Lead and Copper Rule: Potential Regulatory Changes, Corrosion Chemistry, and Stakeholder Communication

April 21, 2016

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. No part of this presentation may be copied,© 2016 reproduced, Water Research or otherwise Foundation. utilized ALL without RIGHTS permission. RESERVED. National Drinking Water Advisory Council Recommendations

Stephen Estes-Smargiassi Director of Planning and Sustainability Massachusetts Water Resources Authority

• LCR Working Group was formed under the auspice of the National Drinking Water Advisory Council (NDWAC) • 15 working group members, with representation from: — State regulators — Local health departments — Drinking water utilities (small/large systems; public/private) — Public interest groups (community, children’s health, national NGOs) — NDWAC members • Seven, two-day, in-person meetings; several web meetings; a webinar up-date with the NDWAC; and a dozen small group calls to discuss issues, develop recommendations and prepare report

• Recommendations to EPA -- December 2015 • Likely Draft Rule revisions -- 2017

• There is no safe level of lead in blood. Lead-bearing plumbing materials in contact with drinking water may pose a risk at all times, not just when AL is exceeded. • Proactive action to remove lead materials from contact with drinking water is needed. • Source is in the service lines and in homes. Thus, elimination of lead materials is a shared responsibility. — PWSs, consumers, property owners and public health community all play important roles. — A holistic effort is required with cross-sector stakeholder partnerships, and creative financing are needed to remove the sources of lead

• The LCR should remain a treatment technique rule. • The issues associated with lead and copper are different. • CCT is complex, dynamic, and varies w/system conditions. — Better understanding of the science (and the complexities) — Attention to unintended consequences is important. • Attention to what systems can implement and States are able to oversee and enforce also is important. • PWS and state resources should be focused on actions that achieve the greatest health protection.

• Read the full report: www.epa.gov/ndwac/letters-recommendations-epa-administrator-ndwac

• The LCRWG’s proposed improvements to the LCR make some fundamental changes: — Proactive approach to actions previously triggered by lead action level exceedance ▪ All systems work with customers to remove LSLs ▪ Stronger public education requirements for all systems — Establish a household action level; results to health dept. if exceeded — Separate requirements for copper; focus on systems w/ aggressive water • Improvements to CCT and monitoring • Complementary critical actions – not just the LCR and EPA • LCRWG conclusion: Taken as a whole, this will achieve more public health protection than the current rule

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Where Does The Lead Come From? From? Kitchen Area 0.8 – 1.7 ug • Contribution of Service Line and Lead Service Line 31Plumbing – 139 ug Fixtures to Lead and Copper Rule • Compliance Issues (2008)

Source: Adapted from Sandvig, A., P. Kwan, G. Kirmeyer, B. Maynard, D. Mast, R. R. Trussell, S. Trussell, A. Cantor, and A. Prescott. 2008. Contribution of Service Line and Premise Plumbing Plumbing Fixtures to Lead and Copper Rule Compliance Issues. Denver, Colo.: Water Research Foundation. Reprinted with permission. 3.4 – 125 ug

• Under the current LCR: — LSL replacement triggered by a lead action level exceedance — Action is required in a short time frame; results in many partial lead service line replacements — The replacement requirement stops with two consecutive rounds of sampling being under the AL

Typically Public Typically Private

Source: Sandvig, A., P. Kwan, G. Kirmeyer, B. Maynard, D. Mast, R. R. Trussell, S. Trussell, A. Cantor, and A. Prescott. 2008. Contribution of Service Line and The views expressed in this presentation are those of the speaker on Plumbing Fixtures to Lead and Copper Rule Compliance Issues. Denver, Colo.: behalf of the LCR work group and do not necessarily represent those of Water Research Foundation. Adapted with permission. the U.S. EPA., the Water Research Foundation ,or the presenter.

