Modifications to the Lead and Copper Rule

The U.S. EPA is currently considering modifications to the Lead and Copper Rule. 

Should the new version of the rule change the status quo monitoring requirement where the water utility is responsible for complicated in-home compliance monitoring? 

What should a new monitoring protocol look like?

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Modifications to the Lead and Copper Rule

November 30, 2017 11:58 AM by Peter Gautreau

If you are in violation. Monitoring should involve two samples one first draw and one after a period of flushing to determine the source. If source water is the issue then by all means treat and take care of the problem. If found to be the homeowner then public education for all and for public housing /rental property lead abatement becomes mandatory. 

Modifications to the Lead and Copper Rule

December 1, 2017 02:08 PM by Allen Kelm

If you are in violation of lead and or copper you should have to do additional monitoring, WQP and public education.  The way it reads now is “Public education is only required if Pb AL is exceeded”.  Copper can cause stomach and intestinal distress, liver or kidney damage and complications of Wilson’s disease in genetically predisposed people.  Why would you not do Public Education for Cu exceedance?  This rule is a TREATMENT TECHNIQUE rule, NOT a lead line replacement rule.  If your water is corrosive it will not only leach the Pb out of the pipes but also Cu and slowly deteriorate your entire system and the plumbing in homes and businesses.   We are getting caught up in the Flint case, which is a terrible thing, and should have never happened.  The lead and copper results for Flint, when they were on the Detroit water, passed the testing.  It was only when they changed water sources, and the water was deemed corrosive, is when Flint started to have problems. Even GM in Flint quit using the water at their factories due to the corrosiveness.  Again, use the current rule as it was intended, it is a treatment technique rule. Non-corrosive water = no problem, Corrosive water = problems within your entire system.  

Replacing all the lead lines and keeping the water corrosive does nothing for the copper issues and the issues of corrosiveness within your entire system.  Make your water non-corrosive through the Treatment Technique requirements and do the WQP sampling as required by the current rule.  Educate the public that just replacing the lead lines doesn’t fix the problem.  Making the water non-corrosive does fix the problem.

LCR Update

February 23, 2018 10:25 AM by Lew Baker

Corrosion control should be THE focus of the rule, including use of Chloride to Sulfate Mass Ratio (CSMR) index.  Systems should routinely monitor concentrations and ratios of chloride and sulfate in both source water and treated water.  Choice of coagulants can add to chlorides or sulfates.  Increased chlorides will tend to increase release of lead, and more sulfates will reduce lead.  Copper corrosion will tend to respond to these ions also, but in the reverse to lead (more sulfate = more copper, more chloride = less copper).

As for monitoring for lead, instead of sampling a handfull of faucets suspected of being most at risk, and having homeowners collect the samples, it would be much better to set a goal of having health agencies test ALL infants for lead in their blood (many infants now tested, but not all, and % tested varies by state depending on $).

Those infants with highest blood lead levels should get immediate assistance, and sanitarians or others certified in proper sampling protocols should collect follow up samples from faucets, as well as of dusts and soils the infants may have been exposed to.  This is also done now, but the goal should be to test ALL infants, and then follow up.  What is typically found, is lead in dust and soil is usually the problem, not the water supply, and when it is the water supply, it may be from a private well rather than a public supply.

Public supplies are sometimes one of the significant sources of lead, but not usually.  However, lead in drinking water may become more common as chlorides in source water increases in urban areas from use of road salt.    Public water systems have also been switching from sulfate based coagulants to chloride based coagulants to reduce DBPs, sometimes resulting in increased lead corrosion.  Owners of private wells often add water softening, which can increase lead corrosion from their plumbing.

We all need to be more aware of the various causes of corrosion, and how to minimize them.  We also need to identify ALL the infants who have been most harmed by lead contamination, and then finding the sources of their lead exposure.

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