in Drinking Water Distribution Systems

  • Lead and Copper Rule and Distribution System Corrosion: An Overview of Foundation Research

What do we know
What Do We Know?

  • Nitrosamines are known carcinogens

  • Causes:

    • Chloramine

    • Amine-based polymers and anion exchange resins

    • Wastewater Impact

  • Widespread occurrence of NDMA

Epa s decision environment
EPA’s Decision Environment

  • A positive regulatory determination is likely

  • If a positive determination is made, then there will almost certainly:

― Be a rule

― Proposal will be completed in ≤2 years

― Rule will be based almost exclusively on what is known about NDMA


― EPA has publicly committed to regulating “nitrosamines”

― There is widespread occurrence of NDMA

― NDMA is a recognized DBP that is nominally carcinogenic; therefore, an MCLG of zero is the policy objective

“Policy Discussion Around Regulation of Nitrosamines” Webcast (9/5/2012)

In terms of timeline there are several considerations multi year research agenda
In terms of timeline, there are several considerationsMulti-year Research Agenda

  • Third round of Regulatory Determinations will occur in 2013

  • A proposed EPA regulation will occur at the earliest in 2015

    • Need to understand limits of treatability and understand cost consequences

  • A final EPA regulation will not be until 2017

    • Need to be able to really understand precursors and treatment options at a high level of detail

  • Compliance will not be required until 2020

    • Need to have a cohesive package of products that allow water systems to make treatment choices and begin construction in 2018

Focus area objective
Focus Area Objective

Develop information on occurrence, precursors, formation, treatment and control, and fate of nitrosamines in distribution systems

  • Inform regulators

  • Assist utility compliance with pending regulations


  • Investigate the contribution of source water quality, treatment processes, and distribution system operations to the total pool of nitrosamine precursors

  • Develop control strategies to prevent or minimize the formation of nitrosamines from source to tap

  • Identify unintended consequences and cost of compliance

Ongoing projects
Ongoing Projects

  • Investigating Coagulant Aid Alternatives to PolyDADMAC

  • Nitrosamine Occurrence Survey

  • Controlling the Formation of Nitrosamines During Water Treatment

  • Seasonal Patterns of NDMA Precursors in Water Sources and Their Removal at Drinking Water Treatment Plants

Related waterrf research
Related WaterRF Research

  • Anion Exchange Resins as a Source of Nitrosamines and Nitrosamine Precursors

  • Development and Application of a Total Nitrosamine Assay for Disinfected Waters

Recent developments
Recent Developments

  • EPA still working on the third round of regulatory determinations

  • Formation of nitrosamines is being used as an argument against the use of chloramines

Background on cvoc rule
Background on cVOC Rule

  • March 2010 – EPA Administrator Jackson released Drinking Water Strategy

    • Regulate groups as opposed to one-at-a time

  • February 2011 – Jackson announced cVOCs would be the first group to be regulated

    • Listed 8 regulated VOCs and up to 8 unregulated

  • Fall 2013 – Proposed cVOC Rule

  • Fall 2015 – Final cVOC Rule

Carcinogenic vocs 2 11 list
Carcinogenic VOCs (2/11 list)


– Benzene

– Carbon tetrachloride

– 1,2-dichloroethane

– 1,2-dichloropropane

– Dichloromethane

– Trichloroethylene (TCE)

– Tetrachloroethylene (PCE)

– Vinyl chloride

Unregulated (CCL3)

– Aniline

– Benzyl chloride

– 1,3-butadiene

– 1,2,3-trichloropropane (TCP)

– 1,1-dichloroethane

– Nitrobenzene

– Methyl-oxirane

– Propylene glycol

– Urethane

Main issues
Main Issues

Analytical Methods

  • How many methods might work for the proposed cVOC Rule?

  • Which method works for which VOC?

  • More than one method?

  • How low could these methods go from a practical perspective?


  • How many treatment technologies might work for the proposed cVOC Rule?

  • Which treatment works for which VOC?

  • More than one treatment?

  • Treatment in series?

  • How low could these treatment technologies go from a practical perspective?

  • What are the costs (capital and O&M)?

Focus area objectives
Focus Area Objectives

Develop a comprehensive research agenda to

  • Assess effectiveness of analytical methods

  • Address occurrence and co-occurrence of VOCs

  • Evaluate treatment for removing VOCs and reliability of technologies

  • Develop cost information for VOC treatment.

Related research
Related Research

  • Removal of VOCs from Drinking Water via Low-Profile Aeration Technologies

  • GAC-Rapid Small Scale Column Test (RSSCT) at Low Concentrations of VOCs

  • Predicting the Impact of Competing Contaminants on GAC Breakthrough at Low Levels VOCs

  • Development of New Innovative Technologies for cVOC Removal


  • Several water regulations are planned

  • Compliance will require:

    • Increased capital expenditures

    • Increased operational costs

  • Utility costs will increase, while water use is declining

Naruc conference washington dc february 2013


Rob Renner

Executive Director