• What we know today: — All removals likely cause a spike in lead levels — Lead levels following a partial replacement do not drop to as low a value nor get to a low level as fast as after a full LSL replacement — Lots of partial LSLR under current LCR mandatory LSLR requirement

Based on Science Advisory Board report

Photos courtesy of Cincinnati Water

• All systems should establish LSLR programs, which set replacement goals, engage customers in implementing those goals, and provide improved access to information

• Recommended framework: — Assume lines are lead if prior to a certain date, unless PWS can demonstrate otherwise (incentive for accurate inventory) — Targeted outreach to customers with LSLs — No penalty for customer refusal; no credit for partial LSLR — Goosenecks removed when found

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Where are the LSLs? • Is there an inventory of service lines? • How can lead service lines be located? • Are there opportunities to engage real estate and home inspectors? • Make the information easily available to the public

Images courtesy of Framingham Water and BWSC

If it looks like a nickel, it’s lead

If it looks like a penny, it’s copper

Information at www.mwra.com

Photos courtesy of EPA: https://www.epa.gov/il/advice-chicago-residents-about-lead-drinking-water

• Recommended framework continued:

— Interim replacement milestones (3 year reporting); credit for lines determined not to be lead; increasing actions if milestones are not met (see Appendix Tables 1 and 2) — Failure to meet target is not a violation; failure to increase actions is — SOPs for partials and planned maintenance, emergency repairs, etc. (EPA guidance/templates for small and medium systems.)

— Primary source of lead in contact with drinking water will be largely removed over time — Reduced public health risk and costs of corrosion control treatment — Improved process for planning and replacing LSLs (e.g. can include in capital improvement programs) — Improved awareness of location of LSLs and PLSLs — Improved communication with consumers and public health partners about the risks of lead in drinking water — Reduced risk/consequences from treatment upsets or source water changes

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Sampling: Continuous & Customer Initiated Lead Control Program Copper Control Program Provide Public Education Information and Consumer Confidence Report Provide Information in Consumer Confidence Report

Maintain Water Quality Monitoring

Corrosion Is water corrosive? Control Do Lead Service Customer Treatment Lines Exist? Requested needed? Tap Sampling No Yes No Yes Yes No Public Education Water Lead Service HAL SAL Quality Line Exceeded? Exceeded? No Parameter Replacement Change such Monitoring Program that water is not Yes No No Yes corrosive

Contact Report to Report to Yes Health Customer Customer Agency and to and to Change and Report State State and Maintain Water Change Treatment Maintain Water to Evaluate Quality Treatment or or Source Quality Conditions Customer CCT and Conditions Source other Conditions

• Currently PWSs conduct tap sampling for lead, with sample site selection tiers and first draw sampling protocol. — If the AL is exceeded, small/med systems triggered to CCT and all systems must do PE and LSLR until results are under the AL for two monitoring periods • Issues with current approach: — Sampling protocol may not capture the highest lead levels (not from LSL, inconsistent sampling from customers, variability among properties, etc.) — Recruitment is difficult and labor intensive — Sampling is infrequent and in relatively few homes

• Voluntary customer initiated tap sampling (with outreach encouraging sampling) to provide customers with information and PWS’s with data to identify and correct unanticipated problems — Targeted outreach to customers with LSLs and vulnerable populations; available to any customer • Tap sampling results will be used to: — Inform and empower individual households to reduce risk — Report to health officials when monitoring exceeds a “household action level” — Evaluate effectiveness of CCT and guide reassessment

• Tap samples would be reported to primacy agency on a routine basis, and include information on sampling protocols used • The PWS should maintain the data to identify trends and changes; data would be available for public review; reviewed during sanitary surveys • If the 90th percentile of the three years of data exceeds the “System Action Level” then the PWS must assess the cause and potentially re-evaluate CCT or take other actions prescribed by the primacy agency

• Review updated EPA guidance, and revise CCT if appropriate

• Aerators – on or off – On

• Preflush before stagnation – No, normal household use

• Defined stagnation period – Maybe, but long

• Flow rate – Normal household use

• Narrow or wide mouth bottle – Wide

• Better instructions Photo courtesy of M Edwards

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Household Action Level Lead Control Program Copper Control Program Provide Public Education Information and Consumer Confidence Report Provide Information in Consumer Confidence Report

Maintain Water Quality Monitoring

• Current lead action level (“system action level”) is based on 90th percentile of all collected tap samples • Household action level would be based on lead concentration in an individual sample necessary to elevate BLL ≥ 5 µg/dL in an average, healthy, formula fed infant — Based on CDC level of concern • PWS to notify local health department (and resident) when result of tap sampling is greater than household action level • Health department to take action it deems best

• Tailor WQPs based on the individual PWS’s CCT plan, increase the frequency of WQP monitoring for process control, and ensure sites are representative of the distribution system (DS) • More systems to do WQP monitoring • EPA should review and consider adding to the list of WQPs in the LCR based on new science — The new information would be disseminated through EPA’s CCT guidance manual • WQP data should support a more rigorous review process such as control charting and other techniques to fine tune operations, reduce variability in DS and detect excursions

• Actions should be based on aggressiveness of water to copper - - not routine in-home monitoring • EPA should develop criteria to define water that is not aggressive to copper for purposes of the LCR • PWSs can choose among options to demonstrate water is not aggressive to copper: — WQP monitoring — One-time evaluation with tap sampling for copper at homes with new copper — Pipe loop study — CCT to change water chemistry

300 300

250 250

200 200 Corrosive

150 150 Corrosive Non-corrosive 100 100 Non-corrosive

50 50 Alkalinity (mg/L as CaCO3 ) CaCO3 as (mg/L Alkalinity

0 0 Alkalinity (mg/L as CaCO3 ) CaCO3 as (mg/L Alkalinity 6.9 7.4 7.9 0 1 2 3 4 pH Orthophosphate Dose (mg/L as PO4 )

Final bins dependant on additional research – see NDWAC report

Courtesy of David Cornwell, EE&T

• For non-aggressive waters, continue to demonstrate that water is not aggressive to copper • For systems with water aggressive to copper, initiate and maintain a PE program to inform: — Owners of new homes at initiation of service; and — Owners of renovated homes or to all customers routinely

• EPA should consider whether and under what circumstances CCT should be required (LCRWG assumes this would be a limited set of circumstances, but option should exist) • Long-term treatment or source water changes may require a demonstration of continued non-aggressiveness of water

• EPA must take a leadership role in a national effort with other partners to reduce lead in drinking water that includes, but is not limited to: — Working across all offices and with other federal agencies on integrated approach to action and education (HUD, CDC) — State and local policies to support LSLR and to assist customers (e.g. inspection/disclosure on sale of homes, building code requirements upon substantial renovation, priority in SRF funding) — Enhanced cooperation among state and local health departments on childhood lead poisoning, screening and prevention that includes a focus on drinking water as a source

• Critical to a national effort to reduce lead in drinking water includes: [continued] — EPA/CDC and PWS efforts to educate healthcare providers and health departments about health threats due to exposure of lead in drinking water — Financial assistance programs for low-income customers — Engaging experts in community-based risk communication to improve PE approaches — Additional research on CCT, tap flushing, defining water aggressive to copper, etc. — National clearinghouse of best practices as a resource both for the public and for small systems (templates)

• Concerns about how and where to sample, and why • The greatest unresolved risk: LSLs • The need for much better public outreach • The difference between lead and copper • The need to help inform and empower customers to take appropriate action

David A. Cornwell Richard Brown EE&T,INC WRF Webcast April 21,2016

• Iron corrosion — Prevent Tuberculation — Prevent pipe loss — Prevent red water

• Controlled by – Ferric oxides & calcium carbonate films at pH >8 (> pHs) – Polyphosphate addition for iron chelating –NOT orthophosphate

Iron corrosion control is not necessarily lead corrosion control

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Presented to NDWAC by EPA Summarizing WG Report © 2016 Water Research Foundation. ALL RIGHTS RESERVED. Presented to NDWAC by EPA Summarizing WG Report © 2016 Water Research Foundation. ALL RIGHTS RESERVED. Lead Corrosion Control Strategies

Adjust pH to Yes 7.2 – 7.8 and Can PO4 be The three primary lead CCT add PO used? 4 methods. Silicates can also be considered No

Can pH be adjusted to Yes No >9?

Maintain free chlorine Maintain pH Can “high” residual in order to Yes Can DIC be free chlorine Yes >9 and promote and maintain adjusted residual be optimal DIC Pb(IV) scale low? maintained?

No No4

Maintain free chlorine Can “high” 4 Re-evaluate residual in order to Yes free chlorine No OCCT promote and maintain residual be Reconsider PO Pb(IV) scale maintained? 4

Source: Brown, R. A., N. E. McTigue, and D. A. Cornwell. 2013. Strategies for assessing optimized corrosion control treatment of lead and copper. Journal AWWA 105(5) May 2013: 62 – 75.

• Particulate lead is very important; harder to control and harder to predict release • There are often higher lead levels at the tap than 1st draw • Houses are unique • Polyphosphate is not a lead corrosion inhibitor— might make Pb worse • Changes in ORP can cause lead releases

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Location KS - All Data (no T change data reported) - Initial 05/2014 initial - Total 1 mo - Total 2 mo - Total LSL initial - Diss 1 mo - Diss 2 mo - Diss service line 30

25 Classical Profile –

20 peak in LSL; mostly dissolved Pb

15 Lead (µg/L) Lead

5 Source: EE&T, WRF 4569

0 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Profile Volume (L)

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Location QA - All Data (initial T change missing) - Initial 11/2011 initial - Total 1 mo - Total 2 mo - Total initial - Diss 1 mo - Diss 2 mo - Diss T change service line LSL 80

60 But, many times peak is absent or is before or after LSL This sample is highly particulate Pb. Particulates can come off any time 50

40 Lead(µg/L) 30 Source: EE&T, WRF 4569 20

0 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Profile Volume (L)

David Cornwell Richard Brown EE&T,INC WRF 4569 & AWWA WITAF

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Participating Water Systems • 8 participating water systems • 3 use free chlorine, 5 use chloramines • All well below AL • 6 systems use orthophosphate — pH 7.2 to 7.6, except one >8.0

— Target PO4 residual = 0.3 to 0.8 mg/L as P • Other systems — One system = pH/alkalinity adjustment (pH ~9.3) — One system uses pH/alkalinity (pH ~8.5) plus Pb(IV) • Sample Collection and analysis — 37 locations (houses) — 96 profiles

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. © 2016 Water Research Foundation. ALL RIGHTS RESERVED. Particulate Pb in all Profiles • Total Profile Samples 1,152 (96 times 12) • Of these — 33 % dissolved lead — 67 % had particulate lead — 31 % primarily particulate lead • 143 of these 1,152 samples were 15 µg/L - of these — 31 % dissolved lead — 69 % had particulate lead — 21 % primarily particulate lead • Overall, as with peak, only about one-third of all samples were dissolved lead

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Additional Particulate Findings • Independent of corrosion control approach, no participating utility was dominated system-wide by any lead form • i.e., none were all “particulate dominated” and none were all “dissolved dominated” • Individual houses • 12 % of houses were always “dissolved dominated” • 21 % of houses were always “particulate dominated” • 67 % were dominated by particulate Pb some dates, and dissolved Pb other dates

 Particulate lead release is a major factor in lead levels  Why do we get particulate lead?

100 1 mg C/L 5 mg C/L 10 mg C/L 10 20 mg C/L 35 mg C/L 50 mg C/L 75 mg C/L 100 mg C/L 1

mg Pb/L 0.1

0.01 6 7 8 9 10 11 pH

Source: Michael Schock EPA presentation to NDWAC working group

0.40 pH = 7.0 • More effective with low TIC 0.35 pH = 7.5 pH = 8.0 • Lower dosages at low TIC 0.30 pH = 8.5 • pH less critical at low TIC 0.25 • Point of diminishing returns 0.20 higher with high TIC

mg Pb/L 48 mg C/L 0.15

0.10 0.05 4.8 mg C/L 0.00 0.0 1.0 2.0 3.0 4.0 5.0

mg PO4/L Source: Michael Schock EPA presentation to NDWAC working group

DIC = 10 mg C/L, 1 mg PO4/L 10 Dissolved Pb with ortho-P Total Pb with ortho-P

Dissolved Pb with CO3

1 Total Pb with CO3

0.1

Pb mg/L US Action Level 0.01

0.001 6.0 6.5 7.0 7.5 8.0 8.5 9.0 9.5 pH

Source: Michael Schock EPA presentation to NDWAC working group

Source: Michael Schock EPA presentation to NDWAC working group Schock, USEPA 52

 Lead can be bound in post-treatment deposition — Iron — Manganese — Aluminum — Calcium — Phosphorus  These mixed deposits are not very stable or “hard”  Could cause erratic release of lead-rich particles  Can create Pb buildup in interior house or building plumbing  Maybe different in zones in a distribution system

• Predominantly PbO2 Scales—these are more stable • Predominantly Pb(II) carbonate and hydroxycarbonates—more stable • Predominantly lead/PO4—more stable • Surface deposits creating barriers, rich in Ca, Al, often P, with some Pb (< 20%, often 5%)-less stable • Surface deposits rich in Fe, Mn, Al, sometimes accumulating P and Pb (< 10 %)-less stable

• Can cause incomplete conversion to Pb(II) phosphate phase • Residual carbonate phase often the higher-

solubility PbCO3 (cerussite) form • Blended phosphate systems rarely (to never) show crystalline Pb(II) phases

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Poly and meta/hexamata phosphates • Sequester metals so are good to minimize Fe and Mn colored water issues • Can reduce calcium carbonate ppt • Tend to prevent metal ppt—including lead • React with lead to prevent Pb-ortho ppt from forming even in blended products • Form amorphous Pb/Ca/Fe/Mn scales

Blue = none White = poly Grey= ortho

Source: Edwards, M., and L. S. McNeill. 2002. Effect of phosphate inhibitors on lead release from pipes. Journal AWWA 94(1) January 2002: 79–90.

Time Control Ortho Poly

Time 1 1.25 0.022 1.65

Time 2 2.25 0.009 0.42

Source: Boffardi, B.P., and A.M. Sherbondy. 1991. Control of lead corrosion by chemical treatment. NACE Corrosion 27(12): 966–975. *permission pending

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Changes in ORP Can Mobilize Pb, In This Example by Mn Release Mn (0.05 mg/L) DIC = 18 mg C/L 1.2 1 Example of ORP change altering .8 .6 Pb release MnO2

.4 Area of main concern .2 ++ Mn3O4 Mn Eh (volts) Eh 0 –.2 MnCO –.4 3 –.6 25°C 5 6 7 8 9 10 11 pH Source: Michael Schock EPA presentation to NDWAC working group

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Summary of Important Pb issues  Water quality zones in distribution system can be different  How we sample makes a difference  Weak scales can release lead more readily  Particulate release—scale type, faucet velocity/aerators/ random  Physical disturbance risk from repairs or infrastructure renewal—PLSLR, street work, utility work  Low water use makes CCT of all kinds less effective  Polyphosphate  WQ changes effecting scales or solubility

• Pipe loops — Harvest Pb pipe – keep moist — New Cu pipe — WaterRF 4317 • Coupon studies • Desktop Studies • Investigate potential for microbial growth w/ orthophosphate — Limiting nutrient assessment (C:N:P) • Systems with Galvanic Corrosion — Benchtop laboratory study or pipe loop

Source: Edwards, M., P. Scardina, J. Parks, and A. Atassi. 2011. Non-Intrusive Methodology for Assessing Lead and Copper Corrosion (Water Research Foundation Project 4317): Installation and Operation Manual for Corrosion Evaluation Rig – Revision 2 (October 26, 2011).

Mild Steel

Lead

Results are relative but coupon studies can be very effective tools

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Presented to NDWAC by EPA Summarizing WG Report © 2016 Water Research Foundation. ALL RIGHTS RESERVED. Which OWQP are typically monitored? • pH, alkalinity, T, Ca, conductivity, silica (if required) and phosphate (if required).

How were the monitoring data used? • Typically reviewed by District Engineers by hand to determine that the system is maintaining treatment. Typically not kept in database.

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. How Should We Rethink WQPs • What should we monitor for and goals • Where should we monitor • How frequently should we take samples • How should we analyze the data

• Larger utilities might consider pipe scale analysis to help define WQPs • Certainly pH, Alkalinity, P if used • Need Consider —ORP —Cl2/NH2CL —Fe, Mn, Al

—Cl/SO4 ratio

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Control Charts • WaterRF 4286 — Distribution System Water Quality Control Demonstration — Process Research Solutions, LLC — This chart uses single data and means — EE&T prefers Grouped data and medians

• “Out of Control” “In Control” — Control chart terms—not a regulatory statement — Out of control indicates room for operations improvement in reducing variability — The better the chemicals are controlled the tighter the band gets

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Group Data Approach • Doesn’t use individual data – uses statistical sub sets (“bins”) • Can use median or mean • Uses Control Limits for median or mean • But median values eliminate outliers • Follows original Shewhart control charts for process control • Upper limits (UCL) and lower limits (LCL) are based on a 3 sigma range • Control charts are not compliance values– they are for process optimization and control

• Next Graph shows individual PO4-P Data — Operator would be reacting to data changes that are beyond operations control — Over-reaction can be worse than no reaction — Contrast with subsequent graph on using statistics of data subsets for control charts

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Water System D - target ~2 mg/L as PO4 (~0.7 mg/L as P) daily data 99.9 percentile of group medians median of group medians 0.1 perecetile of group medians 0.9 Single Data is Difficult to Use & Operators can Overreact 0.8

0.7

0.6

Orthophophate Residual (mg/L as P) as (mg/L Residual Orthophophate 0.5

01/2011 07/2011 04/2011 10/2011

01/2010 04/2010 07/2010 01/2012 04/2012 10/2012 10/2010 07/2012 01/2013

Source: Cornwell, D., R. Brown, and N. McTigue. 2015. Controlling lead and copper rule water quality parameters. Journal AWWA 107(2) February 2015: E86–E96.

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Example Grouped Data • Next Graph shows same data grouped in 1-week bins • Operator now can easily see trends in the plants control of phosphate dose over time — Operations can react to first low data trends seen in the plot and then high data trends seen — Changes can be made slowly without over reacting — Over time variability will be reduced and the upper/lower control lines will come closer together over time

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Water System D - Orthophosphate Median Ciontrol Chart - Weekly Data Subgroups weekly median UCL median of weekly medians LCL 0.9 Goal = 0.7 Requirement = 0.33-1.3 0.8

0.7

0.6 PROCESS WAS INITIALLY NOT IN CONTROL Orthophosphate (mg/L as P) as (mg/L Orthophosphate BUT MOVED TO UNDER CONTROL EE&T Control Chart Tool

0.5

05/08/11 09/25/11 12/04/11 02/27/11 07/17/11 11/18/12

01/03/10 03/14/10 08/01/10 12/19/10 02/12/12 04/22/12 09/09/12 05/23/10 10/10/10 07/01/12 Source: Cornwell, D., R. Brown, and N. McTigue. 2015. Controlling lead and copper rule water quality parameters. Journal AWWA 107(2) February 2015: E86–E96.

(757) 873-1534 www.eetinc.com

A tool designed for utilities to evaluate and control water quality parameters, including Lead and Copper Rule WQPs

What is a How to use the Get Started! Control Chart? Tool (Video)

Melissa Elliott Assistant Director of Public Affairs Denver Water

• Growing body of evidence about increased risk of exposure to lead

• Social and political environment necessitate a conversation

Utilities and public health agencies take a more deliberate approach to communicating about lead to increase awareness and encourage lead service line replacement.

• Who owns the lead service line? • Financial incentives or investments may be necessary for the customer portion of the line • Funding triggers debates for efficacy and equity • Coordination is key as is giving the property owner lots of advance warning • Ultimately this is a conversation where finances, regulations, science and empathy all play a role.

Periods of development when lead used

Portions of the community built with lead lines

Clear time points after which lead was not used

Who to contact for utility records

Current Activity Opportunities  Consumer confidence  Advanced notice of report construction activities  Utility web page  Active outreach to  Door hangers when households likely to have construction affects lead service lines homes  Partner with local health  Bill inserts on lead agency on lead awareness

• Organizations established to handle lead exposure from sources other than water can benefit water systems • Recognized expertise and connections to the most impacted audiences • Partnering lends credibility to the water system’s lead service line communication efforts

• Take initiative, be proactive • Listen and acknowledge concerns • Be a reliable source of information • Be accurate and transparent • Partner with trusted sources • Provide consistent messages • Ensure materials are easy to read and understandable for people with differing education levels, and language needs

• How does that impact messaging (do you need material translated?) • How does it influence channel used to deliver message (access, context, etc.) • How often, what opportunities exist for you to reach them?

• Daycares, schools • Business • Gym/Health Club • Relative’s homes • Retirement/Nursing home

© 2016 Water Research Foundation. ALL RIGHTS RESERVED. Communicating About Lead Service Lines: A Guide for Water Systems Addressing Service Line Repair and Replacement www.awwa.org/resources-tools/water-knowledge/lead.aspx

If we are doing work that may We care about you disturb lead service lines, we and your family’s will notify our customers to minimize any increased risk of health exposure to lead at the tap. • Our first commitment is to protect • When construction will affect a large public health group of customers, we will notify the • Lead in drinking water can be harmful. impacted customers through INSERT It can impact normal physical and MEANS. mental development in babies and • If emergency repair work impacts a young children, cause deficits in the lead service line, we will INDICATE HOW attention span, hearing, and learning YOU WILL PROVIDE relevant abilities of children, and increase blood information. pressure in adults. • After a service line has been replaced, • We will take steps to protect you and INDICATE HOW YOU WILL PROVIDE your family if we expect to disturb lead flushing instructions and additional service lines during the course of utility steps customers can take to reduce lead repair or maintenance. in their drinking water.

There are steps you can take to You can reduce the risk of protect yourself and your family lead in tap water by flushing from lead in tap water, regardless of whether you have a lead your home plumbing before service line. consuming water.

• You can draw fresh water into • The more time water has the home by running cold water been sitting in your home's from the faucets you use for pipes, the more lead it may drinking, particularly after long periods of time when water has contain. not been used. • Even if you do not have a • You can make sure plumbing lead service line, plumbing products contain the lowest fixtures like faucets, valves, possible levels of lead by and lead solder can contain purchasing replacement small amounts of lead, so plumbing products that have flushing can still help reduce been tested and certified to lead exposure. “lead-free” standards.

• Internal • Elected Audiences Officials

Briefings Messaging Papers Outreach Plan Operations Imagery Plan Imagery

Website Financial Bill Inserts assistance Door Hangers Outreach Plan Letters Messaging • Customers • Partners

• How can water utilities assure customers that their drinking water is safe? • What can utilities do to inform customers about lead service lines when no utility inventory is available? • Will what happened in Flint, Michigan cause a loss in trust in tap water?

• Is telling our customers that we are below the action level for the LCR enough? • Should my utility recommend filters and/or bottled water to our customers? • Should my utility be sharing information on lead testing results with our health department?

• Preparing for the inevitable —Understand your program well and what changes you are considering making —Determine a spokesperson —Prepare hard questions and practice —Ensure that your web site and review customer communication materials updated —Encourage transparency and brief everyone that doesn't like surprises

Jonathan Cuppett Research Manager Water Research Foundation

Lead and SDWA Copper Proposed LCR Lead Ban Rule Revisions

1986 1988 1991 2011 2017

Lead Reduction Contamination of Lead Control Act Act

>45 LCR Projects >$14 million value

Project Summaries

Summary of Common Themes

Ongoing Projects

List of all Projects

Role of Phosphate Innovative Techniques for Inhibitors in Lead Control Strategies Lead Service Line Location Mitigating Corrosion

1990 1994 1995 2000 2001

Development of a Lead Pipe Rehabilitation and Pipe Loop Protocol Replacement Techniques For Lead Control

Contribution of Service Line and Plumbing Fixtures to Lead and Lead and Copper Corrosion Copper Rule Compliance Issues in New Construction

2008 2010 2011 2013

CSMR: Changes from Water Galvanic Corrosion Treatment and Its Impact on Following Partial Lead Leaching Lead Service Line Replacement

• 2015 publication “4569” • WRF – AWWA collaboration • Response to attention from profile sampling • Highlighted challenges with customers performing profiles • Webcast available • JAWWA publication forthcoming

• 2015 publication “4409” • WRF – AWWA collaboration • Overview of Lead in drinking water and corrosion chemistry • Lead service line replacement strategies • 6 – OCCT Case Studies

• Evaluation of Lead Service Line Lining and Coating Technologies 2016 • Evaluation of Flushing to Reduce Lead Levels

• Optimization of Phosphorus-Based Corrosion Control Chemicals and Flushing for Lead and Copper Control • Corrosion of Nonleaded Pump Impeller Alloys in 2017 Chlorinated Potable Water

www.waterrf.org/resources/expertsymposiums/P ages/lead-copper-symposium-2016.aspx

• Service Line Material Inventory • Flushing Guidelines to Reduce Lead Exposure • Lead Risk Communication Resources • Service Line Replacement Programs and Partnerships • Copper Corrosion Chemistry

www.epa.gov/sites/production/files/2016- 01/documents/ndwaclcrwgfinalreportaug2015.pdf

www.epa.gov/sites/production/files/2015- 11/documents/occt_req_memo_signed_pg_2 015-11-03-155158_508.pdf

www.epa.gov/dwregi nfo/optimal- corrosion-control- treatment- evaluation-technical- recommendations

https://www.epa.gov/sites/production/files/2016- 02/documents/epa_lcr_sampling_memorandum_dat ed_february_29_2016_508.pdf

http://www.michigan.go v/documents/snyder/FW ATF_FINAL_REPORT_21M arch2016_517805_7.pdf

For more information visit: www.waterrf.org